ML20151T973
| ML20151T973 | |
| Person / Time | |
|---|---|
| Issue date: | 02/07/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20151T963 | List: |
| References | |
| REF-QA-99901039 99901039-85-01, 99901039-85-1, NUDOCS 8602100401 | |
| Download: ML20151T973 (4) | |
Text
1 APPENDIX B Joseph T. Ryerson 99901039/85 NOTICE OF NONCONFORMANCE Based on the results of the NRC inspection conducted on September 16-20, 1985, it appears that the following activities were not conducted in accordance with NRC requirements:
A.
Criterion VIII of Appendix B to 10 CFR Part 50 states, in part:
" Measures shall be established for the identification and control of materials,... including partially fabricated assemblies. These measures shall assure that identification of the item is maintained....
These identification and control measures shall be designed to-prevent the use of incorrect or defective material, parts, and components."
Contrary to the above, Joseph T. Ryerson procedures established for the identification and control of purchased material do not address how sheet steel will be marked.
(85-01-03)
B.
Joseph T. Ryerson Policy and Procedure number 18.400.07, Receivjng and Inspection of Inbound Merchandise,Section I, states, in part:
" Paint proper color identification on all bars."
In addition,Section II states, in part:
" Material will be placed in stock so that the color code'and heat numbers are on the end of the material facing the front of the rack where it is easily accessible."
Contrary to the above (85-01-04):
1.
Material was found in stock without a color code.
2.
Material was found in stock with an incorrect color code.
3.
Material was found in storage racks where the color code could not be determined without removing the material from the rack.
C.
Criterion V of Appendix B to 10 CFR Part 50 states, in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures,...and shall be accomplished in accordance with these instructions, procedures....
Instructions, procedures,...shall include appropriate... qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
9602100401 860207
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PDR GA999 ENVJTRYI 9990103?
PDR I
. 'Section 5.5 " Order Processing Control-Critical Requirement Orders," of the Joseph T. Ryerson QA Manual states, "The Quality Assurance Coordinator verifies heat number and proper signing of processing and. inspection steps.
Special requirements (marking, dimensions and packaging) are physically checked and signed as verified," and "The Quality Assurance Coordinator reviews the test report checklist on the CRMI [ Critical Requirement Materials Instruction] form and signs as verified before release for shipping.
Additionally, he will also sign-off on the Material Certification transmittal form 230.44-2...."
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Contrary to the above, the Quality Assurance Coordinator failed to verify special requirements (marking, packaging and shipping instructions) on the CRMI for numerous orders placed by The Zack Company in 1981, and The Bahnson Company in 1984 and 1985.
(85-01-05)
D.
Criterion XII of Appendix B to 10 CFR Part 50 states, " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits."
Joseph T. Ryerson Policy and Procedure number 18.220.02, " Plant Engineering-Equipment" states, in part, " Calibration shall be against certified measurement standards which have known relationship to national standards where such standards exist." Also, Section_I states, in part:
"The plant Superintendent is responsible for the calibration of measurement and test equipment under his jurisdiction.
In addition, the Superintendent will maintain a record of such checks by means of a checklist."
Contrary to the above, calibration and documentation of calibration of measurement and test equipment were not being performed as required.
Furthermore, Joseph T. Ryerson personnel responsible for the use of measurement and test equipment were not knowledgeable in the established requirements.
(85-01-06)
E.
Criterion XVIII of Appendix B to 10 CFR Part 50 states, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The audits shall be performed in accordance with the written procedures or check lists by appropriately trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reviewed by management having responsibility in the area audited.
Followup action, including re-audit of deficient areas, shall be taken where indicated."
s
. 1.
Section 6.1 of the Joseph T. Ryerson QA Manual states, in part,
" Quality Systems and Practices Audits are performed at local plants and in pertinent general office departments by a Certified Lead Auditor, assigned by the Manager, Quality Assurance, en a scheduled annual basis to assure compliance with company policies and procedure...."
Contrary to the above, annual internal audits of the following J. T.
Ryerson plants were not performed in the years indicated:
(85-01-07)
Detroit 1982, 1983 Philadelphia 1983 St. Louis 1983, 1984 Cincinnati 1983 Kansas City 1984 2.
Section 6.2 of the Joseph T. Ryerson OA Manual states, "The assigned auditor performs re-audits of noted deficient areas to confirm corrective action within a reasonable time unless deficiency is adversly affecting current quality levels, in which case, corrective action shall be taken immediately."
Contrary to the above, deficient areas noted in the Det-
. plant audit of February 25-March 1, 1985 had not been closed out at the time of this inspection. According to the associated audit report, the audit findin s were required to be closed out by April 29, 1985.
(85-01-08 3.
Section 6.4 of the Joseph T. Ryerson QA' Manual states, "The Lead auditor shall be qualified under the criteria as specified in ANSI N45.2.23 and NQA-1."
Section 2.3.2 of ANSI /ASME N45.2.23 states, "The prospective lead auditors shall have the capability to conTnunicate effectively, both written and oral.
These skills shall be attested to in writing by the lead auditor's employer."
In addition, Section 2.3.4 states, in part, "The prospective lead auditor shall have participated in a minimum of five (5) quality assurance audits within a period of time not to exceed three (3) years prior to the date of qualification...."
Contrary to the above, J. T. Ryerson lead auditors were incorrectly qualified as follows:
(85-01-09) a.
The lead auditors were " qualified" without evaluation of their communicatfor, skills. Two of these. improperly cualified lead auditors had perforned lead audit duties at the following J. T.
Ryerson facilities in 1985:
Buffalo, Detroit, Tulsa, and Kansas City.
. b.
Two J. T. Ryerson lead auditors were " qualified" by ANSI /ASME N45.2.23 without having performed a minimum of five QA audits within the required three year time frame. These unqualified lead auditors performed lead audit duties at the following J. T. Ryerson facilities in 1985:
St. Louis, Boston, and Detroit.
c.
Two J. T. Ryerson lead auditors were " qualified" by ANSI /ASPE N45.2.23 without having performed at least five QA audits as required. These lead auditors had performed five type "A"
- audits, instead of five type "S" audits. According to the J. T. Ryerson
" Audit / Survey Participation Record," only the type "S" audits are used for Qualification.
F.
Criterion XV of Appendix B to 10 CFR Part 50 states, in part, " Measures shall be established to control material, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation," and " Nonconforming items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures."
Section 5.3.3 of the Ryerson QA Manual states, in part, "...the required disposition is indicated on the Discrepancy Report and forwarded to the plant for action, to the Merchandise Department for inventory entry, and to the Accounting Department for inventory adjustment in accordance with the Purchase Debit."
Contrary to the above, no evidence of the disposition of defective material received from Acme Tube on May 10, 1985 (receiving ticket 56195) could be found on the associated Discrepancy Report (DR 196031).
(85-01-10)
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