ML19284A644
| ML19284A644 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1978 |
| From: | Mcneill W, Withesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19284A631 | List: |
| References | |
| REF-QA-99900331 NUDOCS 7903150142 | |
| Download: ML19284A644 (8) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION 9
0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900331/78-03 Program No.
51300 00mpany:
Excelco Developments, Incorporated Post Office Box 230 Silver Creek, New York 14136 Inspection Conducted: December 11-15, 1978 Inspector:
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W. M. Mct,eill, Contrr: tor Inspector, Vendor Date Inspection Branch Approved by:
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/ /,2 9 7c V D. E. Whi'tesell, Chief, ComponentsSection I Date Vendor Inspection Branch Summary Inspection on December 11-15, 1978 (99900331/78-03)
Areas Inspected:
Implementation of 10 CFR 71 Appendix E, Certificate of Compliance, Safety Analysis Report, including material identification and control; equipment calibration; nonconformance and corrective action; action on previous inspection findings.
The inspection involved thirty (30) inspector hours on site by one (1) NRC inspector.
Results: The following six (6) deviations and two (2) unresolved items were identified.
Deviations: Material Identification and Control - parts were given a final inspectinn and acceptance which did not include the ASME Code tests required by Criterion 10 of 10 CFR 71, Appendix E, and the Q.'. Manual commitments (Enclosure, Item A); measures did not assure that identification was maintained by heat number as required by Criterion 8 of 10 CFR 71 and the QA Manucl comitments (Enclosure, Item B); welders were not qualified for their positions as required by Criterion 11 of 10 CFR 71, Appendix E and the QA Manual commitments (Enclosure, Item C).
Equipment Calibration - meas ures did not assure devices used are of the proper type and accuracy as required by Criterion 12, ASME Code and the QA Manual commitments (Enclosure, Item D); Inspection Reports did not document gages used as required by Criterion 5 and the QA Manual comitments (Enclosure, Item E).
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. Nonconformance and Corrective Action - measures did not assure that all nonconformances were documented and reported as required by Criterion 15 and the QA Manual commitments (Enclosure, Item F).
Unresolved Items:
Action on Previous Inspection Findings - a QA Manual revision will document how Weld Parameter Sheets are to be used as addenda to the Welding Procedure Specifications (WPS) (See Datails, 8.2.).
Material Identification and Control - records were not on file that would demonstrate conformance of materials to the specification and drawing (See Details C.3.b).
Other Significant Findings: Nuclear Assurance Corporation has identified to the NRC that Excelco is its fabricator.
Nuclear Assurance Corporation has stated in its Certificate of Compliance and Safety Analysis Report that Excelco will comply with Appendix E.
Appendix E has been passed on to Excelco by the Nuclear Assurance Corporation contract as part of the design specification.
P e
DETAILS SECTION A.
Persons Contacted
- W. D. aobott, Chief Engineer, Excelco
- L. A. Brooks, President, Excelco J. L. Brooks, Test Engineer, Excelco G. P. Mcdonald, Records Clerk, Excelco F. I. McLearn, Chief Inspector, Excelco
- M. M. Pulawski, QA Manager, Excelco J. P. Shaw, Purchasing Agent, Excelco
- C. H. McDonnell, Chief, Nuclear Engineer, United States Testing Co.
- C. C. Hoffman, Manager of Cask Operations, Nuclear Assurance Corporation
- M. G. Blackwood, Operations Technican, Nuclear Assurance Corporation
- Denotes those attendina the Exit Interview.
B.
Action on Previous Inseection Findings 1.
(Closed) Deviation (Report No. 78-02): Controls were not provided for cutting oils. Training sessions have been held and documented on this requirement.
Personnel have been instructed to use only one brand and type of cutting oil which has been formulated for use on stainles.
2.
(Closed) Deviation (Report No. 78-02): Welding was not perforned in accordance with procedures. The welding procedure in question, WS-5-10, has been revised, June 20, 1978.
This change corrected the ampere range.
In regard to the other parameter, Excelco has begun the process of changing its QA Manual. This change will establish that Weld Parameter Sheets shall be used to document changes to the WPS as an addenda to the WPS. This is an unresolved item until this change has been approved and issued.
3.
(. Closed) Deviation (Report No. 78-02):
Subvendors were not required to provide a QA Program consistent with Appendix E.
Training sessions have been helded and documented on this requirement.
New purchase orders will incorporate Appendix E.
4.
(Closed) Deviation (Report No. 78-02):
Documentation did not demonstrate that purchased materials conformed to procurement documents.
In regards to the Balsa wood, new certifications have been obtained.
In regards to the safety heads, correspondnce from the subvendor has established that the parts are equivalent.
The manufacturing drawings have been changed and new travelers issued to fix the fire valves so that they conform to drawing E 10080. Training sessions have been held and documented to restate these requirements.
. 5.
(Closed) Deviation (. Report No. 78-02):
Receiving inspection for safety heads, fire valves, etc. was not prescribed by documented instructions. Certifications will be used in lieu of a compre-hensive receiving inspection.
Purchase Orders will note when such certifications are required.
6.
(Closed) Deviation ( Report No. 78-02):
Scheduled audits were not performed nor were there records of qualifications of some personnel. An Internal Audit Schedule dated August 7,1978, has been implemented. Training has been performed and documented for all audit personnel. This training was performed September 23, and October 14 and 15, 1978.
C.
Material Identification and Control 1.
Objective The objective of this area of the inspection was to verify that material identification and control during manufacturing is in accordance with the applicable regulatory, code and contract requirements.
2.
Method of Accomplishment The preceding objective were accomplished by:
Review of the Excelco QA Manual, Revision 0, dated May 20, a.
1977, Section 6.1 which established the general requirements for traceability identification.
b.
Verification that the above manual was implemented by review of the records for a sample of parts. The sample was of ten (10) pressure boundry and other critical parts, namely, shell assembly, trunnions, 0-rings, bolts, heli coils, and copper.
The records reviewed included the Certified Material Test Reports (CMTR); Travelers, documenting the use of a heat as particular part; the "as built" tabulation of parts and heat numbers; the design specification, NAC0001, Revision 4; and the design drawing E 10080, Revision 16.
c.
Verification that parts were marked properly by review of the cask and parts in production.
3.
FindinSs a.
Deviations See Enclosure Items A, B and C.
. 5.
Jm es@ed Items During the above review it was noted that some documentation was incomplete.
For example, certifications did not denote that 0-rings conformed to MS 3651, a requirement of the flAC specification. There was no evidence that the part number of the retaining rings received was equivalent to that called out on NAC drawing E 10080.
Verbal confermation of the above was obtained by Excelco.
Complete documentation will be obtained by Excelco to show conformance to the specification and drawing.
c.
Comments A number of observations were made in this area of the inspection.
(1) f1AC specification, NAC0001, Revision 4, requires cask lid bolts (item 10 on drawing E10080) to be A320 type L43 bolts. A320 requires impact properties be meas-ured by a charpy V-notch test. Although the bolts have been given a final inspection and released no Charpy V-notch test has been performed.
(2) Shipments of copper for heat transfer fins (item 31 on drawing E10080) were accepted and copper installed.
The heat or lot number on the receiver from the supply house does not agree with the number of the heat or lot number on the mill certificaton.
The purchase order for the copper required mill certifications.
It was also noted that the certification was incomplete in that the minimum copper was not fully reported, the hardness was not reported, and the microscopic exami-nation was not reported.
The above are requirements of the material specification for which the copper was to conform.
(3) Gas Tungsten Arc Welding of the cooling tank partition gussets was in process during this inspection.
It was noted that two (2) welders were welding who's symbols were H.F. and R.P.
The welding was performed in the 2F and 3F position.
Welder H.F. was qualified to the 2F position only and R.P. was not qualified to either position.
. D.
Equipment Calibration 1.
Objectives The objectives of this area of the inspection were:
a.
To ascertain that a system has been established and is maintained to assure that tools, gages, instruments and other measuring devices used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to maintain accuracy within specified
- limits, b.
To verify that the system described above, has been adequately documented with approved procedures and that these procedures are being implemented.
2.
Method of Accomplishment l
The preceding objec;ives were accomplished by:
a.
Review of the Excelco QA Manual, Revision 0, dated May 20, 1977, Section 11 which established the general requirements for gage control.
b.
Verification that the above manual was implemented by review of a sample of gages and their calibration records.
The review included establishing the NBS traceability of the secondary standards used. The sample was fourteen (14) gages documented as having been used for cask fabrication.
3.
Findinas a.
Deviations See Enclosure Items D and E.
b.
Unresolved Items None.
c.
Comments Several observations were made of this area of the inspection.
(1)
"Pi" tapes were noted to have been used in at least (5) or more cases were 20 to 30 inch diameters were measured.
These diameters had a tolerance range of.005 to.010
. of an inch. A "Pi" tape is a steel tape which reports an average diameter.
It is not the Excelco policy to calibrate "Pi" tapes. The type and accuracy of the gages used in these cases is not correct.
(2) Cask lid bolts (item 10 on drawing E10080) and lid alignment bolts (item 19 on drawing E10080) were fabricated by Excelco. The cask lid bolt's Inspection Report (IR) did not document the gaging used to inspect the threading. The IR on the lid alignment bolts did not document the correct serial number of the gages used. The IR documented that two (2) male gages had been used to inspect the male threads of the alignment bolts. A proper inspection wculd have used two (2) female gages.
E.
fionconformance and Corrective Action 1.
Objectives The objectives of this area of the inspection were:
a.
To ascertain that a systen for control of nonconformances and for assuring effective corrective actions has been established and is consistent with the QA Program.
b.
To ascertain that the system is properly implemented.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of the Excelco QA Manual, Revision 0, dated May 20, 1977, Section 13 which established the general requirements for control of nonconfori.iances and corrective action.
b.
Review of QC Procedures, Procedure to Prepare and Process A " Inspection Report of Monconformance" (IRN), QC-0203, dated December 6,1967; Control of Nonconforming Material, QC-0205, dated December 6,1967; Material Review Board, QC-0208, dated January 19, 1968; Corrective Action, QC-0209, dated January 19, 1968, which established the specific requirements for control of nonconformances and corrective action.
c.
Verification that the above procedures and manual were implemented by review of six (6) IRN's and about one hundred (100) Inspection Reports (IR's).
.,~
, 3.
Findings a.
Deviation See Enclosure Item F.
b.
Unresolved Items None.
c.
Comments In the review of the IR's, nine (9) parts were found which have twelve (12) dimensional nonconformances.
None of these dimensional nonconformances were documented and reported on IRN's as is required by the QA Manual.
Examples of these nonconformances were that the inside diameter of the cask was undersize, vent cover 0-ring groove was oversize and the impact cover's retaining ring groove was oversize. The irs in question were dated as early as February, April and May of 1978.
F.
Exit Interview The inspector met with management representives (denoted in paragraph A) at the conclusion of the inspection on December 15, 1978.
The inspector summarized the scope and findings of the inspection. The management representatives had no comment in response to each item discussed by the inspector.
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