ML20031D151
| ML20031D151 | |
| Person / Time | |
|---|---|
| Issue date: | 07/09/1981 |
| From: | Barnes I, Ellershaw L, Harris J, Linehan J, Roberds H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031D140 | List: |
| References | |
| REF-QA-99900731 NUDOCS 8110090408 | |
| Download: ML20031D151 (16) | |
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U.S. NUCLEAR REGUALTORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900731/80-01 Program No. 51400 Company:
INRYCO, Incorporated Concrete Systems Group Box 1009, 1550 N. 25th Avenue Melrose Park, Illinois 60161 Inspection Cond c ed:
November 17-21, 1980 Inspectors:
W AO c2// M L. E. Ellershaw, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch
$ ' s tbst c2/8 H. W. Roberds, Contractor Inspector
'Date,
ComponentsSection II Vendor Inspection Branch YSw 2 /C /.?/
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pd.J.Lenahan,ReactorInspector Date Construction Branch, Region II
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[J. R. Harris, Reactor Inspector Date Construction Branch, Region II Approved by:
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I. Barnes. Chief Date Components Section-II Vendor Inspection Branch Summary Inspection conducted on, November 17-21, 1980 (99900731/80-01) s s
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2 Areas Inspected:
Implementation of 10 CFR 50 Appendix 8 Criteria, and applicable codes and standarde, including:
follow-up on a construction deficiency report; manufacturing p;ocess control, control of nonconformances and corrective action; design process management; equipment calibrati n; quality assurance records; 3
procurement source selection; welder qualifications; heat treatment; and indoctrination and training.
Results:
In the 10 areas inspected; seven nonconformances and 2 unresolved items were identified.
The inspection involved 118 inspector hours onsite by four NRC inspectors.
Nonconformances:
Manufacturing Process Control - the qualification of the button-v head machine was not being performed in accordance with the applicable pro-cedure (See Notice of Nonconformance, Item A); Control of Nonconformances and Corrective Actions - certain nonconformance reports do not identify the cause and certain approval blocks were not signed by QA, QC or Engineering (See Notice of Nonconformance, Item B); Nonconformance Reports are not being s/
written or have been voided (See Notice of Nonconformance, Item C): Equipment e Calibration - calibration readings of stressing rams were taken at values other than what was required (See Notice of Nonconformance, Item D); Indoc-/'
trination and Training - there were no certificates stating proficiency, training or qualifications of a QC inspector maintained in the appropriate l
quality file (See Notice of Nonconformance, Item E); Procurement Source <'
Selection - certain suppliers have not been qualified ir. accordance with the specified methods (See Notice of Nonconformance, Item F);
Heat Treatment -/
certain heat treatments were not accomplished in accordance with the appli-cable procedure.
(See Notice of Nonconformance, Item G.).
l Unresolved Items:
Design Process Management - Engineering Section personnel were not famili,ar with the QA/QC design control requirements as stated in the QA/QC manuals (See Details Saction, paragraph E.3.b.).
Indoctrination and Training - QA/QC personnel may perform certain engineering computations, how-
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ever, discussions disclosed that they did not understand the method of analysis used in stressing ram calibrations (See Details Section, caragraph H.3.b.).
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1 DETAILS SECTION (Prepared by L. E. Ellershaw, H. W. Roberds, J. J. Lenahan, J. R. Harris)
A.
Persons Contacted
- L. Bau - General Attorney
- C. Brooks - QC-Inspector
- E. Davis - Assistant to the Vice President J. Fisk - General Manager
- H. F. Hendrickson - Supervisor, QC
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- R. Hough - Supervisor, Quality Engineering
- 8. C. Lathrop - Civil Engineer
- 8. Levinsky - Attorney J. A. Melone - Mechanical Engineer H. Presswalla - Supervisor, Engineering Section C; W. Sieloff - QA Representative E. L. Sulima - Lead Detailer
- D. W. Waitkus - Supervisor, QA
- Denotes those persons attending the exit meeting.
B.
Follow-up on Construction Deficiency Reoort (L. E. Ellershaw) 1.
Introduction TVA notified Region II of questionable heat traceability for certain anchor head material used in the prestressing system for the primary containments of Belleronte Units 1 and 2.
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2.
Inspection Objectives a
The objectives of-this area of the inspection were to review the nature and' scope of the reported deficiency and determine any generic implications.
3.
Method of Accomolishment T,he preceding objectives were accomplished by:
- a.. Review of information presented to tne inspector by Mr.. E. Davis 20 of Inryco, subsequent to the inspection, at NRC Region IV Office, on December 11, 1980.
4.
Findinas 4
During the' course of this inspection, information had not been fully developed by Inryco which would allow for a thorough review of the problem.
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4 It appears that the problem is a result of a vendor's inadequate material identification and control systems in that certain bar material was color coded incorrectly, thus it was not traceable to the correct heat number.
Subsequently, some of this naterial was processed and shipped as a certain heat of material, when in fact the parts consisted of different heats.
This information became available after the inspection.
-This item will require further investigation during the next scheduled inspection at Inryco.
C.
Manufacturing Process Control (J. R. Harris) 1.
Objectives The objectives of this area of the inspection were' to verify that Inryco had implemented 'the requirements for preparing and approving procedures, which prescrice a system for tendon fabrication that is consistent with the commitments of the QA Program and applicable NRC requirements, and to ascertain that the procedures are effectively implemented.
2.
Method of Accomolishment The precedi5g objectives were accomplished by:
Review of QA Manual Title V, " Instructions, Procedures, and a.
Drawings."
b.
Review of QC Manuals for the Bellefonte, Midland, and Byron Braidwood projects.
Review of procedures PT 5.1, dealing with tendon fabrication, c.
and QCP 5, dealing with testing and buttonhead machine quali-fications.
d.
Reviey of Specification 1519, dealing with auttonhead config-uration.
e.
Review of Tencon Fabrication Records.
,f.
Obse vation of 1mplementation of the tendon fabrication control? during fabrication of tendons.
A g.
Discus;. ions with cogni: ant personnel.
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3.
Findings a.
Nonconformance See Notice of Nonconformance, Item A.
While observing the operator performing the buttonhead machine qualification, and in the presence of the QC Supervisor, the operator, stated to the NRC inspector that he buttonheaded one end'of eacn wire sample "like always."
Examination of discarded wire samples verified the operator's statement.
b.
Unresolved Items None.
D.
Control of Nonconformances and Corrective Actions
( L. E. Ellershaw and J. R. Harris) 1.
Objectives The objectives of this area of the inspeltion were to verify that Inryco had implemented the requirements for the control of noncon-formances and corrective action in accordance with the QA Manual and applicable NRC requirements.
a a
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2.
Method of Accomolishment The preceding objectives were accomplished by:
Review of QA Manual, Titles XV, " Nonconforming Items" and a.
XVI, " Corrective Action."
b.
Review of QC Manuals for the Bellefonte, Midland, and Byron-Braidwood projects.
' c.
Review of both open and closed Nonconformance/ Corrective A~ction forms (NC/CA) for the above named projects.
d.
Observation of nonconforming parts to verify that discrepant material is identi,fied.
I e.
Discussions with cognizant personnel.
4 cc 3.
Findings a.
Ncnconformance (1) See Notice of Nonconformance, Item B.
(L. E. Ellershaw and J. R. Harris)
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QA Manual, T'tle XV, Section 3, addresses a "Nonconformance Report Index "which is used to list tho NCR No., item, date written, date submitted, date approved and date com-pleted.
The inspector utilized the index in an attempt to ascertain whicn Nonconformance Reports (NCR) were open or closed.
The following conditions were noted, to supplement Item B.
i.
The index showed NCR 791-35 to be open and it addressed an Anchor Head, JA-81, which failed by cracking into 5 pieces.
The recommended dis-position was Hold for Engineering Investigation.
i;c other section of the NCR was completed.
ii.
The index showed NCR 791-15 to be completed and it addressed 8 bearing plates having gauges' Wsid repair 5 plates in accordance with approved < weld repair.proced6te.
Scrap 3 plates.
There was no approval and no final disposition.
iii.
The index showed NCR 791-49S as being open, and it addressed 114 horizontal tendons having shop applied buttonheads which exceed Inryco's Button.
head Criteria 1610 for splits and slips.
There w3s no disposition acceptance.
iv.
The index showed NCR 791-4S as pending, and it addressed Anchor Head traceability.
The Nonconformance Section stated, " Vendor fail'ed to maintain traceability of slugs for anchor heads.
by Heat No. Consequently 3 heats were heat code stamped with one code.
All JA heads were in fact, some JA, some JG and some JH."
The recommended disposition was, "Use As Is.
- Change, documentation - Add two other Codes JG and JH to documentation and call them both JA.
Therefore, Heat Numbers 6073343, 6052405 and 6061438 all become Heat Code JA."
The Corrective Action to ?rpvent Recurrence section stated, "Vandor reprimanded.' QC Manual procedures changed to reflect color coding of bars by heat prior to,saw cutting and shipping procedures indicate that slugs to be stacked in bins by hea*
_ code and color code on'y."
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(2) See Notice of Nonconformance, Item C.
(L. E. Ellershaw)
.Nonconformance Report #79-515 dated 7-24-80 states under the Nonconformance Section, " Wire received from NOI on RT Numbers 10105, 10126, and 10128 had a total of 50 coils.
Eleven coils are on hold due to no identifying coil numbers, six coils are on hold due to rust and pitting.
Purchase Order 45T791-578."
This Nonconformance Report was voided out and signed by a QC Inspector on 9-29-80.
The inspector asked the QC inspector what the reason was for voiding out the report..The response was, "We have so many situations like this, that we would have so many Nonconformance reports we wouldn't know what to do with them."
In addition, there were over 45 coils of wire which were identified by a hold tag as being nonconforming, but no nonconformance report had been generated.
b.
Unresolved Item None.
s E.
Design Process Management (J. J. Lenahan) b 1.
Objectives The objectives of this area of the inspection were to determine if procedures had been prepared to prescribe a system for control of design, incluoing design changes, which is consistent with the commitments of the Quality Assurance Program and NRC requirements, and that the design procedures are being proterly implemented.
2.
Method of Accomolishment Theprecedinaobjectiveswereaccomplishedby:
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Review.of Title III of the QA Manual, " Design Control."
-b.
Review of quality cont ol procedures covering design control in'the Bellefonte, Midland, and Marble Hill QC Manuals.
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Discussions kith Engineering Section personnel.
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Findings a.
Nonconformance None.
b.
Unresolved Item-On nuclear power plant projects, the majority of design work on structures utilizing post-tensioning is performed by the project's Architect-Engineer.
Inryco's role in performance of design work is generally limited to tendon layout, design of the tendon, and review of field change requests and noncon-formance reports relating to the tendon system.
Discussions with the Engineering Section personnel disclosed that they were not familiar with the QA/QC design control requirements stated in the Inryco QA-Manual and project QC Manuals.
The inspector noted that copies of the project QC Manuals were not maintained in the engineering section.
Based on discussions with the engineering section personnel, it appears that the design process is being controlled by use of informal design control measures.
There was insufficient time during this inspection to determine if the system being used to control the design process meets the requirement.of the Inryco QA Manual and the project QC Manuals.
The apparent lack of formal design control procedures was identified to Inryco as an Unre-solved Item pending further review by NRC.
F.
Ecuioment Calibration (J. J. Lenahan) y 1.
Objectives The objectives of thi's area of the inspection were'to determine if procedures had been prepared to prescribe a system for control of measuring and test equipment, which is consistent with the cammitments of the Quality Assurance Program, NRC requirements, and,that the procedures are being properly implemented.
2.
' Method of Accomoishment The preceding objectives were accomplished by:
Review of Title XII of the QA Manual, Ocntrol of Measuring and a.
' Test Equipment".
a b.
Review of the following calibration procedures:
(1)
Procedure QA 9.1.A, "Go-NoGo Gauge - Drawing AC-20"
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r-9 (2) Procedure QA 9.1.B " Micrometer 0" to 2""
(3) Procedure QA 9.1.C " Pressure Gauges" (4) Procedure QA 9.1.0 " Thermometers" (5) Procedure QA 9.1.E " Feeler Gauges" (6) Procedure QA 9.1.F " Dial Indicator Gauges" (7) Procedure QA 9.1.G " Stressing Ram / Jack Hydraulic" (8) Procedure Q675-G " Stressing Ram / Jack Hydraulic Special" Review of the calibration procedures in Bellefonte, Byron /
c.
Braidwood, Midland and Marble Hill QC Manuals.
These procedures address the requirements for frequency of equipment calibration and acceptance criteria to be used in calibration, d.
Discussions with quality control and engineering section personnel.
3.
Findings a.
Nonconformance See Notice of Nonconformance, Item 0.
Calibration procedure Q 675-G states that values for calibration of stressing rams will be read at 1000, 2000 and 3000 psi and at the maximum jack pressure, 1000 psi below maximum, and at 2000 psi below the maximum.
The calibration procedure states that the data will be ana]yzed using linear regression analysis.
Contrary to the above, readings for calibration of the 1000 ton stressing rams for use at Bellefonte were taken at 1000, 2000, 3000, 4000, 5000, 60CO, 7,000 and 7600 psi.
Readings for cali-6 bration of the 1400 ton strassing rams for use at Midland were taken at 1000, 2000, 3000, 4000, and 4800 psi.
Quality control personnel were not aware that procedure Q675-G had been issued, which addresses the ram calibration by linear rcgression analysis.
b The procedure allows them to perform the computations or Engineering check in cases of extreme urgency. y
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10 In review of the results of-the computer linear regression analysis for the stressing rams.to be used at Bellefonte and Midland, the inspector noted that some readings were deleted from the analysis.
Procedure Q675-G does not permit deletion of readings in the linear regression analysis.
b.
Unresolved Items None.
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G.
Quality Assurance Records (J. J. Lenahan)
'1.
Objectives The objectives of this area of the inspection were to determine that procedures had been prepared to prescribe a system for generation of accurate quality assurance records that is consistent with the commit-
~ment of the Quality Assurance Program, NRC' requirements, and that the procedures are effectively implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Title TNII, of the QA Manual " Quality Assurance Records."
i b.
Review of the Bellefonte, Byron /Braidwood, and Midlang QC' Manuals.,
c.
Review of stressing ram calibration records for Bellefonte and Midland projects.
f d.
@cview of' tendon fabrication records for Bellefonte, Braidwood, t
and Midland projects.
e.
Discussions with Quality Control personnel.
3.
Findings er a.
Nonconformance None.
a b.
Unresolved It@m
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Comment A potential problem has been identified due to certain ambigui-l ties and the intent of a certain document; namely the Tendon l
Fabrication Record.
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11 QA Manual, Title XVII, Sections 1, 2, and 3 states in part,
" Documentation to furnish objective evidence of compliance to the approved drawings specifications, and/or procedures relative to the quality of items and activities affecting quality will be provided for the contract materials or services....
The documentation will include but not be limited to the results of reviews, inspections, tests, audits, monitoring of work performance.
Inspection and test records will identify the date of inspection or test, the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted...."
Certain quality records do not show evidence of the results of inspections.
On the tendon fabrication records for Midland and Braidwood projects, the term "0K" was written next to the descrip-tion of each operation performed in fabrication of the tendon and the records were signed by a QC inspector.
Discussions with Quality Control personnel disclosed that tendon fabrication is inspected on a random sampling basis (as stated in the project QC manuals) and that all operations in the fabrication of the tendons nad not been inspected.
On many of the records the signature of the QC inspector only indicates that the record had been reviewed to verify that it was filled out completely.
There is no way from review of the records to determine if an actual inspection of the tendon fabrication operations had been performed, or if the record had only been reviewed for complete-ness.
A similar problem was noted concerning the Bellefonte and Midland stressing ram calibration records.
On these records 3 there is a signature line labeled "QC Check." Discussiod with the QC, personnel disclosed that their primary role in calibration of the stressing rams is to review the records for completeness.
The ram calibration is recoroed by craftsman, occasionally witnessed by QC inspectors, and submitted to the engineering section for analysis.
From review of the records, it is not
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clear what the role of the QC inspector in stressing ram cali-bration was.
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Indoctrination and Training (L. E. E11ershaw) 1.
Objectives f
e The objectives of this area of the inspection were to verify that Inryco had imp 4emented the requirements for indoctrination and training of personnel wnose activities affect quality in accordance with the QA Manual and applicable NRC requirements.
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Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Title II, " Quality Assurance Program."
b.
Review Tendon Inspection Checklists to ascertain the identity of QC inspectors involved in inspection operations.
c.
Review of procedure QCP QC 5.1 dealing with Tendon Inspection Checklists requirements.
d.
Review of quality files dealing with QC inspector qualification records.
e.
Discussion with cognizant personnel.
3.
Findings a.
Nonconformance See Notice of Nonconformance, Item E.
A review of Tendon Inspection Checklists, revealed the names of two QC inspectors involved in signing off certain inspec-tion operations.
A subsequent review of these inspectors' training record files, showed one file did not contain any certificates stating the proficiency, training or q3alifica-tions of that inspector.
The only document in the^ file per-tained to a physical examination relating to vision and physical limitations.
This document was dated 6-9-80 and was signed off by the,QA Supervisor as being acceptable.
b.
Unresolved Item (J. J. Lenahan)
The last sentence in paragraph 1.6 of Calibration Procedure Q675-6
" Stressing Ram / Jack Hydraulic-Special reads as follows:
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" Quality Control or Quality Assurance personnel may perform the computations or Engineering check in cases of. extreme urgency."
Discussions with QA & QC personnel disclosed that they did not understand the method of analysis usedin stressing ram cali-bration methog Q675-0 and that they would not be able to do the engineering,coniput'ations or check. aThey had received no training in this method of' analysis, er O
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Procurement Source Selection (L. E. E11ershaw) 1.
Objectives The objectives of this area of the inspection were to verify that Inryco had implemented the requirements for procurement source selection in accordance with the QA Manual and applicable NRC requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual Title VII, " Control of Purchased Material, Equipment and Services."
b.
Review of vendor files relative to Irryco's source seleccion process.
c.
Review of the Approved Vendor List (AVL) dated 6-16-80.
d.
Discussions with cognizant personnel.
3.
Findings a.
Nonconformance a
See Notice of Nonconformance, Item F.
e The QA Manual addresses the use of an Evaluation and Quali-fication of Procurement Sources (EQPS) form which describes the method used to qualify a vendor, and the use of a Supplier Quality Program Evaluation Questionnaire (questionnaire) which is used to obtain information relative to a potential suppliers' previous nuclear experience, quality programs in existence, and the vendor's capability.
The manual further allows the waiver of qualifying audits when the justification is adequate and doi:umented.
The follo0ing information was obtained during a review of records pertaining to seven vendors, cf which six are describec:
(1) NOI (Nederlandse Draadindustrie NDI b.v.)
They are listed on the EQPS as being qualified as a primary wire source
- safety related, dated 5-17-78~.
The EQPS states,
" Evaluation by waiver of audit at this time, emergency conditior,. cequire immediate qualification based on d
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4 14 information at hand. Will evaluate more fully within next 60 days." A questionnaire was sent to NDI for completion.
It was returned and dated 6-12-78.
One of the questions-is as follows:
"Does your Company maintain a QA or QC written program manual?" The response No, was checked off.
These were the only evaluation type records in the fiie.
(2) Accurate Steel Treating Company.
An EQPS dated 4-13-78, showed them to be " acceptable", and that they were qualified by:
"Previously qualified by Inryco.
Has been used for many years as the primary supply for heat treat-ment work.
Has helped to develop tne HT 101 pecification."
This was the only evaluation type record in the file.
There were no reco-ds relative to their being previously qualified.
(3) Auto Truck Steel Body An EQPS dated 4-13-78, showed them
'.o bq acceptable for e
i safety related work.' It showed them to be qualified by three audits dated 9-8-77, 9-20-78 and 11-22-78.
There were no records of the 9-20-78 and 11-22-78 audits.
(4) Mason Steel Fabricating Co., Inc.
A questionnaire dated 8-28-79 showed that they have a written QA/QC program, but it is not in accordance with Appendix B or ANSI.
The Inryco QA Review section states that they are
" acceptable for non-safety related work until we can visit and/or audit." This was signed by the Inryco QA Supervisor on 9-4-79.
There was no record of a 6irit and/or audit, nor was there an EQPS, yet they are listed on the AVL as being approved for fabrication on nuclear applications (there is no dis-tinction on the AVL between sifety and non-safety related.
(5) Anderson Metals, Inc.
An EQPS dated 4-4-80, showed them to be " Acceptable" for safety related work.
A comment stated, " Acceptable to supply materials based upon ability to furnish materials to acc?pted codes and standards." There was a questionnaire j
in the file, dated 3-1-80.
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Primary Steel, Inc. (PSI)
There was a questionnaire dated 4-2-80, on which PSI stated that they had no written QA/QC program.
I 15 The EQPS dated 5-28-80 stated:
" Acceptable" for Nuclear safety related work.
A comment stated; " Acceptable as a supplier of materials for commercial, safety related, and non-safety related work based upon their ability to furnish materials to accepted industry codes and standards."
There were no other records in the file; and they were listed on the AVL under steel and wire suppliers.
J.
Heat Treatment (H. W. Roberds) 1.
Objectives The objective of this area of the inspection was to verify that precedures have been established to control the heat treatment of materials and parts and that these procedures are consistent with applicable regulatory, material specifications, and contract requi rement.c.
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Method of Accomplishment The preceding objective was accomplished by:
Review of Title IX of the QA Manual, " Control of Special a.
Processes."
b.
Review of Heat Treatment Specification, HT-101, revision 2.
c.
Review of Heat Treatment charts, supplied by Accurate Steel Treating Company, for lot Nos. 1, 2, & 3 on G&G Manufacturing Company Order No. 39566.
3.
Findings a.
Nonconformance See Notice of Nonconformance, Item G.
b.
Unresolved Items None.
K.
Welder Oualification (H. W. Roberds) 3C 1.
Objectives The objectives of this area of the inspection was to determine if welders and/or welding operators were qualified in accordance with AWS and/or ASME Code requirem,ents.
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Method of Accomplishment The preceding objective was accomplished by:
a.
Review of Title IX of the Quality Assurance Manual
" Control of Special Processes."
b.
Review of Rode Welding Service Inc. audit records.
c.
Review of five (5) welder qualification test records.
3.
Findings a.
Nonconformance None.
b.
Unresolved Item None.
L.
Exit Meeting An exit meeting was held on Nove..ioer 21, if80, with the management repre-sentatives denoted in paragraph A. above.
At the beginning of the meeting, Inryco presented a written position statement to the NRC inspectors, which asserted that the provisions of Appendix B to 10 CFR 50 were appli CP cable directly only to applicants or licensees of the NRC, and Inryco would consequently take exception to any part of the NRC inspection team findings that were based upon Appendix B to 10 CFR 50.
This statement was an amplification of an original statement read to the NRC team on November 19, 1980, which questioned the legality of the NRC's right to audit the Inryco program under the provisions of Appendix B to 10 CFR 50 and asserted that the NRC was abusing its right to inspect, was acting in behalf of a third party, its representatives were uncooperative and held preconceived opinions concerning Inryco's quality assurance program.
This position also stated that Inryco would continue to make available all relevant records, premises, activities and basic components as pre-scribed by 10 CFR 21.41 and that all questions concerning any inspected i
l materials or documents were to be directed to Mr. E. Davis.
The inspectors summarized the scope and f'.laings of the inspection.
Management made no comments relative to the findings as presented to them.
The~ lead inspecter informec Inryco personnel that additional
. review of material relevant to the inspection would be conducted upon return to the respective NRC Regional Offices, which could result in the writing of additional findings, unresolved items, or co.,ments not addressed during the meeting.
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