ML20212P765

Notice of Nonconformance from Insp on 860602-06

ML20212P765
Person / Time
Issue date:	08/28/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20212P693	List: ML20212P690 ML20212P734 ML20212P765 ML20212P813
References
REF-QA-99900362 NUDOCS 8609030264
Download: ML20212P765 (3)

Text

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APPENDIX B ,

Unistrut Corporation Docket No. 99900362/86-01

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NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on June 2-6, 1986 it appears that certain of your activities were not conducted in accordance with NRC re-quirements.

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 accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appro-priate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Nonconformances with these requirements are as follows:

A. The Unitstrut QA procedure 20-01-003, Revision 2, paragraph 2.0 states, in part, "... Defective material shall be tagged with the hard red copy of the rejection ticket and separated from the usable material. Material handling personnel to place nonconforming material in the MRB designated area...."

Contrary to the above, 48 ft. of material #HTHR075A00 had a hard red rejection ticket attached. However, it was not separated fiom the useable material. The red tagged material was not placed in the MRB designated areas. (86-01-04)

B. The Unistrut QA manual section, "XIX, Audits", paragraph 19.6 states, in part, "... External audits shall be performed in accordance with procedure 20-01-007. These audits shall be performed on an annual basis and shall not exceed a twelve month period by more than thirty (30) days...."

Contrary to the above, external audits were not performed on the following vendors in the year (s) indicated (86-01-05):

NAME SERVICE YEAR A. A. Jansson Calibration 1984, 1985, 1986 General Fasterners Supplier of Fasteners / 1985, 1986 Heat Treater Detroit Testing Machine Cortpany Calibration 1985, 1986 n

er 59%; Wuj*y ,

l 99900362

National Testing and Research Laboratory Weld Qualification Testing 1984, 1985, 1986 Rouge Steel Company Material Supplier 1984, 1985, 1986 Material Supplier 1985, 1986 Traid Stateline Steel Company Material Supplier 1985, 1986 United Testing Systems Calibration 1985, 1986 C. The Unistrut QA manual section "XIX, Audits", paragraph 19.2 states, in part,

" ... Audits shall be performed annually on a progressive basis.... Deficient areas shall be documented on the audit finding report and completion of cor-rective action requested within a reasonable time.... Implementation of cor-rective action requested shall be verified by reaudit within 30 days of re-ported completion. . . ."

Contrary to the above, internal audits of 1986 (April), 1985 (March, June, September, December), 1984 (May, July, October) were not performed or were not completed according to schedule. Additionally, implementation of corrective action.for deficient areas found in the January 7, 1986 internal audit had not been carried out as of the time of this inspection. (86-01-06)

D. The Unistrut QA manual Secticn "XII Test Control", paragraph 12, states, in part, "... nondestructive testing performed by either Unistrut or, subcon-tractors shall be performed by personnel qualified to SNT-TC-1A,...."

The Unistrut QA procedure 20-01-031 Section III, states, in part, "...N.D.E.

(P.T.) personnel will be qualified as prescribed in table 1-D of the American Society for Nondestructive Testing recommended practice SNT-TC-IA. ...NDE personnel will be evaluated annually by the certifying authority...."

Contrary to the above, there was no cbjective evidence to show that one Level Il and one Level III NDE inspector had records of an annual eye exanination. In addition, two Level II KCE inspectors had no record of an annual review of certification in 1985. The Level III NDE inspector had no recoro of ever having an annual review of certification. (86-01-07)

E. The Unistrut QA procedure 20-01-024, Revision 2,Section III, states, in part,

" .. 3.3 the manager of Quality Assurance or the Supervisor, of Quality Control, shall review, cn a weekly basis the employee's progress during the first four (4) weeks. These weekly reviews shall be documented and copies placed in the employee's personnel file.. . ."Section IV states, in part, "A file of personnel cualifications will be maintained and will ccrtain applicable in-formation regaroing: 1. Proper Certification of Qualification..., C. Activity Qualified to perform, D. Level of capability, E. Effective period of certi-fication; 2. Levels of capabilities, A. Education, B. Experience, C. Training;

7. Pecords of, A. Fast performance, E. History, C. Evaluations every two years cr as required...."

A Contrary to the above, at the time of the inspection there was no objective evidence that a new Unistrut inspector was given the required first four week written progress report by the QA manager or the supervisor of QC. Addi-tionally, the personnel qualifications files were incomplete for two Unistrut inspectors and nonexistent for one Unistrut inspector. (86-01-08)

F. The Unistrut QA procedure 20-01-030 states, in part, "...This procedure is to define the practice of qualifying lead auditors. Said procedure is similar to N45.2.23 lead qualifications...A. A copy of the lead auditors qualifications, CA form will be maintained on file in the Quality Assurance Office...Shall be qualified and certified by the Vice President of manufacturing...B. Lead auditors will be evaluated annually by the certifying authority...."

Contrary to the above, at the time of the inspection, four lead auditors did not have objective evidence of communication skills on their Record of Lead Auditor Qualifications. Four lead auditors had no objective evidence of taking an audit training course. And two lead auditors had no objective evidence of fulfilling their audit participation requirement. (86-01-09) 0 0