ML20197E021

Notice of Nonconformance from Insp on 860127-31

ML20197E021
Person / Time
Issue date:	05/13/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20197D995	List: ML20197D990 ML20197E008 ML20197E021 ML20197E039
References
REF-QA-99900774 NUDOCS 8605150142
Download: ML20197E021 (5)

Text

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APPENDIX B Airco Filler Metals Docket No. 99900774/86-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on January 27-31, 1986 it appears that certain of your activities were not conducted in accordance with NRC requirements.

1. 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 accom-plished in accordance with these instructions, procedures, or drawings.

Instructions, procedures, or drawings shall include appropriate quanti-tative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Nonconformances with these requirements are as follows:

A. The Airco Quality Assurance Instructions (QAI) Manual Section 7.2.2 states: " Radiographic personnel shall be certified by The Level III in accordance with Airco's written practice which meets the requirements of ASNT recommended practice No. SNT-TC-1A, 1980 Edition and The Code."

SNT-TC-1A 4.2 states, in part: "While in the process of being qualified and certified to NDT Level I, an individual should be considered a trainee. A trainee should work with a certified individual and shall not independently conduct any test....."

Contrary to the above, a radiographic test trainee independently performed radiographic tests on Lot #026C003, Heat #72181, Test No. E391F on June 28, 1984, without being qualified and certified as a NDT Level I. (85-01-02)

B. SNT-TC-1A 8.1.1 states, in part: "(1) The examination should assure natural or corrected near-distance acuity in at least one eye such that the applicant is capable of reading a minimum of Jaeger Number 2 or equivalent type and size letters at a distance of not less than 12 inches (30.5 cm) on a standard Jaeger test chart....(5) Examination results are to be kept on file for the period of certification."

Contrary to the above, there was no record or objective evidence of an eye examination on file for a Radiographic test technician qualified to Level III between the years 1977-83. The 1986 eye examination at the time of the inspection was approximately one month past due. (85-01-03) 8605150142 860513 C0

C. The Airco Quality Assurance Instructions (QAI) Manual Section 2.2.1 states, in prt: "To help assure quality the following actions for quciity assurance personnel shall be established and maintained...~o. A program for personnel indoctrination and training and development in all aspects of the QA program is conducted under the direction of the QA manager...c. Training programs shall be designed to: ... Provide on-the-job training in all facets of the iob's requirements... Identify any manual indoctrination sessions that may be required...d. QA Department personnel's qualification and training status shall be documented in a "Qualificatien of Personnel" record sheet...."

Contrary to the above, the qualification records did not describe in detail the qualifications of the quality department personnel.

In addition, the records do not show correlation between training and qualification of quality personnel and the required qualifi-cations for the position. (85-01-04)

D. The Airco Quality System Manual (QSM) Section 3.2.b states: "The QA manager shall be responsible for the periodic training of quality and non-quality related personnel in matters relating to product quality and this Quality System Program. This training shall be performed in the form of meetings and seminars."

Contrary to the above, wire mill personnel, press operators, packers and inspection spares performing quality related functions were not trained and indoctrinated in the Airco quality system program. (85-01-05)

E. The Airco QSM Section 3.1.3 states: " Wire Mill personnel are responsible for constant surveillance of their operations.

Procedures are available at all work stations."

Contrary to the above, procedures for wire mill operations were not available at the work stations for wire mill personnel.

(85-01-06)

F. The Airco QAI 13.2.1 Section 2.4 states, in part: "The quality assurance records as described in Table I shall be retained for the periods listed. After this time, these records may be disposed of by the QA Manager." Table I specifies three years retention for documentation of personnel qualifications.

Contrary to the above, approximately 25'4 of the qualification records requested were not available for quality system employees (inspectors, radiographers and welders) involved in production of nuclear grade weld rods in 1983. (85-01-07)

l G. The Airco QAI Section 4.2.2 states, in part: "QA Manager shall review and approve all purchase orders prior to release to a vendor.... Review and approval shall be indicated by signature and date on the purchase order."

Contrary to the above, in 1985 11 purchase orders for core wire were not approved by the QA Manager's signature.

In addition, the QA Manager did not sign purchase order

(#4-2019-02) from the blanket order requisition #489114, dated 1985, to The Tensile Test Co. for machining and heat treating services. (85-01-08)

H. The Airco Quality Systen Manual (QSM) section states, in part, "The QA Department shall assure that necessary quality and

, documentation provisions are included in purchase orders for Raw Materials and shall verify compliance to such provisions for Raw Materials received from qualified vendors."

Contrary to the above, the requirements of Appendix B to 10 CFR Part 50 were not imposed on vendors that supplied calibration services and test specimen machining and heat treatment to Airco.

(85-01-09)

I. The Airco QAI manual Section 4.2.1 states: "2.4.4 Vendors of Calibration Services - All vendors of calibration services sfiall be capable of providing services meeting all requirements of MIL-STD-45662 and may be approved without a survey provided the QA Manager reviews and approves the vendor's procedures."

Contrary to the above, the QA Manager did not review and approve the calibration procedures for Brinkman Instruments and Brown &

Sharpe. Brinkman Instruments supplied calibration services to Airco in 1985 for calibration of the Mettle analytical balance model #H10TW. Brown and Sharpe supplied calibration services to Airco in 1984 for calibration of the Jo Block set model #2119.

(85-01-10)

J. The Airco QAI Section 8.2.1 states: ...All procedures shall require that standards used for calibration be certified as traceable to the NBS, or other nationally recognized standards if such standards do not exist...."

Contrary to the above, as of January 31, 1986 there was no objective evidence that the Sartorius analyical balance model #2462 was calibrated and certified traceable to NBS in 1985.

K. Section 2.2 of QAI 8.2 states "The frequency of calibration is (SIC) established for each piece or type of equipment is defined in Table I. Measuring and test equipment shall be calibrated at periodic intervals established on the basis of degree of usage, required accuracy, stability and past history."

Contrary to the above, the certificate of calibration and tracea-bility for Jo Blocks (gage block) set serial #2119 dated June 20, 1984 was incomplete, and therefore invalid since there was no authorized signature from the calibration vendor (Brown & Sharpe).

(85-01-11)

L. The Airco QAI Section 7.2.2 states, in part: " Control of special processes shall be the responsibility of the QA Manager or Welding Supervisor...special processes requiring control are: a. Welding for determining the acceptability of filler metals to specification requirements... records of qualification of welding procedures and personnel shall be filed and maintained current by the QA Manager."

Contrary to the above, welders performing welding to fabricate weld samples used for acceptance testing of nuclear orders #026C007 and #026C008 were not identified by signature on the weld test report. (85-01-12)

M. The Airco QAI Section 4.2.1 states: "Upon satisfactory completion of 2.4.1, 2.4.2 and 2.4.3, QA manager shall approve the vendor and add the vendors name to the Approved Vendors List (AVL)."

Contrary to the above, Brinkman Instruments, supplier of analytical balance calibration for Airco in 1985 and 1986, were not on the Airco AVL. The analytical balance is used in measurements for the rod moisture test. (85-01-12)

N. The Airco QAI manual Section 12.2.1 states, in part: " Vendors not responding or reacting effectively to corrective action reauests shall be subject to removal from the AVL by QA."

Contrary to the above, as of January 1986, there was no objective evidence available to verify that Georgetown Steel implemented corrective action for an audit finding identified in February 1984 by Airco. [The finding involved Georgetown Steels failure to calibrate the Mike Master set, SN 632, used to calibrate their micrometers and provide traceability to NBS.] As of January 1986, Georgetown Steel was not removed from the Airco AVL. Two nuclear purchase orders #497807 and #497810 for core wire were placed with Georgetown Steel in 1985. (85-01-14)

0. The Airco QAI manual Section 14.2.1 states, in part: "The audit shall be performed by trained and qualified auditor (s) not having direct responsibility in the area being audited."

Contrary to the above, as of January 1986, there was no objective evidence that the internal audit performed in August 1985 of the quality department was done by a trained and qualified auditor.

P. Section 2.1 of QAI 14.2.1 states, in part: "The frequency of audits shall be based on the importance, quantity and complexity of the work being performed...; the results of previous audits; and the severity of reported nonconformances. However, audits shall be conducted of the entire system, as a minimum, on a semi-annual basis."

Contrary to the above, in 1985 the quality system was audited on an annual basis. Additionally, the frequency of audits performed 4 in 1985 did not reflect the audit results found in 1984, since in 1984 a minimum of 26 audit findings were reported.

Q. Criterion VI of Appendix B to 10 CFR Part 50 states, in part:

that " Measures shall be established to assure that purchased...

services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents.

These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery...the effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity. . .of. . .or services."

Contrary to the above, quality program audits have never been performed on Airco vendors for calibration services, test specimen machining, and heat treatment vendors. (85-01-16)

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