ML20151R599

Notice of Nonconformance from Insp on 880524-26. Nonconformance Noted:Eight Radioactive Matls Packages Did Not Contain Foam & One Package Contained Rubber Instead of Foam & Records of Fabrication & Use Not Kept

ML20151R599
Person / Time
Issue date:	08/02/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20151R580	List: ML20151R575 ML20151R589 ML20151R599 ML20151R622
References
REF-QA-99901102 99901102-88-01, 99901102-88-1, NUDOCS 8808120230
Download: ML20151R599 (3)

Text

APPENDIX B Sour,e Production and Equipment Company, Inc.

Docket No. 99901102/88-01 NOTICE OF NONCONFORMANCE The NRC inspection was made to determine if the SPEC 2-T Radiographic Materials Package (RMP) was being manufactured in accordance with NRC Certificate of Com-oliance (C of C) 9056, Revision 3, dated March 12, 1986. C of C 9056 requires that the SPEC 2-T RMP be constructed in accordance with SPEC Drawing No.1000, Revision 0. The general license provisions of 10 CFR 71.12 apply to the SPEC 2-T. 10 CFR 71.12 requires that SPEC meet subpart H of 10 CFR Part 71. Subpart H requires that SPEC establish, maintain, and execute a quality assurance (QA) program satisfying each of the applicable criteria in Subpart H. Based on the results of this inspection conducted on May 24-26, 1988, it appears that certain of your activities were not conducted in accordance with C of C 9056, Revision 3.

These items are set forth below.

1. SPEC Drawing No. 1000, Revision 0, requires that polyurethane foam be installed between the depleted uranium shield and the stainless steel shell of the SPEC 2-T RMP.

Contrary to the above, eight RMPs did not contain foam and one RMP contained rubber instead of foam. (88-01-04) l

2. Paragraphs 71.101, 71.103, and 71.105 of Subpart H require each licensee

, to establish, maintain, and execute a QA program which satisfies each of the criteria of Subpart H.

Contrary to the above, SPEC has not executed the QA program which was a l

condition of the license approval (88-01-05)

3. Paragraph 71.107 of Subpart H requires the licensee to establish measures to assure that the package design is correctly translated into sper.ifica-l tions, drawings, procedures and instructions and to control design changes.

l Contrary to the above, SPEC does not use specifications, drawings, procedures, and instructions to fabricate RMPs and design changes are not fonnally reviewed or documented. (88-01-06);

4. Paragraph 71.109 of Subpart H requires the licensee to assure that quality requirements are included in the documents for procurement of material.

Contrary to the above, SPEC does not use procurement documents and material is ordered by telephone. (88-01-07)

5. Poragraph 71.113 of Subpart H requires the licensee to control the issuance of documents.

4 Contrary to the above, SPEC apparently does not issue or control documents.

(88-01-08) 8808120230 880802 PDR OA999 EMVSOUR 99901102 PNV

1

6. Paragraph 71.115 of Subpart H requires tne licensee to assure that purchased meterial conforms to procurement documents.

Contrary to the above, SPEC does not issue procurement documents so purchased material does not have a basis for conformance. (88-01-09)

7. Paragraph 71.117 of Subpart H requires the licensee to establish measures to identify materials, parts, and components by hedt number, part number, or other means on the item or on records traceable to the item throughout fabrication, installation, and use of the item.

Contrary to the above, SPEC does not identify materials, parts, and com-ponents and does not keep records of fabrication and use. (88-01-10)

8. Paragraph 71.119 of Subpert H requires the licensee to assure that special processes including welding, heat treating, and nondestructive testing are controlled and accomplished by qualified personnel using qualified procedures in accordance with codes, standards, specifications, criteria, and other requirements.

Contrary to the above, SPEC does not qualify personnel and does not use written procedures to control or accomplish special processes. (88-01-11)

9. Paragraph 71.121 of Subpart H requires the licensee to establ;sh and execute a program for inspection of activities affecting quality to verify confor-mance with documented instructions, procedures, and drawings.

Contrary to the above, SPEC does not inspect activities to verify confor-mance with documents. (88-01-12)

10. Paragraph 71.123 of Subpart H requires the licensee to establish a test program to assure that testing be performed in accordance with written procedures and document and evaluate the test results to assure that test requirements have been satisfied.

Contrary to the above, SPEC has not established a test program, written test procedures, or cocumented and evaluated test results. (88-01-13)

11. Paragraph 71.125 of Subpart H requires the licensee to assure that tools, I

gages, instruments, and other measuring and testing devices are properly controlled, calibrated, and adjusted to maintoin accuracy within necessary limits.

! Contrary to the above, SPEC does not have a documentea program for the l control and calibration of measuring and testing devices. (88-01-14) l 12. Paragraph 71.127 of Subpart H requires the licensee to control in accor-odnce with instructions the handling, storage, shipping, cleaning, and l preservation of materials and equipment to be used in packaging to pre-

! vent damage or deteriorotiun.

1

Contrary to the above, SPEC has not established instructions for the con-trol of handling, storage, and shipping. (88-01-15)

13. Paragraph 71.129 of Subpart H requires the licensee to indicate by the use of markings such as stamps, tags, labels, routing cards, or other suitable means the status of inspections and tests performed on individual items of the packaging.

Contrary to the above, SPEC does not indicate the status of packaging items by use of markings. (88-01-16)

14. Paragraph 71.131 of Subpart H requires the licensee to control materials, parts, or components which do not conform to the licensee's requirements.

Contrary to the above, SPEC does not have procedures for identification, documentation, segregation, disposition, and notification of affected organizations of nonconforming items. (88-01-17)

15. Paragraph 71.135 of Subpart H requires the licensee to maintain written records of activities affecting quality.

Contrary to the above, SPEC did not maintain any written records of activi-ties affecting quality. (88-01-18)

16. Paragraph 71.137 of Subpart H requires the licensee to carry out periodic audits to verify compliance with all aspects of the QA program.

Contrary to the above, SPEC has not audited their QA program or the QA pro-grams of their suppliers. (88-01-19) i

17. SPEC Drawing No.1000, Revision 0, requires a welded locking assembly with set screw, carbon steel shield hold down bolts, and recessed couplings.

Contrary to the above, RMPs were observed with unwelded locking assemblies l without set screws, stainless steel shield hold down bolts, and couplings that were not recessed within the stainless steel top and bottom plates.

(88-01-20) l l

l l

l