ML20249C683
| ML20249C683 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1998 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20249C680 | List: |
| References | |
| REF-QA-99901335 99901335-98-01, 99901335-98-1, NUDOCS 9807010025 | |
| Download: ML20249C683 (3) | |
Text
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4 NOTICE OF NONCONFORMANCE Columbiana Boiler Company Docket 999-1335 Columbiana, Ohio 1
Based on the results of an NRC inspection conducted on May 11-14,1998, certain Columbiana Boiler Company (CBC) activities were apparently not conducted in conformance with
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requirements.
A.
10 CFR 71.103, " Quality assurance organization," states: "The persons and organizations performing quality assurance functions shall report to a management level that assures that the required authority and organizational freedom, including sufficient independence from cost and schedule, when opposed to safety considerations, are provided."
Contrary to the above, the CBC Quality Systems Manager (QSM) does not have sufficient independence from cost and schedule. CBC's organization chart shows that the QSM reports only to the Executive Vice-President of Commercial Operations; this Vice-President is responsible for controlling costs and meeting fabrication schedules.
B.
10 CFR 71.123, " Test control," states: "The licensee shall establish a test program...
The test procedures must include provisions for assuring that all prerequisites for the given test are met."
Contrary to the above, Procedures OP-4.1 and OP-4.2, the fabrication procedures for the Model 308 and 48Y cylinders, contained no instructions to prevent excessive torquing when seating the valves. Paragraph 6.15.8 in American National Standards
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Institute (ANSI) N14.1-1990, " Uranium Hexafluoride - Packaging for transport," states that not more than 55 foot-pounds torque shall be used to seat the valvas.
C.
10 CFR 71.125, " Control of measuring and test equipment," states: "The licensee shall establish measures to assure that tools, gauges, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific times to maintain accuracy within necessary limits."
Contrary to the above, the following instances were identified regarding inadequate control of measuring and test equipment:
1.
CBC did not calibrate its micrometers used for inspection and acceptance over their entire range of measurement. CBC Quality Assurance (QA) personnel used 1-inch micrometers, over their entire measurement range, to inspect and accept components. However, QA measured the accuracy of the micrometers only at the 0.5-inch and 1-inch points.
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Notice of Nonconformance Docket 999-1335 2.
CBC did not identify its calibrated measuring and test equipment. CBC could not provide any logs listing all of its calibrated measuring and test equipment nor any records indicating the calibration due dates for each piece of equipment. In addition, CBC did t.ct place calibration stickers on any of its measuririg and test equipment except for pressure gauges and welding machines.
3.
CBC did not calibrate the Waksler Instruments mercury thermometer used to measure watet temperature during the cylinder water volume tests.
4.
CBC has no method or procedure in place 69 identify and evaluate previously acceptCd *,omponents if the measuring and test equipment, used to accept the componeat, is found to be defective or out of calibration.
D.-
10 CFR 71.131, ' Nonconforming materials, parts, or components," states: "The licensee shall establish measures to control materials, parts, or components that do not conform to the licensee's requirements to prevent their inadvertent use or installation.
These measures must include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations.
Nonconforming items must be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures."
Contrary to the above, the following instances were identified regarding inadequate control of nonconforming materials, parts, or components:
1.
CBC did not control nonconforming material in its fabrication area. CBC had two pallets of nonconforming weld wire and weld rod in the fabrication area that were not identified in CBC's nonconformance reporting system. This material was not properly controlled, dispositioned, nor secured to prevent its inadvertent use.
2.
CBC's QA staff did not review and approve a Nonconformance Report (NCR).
CBC QA staff initir ted an NCR during receipt inspection of 50 valve end couplings for Model 48Y cylinders; one of the valve end couplings did not display a required heat number. The nonconforming valve end coupling was discarded, as directed by QA staff, but this dispc,sition and final QA review / approval was not recorded on the NCR.
i 3.
CBC's nonconformance control program did not document or control deficiencies or deviations identified during fabrication. A Model 48Y cylinder, X-ray 2116-2-2, l
was rejected by QA because of an unacceptable longitucfinal seam weld. CBC did not document this deficiency in its nonconformance control program.
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e'.,e' Notice of Nonconformance Docket 999-1335
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10 CFR 71.137, " Audits," states: "The licensee shall carry out a comprehensive system of planned and periodic audits, to verify compliance with all aspects of the quality assurance program, and to determine the effectiveness of the program."
Contrary to the above, CBC had not performed any intemal or extemal (vendor) audits.
Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to Susan F. Shankman, Chief, Transportation Safety and Inspection Branch, Spent Fuel Project Office, Office of Nuclear Material Safety and Safeguards, within 30 uays of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a " Reply to a Notice of Nor.conformance" and should include for each nonconformance: (1) the reason for the nonconformance, or if contested, the basis for disputing the nonconformance, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further noncomoliances, and (4) the date when your corrective action will be completed. Where good cause is shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the e:ttent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal pritacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response thit identifies the information that should be protected and a redacted copy of your 3
response that deletes such information, if you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provids an acceptable reaponse, please provide the level of protection, described in 10 CFR 73.21.
Dated at Rockville, Maryland 25th June this day of 1998 i :.
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