ML20154B366

Notice of Nonconformance from Insp on 851104-08

ML20154B366
Person / Time
Issue date:	02/28/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20154B346	List: ML20154B343 ML20154B352 ML20154B366 ML20154B393
References
REF-QA-99900100 NUDOCS 8603040289
Download: ML20154B366 (5)

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AFFENDIX B l Limitorque Corporation Docket No. 9990100/85-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted cn November 4-8, 1985, it appears that certain of your activities were not corducted in accordance with NRC requirements. ,

Criterion V of Appendix B to 10 CFR Part 50 states:

• Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Nonconformances with these requirements are as follows:

A. Subsection A.1 of Section 1 of the Quality Assurance Manual (QAM) dated January 4,1984, states, in part. "It is the intent of this manual...to meet the applicable provisions of... ANSI N45.2 as they pertain to Limitorque's products."

Section 5 of ANSI N45.2-1977 states, in part, "... procurement doctments shall require contractors [ vendors] to provide a Quality Assurance Program consistent with the pertinent requirements of this standard."

Contrary to the above, a review of 13 P0s to vendors (Ryerson Steel-two, Copperweld Steel-one. Foster Lynchburg Foundry-two, WalkerElectric-three, Machine-two,andSouthern Centrifug)al-two.

Wesco-one indicated that quality requirements (e.g., CA Program) were not passed on to these suppliers and manufacturers of components destined for actuators purchased by nuclear customers as safety related items (85-01-04).

B. Section 2 of ANSI N45.2-1977 states, in part, "...The program shall provide for indoctrination and training of personnel perforrning activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained...."

In response to a previous nonconformance (Report No. 99900100/82-02),

Limitorque's letter dated November 15, 1982 to the NRC stated, in part,

...Limitorque Corporation to revise QA Manual to include training of non QC personnel...QA manual revision date is 01/28/83...."

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Centrary to the above, a review of the QAM, Revision 2 dated January 4, l 1984 indicated that 1.imitorque did not update the QAM to address training l of non QC personnel (e.g., engineers, parts and shipping personnel,  !

j j purchasing agents, order processors, and field service personnel) (85-01-05).

l C. Subsection B.Ib of Section VI of the QAM states, in part, " Personnel  ;

i shall be qualified in accordance with SNT-TC-1A." '

i Section 11.A of Procedure No. OCP-11 "Non-Destructive Testing Procedure" dated January 4,1984 references $NT-TC-1A (June 1980 edition).

Section 5.2 of SNT-TC-1A states, in part, "The employer's written '

practice shall describe the responsibility of each level of j  :

certification...."

Section 9.7.3 of SNT-TC-1A states, "The employer's written practice

! should include rules covering the duration of interrupted service which '

! will require re-examination and recertification."

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] Section 9.6.1 of SNT-TC-1A states, in part, "The qualification records of

! the certifieo individuals shall be maintained and... include the j following:...(4) statement Indicating satisfactory completion of training j in accordance with the employer's written procedure...." ,

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l Contrary to the above, a review of 1.imitorque's written practice for <

, nondestructive examination (hDE) and qualification records for three NDE  !

j personnel revealed that (85-01-06).

1 j 1. Procedure No OCP-11 did r.ot describe the responsibility of each ,

! level of e.ertification or rules covering the duration of interrupted L j service requiring re-exactination and recertification.  !

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2. The cualifict. tion records of the three NDE personnel did not contain a staten;ent indicating satisfactory completion of training in j occordance with Procedure No. QCP-11. $

j D. Subsection C.1 of Section I of the QAM states, in part, "This Quality ,

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Control System shall be subject to an internal audit on an annual basis  !

in accordance with QCP-14 to examine and verify compliance with all .

aspects of the Quality Program...." l Sectio 114.A.2 of Procedure No. OCP-14 " Internal Audit Procedure" dated l August 18, 1983 states, in part " Internal audits shall be performed using chacklist foro No. OC0019."

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l Contrary to the above, the inspector reviewed checklist form No. QC0019 for internal audits conducted in 1983 and 1984, and it was noted that the area of QA Records (i.e.,Section XI of the QAM) was not on the checklist and was not audited (85-01-07). ,

i E. Subsection B.3 of Section III of the QAM states, in part, "It is the responsibility of the Quality Control Department...to adequately assess ,

the capability of a Vendor's performance.... Vendor Evaluation Report is '

submitted to the Plant Manager and Purchasing Panager on a semi-annual  :

basis. This report is the basis for maintaining a vendor on the " Approved <

Yendor List".

Section 3.E of Procedure No. QCP-3 " Receiving Inspection Procedure" dated November 5, 1981 states, in part, "If any vendor on the AVL falls below our quality standard, he will be removed from the Approved Vendor List."

Section 25.A of Procedure No. QCP-25 "Limitorque Evaluation and Qualification of Service Organizations dated January 5,1984 states,1.1 part, " Vendors performing calibration and testing services shall be qualified by on site evaluation and placed on the Approved Vendor List."

Contrary to the above, it was noted (85-01-08):

1. Vendor Evaluation Reports (VER) were not generated semi-annually for

• the following vendors:

Vendor V R Period

• j Peerless-Winsmith Reliance Electric Co. '

Electric Apparatus Co. (2)(3)

Drever Co. (2)(3) '

Wesco  ;

Philadelphia Gear Corp. (2(3)

Sovereign Metal Corp. (1 valley Fasteners Tubular Steel Inc. .

NES/Selamco i Foster Electric  ;

2. Vendors listed below with evaluated rating below limitorque's ,

quality standard were not removed from the AVL. ,

Vendor _ Rating VER Perind* [

Advance Pressure Casting 20% rejects (3) 100% rejects (2) 100% rejects (1) ,

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yennor Rating VER Period

• Bronze & Plastics Specialty 70% rejects (3)

Duer Spring & Manufacturirg Co. 45% rejects (3) ,

international Spring 43% refects (3) fiewcomo Spring 56% rejects (3) 40% rejects I2) ,

Southwire Naccine Div. 95'l rejects . /3)

The Spring Work 56% rejects (3) i Sullford foundry Co. 55f, rejects (3 8% rejects (2 Handwheel Inc. 50% rejects (3 Aeerican Spring i Wire 91% rejects (2)

Rocky Nodntair. Casting 96% rejects (2)

• (1) - 1/84-6/84 (2) - 7/84-12/64 ,

(3) - 1/85-6/85 t

3. Audits were not perforrned on Page-Wfison Corporation and Hartzog Granite Con $ciy who calibrated tee Nrdcess testers and surface plates, respectively, F. Procedure No. QCP-22, "Reportir.g Defects for Safety Related Equipment -

Reference 10 CFR 21" dated A gust 31, 1933, statss, in part, Technical Ranaaer: All field cervice reports tnd customer probleni reports are to be reviewed by the Technical Maneger. If during his evaluation he feels that a problew, may exist in design, application, manufacturing, etc., he will forward the applicable field service report or customer problem report to the Quality Assurance Administrator for his evaluation.

Quality Assurance Adninistrator: If during his evaluation, he determines a problem does exist in design, applicatioc, r.anufacturing, etc., the QA Adininistrator will send a letter to the appropriate people d o are' responsible for thete areas (i.e., Chief Engineer, Quality Control Manager, Application Engineering). He will then send a copy of this letter to the Design Review Committee members.

Materiat Review Board: If the Material Resley Board (fiRB) deternines parts in question tray affect the operability cf a valve actuator and some of these par ts may be in units that have left our assembly plant, the results of the Materiel Review Board will be forwarded to the Design Review Correnittee for further investigetion, t

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j Procedure .No. QCP-13, "raterial f.eview Board Procedure" dated April 21, 1 1580, states that the QC Manager' is< responsible for preparing the reports of the board.

j Contrarv to the above, limitcrque js not effecti(ely implemstating QA

! pregran requirerents for reporting defects in cafety related equipment as roted by the following (05-01-09). s A field service report was crepared in May 1983 when Limitorque '

field servi.;e persont.el installed qualified Relf ance motors in r, lace of unqualified Baldor motors in safety related actuators for four Crane valves at Pub)te-Service Elerdric & Gas' Sale;n nuclear power punt. r  ;

Also, in May 1983, a custour preblem report was made when WPPSS ad,'ised Limitoroue service and special project personnel that e unqualified Caldor (30 tors were installed in safety related cctuators

for four Velan valves at WNP-2. The Technical Manager did not see the field service report or the problen report vetil he reviewed the Crder File as part of the record reflew initiated after the unqualified Baldor motor problem was raised as en issue during the January-February 1984 MC trspection. The record review was completed in August 1984 which is approximately 15 inonths after the problem was reported to Limitor

;ue personnel. '

a The Quality Assurance Administrator could not provide a copy of his letter to the Design Review Consnittee cor,cerning the unqualified Baldor motor

• problem por a enpy of any letter frcm him to the Design Review Coninf ttee cencerning problems for tvaluation and investigation as required 1 by .Orocedure No. QCP-22.

i The Quality Control Manager could not provide copies of any documen-i tation showing that the Paterial Reviw Board evaluated the circum-i stances concerning the installation of unqualified Baldor motors in the safety related actuators for four Crane valves at the Salem nuclear power plant. This probic'n was identified by the QC Manager durIng a j review of QA records for the particular order.

G. Section 17 of ANSI MS.2-1977 states, in part, "The identification of the significart condition adverse to quality, the cause of the conditicn, and the corrective action taten shall be documented and reported to appropriate levels of mnagement,"

Contrary to the above, Limitoroue discovered on March 28, 1983 that unqualified Baldor motors were irstalled in safety related actuators for four Crane Valves at Public Service Electvic & Gas' Salem nuclear power plant. Further, limitorque was advised by WppSS on May 27, 1983 thet unqualified Baldor (notors were installed in safety related l actuators for four '/ elan valves at WNP-2. For the two cases in point, Limitorque could not provide any documented evidence that measures were taken to identify the cause of the cordition, the extent of the problem, and necessary corrective action to prsclude repetition; or that the condition was reported to appropriate ' levels of management (85pl-10),

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