ML20209A678
| ML20209A678 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1987 |
| From: | Merschoff E Office of Nuclear Reactor Regulation |
| To: | Shulte H AMERACE CORP. |
| Shared Package | |
| ML20209A683 | List: |
| References | |
| REF-QA-99900296 NUDOCS 8704280255 | |
| Download: ML20209A678 (8) | |
Text
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UNITED STATES P
NUCLEAR REGULATORY COMMISSION o
h WASHINGTON, D. C. 20655 April 24, 1987 Docket No. 99900296/86-01 Amerace Corporation-Control Products Division ATTN: Mr. H. Shulte, Vice-President and General Manager Route 24 Hackettstown, New Jersey 07840 Gentlemen:
We have received your letter of December 29, 1986 in response to our letter dated October 27, 1986. We have reviewed your reply and fina that your responses to items 86-01-01 and 86-01-02 satisfactorily address the concerns raised in our Notice of Violation /Nonconformance. However, we find that your responses to items 86-01-03 thru 86-01-10 do not adequately address our concerns. We
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ask you to review our findings in conjunction with the applicable inspection details in our report and respond accordingly.
Five examples of responses that dre Considered inadequate are:
1.
Item 86-01-03, a. - Requests that Amerace Corporation, Control Products Division (CPD), address their failure to translate its [P5-71] design torque parameters for component assembly screws on the Agastat 7000 series relays into inspection verification attributes. However, the CPD response addressed the adequacy of the PS-71 specification, instead of addressing how it assures that some method of QA/QC verification of the torques are performed. Attachment #1 to your December 29, 1986 letter supplied as with a copy of CPD's PS-71 design specification, even though this specification is not a concern. As we previously discussed in our report, no written QA/QC instructions to perform verification of PS-71 design specification torque parameters were in evidence during our inspection.
We fully understand that the PS-71 specification addresses fastener torque values and we find that your engineering department has adequately complied with their responsibility of preparing this design acceptance and rejection criteria as stated in part 1.7 of section 13 of your quality assurance manuel (QAM). However, your QA/QC department has neither complied with its QAM responsibilities, nor has it implemented the QA program aspect that; "... assures that deviations from such standards [PS-71] are controlled..." as required by sections 6 and 13 of your QAM. Therefore, please address our original concern of CPD's failure to verify that the minimum torque values are reached and that the maximum torque values are not exceeded.
8704280255 870424 00g99ENVA
Amerace Corporation April 24, 1987 2.
Item 86-01 Requests that CPD address their failure to establish QA/QC inspection procedures or instructions for receipt inspection and in-process inspection activities for the Agastat 7000 series relays.
Instead, the CPD response addresses the adequacy of the CPD QC receipt inspectors and the fact that it has " drawings, travelers / route sheets and specifications" in its 7000 series relay fabrication areas. However, you have not responded to your failure to establish QC inspection instructions and procedures a required in sections 6 and 13 of your QAM. Additionally, the documents that you have provided with your December 29, 1986 response letter do not respond to the CPD failure to establish its QAM required QA/QC inspection instructions or procedures. Specifically:
a)
CPD Inspection Record Card sample, (used by the receipt inspection inspectors). - We found this type of record to be of questionable value since the card given to the inspectors is blank and they fill in the inspection characteristics without the benefit of written instructions as to which characteristics should be placed on the checklist.
b)
CPD Test Data Sheet, (indicates that manufacturing performed a resistance check of CPD part No. 32956-17)- This does not address the nonconformance issue, and was found to be a questionable practice because it was revealed that QC is allowed to inspect fewer attributes and items than they have documented as inspecting (see item 86-01-07below).
Furthermore, our inspection report did not request that CPD generate additieral instructions or procedures as its December 29, 1986 letter stated. We based our findings on the CPD failure to comply with its own QAM requirements that in turn address our 10 CFR Part 50 regulations. We found that section 6 and 13 of your QAM adequately addressed our Criterion V Regulations for the subject aspect. However, in these areas, we found that you failed to implement your own QAM requirements for preparing and supplying QA/QC instructions / procedures for at least two areas (i.e.,
receipt inspection and Agastat in-process inspection). Therefore, please address the CPD failure tc provide its inspection personnel with the required inspection instructions, that are required by sections 6 and 13 of your QAM in regard to inspection methods, hold points, standards, characteristics to be verified, and other attributes.
3.
Item 86-01-05, a. - Requests that CPD address their failure to assure that the QC inspection department supervisor pre? ares the material receipt inspection checklists [as required by the C)D-QAM].
Instead, the CPD response addresses the adequacy of the QC inspectors training.
l*
Amerace Corporation April 24, 1987 We are not sure how to interpret your corrective action statement that you intend to " review / approve all QC receiving inspection cards and will 1
continue until completed." Please clarify whether your review approval is applicable to previously completed receipt inspections, future inspections or both, Also please indicate the intent of your review / approval cycle, (i.e., looking for inconsistencies and nonconformances to assure that all important characteristics have been verified).
If your program is not applicable to future inspection cards state your intended action to prevent recurrence.
Additionally, you have indicated on your responte letter that your
" attachment #3" documents are relevant to item 86-01-05, a/b; however, a review of that section did not disclose any relevant documents except for QC instructions that our NRC inspector found to be in use at your former Grafton, Wisconsin facility on June 23-26, 1986. The QC instructions from Grafton were not found to be in use at your Floral Avenue facility and were not provided to the NRC inspectors in response to their questions.
Therefore, please clarify what your intent was for referencing "attachnient 4
- 3" for this item.
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4.
Item 86-01-05, b. - Requests that CPD address the failure of QA/QC ma.,agement to review and approve QC material receipt inspection checklists that were prepared by the receiving department QC inspectors who perfonned the receipt inspections.
Instead, as discussed in a. above, the t,PD response addressed the adequacy of the QC inspectors. Again, our concern is not with the QC inspectors, but rather with the lack of adequate QA management involvement in the QA program implementation.
Please see item 3. above for additional clarification that we request.
5.
Item 86-01 States, in part, that CPD procured the calibration services
-4 of an unapproved vencor for CPD's Cordax 1000 dimensional measuring machine for use in the CPD receiving inspection department. However, the CPD response does not address whether its Cordax 1000 machine is going to be I
verified for correct calibration by an approved vendor and what steps would be appropriate if the machine is found to be out of tolerance.
I Aoditionally, your " attachment #4" documents did not contain the CPD, Grafton, approved vendor survey or audit documents that you have j
discussed.
l Therefore, ple6se: a) Provide us a copy of the CPD/Grafton survey or audit document if you wish us to consider your statement; b) State whether CPD verified the traceability of the vendor's NBS standards; and c) State what steps CPD would take if the Cordax 1000 is found to be out of calibration or its standards are not traceable back to NBS.
Furthermore, we find serious discrepancies in two of your responses.
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Amerace Corporation April 24, 1987 l
l 1.
Item 86-01 QC documented acceptance of inspection characteristics i
that were never actually inspected.. Explain why a response to B.6.a of our report, above subject, was omitted from your. letter and the rationale for allowing QC personnel to document their acceptence of dielectric tests of electrical coils when the tests were perfonned by production i
personnel after the fact and without QC witnessing the test.
l 2.
Item 86-01 Defective E-7000 series timing relay contact am assem-i blies. Explain why your response emphatically states that the subject contact arm assemblies were never used on your product; when, in fact j
your February 12, 1986, Schulien to Earl memo, states, in part, "... problem 1
discovered [9/85] in production line of 7000 series timing relay. Terminal i
i block assemblies would not weigh properly due to bowed ano damaged contact arm assemblies. This was the first that Floral Avenues Manufacturing and i
Design Engineering Departments were aware of the new vendor, Universal Stamping...
Removed all known parts from production..." (emphasis added).
It should be noted that J. Ferguson, R. Hlavac, E. Leszczak, H. Martin, and W. Waddington were on distribution for this memorandum.
We are very concerned with your response to this item because it is quite possible that the nonconforming parts could have been used in any of your nuclear, commercial or military grades of Agastat 7000 timing relays during June 4, 1985 through September 19, 1985. As discussed with your i
staff during our inspection, your Floral Avenue facility received 31,299 l
contact arm assemblies during that time period, of which 23,604 were nonconfoming and 7,625 were acceptable. However, documentation shows i
that no formal QA/QC defective material controls were implemented until l
September 19, 1985 when a CPD " defective material report" (DMR) was l
written. Subsequently, two more DMR's were written on September 20, 1985.
l This raises the question of how can CPD assure themselves that none of the nonconforming parts were used in their product when your February 12, 1986 memorandum cic6rly states that the subject nonconfoming parts did in fact i
make it onto the production floor. Additional bases for some of our I
concern involve statements that appeared on the above subject memorandum.
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Specifically:
a)
" Initial sanple parts were received at Grafton from Universal on 2
January 22, 1985 and rejected for an unoersize diameter (dia.),
undersize dimeniston (dim.), undersize bend angle and bowing of
.007.
A second set of parts was inspected on January 24, 1985 and conditionally accepted even though the questioned dia, was still undersize ano one of the samples was bowed worse than the original lot.
NOTE: A critical dim. was apparently not checked in either of l
the two sample lots."
b)
"The first production parts from Universal arrived at Floral Avenue on June 4, 1985 and were accepted. Various lots arrived through 4
June and July of 1985, some of which were accepted others rejected.
)
All the rejected lots were consistent in their reason for rejection; i.e., undersize bend angle, undersize dim and twist (bow). The l
vendor contends that [one particular] dim. was never challenged at Grafton and therefore acceptable and that the bend angle is correct."
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Amerace Corporation April 24, 1987 c)
Nine heat treat fixtures, (used in a fabrication process), have never been inspected or approved, even though thousands of parts had been produced and shipped for use at Amerace (not a verbetim quote).
d)
" Problem discovered in production line of 7000 Series timing relay.
Terminal block assemblies would not weigh properly due to bowed and damaged contact arm assemblies.
This was the first that Floral Avenue's Manufacturing and Design Engineering Departir,ents were aware of new vendor [9/85]. Removed all known parts from proouction, replaced with original vendor - blocks weighed properly."
e)
"Our engineering [CPD] people are highly suspicious of these parts because of the undersize dim. noted previcusly. They strongly feel that any use of these parts will lead to premature failure of assemblies on a world wide basis."
f)
"Apparently, Grafton personnel were also suspicious of these parts because they conducted a life cycle test, dated February 22, 1985, to prove these parts. All parts passed this testing procedure. However, since Grafton does not measure or question the dim. we are challenging.
l We do not know if they used " worst case" parts to conduct the test.
This entire test is therefore questioriable and should be reconducted."
Therefore, please explain the disparity between your response to our nonconformance and the CPD discovery in September,1985 of subject nonconforming parts that had been used in your product, address the potential " premature failure" of the assemblies, and state what corrective action steps CPD considers appropriate for items that were produced during the time frame in question.
Correction - for item 86-01-03, b. - Our report documented an incorrect part number and engineering change notice (ECN) number that is used on your nuclear grade of Buchanan terminal blocks. Please note the following clarifications to our report and respond to the intent of 86-01-03, b. accordingly:
d)
Page 2, item B.2.b - ECN #083924 should be ECN #083929.
b)
Page 6v item E.3 - ECN #083924 should be ECN #083929, and part numbe s700964 should be part number 7001964.
i In summary, we continue to be concerned about the apparent lack of managerent involvement in your quality assurance program as evidenced by the above stated problems.
You are requested to submit additional information for items 86-01-03 through 86-01-10 and to address for each item:
(1) a oescription of steps that have been or will be taken to correct those items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed.
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Amerace Corporation April 24, 1987 The responses requested by this letter are not subject to the clearance 4
procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Please respond within 25 days of receipt of this letter.
Should you have any questions concerning this letter, we will be pleased to discuss them with you.
Sincerely, I
c Ellis W. Merschoff, cting Chief Vendor Inspection anch Division of Reacto Inspection and Safeguards Office of Nuclear Reactor Regulation Attachments:
The Amerace December 29, 1986 NRC Resporise Letter cc: Amerace Corporation l
ATTN: Mr. W. H. Ward i
President Route 24 Hackettstown, New Jersey 07840 Mr. Joseph Ferguson Control Products Division 1065 Floral Avenue Union, New Jersey 07083 DCASMA/ Springfield ATTN: Mr. L. Stokes 240 Route 22 Springfield, New Jersey 07081-3170
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Amerace Corporation April 24, 1987 1
4 The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork 1
1 Reduction Act of 1980, PL 96-511.
In accordance with 10 CFR 2.790 of the i
Commission's regulations, a copy of this letter will be placed in the NRC's Public Document Room, i
Please respond within 25 days of receipt of this letter. Should you have any I
questions concerning this letter, we will be pleased to discuss them with you.
Sincerely, d by
?'
'Origirial Signe EllisW.Merschott i
Ellis W. Merschoff, Acting Chief Vendor Inspection Branch j
Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation l'
Attachinents:
i The Amerace December 29, 1986 NRC Response Letter i
cc: Amerace Corporation ATTN: Mr. W. H. Ward President 4
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Route 24 j
Hackettstown, New Jersey 07840 i
Mr. Joseph Ferguson Control Products Division 1065 Floral Avenue j
Union, New Jersey 07083 DCASMA/ Springfield
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ATTN: Mr. L. Stokes i
240 Route 22 i
Springfield, New Jersey 07081-3170 DISTRIBUTION:
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Amerace Corporation April 24, 1987 The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter will be placed in the NRC's Public Document Room.
Please respond within 25 days of receipt of this letter. Should you have any questions concerning this letter, we will be pleased to discuss them with you.
Sincerely, DriginalSigned by pnsW.taerschott Ellis W. Herschoff Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguaros Office of Nuclear Reactor Regulation Attachments:
The Amerace December 29, 1986 NRC Response Letter cc: Amerace Corporation ATTN: Mr. W. H. Ward President Route 24 Hackettstown, New Jersey 07840 Mr. Joseph Ferguson Control Products Division 1065 Floral Avenue Union, New Jersey 07083 DCASMA/ Springfield ATTN: Mr. L. Stokes 240 Route 22 Springfield, New Jersey 07081 3170 DISTRIBUTION:
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