ML19270G907
| ML19270G907 | |
| Person / Time | |
|---|---|
| Issue date: | 04/03/1979 |
| From: | Kelley W, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19270G898 | List: |
| References | |
| REF-QA-99900052 99900052-79-1, NUDOCS 7906210099 | |
| Download: ML19270G907 (10) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900052/79-01 Program No.
51300 Company:
Crosby Valve and Gage Company 43 Kendrick Street Inspection at: Wrentham, Massachusetts 02093 Inspection Conducted: March 20-21,1979 l /. 0 Inspect.
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' William D. Kelley, Contractor Inspector, Date Vendor Inspection Branch Approved by:
J. -7 7e D. E. Whitesell, Chief, ComponentsSection I, Date' ~
Vendor Inspection Branch Summary Inspection on March 20-21, 1979 (99900052/79-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B and applicable codes and standards including, design verification - computer program, manufacturing process control - weld material control, control of special processes - welding procedure specification, and audit. Also, reviewed previously identified items.
The inspection involved twelve (12) inspector-hours on site by one (1) NRC inspector.
Results:
In the four (4) areas inspected, no apparent deviations or<
unresolved items were identified in two (2) areas. The following were identified in the remaining two (2) areas.
Deviations:
Design Verification - (See Enclosure, Item A); and Audits -
(See Enclosure, Item B).
2240 258 79062100%
. 4 Details (Prepared by William D. Kelley)
A.
P_e nons Contacted Crosby Valve and Gage Company (CV)
P. Chase, Quality Assurance Engineer
- J. Greene, Quality Assurance Manager
- W. Greenlaw, Vice President, Engineering A. Nesta, Quality Engineering Technician J. Palmer, Chief Stress Analysis D. Thibault, Project Engineer
- Denotes those persons who attended Exit Interview (See paragraph H).
B.
General Review of Vendor's Activities 1.
The ASME issued the following Certificates of Authorization to CV to use their symbol:
Certification No.
Symbol Product N-1876 N
Class 1, 2, & 3 valves N-1877 NPT Class 1, 2, & 3 valve appurtenances N-1878 NV Class 1, 2, & 3 safety & safety relief valve These certificates expire on September 30, 1980.
2.
The authorized inspection agency is Factory Mutual System. The authorized nuclear inspector is a full time resident inspector.
3.
Crosby's contribution to the nuclear inductry represents approximately twenty-five percent (25%) of its total workload.
C.
Previously Identified Items (Closed) Deviation (Report No. 78-01):
Criterion V of Appendix B to 10 CFR 50 and paragraph NCA-4134.5 of Section III to the ASME Code 2240 259
i states in part, " 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...."
C.V. Procedure Q.C.-125 Approval Date August 24, 1977, paragraph 2.3.1.
states, " SPA Supervisor shall submit the necessary documentation regarding each individual meeting the requirements of Paragraphs 2.1 and 2.2... to the Quality Assurance Manager."
Paragraph 2.3.2 states, " Quality Assurance Manager shall review the documentation and upon his satisfactory review, he shall issue a Level II card listing applicable exceptions for the individual who satisfied the necessary requirements."
Contrary to these requirements the SPA Supervisor had not submitted the education and experience qualification documentation (required by para-graph 2.1.) and on-the-job-training documentation (required by paragraph 2.2.) to the Quality Assurance Manager, nor had the QA Manager provided the qualified personnel, with the prescribed credentials attesting to their qualifications.
(Required by paragraph 2.3.2.).
The inspector verified that the SPA supervisor had submitted the necessary documentation regarding each individual and the Quality Assurance Manager had reviewed and approved the documentation and approved qualification cards had been issued to each qualified individual.
(Closed) Unresolved Item (Report No. 78-01): Documents were being corrected using " white-out" and corrections were made on other documents without the responsible person's signature and date.
The inspector verified that the use of " white-out" had been discontinued in the Quality Assurance Department.
D.
Design Verification (Computer Programs) 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Procedures had been prepared and approved by the vendor to prescribe a system for computer design program verification which is consistent with NRC rules and regulations, ASME Code requirements, and the vendor's comitments in the ASME accepted Quality Assurance Program.
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_ b.
The computer design program verifiecation procedures are properly and effectively implemented by the vendor.
2.
Method of Accomplishmen_t_
The objectives of this area of the inspection were accomplished by:
a.
Review of the ASME accepted Quality Assurance Manual QC-110, Revision 3;
(.1)Section III, Customer Inquiry and Order Control, and (2)Section IV, Design Engineering Control, to verify the vendor had established procedures to prescribe a system for design verification.
b.
Reviewed procedure, Departmental Operating Instruction General Engineering 40-3003, Computer Program Verification Approval date October 10, 1974, to verify that the measures provided for verifing the adequacy of the computer design program. Also that the measures provided for the design I
verification to consider importance to safety, identify method of performing the design verification, identify the items to be addressed during design review, and prescribes the requirements for perfonning verification by alternate calculations or by qualification test.
c.
Reviewed design verifications; (1) Design Report EC-273, Revision 3, Crosby 6 x N x 8 HB-BP-86 Nozzel Type Safety Valve... Crosby Assembly No. N60582, (2) Computer Program Library, (3) Computer Program Verification Calculations (Cases 21 &
22, Cases 7 & 8, and Case 18),
(4)
Engineering Calculation No. EC-175 for Valve 102 JB-25, and
(.5 ) Seismic Stress Report EC-274, for Crosby 6 x 0 x 8 HA-75-FN Safety Valve Assembly No. N60602, to verify that the computer design verification procedures are being properly implemented.
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-__ _ d.
Interviews with personnel to verify they were knowledgeable in the procedures applicable to computer design verification.
3.
Findings a.
Deviation, See Enclosure, Item A.
b.
Within this area of the inspection no unresolved items were identified.
c.
Other Findings CV Departmental Operating Instruction, General Engineering 40-3003, Computer Program Verification Approval date October 10, 1974 states in paragraph 1.1, "The purpose of this instruction is to verify the responsibility and procedures for the documentaticn and verification of computer programs used in stress analysis...." The instruction defines the responsibility of the stress analyst, but it does not provide for how the computer programs are to be verified and documents.
I The computer programs for stress analysis are documented j
and verified by CV. CV management stated the instruction would be revised to describe how the programs are documented I
and verified.
E.
Manufacturing process Control Welding Material Control 1.
Objective The objective of this area of the inspection was to verify that welding material is identified and controlled until it is consumed in the welding process in accordance with the customer's design specifications, ASME accepted Quality Assurance Program, and applicable NRC Regulations.
2.
Method of Accomolishment The objective of this area of the inspection was accomplished by:
a.
Review of the ASME accepted Quality Assurance Manual QC-110, Revision 3,Section XII Welding Centrol; (1) Paragraph 12.1, Procurement Centrol of Welding Material, and 2240 262
_._ (2) Paragraph 12.4, Welding Control, to verify that procedures had been established for purchasing, receiving, distribution and handling of welding materials.
b.
Review of welding records and parts being welded, to verify that distribution of the welding material is being controlled in accordance with approved procedures, and that unused welding materials are scrapped, or recycled, in accordance with the procedures.
c.
Observation in the shop welding area and storage area, to verify that:
(1) Welding materials are clearly identified at all times in accordance with the approved procedures, and that the identification of acceptable materials was being maintained through-out the storage and manufacturing operations, until the material is consumed in the welding process.
(2) Welding material requiring environmental control is held at the appropriate storage, and/or baking temper-atures, for the time specified in the procedure.
d.
Interviews with personnel to verify they are knowledgeable of the vendors procedures applicable to Welding Material Con trol.
3.
Findings a.
The inspector verified that welding material is identified and controlled until it is consumed in the welding process in accordance with NRC regulations, the ASME accepted Quality Assurance Program, and contract requirements.
b.
Within this area of the inspection no deviations or unresolved items were identified.
F.
Control of Soecial Processes Welding Procedure Soecification 1.
Objective The objective of this area of the inspection was to deter nine if the welding procedure specifications used by the vendor in 2240 263
- production welding had been prepared, qualified and controlled in accordance with the applicable NRC regulation, the ASME accepted Quality Assurance Program, and ASME Code requirements.
2.
Method of Accomplishment The objective of this area of the inspecticq was accomplished by:
a.
Review of the ASME accepted Quality Assurance Manual QC-110, Revision 3; (1)Section XII, Welding Control, (2)Section XV, Heat Treating, and (3)Section XVIII, Nonconfonnities, to verify whether the vendor had established procedures for the preparation, qualification, certification, dis-tribution, and revision of welding procedure specifications.
b.
Review of Welding procedure W-13013, Revision 2, and W-13037, Revision 1, to verify that all essential variables, supplementry essential variables and nonessential variables are in accordance with the applicable Sections of the ASME Code.
c.
Review of Certification W1354, W-1373 and W13006 to verify that:
(1) The procedures had been qualified in accordance with Section IX of the ASME Code and the supporting procedure qualification records were on file.
(2) The precedures qualification records had been certified by the vendor and the mechanical test results meet or exceed the minimum ASME Code requirements.
(3) The procedure qualification record list the essential variables for the specific welding processes and the values and ranges of the variables are consistent within the limits of Section IX of the ASME Code.
d.
Review of the Welding Procedure Specifications and Procedure Qualification Records listed in paragraphs
- b. and c. above to verify that:
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. (1) All mechanical tests, required by Sections III and IX of the ASME Code, had been completed and are properly documented in the procedure qualification records.
(2) Changes and/or revisions of essential variables in any welding procedure specification, is supported by requalification documents.
(3) Changes in the nonessential variables of the welding procedure specification are properly identified and documented.
f.
Observation in the shop to verify that the welding proce-dure specifications are available to the welders and the specifications are properly followed.
g.
Interviews with personnel to verify they are knowledgeable in the procedures applicable to welding.
3.
Findings a.
The inspector verified that the welding procedure specifi-cations used by the vendor in production welding had been prepared, qualified end controlled in accordance with the applicable NRC regulations the ASME accepted Quality Assurance Program, and the ASME Code, b.
Within this area of the inspection no deviations or unresolved items were identified.
G.
Audits 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Procedures had been prepared and approved by the vendor to prescribe a system for auditing which is consistent with NRC rules and regulation, ASME Code requirements, and the vendor's commitments in the ASME accepted Quality Assurance Program.
b.
The audit procedure are being properly and effectively implemented by the vendor.
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_g_
2.
Method of Accomolishment The objectives of this area of the inspection were accomplished by:
a.
Review of the ASME accepted Quality Assurance Manual QC-110, Revision 3; (1)Section IX paragraph 9.5, Supplier Control, (2)Section XVIII, Nonconformities, and (3)Section XIX, Quality Assurance Audits, to verify that the vendor had established procedures to prescribe a system for audits.
b.
Review of the following departmental operating instructions; (1) Quality Assurance Department 48-3003, Revision 1, Quality Assurance System Audits, and i
(2) Quality Assurance Department 40-3004, Revision 1, j
Suppliers Audits, to verify that they had been prepared by the designated authority, approved by responsible management, and reviewed by the qualiti assurance function.
c.
Review of the procedures identified in aragraph b. above, to verify that they identify the organuation responsible for auditing, establishes the audit personnel qualifications, provides for training and indoctrination of audit personnel, establishes the essential elements of the audit system, provides for audit schedules to assure coverage of all elements of the quality assurance program, and requires reporting to and follow-up corrective action by both the audited and the auditing organizations.
d.
Review of six (6) audit reports to verify whether the procedures and the necessary audit system documents, are available to the auditing personnel, and whether the procedures are being properly and effectively implemented.
e.
Review of Approved Suppliers List QC-59 approved March 5, 1979.
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. 3.
Findings a.
Deviations, See Enclosure, Item B.
b.
Within this area of the inspection no unresolved items were identified.
H.
Exit Interview At the conclusion of the inspection on March 21, 1979, the inspector met with the company's management, identified in paragraph A, for the purpose of informing them as to the results of the inspection. During this meeting each identified deviation was discussed and the evidence j
which supported the findings were identified.
The company's management acknowledged the findings and supporting evidence as being understood, but had no additional comments.
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