ML20214Q327
| ML20214Q327 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/1986 |
| From: | Baker E, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20214Q300 | List: |
| References | |
| REF-QA-99901052 99901052-86-01, 99901052-86-1, NUDOCS 8612050106 | |
| Download: ML20214Q327 (7) | |
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ORGANIZATION: NOVA MACHINE PRODUCTS CORPORATION MIDDLEBURG HEIGHTS, Ofi10 INSPECTION INSPECTION REPORT ON-SITE HOURS: 64 NO.: 99901052/86-01 DATES: 7/14-18/86 CORRESPONDENCE ADDRESS: NOVA Machine Products Corporation
~
ATTN: Mr. Paul Novosel President ~
Post Office Box 30287 Middleburg Heights, Ohio 44130 ORGANIZATIONAL CONTACT: Jim Fitzwilliam, QA Manager TELEPHONE NUMBER: (216) 267-3200 NUCLEAR INDUSTRY ACTIVITY: Material supplier of fasteners and special order material.
ASSIGNED INSPECTOR: d / 6 E. T. Baker, Reactive Inspection Section, (RIS) Ddte OTHER INSPECTOR (S): Ronald Dahl, o and Associates APPROVED BY:
s 7 rir E.Merschoff,Chier/RIS,VendorProgramBranch Date INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 50, Appendix B; 10 CFR Part 21; and NCA-3800.
B. SCOPE: This inspection was made as a result of information received from Pacific Gas & Electric concerning NOVA's use of an unqualified material supplier and questions regarding the applicability and implementation of 10 CFR Part 21.
PLANT SITE APPLICABILITY: Waterford 3 (50-382), Vogtle (50-424/425), Diablo Canyon (50-275/323); Nine Mile Point (50-410).
1 I 8612050106 861128 l PDR GA999 EMVNOVA 99901052 PDR
ORGANIZATION: NOVA MACHINE PRODUCTS CORPORATION MIDDLEBURG HEIGHTS, OHIO i
INSPECTION REPORT RESULTS: PAGE 2 of 7 N0.: 99901052/86-01 A. VIOLATIONS: ,
None.
B. NONCONFORMANCES:
- 1. Contrary to Criterion II of Appendix B to 10 CFR Part 50
( Appendix B), subparagraph NCA-3864.2 of Section III of the ASME Boiler and Pressure Vessel Code (the Code), and paragraph 3.2 of NOVA's Quality Assurance Procedure (QAP) NP-RSHS1, a warehouseman employed in that capacity since 3/27/86 had not received the required indoctrination training. (86-01-01)
- 2. Contrary to Criterion V of Appendix B and subparagraph NCA-3866.1 of the Code:
- a. Neither NOVA's Quality Assurance Manual (QAM) nor QAP NP-11 provided instructions on how many pieces were to be in-spected, what dimensions were required to be checked, or what the acceptance / rejection criteria are for receipt inspection. (86-01-02)
- b. Neither NOVA's QAM, QAP NP-12, nor the sequence sheet provide instructions on what dimensions are required to be inspected, what the acceptance / rejection criteria are or a reference to the applicable standard. (86-01-03)
- 3. Contrary to Criterion VI to Appendix B, subparagraph NCA-3866.2 of the Code and paragraphs 8.0 and 8.2 of NOVA's QAM:
- a. On sales order 1515 the QA Manager, during his review, failed to detect that NCA-3800 had been incorrectly listed as a requirement on the sales order. (86-01-04)
- b. Neither NOVA's QAM nor their QAPs require that the secuence sheet be approved prior to issuance to the shop. (86-01-05)
- c. Neither NOVA's QAM nor their 0APs provide controls over changes to the sequence sheet. (86-01-06)
- 4. Contrary to Criteria VII and XVIII of Appendix B, subparagraph NCA-3861(a)(3) of the Code, and paragraphs 3.0 and 5.2 of NOVA's OAM:
10 CFR 2.790 INFORMATION HAS BEEN DELETED m
ORGANIZATION: NOVA MACHINE PRODUCTS CORPORATION MIDDLEBURG HEIGHTS, OHIO l I
INSPECTION REPORT PAGE 3 of 7 l RESULTS:
NO.: 99901052/86-01 l l
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- a. NOVA could not provide a checklist for the 1985. audit of (86-01-07) l i
- b. The audit checklist used by NOVA does not cover the pesting, procedural, or reporting requirements of 10 CFR Part 21 i when Part 21 is imposed on the subtier supplier by NOVA.
(86-01-08) !
- 5. Contrary to Criterion VIII of Appendix B, subparagraph NCA-3866.6 of the Code and paragraph 6.2 of QAP NP-03, NOVA has not stamped all individual pieces of bar stock 1" in diameter or larger.
(86-01-09)
- 6. Contrary to Criterion XV of Appendix B, subparagraph NCA-3867.3 and paragraphs 12.0 and 12.1 of NOVA's QAM:
- a. Paragraph 4.1.4.1.1 of QAP NP-11 and paragraph 3.1.1.1 of QAP NP-VP permit NOVA to not complete a nonconformance report on incoming nonconforming material when the nonconformance is minor and can be reworked by NOVA. (86-01-10)
, b. Neither Section XII of the QAM nor QAP NP-05 provide controls for the reworking of nonconforming material. (86-01-11)
- c. Neither the QAM nor the QAPs provide instructions on how nonconforming material returned by a customer will be controlled, documented, or dispositioned. (86-01-12)
- 7. Contrary to Criterion XVIII of Appendix B and subparagraph NCA-3867.2 of the Code, NOVA's QAM, QAPs, and sequence sheets do not require the recording of the number of pieces inspected or the number of pieces accepted or rejected. (86-01-13)
- 8. Contrary to Criterion XVI of Appendix B, subparagraph NCA-3879.2 and paragraph 12.2 of NOVA's QAM, the QA Manager had closed nonconformance/ corrective Action Report #26 on 6/2/86 indicating that corrective action had been completed, when in fact as of 7/16/86, corrective action had not been completed. (86-01-14)
C. UNRESOLVED ITEMS:
None.
10 CFR 2.790 INFOR!iATION HAS BEEN DELETED
ORGANIZATION: NOVA MACHINE PRODUCTS CORPORATION MIDDLEBURG HEIGHTS, OHIO INSPECTION REPORT PAGE 4 of 7 RESULTS:
N0.: 99901052/86-01 D. STATUS OF PREVIOUS INSPECTION FINDINGS: ,
l None, i E. OTHER FINDINGS OR COMMENTS:
- 1. Manufacturing Control The NOVA Sales Orders are initiated by the Sales Department and reviewed by the Quality Assurance Manager. The Sales Order requirements are entered on the Manufacturing Sequence Sheet by the Production and Quality Assurance Department. The Manufacturing Sequence Sheet includes such information as: part description, material specification, QA reouirements, hold points, inspection requirements and results, testing requirements, special processes required, documentation requirements, material traceability references, design requirements, and indication of final Quality Assurance Review.
The inspectors reviewed 17 sales orders and 22 sequence sheets during the course of the inspection. This resulted in identifying the following nonconformances:
- a. On sales order 1515 the QA manager, during his review of the sales order failed to note that NCA-3800 had been incorrectly listed as a requirement on the sales order.
(86-01-04)
- b. Neither the QAM nor the OAPs required that the sequences sheet be reviewed and approved prior to issuance to the shop.
Although notations along with initials and dates on the sales order indicate that the sequence sheets were reviewed and approved at the time the sales order was reviewed and approved, there is no indication on the sequence sheets in the manufactur-ing area indicating they were approved. (86-01-05)
- c. Neither the QAM nor the OAPs provide control over changes to the sequence sheet. Additionally, it was noted that sequence sheets in completed files for shipped material contained changes with no indication' that the changes had been reviewed and approved at the same level as the original approvals. (86-01-06) 10 CFR 2.790 INFORMATION HAS BEEN DELETED
ORGANIZATION: NOVA PACHINE PRODUCTS CORPORATION MIDDLEBURG HEIGHTS, OHIO INSPECTION REPORT PAGE 5 of 7 RESULTS:
N0.: 99901052/86-01
- d. The sequence sheets provide instructions for fin,al inspection as to whether 100% or sampling inspection is required and what Acceptable Quality Level (AQL) is to be used. However, the QAM, QAPs, and sequence sheets do not require that the inspector record the number of pieces inspected, the number of pieces accepted, and the number of pieces rejected.
Without this information, a review of the sequence sheet does not indicate whether or not the inspector complied with the sampling plan. (86-01-13)
- e. The sequence sheets require a dimensional inspection and reference OAP NP-12. However, neither the CAM nor QAP NP-12 provide instructions on what dimensions are required to be examined, what the acceptance or rejection criteria are, or a reference to the applicable standard (e.g. ANSI B18.1.1, B18.1.2,B18.2.2). (86-01-03) It was noted that the inspector was knowledgeable as to what was required due to his training and experience.
- 2. Training The inspectors reviewed the training records for the Level III QA inspector, QA Manager / Lead Auditor, and the warehouseman. The training file for the warehouseman did not contain documentation th.at he had been indoctrinated in NOVA's QAP NP-RSHS-1, although .
he had been perfonning in his present capacity for approximately ]
three months. (86-01-01) The other documentation contained in the j files, visual acuity test, training attendance records, and training i
and qualification certifications were found to be acceptable.
- 3. Receipt Inspection In reviewing the requirements for receipt inspection it was noted that when material is ordered for stock a sequence sheet is not generated. Without a sequence sheet there is no mechanism for providing the inspector with instructions on how many pieces are to be inspected, what dimensions are to be inspected, or what the acceptance / rejection criteria are for receipt inspection. (86-01-02)
The extent and results of the receipt inspection actually performed were documented on the receiving copy of the NOVA purchase order.
10 CFR 2.790 INFORf1ATION HAS BEEN DELETED e -
ORGANIZATION: NOVA MACHINE PRODUCTS CORPORATION MIDDLEBURG HEIGHTS, OHIO INSPECTION REPORT RESULTS: PAGE 6 of 7 NO.: 99901052/86-01
- 4. Procurement ,
NOVA's use of a subtier supplier prior to auditing the supplier and placing them on the Approved Vendor List was one of the reasons for performing the inspection at NOVA. The inspectors reviewed 22 purchase orders placed by NOVA, the audits for the fifteen companies involved, and the associated test reports. For the purchase order files and audit reports reviewed, no instances of NOVA placing purchase orders with subtier suppliers prior to auditing the supplier were noted with the exception of the instance noted by in their audit. In response to the PG&E finding, NOVA hired an external auditor to review their files to determine the extent of their error. The external auditor determined that the error was an isolated incident and based on that finding NOVA concluded that no additional notification of their customers was required under Part 21. The results of the limited review performed by the inspectors tends to support NOVA's conclusion.
However, the review of the audit folders did reveal that NOVA had failed to follow their QAP NP-V5 in that the 1985 audit of was not documented on NOVA's audit checklist.
The file only contained a single sheet of paper on which appeared the names of the company officials and a brief discussion of the type of work performed. There was no description of what was actually reviewed by the NOVA auditor. (86-01-07)
It was also noted that the audit checklist developed by NOVA for this purpose did not cover the posting, procedural, or reporting requirements of 10 CFR Part 21. (86-01-08)
- 5. Traceability The inspectors reviewed the shipping, handling, storage, and marking of material in the warehouse to assure that traceability was maintained. Two product forms were selected and examined, 5/16" diameter bolts and 1-7/8"' diameter bar stock, for marking /
tagging, segregation from other material, and retrievability of certified material test reports (CMTR). While all material was found to be identified by either marking or tags and traceable to the CMTR, NOVA's QAP NP-03 requires each 1" diameter or greater piece of bar stock to be individually stamped with the appropriate heat number or heat code. Not all bar stock 1" diameter or greater was individually stamped. (86-01-09) 10 CFR 2.790 INFORMATION HAS BEEN DELETED
i ORGANIZATION: NOVA MACHINE PRODUCTS CORPORATION )
MIDDLEBURG HEIGHTS, OHIO INSPECTION '
REPORT PAGE 7 of 7 RESULTS:
NO.: 99901052/86-01 l
- 6. Calibration ,
The inspectors reviewed the QAM and QAPs for controls on measuring and test equipment. Six instruments were selected during a tour of the manufacturing and inspection areas to verify the implemen-tation of the requirements. No nonconformances were found in this area.
- 7. Nonconforming Material / Corrective Action The inspectors reviewed the QAM and QAPs for controls on nonconform-ing material and requirements for corrective action. In reviewing the implementation of those requirements the inspectors reviewed all of the nonconformance reports generated since the company started in March,1984 and the associated corrective action. The review revealed several procedural inadequacies. If minor nonconformances are discovered on incoming material which NOVA could correct through rework, the procedures NP-Il and NP-V4 permit the QA Manager to not fill out a nonconformance report. This is in conflict with the QAM.
4 Also, if a nonconformance report is not required then the inspector or QA Manager never gets to the portion of procedures which require that a sequence sheet be used to control rework of nonconforming material (86-01-11). Additionally, if a nonconformance report is not generated, there is no place to document the disposition of the nonconforming material (86-01-10). In practice, NOVA was noting on the blue
" accept" tag that rework was necessary prior to using the material.
Another procedural inadequacy was the lack of instructions in the QAM or QAPs on how material returned by a customer would be controlled.
(86-01-12)
The implementation review of the Nonconformance/ Corrective Action Reports revealed that on report #26 the OA Manager had signed the report on 6/2/86, indicating that the corrective action had been completed, when in fact the corrective action had not been completed as of 7/16/86. (86-01-14) i l
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10 CFR 2.790 INFORftATION HAS BEEN DELETED l
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