ML20151R622
| ML20151R622 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/1988 |
| From: | Baker E, Cilimberg R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20151R580 | List: |
| References | |
| REF-QA-99901102 99901102-88-01, 99901102-88-1, NUDOCS 8808120235 | |
| Download: ML20151R622 (7) | |
Text
- ORGANIZATION: SOURCE PRODUCTION & EQUIPMENT COMPANY, INC.
. ST. ROSE, LOUISIANA REPORT INSPECTION INSPECTION NO.: 99901102/88-01 DATES: 05/24-26/88 ON-SITE HOURS: 40 CORRESPONDENCE ADDRESS: Mr. R. D. Dicharry, President Source Production & Equipment Co. , Inc.
113 Teal Street St. Rose, Louisiana 70087 ORGANIZATIONAL CONTACT: Mr. R. D. Dicharry TELEPHONE NUMBER: (504)464-9471 NUCLEAR INDUSTRY ACTIVITY: Designer, supplier and owner of radioactive materials packages (RMPs).
ASSIGNED INSPECTOR: M R. L. Cilimberg, Program De% 1opment and Reactive 2
Date Inspection Section (PDRIS)
OTHER INSPECTOR (S): C. E. Williams, NMSS APPROVED BY: I E. T. Baker, Chief, PDRIS, Vendor Inspection Branch
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INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 71, 10 CFR Part 21, C of C 9056.
B. SCOPE: To determine if the SPEC 2-T was being manufactured in accordance with Certificate of Compliance (C of C) 9056, Revision 3, dated March 12, 1986.
PLA"T SITE APPLICABILITY: None.
8908120235 880802 PDR GA999 EMVSOUR 99901102 PNV
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ORGANIZATION: SOURCE PROTECTION & EQUIPMENT COMPANY, INC.
ST. ROSE, LOUISIAhA REPORT INSPECTION NO.- 99901102/88-01 RESULTS: PAGE 2 of 5 A. VIOLATIONS:
- 1. Contrary to Section 21.6 of 10 CFR Part 21, SPEC has not posted current copies of the Part 21 regulations, Section 206 of the Energy Reorganization Act of 1974 or procedures adopted pursuant to the Part 21 regulations. (88-01-01)
- 2. Contrary to Section 21.21 of 10 CFR Part 21, SPEC has not adopted written procedures to evaluate deviations or inform licensees or purchasers of deviations and to assure that a director or responsible officer is informed if a basic component supplied by SPEC contains a detect. (88-01-02)
- 3. Contrary to Section 21.31 of 10 CFR Part 21, SPEC has not specified that 10 CFR Part 21 requirements would apply on any purchase orders.
(88-01-03) l B. NONCONFORMt.NCES:
- 1. Contrary to Certificate of Compliance (C of C) 9056, Revision 3, dated March 12, 1986 and Source Production & Equipment Co., Inc.
l (SPEC) Drawing No. 1000, Revision 0, eight RMPs did not contain poly-l urethane foam and one RMP contained rubber. (88-01-04) l
- 2. Contrary to Paragraphs 71.101, 71.103, and 71.105 of Subpart H to 10 CFR Part 71, SPEC has not executed the Quality Assurance (QA) program which was a condition of the license approval. (88-01-05)
- 3. Contrary to Paragraph 71.107 of Subpart H SPEC does not use specifi-cations, drawings, procedure ,, ano instructions to fabricate RMPs and design changes are not formally reviewed or documented. (88-01-06)
- 4. Contrary to Paragraph 71.109 of Subpart H, SPEC does not use procure-ment oocuments and material is ordereo by telephone. (88-01-07)
- 5. Contrary to Paragraph 71.113 of Subpart H, SPEC does not issue or control documents. (88-01-08)
- 6. Contrary to Paragraph 71.115 of Subpart H, SPEC does not issue procure-ment documents so purchased material does not have a basis for con-formance. (88-01-09)
- 7. Contrary to Paragraph 71.117 of Subpart H, SPEC does not identify materials, parts, and components and does not keep records of fabrica-tion and use. (88-01-10)
. ORGANIZATION: SOURCE PROTECil0N & EQUIPMENT COMPANY, INC.
ST. ROSE, LOUISIANA REPORT INSPECTION N0.- 99901102/88-01 RESULTS: PAGE 3 of 5
- 8. Contrary to Paragraph 71.119 of Subpart H, SPEC does not qualify personnel and does not use written procedures to control or accomplish special processes. (88-01-11)
- 9. Contrary to Paragraph 71.121 of Subpart H, SPEC does not inspect their activities to verify conformance with documented instructions, proce-dures, and drawings. (80 01-12)
- 10. Contrary to Paragraph 71.123 of Subpart H, SPEC has not established a test program, written test procedures, or documented, and evaluated l
test results. (88-01-13) l
- 11. Contrary to Paragraph 71.125 of Subpart H. SPEC does not have a docu-mented program for the control and calibration of measuring and testing devices. (88-01-14)
- 12. Contrary to Paragraph 71.127 of Subpart H, SPEC hos not established instructions for the control of handling, storage, and shipping.
(88-01-15)
- 13. Contrary to Paragraph 71.129 of Subpart H, SPEC does not indicate
{ the status of packaging items by use of markings. (88-01-16)
- 14. Contrary to Paragraph 71.131 of Subpart H, SPEC does not have proce-dures for identification, documentation, segregation, disposition, and notification of affected organizations of nonconforming items.
l (88-01-17) l
- 15. Contrary to Paragraph 71.135 of Subpart H, SPEC does not maintain dny written records of activities affecting quality. (88-01-18)
- 16. Contrary to Paragraph 71.137 of Subpart H, SPEC has not audited the l SPEC QA program or the QA programs of SPEC's suppliers. (88-01-19) l l 17. Contrary to SPEC Drowing No.1000, Revision 0, RMPs were observed with unwelded locking assembly plates without set screws, stainless
- instead of carbon steel shield hold down bolts, and couplings that were not recessed within the stainless steel top and bottom plates.
(88-01-20)
C. UNRESOLVED ITEMS:
Status of NRC Certificates of Compliance issued to SPEC and NRC approval of the SPEC QA program will be reviewed by NRC and any resultant actions will be separate from inspection report 88-01.
ORGAf'IZATION: SOURCE PROTECTION & EQUIPMENT COMPANY, INC.
ST. ROSE, LOUISIANA REPORT INSPECTION N0.: 99901102/88-01 RESULTS: PAGE 4 of 5 D. STATUS OF PREVIOUS INSPECTION FINDINGS:
Not Applicable.
E. OTHER FINDINGS OR COMMENTS:
- 1. The NRC staff informed SPEC management of the scope of the inspection during the entrance meeting on May 25, 1988, and summarized the inspection findings and observations curing the exit meeting on May 26, 1988.
- 2. Background This inspection was requested by the NRC Office of Nuclear Material Safety and Safeguards (NMSS) to review SPEC's conformance with their NRC certificate for manuf acture of the SPEC 2-T radiographic camera and integral transport cask (RMP). Earlier in 1988, a radiographic camera manufactured by SPEC was involved in a traffic accident and the camera's source was exposed.
- 3. Document Review The NRC inspectors detennined through discussion with Mr. R. Dicharry, President of SPEC, that SPEC has not implemented the QA program in Subpart H of 10 CFR Part 71 which is required by NRC C of C 9056.
Revision 3. The discussion revealed that SPEC does not manufacture or test RMPs in accordance with written procedures, instructions, or detailed crawings. Additionally, manufacturing and testing of RMPs is not documented and further records are not maintained by SPEC.
(See nonconformances 88-01-05, 88-01-06, 88-01-08, 88-01-10, 88-01-11, 88-01-12,88-01-13,88-01-15,88-01-16,88-01-17,88-01-18,88-01-19)
- 4. Procurement and 10 CFR Part 21 SPEC was not aware of the requjrements of 10 CFR Part 21; consequently procedures were not available, required documents were not posted, and 10 CFR Part 21 was not imposed on suppliers. The applicability of 10 CFR Part 21 was not written on procurement documents. SPEC orders materials and services by telephone and does not confirm orcers with procurement documents. (See violatior.s 88-01-01 to 88-01-03 and nonconformances 88-01-07 ano 68-Oi-09)
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ORGANIZATION: SOURCE PROTECTION & EQUIPMENT COMPANY, INC.
ST. ROSE, LOUISIANA REPORT INSPECTION N0.- 99901102/88-01 RESULTS: PAGE 5 of 5
- 5. RMP Fabrication The NRC inspectors observed a SPEC camera maker fabricating a SPEC 2-T RMP. The camera maker was not using written procedures and stated that he fabricates cameras because he knows what to do based on years of experience. The camera maker performs welding but he statea that his welding has not been tested nor has he been formally trained or qualified to any written welding procedures. Based on observation and discussion by inspectors, it was determined that SPEC does not have a documented program for the control and calibra-tion of measuring and testing devices (see nonconformances 88-01-11 dnd 88-01-14).
- 6. RMP Inspection The NRC inspectors examined 14 SPEC 2-T RMPs that had been returned to SPEC for maintenance. RMPs with Serial Nos. 547, 523, 535, 484, 346, 385, and 491 did not contain the polyurethane foam required by SPEC Drawing No. 1000, Revision 0. The RMP with Serial No. 744 contained rubber instead of polyurethane foam. Drawing 1000 requires set screws to hold the lock assembly but RMPs with Serial Nos. 458, 744, and 670 did not contain set screws. Drawing 1000 requires that a locking assembly plate be welded to the stainless steel case. RMPs with Serial Nos. 547, 523, 535, 484, 346, 206, 259, 114, 243, 385, and 491 contained locking assemblies without welded plates. Drawing 1000 requires that couplings be recessed within the stainless steel top and bottom plates. RMPs with Serial Nos. 547, 523, 535, 346, and 243 contained couplings that were not recessed. This nonconformance may be significant because the RMP with Serial No. 563 which was in the accident in Texas contained a coupling which was not recessed and this coupling was never found after the accident. Drawing 1000 specifies the use of carbon steel shield hold down bolts. RMPs with Serial Nos. 547, 523, 458, 484, 346, 744, 670, 385, and 491 contained stainless steel shield hold down bolts. (See nonconformances 88-01-04 and 88-01-20)
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