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APPENDIX B

Texas Bolt CompanyDocket No. 999Q(L8.88/84-01

NOTICE OF NONCONFORMANCE

Based on the results of an NRC inspection conducted on November 12-15, 1984, itappears that certain of your activities were not conducted in accordance withNRC requirements.

Criterion V of Appendix B to 10 CFR Part 50 states: " Activities affecting-quality shall be prescribed by documented instructions, procedures, ordrawings, of a type appropriate to the circumstances and shall be accomplishedin accordance with these instructions, procedures, or drawings. Instructions,procedures, or drawings shall include appropriate quantitative or qualitativeacceptance criteria for determining that important activities have beensatisfactorily accomplished."

Nonconformances with these requirements are as follows:

A. Section 1.7 of the Quality System Maual (QSM), Revision 7 states, in part," Qualification of personnel performing and interpreting non destructiveexaminations ... will be qualified in accordance with ASME S6ction III andSNT-TC-1A.

Section 9.2.3 of SNT-TC-1A (June 1975 Edition) states, "The employer shallin his written practice establish rules covering the duration of interruptedservices which will require re-examination and re-certification.,

Section 9.6 of SNT-TC-1A states, in part, " Certification records shall bemaintained on file by the employer and should contain personnel recordsof the certified individuals ...."

Section 9.6.1 of SNT-TC-1A states, in part, "The personnel records of thecertified individuals should include as a minimum the following: ... d.Statement indicating satisfactory completion of training in accordancewith the employer's written procedure. e. Results of the physicalexamination ... f. Copies of current examinations ...."

Section 8.5.3(c) of SNT-TC-1A requires that the practical examination fora Level III include the writing of a specification or procedure fo* the

- performance of the applicable nondestructive test.

Centrary to the above, a review of nondestructive examination (NDE) recordsrevealed the following:

(1) . Procedure No. TB-NDT-PQC-#1, "NDT Personnel Qualification & Certi-fication" dated March 2, 1981, did not contain rules covering. interrupted service requiring re-examination and re-certification.

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(2) Records for five NDE personnel (3-Level II and 2-Level III) fromTexasTolt (TB) did not contain a statement indicating completion

i . of- training in accordance with TB's written procedure.

(3)were certified as Level III-liquid penetrant -(PT)pection (II), whoRecords for two-NDE personnel from Industrial Ins

and Level II-magnetic particle (MT), did not contain a physical' examination (s)or copies of the PT or MT examinations.4

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(4) The practical examination for both of TB's Level III-MT examiners(QA/QC Manager and Assistant QA/QC Manager) were incomplete in that

.a specification or procedure for the performance of a MT examinationwas not written. '

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B. The Policy Statement of the QSM states, in part, "... Texas Bolt Company; Quality System to comply with the quality program criteria set forth in

ASME Section III Sub-section NCA-3800 and ANSI N45.2 ....".

Subsection NCA-3866.2 of Section III, the ASME Code states, in part," ... measures shall assure that documents including changes, are

= reviewed for adequacy ... by authorized personnel ...."

Section 7 of. ANSI /ASME N45.2-1977, "QA Program Requirements for Nuclear.

Facilities" states.-in part, " Document control measures shall provide*

for: (1) . identification o.f individuals or organizations responsible forpreparing, reviewing, approving ... documents and revisions thereto ...."

Contrary to the above, measures were not in place to identify individuals /organizations responsible for preparing, reviewing and ' approving theprocedures contained in;the Procedure Manual.

.C. Section 4.3 of the QSM states, in part, " Purchase of ... services will be

from the approved vendors list."

- Section 7.lb of the QSM states "Only supplier's (sic) approved for use-by the Quality System department will be utilized."

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Contrary to the above, a review of purchase orders (P0) ~to suppliers and-~

external audits conducted by'TB revealed that the plating services of-

, Southwestern Plating were utilized in September 1984 on nuclear bolts,-

and the calibration-services of Honeywell Corporation, W. H. KesslerCompany, and Newport Instrument. Company were utilized for quality-related,temperature measuring equipment on November, June, and May 1984,,

.respectively, although none of these firms were included on the approvedvendors list.'

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D. Section 12.1 of the QSM states, in part, " Calibrations are traceable toNational Standards ...."

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Subsection NCA-3868.1 of Section III of the ASME Code states, in part," Calibration shall be against measurement standards which have knownrelationship to national standards ...."

Section 13 of ANSI /ASME N45.2-1977 states, in part, " ... inspection,measuring, and test equipment shall be ... calibrated ... againstcertified equipment having known valid relationships to nationallyrecognized standards."

Contrary to the above, II calibrated two magnaflux units'(S/N 43253 and-

S/N 81409) but II's Machinery Inspection Report for each unit did notindicate the standards used for calibration to assure that traceabilityto national standards was maintained.

E. Section 5.1 of the QSM states, in part, " Published instructions andprocedures are utilized to assure that activities affecting quality arecontrolled."

Sections 2 and 6 of ANSI /ASME N45.2-1977 require that activities affectingquality be prescribed and accomplished in accordance with written instruc-tions or procedures.

Subsection NCA-3866.4 of Section III of the ASME Code states, in part," Measures shall be established to assure that processes includingheat treating are controlled ...."

Subsection NCA-3866.1 states, in part, "... maintain a written descriptionof the procedures ... for control of quality ...."

Contrary to the above, it was noted that procedures or instructions did notexist for the following activities:

Heat treating in the Electric Box Furnace (S/N F-10-65).-

- Material testing such as tensile strength,-hardness, and proofloading evaluations.

Utilization of stamps such as " LAB," " NUCLEAR," and " Material-

| Approved by Met Lab."

F. Section 4.2 of the QSM states, "The Quality Systems Manager, or his designee,will review and sign each purchase order and changes for nuclear materials

! or services. This review will assure that the requirements of the codes oradditional customer requirements, that pertain to materials or services,are satisfied."

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Contrary to the above, the Quality System Manager or his designee didnot sign a'lotal of 19 internal purchase order forms reviewed duringthe inspection.

G. Section 12.5 of the QSM states " Discrepant gauges are separated andplaced under lock and key. These gauges are also tagged with a "00 NOTUSE" tag.

Contrary to the above, on November 14, 1984, numerous discrepant gaugesincluding a "no-go" gauge and a micrometer were not placed under lockand key and were not tagged with a "D0 NOT USE" tag.

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H. Section 15.2 of the QSM states, in part, "At discovery, materialevaluated to be nonconforming shall be properly identified and tagged.Segregation of material will be accomplished as necessary to preventmix (SIC) with acceptable material and maintained until proper disposi- .

tion has been made."

Contrary to the above, TB did not tag and segregate nonconformingmaterial following final _ visual inspection as evidenced during a planttour when bolts, nuts, and threaded rods were stored in untaggedcartons which were mixed with cartons of acceptable materialspending final product packaging and shipment. |

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I. Section 15.2 of the QSM states, in part, "The Quality Systems Managerwill determine disposition of nonconformances and indicate the remedialaction to be taken for correction of the conditions reported."

Contrary to the above, three nonconformance reports for 1984 and threenonconformance reports for 1982, constituting the total number of reportsfor each year, were dispositioned by the Assistant Quality Systems Manager /Laboratory Supervisor.

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