ML20203F063

Notice of Nonconformance from Insp on 860414-30

ML20203F063
Person / Time
Issue date:	07/28/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20203F048	List: ML20203F040 ML20203F058 ML20203F063 ML20203F090
References
REF-QA-99900323 NUDOCS 8607300089
Download: ML20203F063 (4)

Text

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APPENDIX B Conax Buffalo Corporation Docket No. 99900323/86-01

- NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on April 14-30,1986, i t appears that certain of your activities were not conducted in accordance with NRC requirements. Nonconformances with these requirements are as follows:

A. Criterion I, " Organization," of Appendix B of 10 CFR Part 50 states, in

" ...the quality assurance functions are those of (a) assuring that part:

an appropriate quality assurance program is established and effectively executed and (b) verifying, such as by checking, auditing, and inspection, that activities affecting the safety-related functions have been correctly performed...."

Section 1.1, " Statement of Authority and Policy," of the Conax Buffalo Corporation (CBC) Nuclear Quality Assurance Manual (NQAM) states, in part:

"Conax Buffalo Corporation... pledges to continue to produce components and*

parts for nuclear power plants in accordance with the requirements of Section III, Division I, of the ASME Boiler and Pressure Vessel Code; Appendix B of 10 CFR Part 50; and ANSI N45.2. In order to meet these requirements, a nuclear quality assurance program is hereby established

...the quality of all products, and services whether manufactured by Conax or obtained from an outside supplier, shall be controlled at all points necessary to assure conformance within specification requirements...."

Contrary to the above, CBC failed to assure that an appropriate nuclear quality assurance program was established and effectively executed for the control of nuclear safety-related activities performed at the Conax Florida facility (approximate time period was between December 1983 until April 1986). These activities were in regard to the manufacture of Standby Liquid Control (SLC) squib valve components and included drawing changes, purchasing, fabricating, handling, shipping, storing, cleaning, inspecting, testing, and repairs (86-01-03).

B. Criterion II, " Quality Assurance Program," of Appendix B to 10 CFR Part 50

" ...The quality assurance program shall provide control states, in part:

over activities affecting the quality of the identified... systems and com-ponents, to an extent consistent with their importance to safety. Activities affecting quality shall be occomplished under suitably controlled condi-tions...The program shall take into account the need for special controls, processes...and skills to attain the required quality, and the need for

$7300089860728 99900h79ENVCONAX PDR

verification of quality by inspection and test. The program shall provide for indoctrination and training of personnel performing activities affec-ting qualitysas necessary... Management of other organizations...shall review the... adequacy...of the quality assurance program which they are executing." .

Contrary to the above, the CBC failed to assure that the Conax Florida facility personnel were indoctrinated in regard to the nuclear quality assurance requirements and codes, from December,1983 until April 22, 1986(86-01-04).

C. Criterion V, " Instructions, Procedures, and Drawings", 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 draw-ings shall include appropriate cuantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Contrary to the above, CBC has failed to establish adequate procedures, instructions, or drawings, delineating qualitative.or quantitative accep-."

tance criteria for determining that the squib valve explosive primer chamber " potting" process has been sat'sfactorily performed (86-01-05).

D. Criterion VII, " Control of Purchased Material, Equipment, and Services",

of Appendix B to 10 CFR Part 50 states, in part: " Measures shall be esta-blished to assure chat purchased material, equipment, and services, whether purchased direct 1 / or through contractors and subcontractors, conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection...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...."

Contrary to the above, CBC failed to perform source evaluations to establish the effectiveness of the control of quality activities at the Conax Florida facility in regard to the trigger and EPC assemblies (86-01-06).

E. Criterion IX, " Control of Special Processes," of Appendix B to 10 CFR Part 50 states: " Measures shall be established 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 applicable codes, standards, specifica-tions, criteria, and other special requirements."

Contrary to the above, CBC has failed to establish a qualified " potting" procedure for the accomplishment of safety-related EPC activities at both Conax faciliYies (86-01-07).

F. Criterion XV, " Nonconforming Material, Parts, or Components" of Appendix B to 10 CFR Part 50 states, " Measures shall be established to control mate-rials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations. Non-conforming items shall be reviewed and accepted, rejected, repaired or re-worked in accordance with documented procedures.

Contrary to the above, records were not in evidence' to assure that CBC adequately controlled a " potting" process deviation found in six of twelve EPC assemblies which were assembled and potted at the Conax Florida facility, shipped to CBC, and then shipped to the Susquehanna nuclear station (re-ference GE P0 #205-83L438, 10/20/83) (86-01-08). Specifically:

1. No nonconformance report or similar record was written to identify thd potting deviation. A January 31, 1984 Conax internal memo discusses the deviation and indicates that subsequent rework was  !*

performed at the Buffalo facility.

2. No records were written to document the Buffalo facility rework and re-inspection of the six nonconforming EPC assemblies for the Susquehanna nuclear site.

G. Criterion XVI, " Corrective Action", of Appendix B to 10 CFR Part 50 states:

" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are prceptly identified and corrected.

In the case of significant conditions adverse to quality, the treasures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."

Contrary to the above, records were not in evidence to assure that CBC l adequately identified and corrected a " potting" process deviation found in six of twelve EPC assemblies which were assembled and potted at the Conax Florida facility, shipped to the CBC (where rework was performed),

and then shipped to the Susquehanna nuclear station (reference GE PO

1. 205-83L438, 10/20/83) (86-01-09). Specifically:

1. No documents were written which would indicate that the significant condition adverse to cuality was reviewed for root cause and that actions were taken to preclude repetition.

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2. No records were written which would indicate that corrective actions were performed and that appropriate levels of management were aware of the problem, with the exception of the Conax January 31, 1984 internal memo.

It should be noted 'that this deviation to the special " potting" process is significant to safety because the explosive power output is an inverse function of voids or gaps around the explosive primers.

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