IR 05000429/2005002

QA Program Insp Rept 99901006/85-01 on 850429-0502. Nonconformances Noted:Sufficient Objective Evidence Not Documented on Vendor Audit Checklists,Required Checks of Measuring Equipment Not Performed & Gauge Not Color Coded

ML20129J199
Person / Time
Site:	05000429
Issue date:	06/28/1985
From:	Merschoff E, Miegel N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20129J190	List: IR 05000429/2005002 ML20129J186 ML20129J193
References
REF-QA-99901006 99901006-85-01, 99901006-85-1, NUDOCS 8507220354
Download: ML20129J199 (8)

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ORGANIZATION: A&G ENGINEERING CO. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION INSPECTION NO.: 99901006/85-01 DATF(0 - a/?Q R/7/pR nu_e r Te uru me , A7 CORRESPONDENCE ADDRESS: A&G Engineering Co. II, In ATTN: Mr. Marvin Thomas President 4640 E. LaPalma Avenue Anaheim, California 92806 ORGANIZATIONAL CONTACT: Mr. John Thalasinos, QA Manager TF1FPHONF NINRF (71A1 77a_Ainn PRINCIPAL PRODUCT: Ferrous & nonferrous boltin NUCLEAR INDUSTRY ACTIVITY: 10%

ASSIGNED INSPECTOR: 3 '7 D 4! 69/.#7 N. $ Miegey Reactive Inspection Section (RIS) Date OTHERINSPECTOR(S): T. F. Burns, Consultant APPROVED BY: A . 4 f!Os-

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E. W. Herschoff. aMe ,

RIS. Vendni Proaram Branch na+o INSPECTION BASES AND SCOPE: BASES: 10 CFR 50 Appendix B, 10 CFR 2 SCOPE: This inspection was performed as the result of an allegation made to the NRC concerning inadequate implementation of the A&G Engineering Co. II, Inc. (A&G) quality assurance program.

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PLANT SITE APPLICABILITY: Not determined during this inspectiori.~

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ORGANIZATION: A&G ENGINEERING CO. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION NO.: 99901006/85-01 RESULTS: PAGE 2 of 8 VIOLATIONS:

None. NONCONFORMANCES: Contrary to Criterion VII of 10 CFR 50 Appendix B and Section V, Paragraph II.C.1 of the A&G Engineering Co. II, Inc. (A&G) Quality Assurance Manual (QAM) sufficient objective evidence was not documented on vendor audit checklists to substantiate and/or verify the A&G auditor's finding . Contrary to Criterion XII of 10 CFR 50 Appendix B, Section XX, Paragraph II.I.2 of the A&G QAM and A&G Quality Assurance Procedure (QAP) PR XX-A, Rev. A, paragraph VI: the performance of the required " periodic checks" of measuring equipment could not be verified, gauge 92A was incorrectly color coded. UNRESOLVED ITEMS:

None. OTHER FINDINGS AND COMMENTS:

10 CFR Part 21 The procedures adopted by A&G to comply with 10 CFR Part 21 were reviewed and the inspector verified that the procedures were adequate. The posting of these procedures,10 CFR Part 21, and Section 206 of the Energy Reorganization Act of 1974 was also verified. A&G has never made a Part 21 report, nor was the QA manager aware of any instance where A&G material was the subject of a Part 21 report issued by either an A&G customer or a utilit There were no findings in this area of the inspectio Documentation Review Fourteen purchase order (P0) packages from eight different customers were reviewed. The packages typically included: A&G's nuclear price quotation, certified material test reports, invoices, shipping manifests, A&G Certificates of Compliance, the customer's incoming P0, A&G's P0 to a

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l ORGANIZATION: A&G ENGINEERING CO. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION NO - 44901006/85-01 RESULTS: PAGE 3 of 8 vendor to procure material, A&G nuclear receiving inspection report, A&G nuclear receiving ticket, reports of physical testing results, and special customer requirements when applicable. The review was undertaken to ensure that A&G procures nuclear material and services from properly qualified sources, correctly invokes federal and customer requirements on their vendor, maintains traceability of material, and properly implenents the requirements of their quality assurance program. A review of the A&G Qualified Vendor List and selected vendor audits was also performed in conjunction with this P0 review. The vendor audits were performed by personnel qualified in accordance with NQA-1 and using written checklists. However, the checklists were not always suited to the particular activity performed by the vendor, for example, calibration services or physical and chemical testing and analysis. Sufficient objective evidence to substantiate the audit findings (such as a list of procedures or P0s reviewed) was also generally lackin Nonconformance B.1 was identified in this area of the inspectio It was not possible to review and evaluate A&G's procedure for upgrading material to ASME Section III Class 1 since all ASME Section III Class 1 material which A&G has supplied has been excluded from any additional NDE testing requirements due to its small size (i.e., less than one inch diameter).

Corrective Action Section XXIII, " Corrective Action," of the A&G QAM, the Corrective Action Request Log - Nuclear and 36 Corrective Action Reports (CARS)

dated from January 20, 1982, through April 18, 1985, were reviewe All CARS examined had been properly completed and signed off by A&G personnel as required by the QAM. The approoriateness of the corrective action taken was not evaluate There were no findings in this area of the inspectio Nonconformance Material Section XVII, " Nonconforming Material Control," of the A&G QAM, the Nonconforming Material Log, and 73 Nonconforming Material Reports (NMRs)

dated from January 15, 1982 through April 4, 1985, were reviewed. All NMRs reviewed had been completed and signed off by A&G personnel per the requirements of the QA .

There were no findings in this area of the inspectio _

ORGANIZATION: A&G ENGINEERING CO. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION NO.- 99901006/85-01 RESULTS: PAGE 4 of 8 Internal AuditsSection XXII, " Audits" of the A&G QAM and internal audit reports for the years 1981, 1982, 1983, 1984, and 1985 were reviewed. All audits were performed within the prescribed twelve month time interval. However, prior to 1984 the audit reports were generally inadequate and objective evidence to support the auditor's conclusions was not provided. In 1984 A&G hired a private firm to perform both the internal audits and management system audit. The private firm developed checklist questions and provided lists of the documents examined during the audits (for example: P0s, shop travellers,etc.).

There were no findings in this area of the inspectio Plant Tour A tour was conducted of the A&G facilities to evaluate the adequacy of material control and storage activities. The facility was found to be clean and orderly. Raw materials were found to be in protective storage segregated by product form and size. Also, both raw and finished products were tagged or hard marked to identify the manufacturer / supplier, size, ASTM or AISI specification and quantity. One order being processed was identified as nuclear and was found to be segregated from commercial items, hard marked (die stamped) and further identified by a shop traveler. The shop traveler identified the heat code customer, item, size, quantity, and each step in the manufacturing proces There were no findings in this area of the inspectio Calibration of Measuring and Test Equipment l Section XX, " Control of Measuring and Testing Equipment," and calibration l records (Gauge Control Records and Calibration Cards) dated from 1981 ,

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through April 1985 for nine different gauges were reviewed. A&G subcontracts to outside calibration services the task of calibrating their measuring and test equipment in accordance with a predetermined schedule. The gauges are color coded to identify the specific months when each must be calibrated. A " periodic check" as defined in Section XX is also required each time an instrument is used to ensure continued accurac .

f ORGANIZATION: A&G ENGINEERING CO. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION NA -

QQQn1006/R5-01 RESULTS: PAGE 5 of 8 Nine gauge were selected at random to verify that each was color coded and cclibrated correctly. One gauge, 92A, was found to be marked with an incorrect color code. It was also impossible to verify the performance of the " Periodic Checks." The check is to be performed by a quality control / quality assurance person who makes the pertinent entries on the Gauge Control Record. A review of the Gauge Control Records revealed that there were no entries indicating that the checks had been performed. Specific examples of such records are:

Gauge " Periodic Checks" not verified 6A 9/2, 8, 13, 15, 26 and 30 (1982)

1/22/83 to 6/1/83 6/21/83 to 12/1/83 12/1/83 to 6/1/84 23A 2/4/82 to 8/11/82 9/21/82 to 10/25/82 5/5/83 to.1/29/85 67A 4/14/82 (one day only)

5/3/82 to 6/21/82 7/12/82 to 9/23/82 3/18/82 to 9/2/83 9/12/83 to 6/16/84

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Nonconformance B.2 was identified in this area of the inspectio Training Section XXI, " Training of Personnel" of the A&G QAM was reviewed, and A&G training records were examined. Lesson plan content was examined for the period 1981 through 1985 and was found to be substantiv Training was directed to those employees having duties and responsibil-ities affecting the quality of A&G products. Personnel who have received this training include the president, QA manager, QA auditor, production foreman, purchasing agent, quality control inspectors, manufacturing manager, and document control clerk. Topics covered during training sessions included but were not limited to: examinations, tests, and reports identification control of product receipt inspection audits control of special processes

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ORGANIZATION: A&G ENGINEERING C0. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION NO.- 99901006/85-01 RESULTS: PAGE 6 of 8 certification QAM and subsequent revisions There were no findings in this area of the inspection.

i Allegation An allegation was made to the NRC concerning inadequate implementation by A&G of their quality assurance program. This allegation was not substan-tiated in that, with the exception of several isolated instances (Nonconformances B.1 and B.2), the A&G quality assurance program is adequately implemente PERSONS CONTACTED:

• J. Thalasinos, QA Manager, A&G

• M. Thomas, President, A&G

• Cook, Assistant QA, A&G DOCUMENTS EXAMINED: QAM, Rev. C, 4/17/85, A&G Engineering Co. II, Inc. Quality Assurance Manua . Documentation Package, 14 documentation packages for orders from 8 different customers packages typically included: - A&G Nuclear Price Quotation - CMTRs - Invoices - Shipping Manifests - A&G Certificates of Compliance - Customer's Incoming P0 - A&G P0 to Vendor to Procure Material - A&G Nuclear Receiving Inspection

, Report - Special Customer Requirements (when applicable) - A&G l Nuclear Receiving Ticket - Report of Physical Testing Result . Other, Approved Vendors List and Vendor Audit Checklist . Other, 9 Shop Traveler . Procedure, A&G Procedures for Compliance with 10 CFR Part 2 . Other, Exhibit XXXI, Rev. A, 5/7/82, Nonconforming Material Report Log.

l l QCD, 73 Nonconforming Material Reports dated 1/15/82 _ 4/4/8 * attended exit meeting

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e ORGANIZATION: A&G ENGINEERING CO. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION NO.- 99901006/85-01 RESULTS: PAGE 7 of 8 QCD, Exhibit XI, Rev. A, 5/7/82, Corrective Action Request Log a' ~

Nuclea ' QCD, 36 Corrective Action Reports dated 1/20/82 - 4/18/8 . Other, Internal Audit Reports - 1982, 1983, 1984, 198 . Other, Auditor Qualification Records for two A&G Employee . Internal Memo, 12 Semi-Annual Reports on the Status and Adequacy of the QA Progra . Other, Six reviews of ASME Code Addend . Lesson Plan, 1981-1985, Twenty Lesson Plans - Training of Personnel

(for period 1981 thru 1985).

15. Purchase Order, 12489-S, 1985, Material " Upgrade" - 20 pcs. SA 540 Bolts, 8 pcs SA194 Nut . Purchase Order, H-58798, 2/1/85, Material " Upgrade" - 2000 pc SA194 Gr. 6 Nut . Audit Report, 5/25/84, Audit Report of a material manufacture . Audit Report, 1983/1984, Audit Report of a material manufacturer,

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12/6 & 7/83 and 11/29 & 30/8 . Audit Report, 5/18/84, Audit Report of a material manufacture . Audit Report, 6/15/84, Audit Report of a calibration servic . Audit Report, 3/11/85, Audit Report of a testing la . Purchase Order, 8E 104035, 10/11/84, Cap Screws - Class 3, 1974 Edition 1, ASME III, SA 193 B . Purchase Order, 8E 204103, 10/23/84, Safety Related "Monel" B-164 Nut . Purchase Order, 8W 094124, 10/2/84, Safety Related Bolts ASTM A193 88 ..

2 Purchase Order, 8K 084011, 8/29/84, Safety Related Bolts and Nuts SA 193 B8M, SA 194, O

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DR$A'NIZATION: A&G ENGINEERING C0. II, IN ANAHEIM, CALIFORNIA REPORT INSPECTION NO.- 99901006/85-01 RESULTS: PAGE 8 of 8 26. Purchase Order, 4R-67787, 7/12/84 ASTM A 193 Gr. B6 Main Steam Check Valve, Hex Head Bolts - Replacement Part . Purchase Order, 61057, 8/8/84, SA 193 Gr. B7 (10' length) SA 617 Visual, Bar Steel - All threaded inspectio . Audit Report, 4/30.84, Audit Report of a laboratory.

29. Gauge Calibration Records, various document nos., 1982-1983 and 1984-1985, Nine Gauge Calibration Records 6A, 23A, 35A, 67A, 92A,

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113A, 139A, 127A, 3B.

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