ML20148H560

Requests Info Re Fabrication of Spent Fuel Pool Racks as Listed.Insp on 870323-27 Revealed That Implementation of Us Tool & Die QA Failed to Meet Certain NRC Requirements. Details of Insp Encl

ML20148H560
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/24/1988
From:	Butler W Office of Nuclear Reactor Regulation
To:	Leonard J LONG ISLAND LIGHTING CO.
References
NUDOCS 8803300028
Download: ML20148H560 (5)

Text

_

1 o

I

!e Cfog#o UNITED STATES g

E NUCLEAR REGULATORY COMMISSION o

l g

E WASHINGTON, D. C. 20555 March 24, 1988 Docket No. 50-322 Mr. John D. Leonard, Jr.

Vice President-Nuclear Operations Long Island Lighting Co.

Shoreham Nuclear Power Station P. O. Box 618, North Country Road i

Wading River, NY 11792

Dear Mr. Leonard:

1

SUBJECT:

QUALITY OF SPENT FUEL RACKS FARRICATED BY U. S. TOOL AND DIE AND ITS i

PREDECESSOR The U. S. Nuclear Regulatory Commission conducted an inspection of the U. S.

j Tool and Die facilities in Allison Park and Glenshaw, Pennsylvania, on i

March 23-27, 1987.

During this inspection, it was found that the l

implementation of the U. S. Tool and Die 0A program failed to meet certain NDC reouirements. The most serious of these appeared to be a breakdown in the QA/QC proaram concerning in-process examination and weld inspection. This breakdown resulted in cracked or missing welds. A copy of the inspection report (dated May 12,1987) sent to V. S. Tool and Die, Inc., is enclosed (Enclosure 1).

U. 3. Tool and Die's corrective actions were described in a response dated June 9, 1987 (Enclosure 2).

NRC's review of the corrective actions were detailed in a letter to V. S. Tool and Die, dated July 28,_1987 (Enclosure 3).

Because the inspection findings raise ouestions concerning the fabrication of spent fuel pool racks and it is our understanding that U. S. Tool and Die (or its predecessor, believed to be Wachter Engineering) racks have been purchased for your facility, please provide the following information.

1.

Please describe the extent to which the U. S. Tool and Die OA/QC progran was relied upon to assure rack quality; 2.

Please describe your in-factory and/or receipt inspection of the racks; 3.

What findings were made during your receipt inspection of the racks; and 4.

If your receipt inspections found deficiencies in the racks, what corrective actions were taken.

5.

Please describe any additional actions or examinations you plan to undertake to assure that your racks meet the original design and regulatory requirements.

Please provide your response within 60 days of your receipt of this letter.

8803300028 880324 PDR ADOCK 05000322 o

PDR

i

' This request for information was approved by OMB under clearance number 3150-0011 which expires December 30, 1989.

Comments on burden-and duplication may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, C. C.

20503.

Sincerely,

\\

Walter R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II

Enclosure:

As stated cc:

See next page

~

i Mr. John D. Leonard, Jr.

Shoreham Nuclear Power Station Long Island Lighting Company (list 1) cc:

Stephen B. Latham, Esq.

Gerald C. Crotty, Esq.

John F. Shea, III, Esq.

Ben Wiles, Esq.

Twomey, Latham & Shea Counsel to the Governor i

Attorneys at Law Executive Chamber Post Office Box 398 State Capitol 33 West Second Street Albany, New York 1222d Riverhead, New York 11901 Herbert H. Brown, Esq.

Alan S. Rosenthal, Esq., Chairman Lawrence Coe Lanpher, Esq.

l Atomic Safety & Licensing Appeal Board Karla J. Letsche, Esq.

U.S. Nuclear Regulatory Comission Kirkpatrick & Lockhart Washington, D.C.

20555 South Lobby 9th Floor 1800 M Street, N.W.

Washington, D.C.

20036-5891 W. Taylor Reveley, III, Esq.

Hunton & Williams Dr. Monroe Schneider Post Office Box 1535 North Shore Committee 707 East Main Street Post Office Box 231 Richmond, Virginia 23212 Wading River, New York 11792 Howard A. Wilber Fabian G. Palomino, Esq.

)

Atomic Safety & Licensing Appeal Board Special Counsel to the Governor j

U.S. Nuclear Regulatory Commission Executive Chamber - State Capitol Washington, D.C.

20555 Albany, New York 12224 Atomic Safety & Licensing Board Panel Anthony F. Earley, Jr., Esq.

U.S. Nuclear Regulatory Commission General Counsel Washington, D.C.

20555 Long Island Lighting Company 175 East Old County Road Atomic Safety & Licensing Appeal Board Hicksville, New York 11801 Panel U.S. Nuclear Regulatory Commission Mr. Lawrence Britt Washington, D.C.

20555 Shoreham Nuclear Power Station Post Office Box 618 Gary J. Edles, Esq.

Wading River, New York 11792 Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Comission Martin Bradley Ashare, Esq.

Washington, D.C.

20555 Suffolk County Attorney H. Lee Dennison Building Richard M. Kessel Veteran's Memorial Highway Chairman & Executive Director Hauppauge, New York 11788 New York State Consumer Protection Board Room 1725 Resident Inspector 250 Broadway Shoreham NPS New York, New York 10007 U.S. Nuclear Regulatory Comission Post Office Box B Jonathan D. Feinberg, Esq.

Rocky Point, New York 11778 New York State Department of Public Service Regional Administrator, Region I Three Empire State Plaza U.S. Nuclear Regulatory Commission Albany, New York 12223 475 Allendale Road King of Prussia, Pennsylvania 19406

i Long Island Lighting Company Shoreham (1) cc:

Robert Abrams, Esq.

Town Attorney Attorney General of the State Town of Brookhaven of New York 3232, Route 112 ATTN: John Corwin, Esq.

Medford, NY 11763 New York State Department of Law Consumer Protection Bureau 120 Broadway 3rd Floor New York, New York 10271 Mr. William Steiger Plant Manager Shoreham Nuclear Power Station Post Office Box 6?8 Wading River, New York 11792 MHB Technical Associates 1723 Hamilton Avenue - Suite X San Jose, California 95125 Honorable Peter Cohalan Suffolk County Executive County Executive / Legislative Building Veteran's Memorial Highway Hauppauge, New York 11788 Ms. Donna Ross New York State Energy Office Agency Building 2 Empire State Plaza Albany, New York 122?3 Ms. Nora Bredes Shoreham Opponents Coalition 195 East Main Street Smithtown, New York 11787 Chris Nolin y

New York State Assembly Energy Committee 6?6 Legislative Office Building Albany, New York 12248 Peter S. Everett, Eso.

Hunton & Williams t

I 2000 Pennsylvania Avenue, NW

)

j Washington, D.C.

20036 l

l

-n_--

bMk

\\

ps atag'o, s

~

UNITED STATES se i

NUCLEAR REGULATORY COMMISSION

[

wasmworoN,0. C. 20665 t

May 12, 1987 Lec<et !R 290C1082/87-01 J

1 U.S. Tool and Die, Incorporated ATTh:

Mr. Michael J. Rodgers President 4030 Route 8 Allison Park, Pennsylvania 15101 Gentierren:

This refers to the inspection conducted by Ms. C. Abbate and Messrs. J. Conway and K. Aspinwall of this office on March 23-27, 1987, of your facilities in Allison Park and Glenshaw, Pennsylvania and to the discussions of our findings with you and members of your staff at the conclusion of the inspection.

The purpose of this inspection was to observe the fabrication and testing processes of spent fuel storage racks at U.S. Tool and Die (UST&D). The areas which were covered included welding, nondestructive examination, personnel training, procurement,shopqualityassurance(QA)implementationandquality records. Areas examined during the inspection and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the irspectors.

During the inspection, it was found that the implementation of your QA program failed to meet certain NRC requirements. The, most serious of these appautrs-1 to be the breakdown in the OA/0C orocran concernins 16-7tocert extmination aM weTd fnspection.

No in-process examinations or weld inspections were beinrperftms in 'the initial stages of fuel storage rack fabrication.

Additionally, two undersize fillet welds were identified by the NRC inspector after the welds had been inspected and accepted by the.UST&D inspector.

Several other noncenfomances were identified in the areas of measuring and test equipment, procurement, and training, while two violations were identified in the areas of specifying 10 CFR Part 21 on procurement documents and the posting requirements of 10 CFR Part 21. The specific findings and references te the pertinent requirements are identified in the enclosures to this letter.

The enclosed Notice of Violation is sent to you pursuant to the provisions of Section 206 of the Energy Reorganization Act of 1974. You are required to submit to this office within 30 days from the date of this letter a written staterr,ent containing:

(1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed.

Consideration may be given to extending your response for good cause shown.

)

i

U.S Tcoi and Die, Incorporated May 12, 1987 You are also requested te submit a similar written sta'.ement for each item which appears in the enclosed Nctice of Nonconfomance.

The responses requested by this letter are not subject to the clearance precedures of the Office of Managerer.t and Budget as required by the Paperwork Reduction Act of 1900, PL 96-511.

In accordan:e with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.

j Should yo; have any questions concerning this inspection, we will be pleased to ciscuss them with you.

Sincerely, a

c-lis W. Herschof Acting Chief

-r Vendor Inspection ranch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosures:

1.

Appendix A-Notice of Violation 2.

Appendix B-Notice of Nonconformance 3.

Appendix C-Inspection Report No. 99901082/E7-01 f

4.

Appendix D-Inspection Data Sheets (6 pages) cc-Comonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Pcst Office box 767 Chicago, Illinois 60690 Wisconsin Public Service Corporation ATTN:

Fr. D. C. Hintz hanager, Nuclear Power Post Office Box 19002 Green Bay, Wisconsin 54307 Vemont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy, Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vemont 05301

APPENDIX A U.S. Tool and Die, Incorporated Oceke: No. 99901082/E7-01 NOTICE OF VIOLATION As a result of the inspection conducted on March 23-27, 1987 and in accordance with Section 206 of the Energy Reorganization Act of 1974 and its implementing regulation, 10 CFR Part 21, the followir.g violations were identified and categorized in accordance with the hRC Enforcement Policy,10 CFR Part 2 Appendix C.

1.

Section 21.31 of 10 CFR Part 21 requires, in part, that each corporation subject to the regulations in this part assure that each procurement cccument for a basic component specifies, when applicable, that the provisiens of 10 CFR Part 21 apply.

i Contrary to the above, a review of documentation packages for spent fuel storage racks fabricated under ASME Code Section III, Subsection NF revealed that while 10 CFR Part 21 was imposed on U.S. Tool and Gie, Incorporated (UST&D) by their customers, UST&D did not specify that 10 CFR Part 21 requirements would apply on Purchase Orders (PO) 86-60208 to Columbia Electric Manufacturing; 84-1701 and -1679 to to All Pittsburgh:

86-61228 to Cromie Machine and Tool; 82-1051 to Comercial Fasteners; 86-60802, -01208 and 87-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 86-60620 to Industrial Service Centers; 83-1387 to Sandvik; 87-70115 to Weld Star; 86-61112, -70103 and 87-70118 to Alloy-Oxygen Weld Supply; 86-61218 to Metal Goods; and 06-60921, 87-70130 and -70208 to killiams and Company.

(87-01-01)

This is a Severity Level V violation (Supplement VII).

2.

Section 21.0 of 10 CFR Part 21 requires, in part, that each corporation post current copies of the regulations of 10 CFR Part 21 Section 206 cf the Energy Reorganization Act cf 1974 and procedures adopted pursuant to the regulations of 10 CFR Part 21.

If posting of the regulations or the procedures is not practical, the licensee may, in addition to posting Section 206, post a notice which describes the regulations / procedures.

Contrary to the above, UST&D failed to post Section 206 of the Energy Reorganization Act of 1974.

(87-01-02)

This is a Severity Level V violation (Supplement VII).

4-6 v i S S S t'

APPENDIX B U.S. Tool and Die, Incorporated Decket Nc. 999010E2/67-01 hCTICE OF NONCONFORMANCE Durirg ar. inspection conducted March 23-27, 1987, the implementation of the Quality Assurance (CA) Program at the UST&D facilities in Allison Park and Glenshaw, Pennsylvania was reviewed with respect to the fabrication of spent fuel stcrage racks.

The applicable QA Program requirements are 10 CFR Part CC, Apperdix B,10 CFP Part 21, and UST&D's QA Prograr Manual (QAPM), Revision 2, dated Jaruary 20, 1986.

Based on the results of this inspection, it appears that certain activities at the UST&D f acilities were not conducted in accordance with these corritrents. These items are listed below.

I.

Criterion X of Appencix B to 10 CFR Part 50 requires, in part, that a progran for inspection be established and executed by or for the crganizaticr. performing the activity to verify confomance with the documented instructions, procedures and drawings.

Section 14.3C cf the UST&C QAPM, requires, in part, that in-process examination or surveillance be conducted by Quality Control personnel to verify dimensiens and that fabrication methods used by production are in accordance with the contract documents and industry practice.

Section 3.3 of Procedure 14.1, "Production Work Routing and Inspection Plan," Revision 0, requires, in part, that Quality Control perfom 311 inspections, in-process examinations, testing verification, etc. noted on the flow chart (the "Production Work Routing and Inspection Plan") in accordance with the apprcpriate procedures and that no production activi-ties progress past these points until Quality Control has perfomed their duties.

Contrary te the above, in-process examinatiens were not being performed at the south shop per the "Production Work Routing and Inspecticn Plan,"

l Drawing 8601-0, Revision 1, for the spent fuel racks being manufactureo for the LaSalle project.

(87-01-03) 2.

Criterion X of Appendix B to 10 CFR Part 50 requires, in part, that a prograr, for inspection of activities affecting quality be established and executed to verify conformance with the documented instructions, procedures and drawings.

Section 10.2A of the UST&D QAFh requires, in part, that all shcp inspections / examinations / monitoring are perfomed by qualified Quality Control personnel and in accordance with written procedures.

9 5.2 5kW W'

2-Section 2.2.1 of Procedure 10.4, "Final Inspection," Revision 1, requires, in part, that verification of the physical dimensions of the shipping piece with the approved shop drawing dimensions be perfomed.

Centrary to the above, two undersize welds were identified by the NRC inspectors on a fuel rack which had been inspected and found acceptable by UST&D Quality Control.

(87-01-04) 3.

Criterien XII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that tools, gages, instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to ma4rtain 8CCuracy.

Section 12.2B, of the UST&D QAPM requires, in part, that the interval t

of calibration for each item be established in procedures.

Section 2.4 of UST&D Procedure 12.1, "Control of Inspection Measuring Equipment," Revision 2, requires, in part, that each piece of inspection equipment be assigned a pemanent unique serial number which will t,e applied to the equipment by vibro-etching or with a durable label.

Section 2.6 of Procedure 12.1 requires, in part, that a "Cardex" system be used to log calibration infortnation and this record card include among other criteria, the calibration interval.

Contrary to the above, a review of measuring and test equipment (M&TE) and calibration records revealed the following:

a.

Documented evidence was not available to verify that the calibration interval for M&TE was established in procedures.

b.

The four inner diameter (ID) box mandrels for the Kewaunee, Vemont Yankee, and LaSalle projects in the south fabrication shop were not identified with a permanent unique S/N applied by vibro-etching or with a durable label, c.

A calibration interval was not established in the "Cardex" system for the modified ID box mandrel for the LaSalle project in the north fabrication shop.

(87-01-05) 4.

Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that to the extent necessary, procurement documents require subcontractors to provide a quality assurance program consistent with the pertinent provisions of this appendix.

Section 2.2A of the QAPM requires, in part, that the UST&D Quality Assurance Program be developed to comply with the requirements of ANSI N45.2 and ANSI /ASFE HQA-1-Quality Assurance Program Basic Requirements.

. The Q* sectior.s of the technical specifications for the Kewaunee, Yemcr.t Yar,kee, and LaSalle projects impese the requirements of ANSI N45.2 and/or ANS!/ASPE NCA-1 upon L'STLD.

Section 5 cf ANSI N45.2-1977 and Section 4 (Basic Requirements) of ANSI /

ASPE NCA-1-1983 indicate that PCs shall require suppliers / vendors to have a QA program consistent with the applicable requirements of the standard.

Contrary to the above, a review of 43 P0s for materials and services related to spent fuel racks fabricated under ASME Code Section III, Subsection NF indicated that quality requirements (e.g., QA Progran) were not passed on to vendors for the following P0s: 86-60746 -60613 -60814 and -61220 to Cromie Machine and Tool; 60-60200 to Columbia Electric Manufacturing; E4-1701 and -1679 to Do All Pittsburgh; 82-1068 to Capitol Pipe and Steel Products; 82-1051 to Comercial Fasteners; 86-6 CEC 2,

-C1208, and 07-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 85-51023 to Techalloy; 82-1311 and C3-1387 to Sandvik; 87-70115 to Weldstar; C6-70103 to Alloy-Oxygen Weld Supply; and 66-61218 to Fetal Goeds.

(87-01-06) 5.

Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that applicable regulatcry requirements, desi5n bases, and other requirements which are necessary to assure quality are suitably included or referenced in the documents for procurement.

Section 4.2B of the QAPM requires, in part, that purchase orders for material delireate all applicable requirements of the contract documents.

1 Section 2.2 of Procedure 4.1, "Procurement Cocument Control," Revision 5, l

requ.res, in part, thbt precurement documents reference all design specification requiremer.ts applicable to the items being purchased.

Sectien 5.3 of NES Specification No. 83A2256, "Specification for the Fabrication and Inspection of the Yemont Yankee Nuclear Power Station Spent Fuel Storage Racks," Revision 0, requires that all weld filler metals meet the requirements of Section III, Subsection NF including celtc ferrite determination.

Section 4.4B of the QAPM requires, in part, that the quality assurance manager or his designee review and approve purchase orders prior to issuance to the vendor.

Sections 3.2 and 4.1 of Procedure 4.1 require that all PCs be reviewec and approved by QA.

Contrary to the above, a review of P0s indicated that PO 87-70118 to Alloy-Oxygen Welding Supply for stainless steel weld filler metal did not contain a delta ferrite determination statement, and PO 86-00610 to WALCO Corporation for markers and tape was not signed / initialed and dated by QA personnel.

(87-01-07)

4 6.

Criterion V of Appendix B to 10 CFR Part 50' requires, in part, that activities affecting quality be prescribed by cocumented instructions, procedures or drawings.

Section 5.2B of the QAPM and Section 6.0 of ANSI N45.2 1977 requires, in part, that all activities affecting quality be prescribed and accomplished with appropriate documented procedures.

Contrary to the above, it was noted that a documented procedure / instruction did not exist to control tools (e.g., wire burshes, grinding wheels, harrrners, etc.) that were designated for use only nn stainless steel naterial.

(87-01-08) 7, Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that i

instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Section 5.2B of the OAPM requires, in part, that, as applicable, procedures, instructions, and/or drawings will include quantitative and qualitative acceptance criteria.

Section 2.2 of Procedure 10.3, "Inprocess Examination," Revision 3, defines in-process examinations as periodic, random sampling type checks and er surveillance to determine that the shop is providino material, parts, subassemblies, pieces, and/or components which comply with UST&D QA/0C i

prograr,and project requirements.

Contrary to the above, Procedure 10.3 does not provide the QC inspector appropriate guidance indicating the required random sample quantities or percentages needed to ensure a representative sample during in-process examinations.

(87-01-09) 8.

Criterion XIV of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to indicate, by the use of marking, the status of inspections and tests perfonned upon individual items, and that these reasures provide for identification of items which havc satisfactorily passed required inspections and tests, where necessary, to preclude inadvertent bypassing of such inspections and tests.

Secticn 14.2A of the QAPM requires, in part, that record of in-process examination or surveillance be noted on the part/ component / subassembly.

Section 2.3 of Procedure 10.3, "Inprecess ixaminaticn," Revision 3, requires, in part, that documentation is ',ot required for in-process examinations; however, each part, subassembly, piece and/or component which is in-process examined be physically marked or documented as being examined by UST&D personnel performing the examination.

. Section 3.2 of Procedure 10.3 requires, in part, that QA/QC personnel mark each piece in-process examined with a unique marking to indicate the piece, part, sub-assembly and/or component has been examined and by whom.

Contrary to the above, marking procedures used by the' south shop QC inspector for in-process examination do not clearly identify items or components which have satisfactorily passed the required examinatiens or who exanined the part.

(67-01-10) g.

Criterion VII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that purchased material, equipment and services confom to the procurement documents, and that the effectiveness of the control ef quality by contractors and subcontractors be assessed at intervals consistent with the importance, complexity, and quantity of thc product or services.

e Sectier. 7.2B of the QAPM requires, in part, that vendors be evaluated and approved based on their capability to provide material, equipment and/or

-r services.

Section 1.1.1 of Procedure 7.2, "Evaluation of Vendors," Revision 1, requires, in part, that vendor evaluations be conducted to provide confi-dence in the vendor's QA Progran for meeting the quality requirements.

Contrary to the above, vendor evaluations had not been performed on De All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D.

(87-01-11) 10.

Criterion II of Appendix B to 10 CFR Part 50 requires, in part, that the quality assurance program provide for indoctrination and training of

]

persennel perfoming activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Section 2.5 of the QAPM requires, in part, that all UST&D personnel perfor-ming quality activities be trained in the requirements of UST&D's QA Pro-gram as applicable to their activity and that their qualification, indoctri-nation, and training be centrolled te obtain suitable proficiency.

Secticr. 2.1 of Procedure 2.3, "Training," Revision 3, requires, in part, that all USTl0 personnel performing quality related activities be trained in the requirements of UST&D's QA Program as applicable to their activity.

Centrary to the above, training records did not exist for two UST&D shop employees.

(87-01 12) 11.

Criterion VII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that purchased material, equipment and services conform to the procurement documents.

1

\\

t

. Section 7.2B of the QAPM requires, in part, that vendors shall be evaluated and approved based on their capability to provide material, equiprent and/or services.

Section 2.1 of Procedure 7.2, "Evaluation of Vendors," Ravision 1, requires, in ptrt, that an evaluation be made on proposed new vendors furnishing quality related matcrials and/ar services prior to, or within 14 days of, issuance of a purchase order.

Contrary to the above, PO 86-60143, dated February 14, 1986, was placed with Industrial Service Center while the evaluation was performed March 12-13, 19EC.

(87-01-13)

CPGA. RAT:JN:

U.S. TOOL AND CIE ALLISON PARK, PENNSYLVANIA REcCF1 INSPECTION INSPECTION NO..

09901082/E7-01 DATES:

03/23-27/97 ON-SITE Rt'P(-

11n C0F.RESDONDENCE ADCRESS:

U.S. Tool and Die ATTN: Mr. Michael T. Rodgers President 4030 Route 8 Allison Park, Pennsylvania 15101 l

ORGAh!ZATI0i:AL CONTACT: Mr. Frank E. Witsch TELEDHONE EUkBED:

412 aF7-7030 NUCLEAF 1hDUSTRY ACTIVITY:

Fabricator of spent fuel storage racks.

F ASSIGhED INSPECTCR: hibIit M k 6

9 Claudia M. Abbate, TrogrTim' Development and Reactive ate Inspection Section (PCRIS)

OTHER IhSPECTORS: James T. Conway, PDRIS Kenneth G. A pinwall, Consultant APPP.0VED BY:

SX

1. M#7 Jafes C. Stone, Chief, PORIS, Vendor Inspection Branch Uate If;S:ECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 50 Appendix B, 10 CFR Part 21.

G.

SCOPE: Observe the fabricatien and testing processes regarding the fabrication of spent fuel storage racks. Welding, nondestructive testing, persennel training, quality contrG inspection, procurement, shop QA implementation and quality records were reviewed.

PLANT SITE APPLICABILITY:

Callaway, Ginna, KawauneT, QSalle 2,~ Nine Mile Point 2, Seabrook, Shoreham, Temon1 ionnue,lolf' Creek

~

y.? Q Lff

OUAhi2ATICh:

U.S. TOOL AND DIE ALLISON PARK, PElmSYLVANIA PEPORT INSPECTION NO.: 99901062/67-01 RESULTS:

PAGE 2 of 15

/.

30LATIOhS:

Contrary to Secticn 21.31 of 10 CFR Part 21, a review of documentation packages for spent fuel storage racks fabricated under ASME Coce Section III, Subsection NF revealed that while 10 CFR Part 21 was it. posed on U.S. Tool & Die (UST&D) by their customers, UST&D did not specify that 10 CFR Part 21 requirements would apply on Purchase Crders (PO) 86-60208 to Columbia Electric Manufacturing; 84-1701 and

-1679 to to All Pittsburgh; 80-61228 to Cromie Machine & Tool; 1

82-1051 to Cotrercial Fasteners; 86-10802, -81208 and 87-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 86-60620 to Industrial Service Centers; 83-1387 to Sandvik; 87-70115 to Weld Star; 86-61112, -70103 and 87-70118 to Alloy-Oxygen Weld Supply; S6-61218 to Metal Goods; and 86-60921, 87-70130 and -70ECS to Williams and Company.

(87-01-01)

This is a Severity Level V violation (Supplement VII).

2.

Contrary to Secticn 21.6 of 10 CFR Part 21, UST&D failed to post Section 206 of the Energy Reorganization Act of 1974.

(87-01-02)

This is a Severity level V violation (Supplement VII).

B.

NONCONFORMANCES:

1.

Contrary to Criterien X of Appendix B to 10 CFR Part 50, Section 14.3C cf the UST&D Quality Assurance Prograr Manual (QAPM),

Revision 2, and Section 3.3 of Procedure 14.1, "Production Work Rcuting anc Inspection Plan," Revision 0, no in-process examinations were being performed at the south shop per the "Production Work Routing and Inspection Plan," Drawing 8601-0, Revision 1, for spent fuel racks being fabricated for the LaSalle project.

(67-01-03) 2.

Contrary to Criterien X of Appendix B to 10 CFR Part 50. Section 10.2A of the UST&D QAPM, Revision 2, and Section 2.2.1 of Procedure 10.4, "Final Inspection," Revision 1, two undersize welds were identi-fied by the NRC inspectors on a fuel rack which had been inspected and fcund acceptable by USTSD Quality Control.

(87-01-04) 3.

Contrary to Criterion XII of Appendix B to 10 CFR Part 50, Section 12.2B of the UST&D QAPh. Revision 2, and Sections 2.4 and 2.6 of Frocedure 12.1, "Control of Measuring and Test Equipment," Revision 2,areviewofmeasuringandtestequipment(M&TE)andcalibration records revealed the following:

ORGAhl2A*iCN-U.S. TOOL AND DIE ALLISON PARK, PEhNSYLVANIA REPORT lhSPECTION NO.:

99901002/87-01 RESULTS:

PAGE 3 of 15 a.

Documented evidence was not available to verify that the calibration interval for M&TE was established in procedures, b.

The four inner diameter (ID) Box Mandrels for the Kewaunee, Vermont Yankee, and LaSalle projects in the south fabrication shcp were not identified with a permanent unique S/N applied by vibre-etching or with a durable label.

c.

A calibration interval was not established in the "Cardex" system for the modified ID Box Mandrel for the LaSalle project in the north fabrication shop.

(87-01-05)

Contrary to Criterion IV of Appendix B to 10 CFR Part 50, Section 2.2A of the QAPM, Revision 2, Section 5 of ANSI N45.2 and Section 5 (Basic Requirements) of ANSI /ASME NQA-1, a review of 40 P0s for materials and services related to spent fuel racks fabricated under ASNE Code Section III, Subsection NF indicated that quality requirements (e.g., QA Program) were not passed on to vendors for the following PCs: 86-60746, -60813, -60814, and -61228 to Cromie Machine anc Tool; 80-6028 to Columbia Electric Manufacturing; 84-1701 and -1679 to Do All Pittsburgh; 82-1068 to Capitol Pipe &

Steel Products; 82-1051 to Commercial Fasteners; 86-6082. -81208, anc 87-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 85-51023 to Techallcy; 82-1311 and 83-1387 to Sandvik; 87-70115 to Keldstar; 86-70103 to Alloy-Oxygen Weld Supply; and 86-61218 to Metal Goods.

(87-01-06) 5.

Contrary to Criterion IV of Appendix B to'10 CFR Part 50, Sections l

4.ZB and 4.4B of the QAPM, Revision 2, Sections 2.2, 3.2 and 4.1 of Procedure a.1, "Procurement Document Control," Revision 5, and Section 5.3 of NES Specification No. 83A2256, a review of P0s indicated that PO 87-70118 to Alloy Oxygen Welding Supply for stainless steel weld filler metal did not contain a delta ferrite determination statement, and PO 66-60610 to WALCC Corporation for markers and tape was not signed /initicled and datec by QA persennel.

(87-01-07) 6.

Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 5.2B of the QAPM, Revision 2, and Section 6.0 of ANSI N45.2, it was noted that a documented procedure / instruction did not exist to control tools (e.g., wire brushes, grinding wheels, hammers, etc.)

that were designated for use only on stainless steel material.

(87-01-08) l e

ORGAh12AT10L:

U.S. TOOL AND DIE ALLISON PARK, PENNSYLVANI A REPCRT INSPECTION h0.: 99901082/87-01 RESULTS:

PAGE 4 of 15 7.

Contrary to Criterion V of Appendix B to 10 CFR Part 50, Secticn 5.2B cf the UST&D QAPM, Revision 2, and Section 2.2 of Procedure 10.3, "Inprocess Inspection," Revision 3, Procedure 10.3 does not provide the QC inspector appropriate guidance indicating the rec,uired rancem sample quantities or percentages needed to ensure a representative sample during in-process examinations.

(87-01-09) 8.

Contrary to Criterion XIV of Appendix B to 10 CFR Part 50, Section j

14.2A of the UST&D QAPM, Revision 2, and Sections 2.3 and 3.2 of Procedure 10.3, "Inprocess Inspection," Revision 3, marking procedures used by the south shop QC inspector for in-process exanination do not clearly identify items or components which have satisfactorily passed the required examinations or who examined the part.

(07-01-10) 9.

Contrary to Criterion VII of Appendix B to 10 CFR Part 50, Section 7.2B of the UST&D QAPH, Revision 2, and Section 1.1.1 of Procedure 7.2, "Evaluation of Vendors," Revision 1, vender evaluatiens had not been perfortned on Do All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D.

(87-01-11) 10.

Contrary to Criterion II of Appendix B to 20 CFR Part 50, Section 2.5 of the UST&D QAPM, Revision 2, and Section 2.1 of Procedure 2.3, "Training," Revision 3, no training records existeo for the UST&D shop employees.

(87-01-12) 11.

Contrary to Criterion VII of Appendix B to 10 CFR Part 50, Section 7.2E of the UST&D QAPM, Revision 2, and Section 2.1 cf Procedure 7.2, "Evaluation of Vendors," Revision 1, P0 86-60143, dated February 14, 1986, was placed with Industrial Service Center prior to the vendor evaluation which was perfortned March 12-13, 1986.

(87-01-13)

(..

UNRESOLVED ITEMS:

None.

D.

STATUS CF PREVIOUS INSFECTION FINDINGS:

hone. This was the first NRC/VIB inspection of this facility.

ORGANIZATIch.

L'.S. TOOL AND DIE ALLISON PARL, PENNSYLVANIA FEPCRT INSFECTION h0.: 999C1002/87-01 RESULTS:

PAGE 5 of 15 E.

INSPECTION FINDINGS ANC OTHER COPEENTS:

1.

Entrance and Exit Meetings An entrance nieeting was conducted on March 23, 1987 at the Allison Park, Pennsylvania office of UST&D. The purpose and scope of the inspection were discussed during this meeting. UST&D has two fabrication shops.

The south shop, located in Glenshaw, Pennsylvi.r.ia, receives the material and fcrms and welds the individual cells.

The north shop, locateo in Allison Park, Pennsylvania, assembles ar.d welds the cells into fuel storage racks and performs the final inspection.

During the exit meeting conducted on March 27, 1987, I

the inspection findings and observations were discussed with UST&D persennel.

2.

Spent Fuel Racks - huclear Since 1982, UST&D has fabricated spent fuel racks for six conrnercial nuclear customers (see Table 1, page 15). Three projects are currently in progress: LaSalle 2, Kewaunee and Vermont Yankee.

The J

customer's design is being used for the Vern.cnt Yankee and Kewaunee projects, while UST&D's design is being used for the LaSalle project. To date, only five prototype cells have been fabricated for Vereont Yankee. A number of cells have been fabricated for Kewaunee, but they have not been assembled into a completed rack.

j The NRC inspector reviewed the customer's procurement packages for the nine projects including a detailed review of the P0s and/or the technical specifications fcr four projects: hine Mile Point 2, Verment Yankee, Kewaunee and LaSalle 2.

For all four projects, it was notec that the requirements of 10 CFR Part 50, Appendix 5 and 10 CFR Part 21 were referenced in the P0s and/or specifications.

The Nuclear Energy Services (hES) specifiu tion for the Vermont Yankee project referenced the 19E0 Edition of Sections II, III (Subsection NF), V and IX of the ASME Code, whereas the 1977 Editien of the same Sections were listed as applicable documents in the Store and hebster (S&k') specification for the Nine Mile Point 2 project.

KDE personnel were to be trained and quclified per ShT-TC-1A, and inspectors were to be qualified to AhSI N45.2.6.

Weld filler metal was to be in accordance with Subsection NF of Section III and specificatien Ak'S A5.9.

In general, the material specifications included ASTM A240, A276, and A564.

Cleaning

ORGANIZATION:

U.S. TOOL AND DIE ALLISON PARK, PEhhSYLVANIA i

REPORT INSPECTION NO.: 99901082/S7-01 RESULTS:

PAGE 6 of 15 requirements were noted as Class B of ANSI N45.2.1; and handling, packaging, and shipping were to meet the Level C requirements of AhSI h45.2.2.

Record retention was in accordance with ANSI N45.2.9 and typical documents shipped to the customer included:

certified material test reports for stainless steel and weld material, heat treatment certificatiens (17-4 PH material), NCE reports, inspection reports, nonconformance reports, repair and rework reports, and a certificate of conformance from UST&D.

3.

Plant Tour The inspectors toured the north and south fabrication facilities at varicus times in the company of UST&D officials.

Receipt inspection, press forming of stainless steel sheet and welding of cells were activities noted in the south shop.

Items witnessed in the north

-r shop includeo machining, installation of poison material (i.e.,

boraflex strips), welding of support plates, PT examination, welding of racks, in-process inspection, cleaning and final inspection.

During the plant tours, it was noted by the inspector that one harrner had a painted handle.

UST&C personnel infonned the inspector that the paintee tools are used on projects which involve stainless steel while the unpainted tools are used on projects which involve carbon steel. There was no documented instruction / procedure to centrol the use of painted and unpainted tools.

fionconfohance 87-01-08 was identified in this area.

4.

Production Work Routing & Inspection Plan (PWRIP)

A PWRIP, which is similar to a "shop traveler," is generated by the Project hanager for each nuclear job. The PWRIP is laid out as an E-size drawing and identifies, for both the north and south shops, each production operation, CC inspection /in-process examinations, and custerer witness points and mandatory hold points.

Several notes pertaining to the requirements of the customer's specification, inspections including documentation, and hold points are also included.

Item No. 7 of the PWRIP states that "documen-tation is not always required" for in-process examinations. This does not agree with Section 14.2 of the QAPM which states, in part, "Ir.spection reports will document all inspections and testing delineated on the Production Work Routing & Inspection Plan." The

ORGANIZA~10N:

U.S. TOOL AND DIE ALLISON PARK, PEhhSYLVANIA REPORT INSPECTION h0.:

999C1080/67-01 RESULTS:

PAGE 7 of 15 PWE!P, including changes, is approved by the Engineering and QA departments.

The PWRIP cane into effect upon the generation of the QAPM in Dece-ber 1981, and the dccument was used on all the nuclear prcjects beginning with Welf Creek.

The inspector reviewed and verified that a PWRIP existed for the nine nuclear prcjects since 10C2.

Curing the inspection of shop activities, UST&C Drawing 8601-0, Revision 1, "Production Work Routing and Inspection Plan," for the LaSalle project was reviewed. After the individual cell is tack-welded and jetline welded together, an in-process examination anc weld inspection were to be performed. These two activities are cutlined in Proceoures 10.3 and 10.5 respectively.

khen decurentaticn or inspection reports were requested for the in-process exarinations anc weld inspections, none existed.

No in-process examinatiens were being performed on the fuel racks in the initial stages of fabricetion at the south shop.

Nonconformance 87-01-03 was identified in this area.

Upen further review of the procedure, it was noted that in-process exaninations were defined as periodic randem sampling type checks to determine that the shop is providing material which complies with the UST&D QA/QC program requirements.

The shop QC personnel were unable te define, quantitatively or with a percentage, the number of periodic random sampling type checks to be performed by the inspector.

Procedure 10.3 is inadequate in that it does not give sufficient instructions to the QC inspector as to what quantity a random sample is anc oces net ensure a censistent number of in-process examinations among the different inspectors.

henconformance 87-01-09 was identified in this area.

1 In addition, Procedure 10.3 does not require documentation of the in-process examinations, however, each part may be physically marked after an in-process examination has been performed. The option of marking components to indicate completion of an in-process examination is used by the south shop QC inspector. However, the mark used is a check mark made en the compenent surface with a marking pen. Several similar marks are also rade on the component surface during manufacturing.

There is no instruction or guidance in Procedure 10.3 for the QC inspector or other shop personnel on hew to distinguish the inspector's markings from other r,anufacturing l

markings, i

i

l ORGANIZATION:

U.S. TOOL AND DIE ALLISON PARK, PENNSYLVANIA i

l

'I l

REPORT INSPECTICN H0.: 99901082/87-01 RESULTS:

PAGE 8 of 15 Nonconformance 57-01-10 was identified in this area.

5.

Welding and Welding Machines Welding being perfomed on spent fuel storage racks for the LaSalle and Vermont Yankee projects was observed. Three welders were perfoming production work at the tire of the inspection. The followirs items were reviewed during the inspection:

presence of Welding Procedure Specifications (WPS) at the work area, preheat and interpass temperature control, compatability of WPSs to production work and compliance with WPS essential anc nonessential variables.

Welding machines were icentified with a unique identification number for verification of amperage and voltage requirements.

Automatic welding equipment had attached documentation to alert the welding operators of amperage and voltage ranges and tolerances for the thickness of the material being used.

In addition, each rarval welding machine contained a ccttrolled record showing each welder who used the machine, date of use, and WPS used. This record is used as a surmary of weld performances for welder qualification records.

No items of nonconformance or unresolved items were identifiec in this area.

6.

Weld Inspection Final inspection of the completed spent fuel storage racks is outlined in Procedure 10.4, Revision 1, and includes a verification cf the physical dirensions of the completed rack to the approved shop drawing dimensions.

During the inspection of completed fuel storage racks for the laSalle project, visual and dirrensional checks of fillet welds on fuel rack pedestal mounting pads were perfortted by the NRC inspector. Drawing 8601-30, Revision 4, was used for the inspection. During the inspection, two fillet welds on the mounting pad were found to be less than the one-quarter inch weld specified on the drawing. The rack was identified as UST&D rack number 11 (Comonwealth Edison racknumber2FC16C). A review of the final inspection checklist revealec that these welds had been inspected and fcund acceptable by the UST&D QC inspector.

1 OPGAh12A!!0h:

U.S. TOOL AND DIE ALLISCh PAPK, PENNSYLVANIA REPCRT INSPECTION NO.:

99901082/E7-01 RESULTS:

PAGE 9 of 15 Prior to the exit meeting, the welds were repaired. The new welds were examined by UST&C QC perscnnel and found acceptable. The NRC inspector verified that the welds were acceptable per the drawing.

Nonconf o rmance 87-01-04 was identified in this area.

7.

Welder Qualifications and Training The welder qualifications to applicable Welding (Procedure Specifi-catiens (WPS), Procedure Qualification Records PQR) and design specification requirements were reviewed. Each welder record included

~

his unique welder identification number, the WPS to which he was qualified and the supporting PQRs.

Training records for four weleers were reviewed. The records documented which training sessicn the welders attended and the date (see Section 16 of this repert).

The UST&D QA program requires that all personnel qualified to WPS 53 for automatic spot / fusion welding be trained to the applicable kPS, have practical experience and perform two test samples prior to preduction welding. The records of e'ight welders qualified to WPS 53 were reviewed and found in compliance with the require-ments mentioned above.

The review of welder qualifications and training resulted in nc items of nonconformance or unresolved items; however, training was minimal in that welders are trained only to the WPSs and there is no evidence that welders are tr61ned to new revisions of WPSs.

C.

Weld Filler Vaterial Control A review of weld filler material control was performed using UST&D Procedure 9.2, Revision 4.

The areas which were examined included:

I markir.g of material (straight and spools)ge of filler material, weld filler material storage areas, stora

, assignment of material inventory control (MIC) numbers and issuance / return records. These items were inspected at the weld filler material issuance stations at both the north and south shops. The review of weld filler material control indicated that Procedure 9.2 was being implemented.

No items of nonconformance or unresclved items were identified in this area.

1

,,,,y

ORGAh1ZAT10h:

U.S. TOOL AND DIE I

ALLISON PARK, PENNSYLVANIA REPCRT INSPECTION NO.: 95901082/87-01 RESULTS:

PAGE 10 of 15 d

9.

Nondestructive Examination (NDE) Personnel Qualifications The hCE qualification records were reviewed using UST&O Procedure 2.5, Revision 1.

Certifications and qualificatiens of the UST&C Level III NDE consultant, the QC Manager and two QC inspectors were reviewed.

Prior training hours; general, practical, and specific tests, incitding the amount of questions per discipline and test results; ar.d a verification of annual eye examinations received by the personnel were reviewed. Records of training and indoctrination of personnel to the hDE procedures and prcgram were also reviewed.

t The review of documentation for KDE personnel qualifications resulted in no items of nonconformance or unresolved items; hewever, documer.ted evidence of training of NDE perscenel was n.ir.iral.

n 10.

Control of Measuring and Test Equipment (MT&E)

Tne NRC inspector reviewed applicable sections of the QAPM, one procedure ano calibration records to detemine whether M&TE was properly identified, controlled and calibrated at specified intervals.

Inspection areas in the north and south fabrication shops were inspected to review the calibration status of gages and measuring instruments found in these areas.

With the exception of four 10 box rnandrels, the inspected equipment contained a vibro-etcheo S/N. The four mandrels were for the Kewaunee, LaSalle and Vermcht Yankee projects and were located in the south shop. A Cardex system, which is anaintained by the QC Manager, is used to record calibration information.

Each card identifies the type of equipment including S/N, calibration date.

calibration frequency, the standard used, and the ioentity of the individual perfoming the calibration.

Equipment examined at the south shop included a vernier caliper, two n.icrometers, one thickness gage, one width gage, one tong test ameter, and four 10 box mandrels. At the north shop, one tcng test anreter, three micrometers, one f lal thickness gage, one vernier caliper, one bore gage, one radius gage set, one inside micrometer set, one optical comparator, one box mandrel (LaSalle prcject) and three micremeter standards were examined.

In addition, the calibration status of the eight welding machines in the north shop was checked.

The infomation contained on the calibration stickers on the items was in agreement with the applicable card.

ORGAh!ZA1:0N-U.S. TOOL AND DIE ALLISON PARK, PENNSYLVANIA i

REPOR IhSPECTICL NO.: 99901062/67-01 RESULTS:

PAGE 11 of 15 The two AC-DC tong test ameters (S/N AX-42975 and -58261) are sent te Columbia Electric Manufacturing (CEh) for calibration every two years. Test reports from CEM indicated that the equipment was calibrated in February 1966 with standards traceat,le to the National 4

Bureau of Standards (NBS). A Certificate of Calibration from Oc All Pittsburgh indicated that a master gage bic:k set (S/N C-4) was calibrated in Octcber ISE4 with standards traceable to NBS.

It was noted that a document dio not exist to identify the specific equipment covered by the calibration program including the calibration frequency of such equipment.

I honconfomance 87-01-05 was identified in tnis area.

e i

11.

Procurerent Document Control Forty-three P0s to 15 material manufacturers / suppliers, four P0s to a machining vendor, three P0s to two vendors for calibration services, and one PO to a plating venoor were reviewed te assure that applicable technical and QA program requirements were included or referanced in the F0s. With the exception of one order, all the P0s were initialed and dated by a QA inoividual. The PO in question was No. 86-60610, dated June 6, 1986, to WALCO Corpnration for felt tip markers and nuclear grade cloth tape.

Nineteen PCs did not invoke the requirerients of 10 CFR Part 21 upon vendors - eight P0s to four n.anufacturers/ suppliers of weld wire, three P0r. to two calibration service vendors, one PO tc a machining vendor, one P0 to l

a supplier of fasteners, and six P0s to manufacturers / suppliers of stainless steel.

In addition, the requirement that a vendor have a OA pre 5 ram which was approved by UST&D was not included in nineteen P0s te vendors - four P0s to Cremie Machine and Tool, one PG to Colurbia Electric Manufacturing, two P0s to Do All Pittsburgh, one PO to Capitol Pipe & Steel Products, one PO to Comercial Fasteners, three P0s to West Penn Laco, one PO to Allegheny Ludlum, one PC to Techalley, two P0s to Sandvik, one PO to Weldstar, one PO to Alloy-0xygen Weld Supply and one PO to Metal Goods.

It was also notec 1

that for PO 87-70118, dated January 16, 1987, to Alloy-Oxygen helding Supply for 200# ASME Section II SFA 5.9 Type 312 filler 1

metal did not contain a oelta ferrite detemination" statement.

Violation 87-01-01 and Nonconfomances 07-01-06 and 87-01-07 were identified in this area.

12. Documentation Packages (DP)

A DP did not exist for the Vemont Yankee and Kewaunee projects as finished racks were not yet completed for these projects. The

l OFCAhl2ATICN:

U.S. TOOL AND DIE ALLISON PARK, PENNSYLVAhl A i

REPORT INSPECTION h0.: 99901082/87-01 RESULTS:

PAGE 12 of 15 inspector reviewed three DPs for Rack M120-24 for Wolf Creek and Racks he. 5 and 9 for LaSalle.

For Wolf Creek, the DP consisted of a Bechtel EnSineering and Cuality Verification Document; Material Certification Data Sheet; CMTRs from Eastern Stainless Steel, Allegheny Ludlum Steel, and Colt Crucible for stainless steel products; a CMTR from Sandvik, who is a certificate holder, for ER 308 L weld wire; and a certificate of conformance (C of C) from Corrercial fasteners for fasteners. Several foms for box identifi-cation / inspection, bottom plate identification / inspection, lead-in i

guide assembly to rack, and visual weld inspection reports were included. A Bechtel Supplier Deviation Disposition Request and a UST&D henconfomance Report and Verticality Test Report were also part of the package.

In addition, a UST&D C of C noted that all e

materials used in the icbrication of the reference rack assembly confomed to Bechtel specification 10466-C-175.

The LPs for the two LaSalle racks consisted of the folicwing:

Occumentation Checklist, Shop Bill of Material (SEM), CMTRs, UST&D C of C, Weld Examination Records, Final Inspection Checklists (FIC),

Ceviatier./ Variance Requests, Qualified Welders List, and a C of C for the boraflex. The SBM listed the material inventory control (MIC) number as well as the material specification and supplier fer each item (e.g., bcx half, bottom plate, pedestal body, etc.). The FIC verified that the following activities were accomplished or a finished rack: dimensional verification, MIC No. verification, i

visual weld inspection, cleaning, marking, boraflex verification, and the mandrel insertion test.

ho items of nonconformance or unresolved items were identified in-this area.

13. Vendor Evaluations The NRC inspector reviewed the evaluations UST&D performed en its vendors and how approved vendors remain on the Approved Venciors List. This process is outlinec in Procedure 7.2 "Evaluation of Vendors," Revision 1, dated March 12, 1987.

Eleven vendor evaluation packages were reviewed. The packages contained the original survey or audit checklist of the vendor and reevaluations of the vendor. The reevaluations consisted of a Vendor EvaluatioD Questiennaire and a historical quality performance data review.

I

__.-.-._\\

l OhGAhllATICN:

U.S. TOOL AhD DIE ALLISON PARK, PENNSYLVANIA 1

REFOR-INSPECTION NO.: 99901082/87-01 RESULTS:

PAGE 13 of 15 During the review,'it was noted that Oo All Pittsburgh and Columbia hanufacturing Electric, who supply calibration services, have net been evaluated by UST&D, nor has a historical quality perfomance data record been maintained en either ver. dor. Also during the review, it was noted that Industrial Service Center had been audited by UST&D March 12-13, 1986, while PO 86-60143 to Industrial Service Center had been placed February 14, 1986. This evaluation was not performed within the specified 14 days of issuance of the PC as 1

1 required by Secticn 2.1 of Procedure 7.2.

Nonconfomances E7-01-11 and 87-01-13 were identified in this area.

14 10 CFR Part 21 During the inspection, the NRC inspectors examined areas for the posting of 10 CFR Part 21 at both fabrication shops.

It was noted that 10 CFR Part 21. UST&C Procedure 16.2 and Public Law 96-295 Act of June 30, 1980, Section 223 were posted, but Section 206 of the Energy Recrgar.ization Act of 1974 was not posted at the south shop.

Section 21.6 of 10 CFP Part 21 and UST&D Procedure 16.2, "Reportable Defects and Noncompliances (huclear Projects) 10 CFR 21," Revision 2, i

dated March 12, 1987, require Section 206 to be posted. Prior to the exit meeting, Section 206 and other applicable documents were posted at both shops.

Violation E7-01-02 was identified in this area.

15.

Trcining 1

The NRC inspector reviewed UST&D Procedure 2.3, "Training," Revision 3, cated March 23, 1966.

The procedure requires all UST&D persennel performing quality related activites te be trained as applicable to i

their activity. The pro:edure also requires that training records be maintained.

The NRC inspector reviewed 13 employee training records and training session records. The employee training records identify what training the employee has received while the training session records identify who attended the training, the date and an outlir.e of the subjects which were covered during the training.

During this review it was noted that two machinists employed in the shop had training record files, but had not received eny training.

Also noted were the facts that a training record, with no documented training, was present for a retired employee; several training I

_.g-w

ORGAhlIAilCt;:

U.S. TOCL ANC DIE ALLISON PARK, PENNSvi.VANIA FEFORT INSPECTI0tl NO.: 999C1082/87-01 RESULTS:

PAGE 14 of it records were incomplete in that hire dates and training session subjects were missing; and two employees were trained outside the 45 day limit for new employees.

In addition, U5T&D only trains its personnel to the quality control procedure which the employee will be using without an overall QA/QC program training session. The personnel are not trained to new revisions of the procedures nor 'is there any type of refresher trainirig given to current employees after the initial training course and after they have been employed fer a lengthy amount of time.

Nonconfomance E7-01-12 was identified in this area.

'~

16. Audits 1

The KRC inspectors reviewed four internal audits. The Internal y

Project kanagement Audit, dated May 29, 1986, the Production Audit, i

dated August 13, 1986, the CA/QC Audit, dated November 12, 1900, and the Engineering Department Audit, dated March 4, 1507, were reviewed.

Each audit included a checklist, an audit report (sumary of results),

and was perfomed by a qualified auditor. The audits which were reviewed were perfomed ari occumented in accordance with Procedure 18.1, "Audits," Revision 5, dated March 12, 1987.

No items of nonconfomance or unresolved items were identified in this area.

F.

PERSCNS C0tiTACTED:

4 P. Brinks, QC Manager, South Shop F. CeSimons, Foreman, horth Shop W. Dickson, Director of Manufacturing E. Jablonsky, QC Inspector, North Shop L. Karenboyer, Welder

• R. Linder, Manager of Engineering

• E. March, Vice Chairman of the Board, Chief Executive Officer E. Reinhart, QC Mar.ager, North Shop J. Rhoden, Project hanager F. Rhodes, Vice President, Manufacturing R. Rudisill, Welder

• M. Rodgers, President R. Stewart, Machinist

• B. Wachter, Vice President, Engineering and Research K. Weber, Assistant Project Manager

• F. Witsch, QA Manager

• Attenced Exit Meeting

CRCANIZATION:

U.S. TOOL AND DlE ALLISON PARK, PEhhSYLVANIA I

REFORT INSPECTION NO.: 99901052/87-01 RESULTS:

PAGE 15 of 15 TABLE 1 i

Number of Date Utility /AE Projec_t Tyge R,acks/ Positions Ccepleted SNLPPS Wolf Creek PWR-MOR 12/1328 1982 Kansas Gas &

hen-Poison Electric /Cechtel e

SNUPPS Callawty PkR-MOR 12/1328 19C2 Unicn Electric /

Non-Poison Bechtet Long Islanc Shorehan BWR-Non 15/1700 1983 Lighting /Stene Poison 8/756

& Webster Water Flux 2/144 Trap Control Rods Public Services Seabrook New Fuel 3/90 1983 Company Storage Racks hiagara Mohawk hine Mile II BWR-MDR Stone t kebster Poison 17/2530 1984 10/1519 Rochester Gas &

Ginna Modified 6/420 1984 Electric PWR Checker-board to Poison Racks Correnwealtt LaSalle II BWR Poison 20/4073 In Progress Ediser Wisconsin Public Service Corp.

Kewaunec

.PWR Poison 4/360 In Pregress Huclear Energy Verment Services Yankee-BWR Poison 10/2820 In Progress 4

-e-

l DOC"EI"0'CfIlOII)S[3-m DOCUMENTS EX AM1NED inm aan,p A g g !p REPORT NO. K]

()(

l 4

PAGE Of SCOPE:

DOCUMENT TITLE /5U6 JECT urE or a

ne.

00CtMENT DOCtMENT NO.

REV.

DA1E ITEn 4

)Df{k bn\\% 0YA}[a,yq h(nr(a m %h m w}.[nf(),3 ~Qy) a y,f

\\-

D$0

](>(((' y) l Ni O

Cdf h I(C k.

A NIA b 94 p M n hit b ie( b et(sd h o n(ty m B)*,ct e t e

~

3 9f G (l@

iL I

's-aln C1 M( >rk i45 dl t(d t a to libvk n(dine,ATt600(-;AM fi _ ts hkCN

_O/@

N.k b Ici l'ir, d

S Mb Ck D \\O.3 3

9bikin du -hven e s-s l-Vo tai i vili mu O.

M t.

QItin 41)Drr' Je.AUp t er;\\/w- -[] sf I(71 m l i t (1 f e r OV/$ $

~

At A fr+ ( R % - Kt O )

hat v art Q

\\k & cr E~en l n4 ttm Ofhane,

1

~

(nl (b h h t'){ (r M k/',v M O M ( f_R

~

h W_0

~

$ - 6 h-t r

\\

p(>n L,c ? m. 8 1 h h3 Ex o W nca %se <kinv i A. @kO (s h 3. b 3

N h fD, e VIA k 0 t/!'l(i(O h 614 (i I T/

4' e(i 6 t' _

a 9Lo fx D O 3 2.nyc ~Gn 'an v, b0 kill hb n f-Y l n /I( ' t' 5

}k 9.O [t(h 9.d Y /4

/

oTYPE OF DOCUMENT _

INTERNAL MEMQ INM LCITER DWG

- DRAWING LIR SMC - SPECIFICATION PROC - PROCEDURE QAM

. QA MANUAL

' ' I -

_ g, -

nosornatr nar)fa a a

b dc...

O

\\L C ;

i x

(, P V

b r

. h.

~

C f L

s A,

c m

q" W Q

.4 '

Y ea a

+

• 2 "a 8

c'

.s v

s

(

8mm s W

C_

S d

E v

E

• s

( '

w

)

/s w

j_

m 2

8 C.

s E

.)

h u c p q g

x m

C W

0 J w

U e

w "4'

NE 4

2

<5 zu

-a i

W G

g t.

i i*

O E

b E%

a y

o

-a O*

i l

o u

/

E i

l 5

o 5

s a sm)

+

-m.

3 g"5 a

=

g w

w 9

$ BSE8E w,-

0 o

==

r1 e l

5 q &

-r 88 v isrL<

b.-

5

<k*

4\\p

= g t

g l

l v

kt i

I

!,ii..

a r i

i

. <- e

'I I

j4 D@q,

I l

i l

l

!"3 l

i

~

de' 2

[

'D l'I i

o I

v 6

A L<.L.

i l

I

!o r

.s s i

t Pl y

y; l

I w$$

I -h. l I lO

$. n b

l l

l J.

.v x

hw vesj-4v p.n "7

I 4iw e+

o 0

f t 5:

i > Bl g h&Q e:

e.

lt f ;i ') 4 A

N i #!

ky o

3

+e j

O

(

a N

,7.!

"! e j I h,[Qr w

'w x

.a e o c.j i

UN TE 3

l 4'

e 4.s s es_ *,.

q i

f Y

m 5

-5 k W

-)g

-)+

-4.$

E s

8 V '1 2

O " 2 4 9 d tS 6 0

e M

MI l

1 w

k

! As i

.i,,i bf i

l l

l 0 "

i

.a t

w

%o 5

1 5

H h,

lf o

u

~

!=

..e w ):

• 3d:o:*h 3h e

%{sr' 2

I 0

r x

x

>1 K, 3E :r t

v T-d v

ig t

i e gpc.ee u

.y g. u o

u c

e o

e o

w w

he t e.,,iye-c o

3 5 I s,. ',

N e

,0 EJN

%V dl "

g4 l

5 N

d' u

4, l M.

p s

JJ J r

g,-

4 g e

-l 4

%o m)d J8

':25

'f t

d

-4 e!

)^24 i

ne g

,1 e

Ca 4

t L,

.5 U

d y2 E

g 1 27

,5

==

c 5

4 Q,

c4 W

c 9

o m

I u j 1

-f

_8 4-p j

4

- g b

=

M h ] l 3NM;9 c

g g

l 4

4 e 2 kh k k &N ~$ N $

w

$ s h$ h $ $

2 W

3 3 5i }

d N O 0 4 o O w N,t N y u N v) he.

5 S

J d

!!..IS k g

q. m w e o 5 o o')

d3 IST 9$ 2 ct c8 4 8 e c.5 6 *.2 :i

~

a.

a s e a s

,n g

2 8 E =-

h d

c =j$;&si ge n o 8 o o e e e c ec 8 e, & e t

w isi N () tm o F W e S, d d M

$$$did!

• . :W"

M j

g M

W 3 i g

& oC

[

f,E 2

~&

+[

~

~% d)

'a W G

=

b E

' c U

~_

Ee y

b 22 N

55 0

b h

.f'3 v~

p n.

c 6

q.

m.4

==

a a

=

].7 t y 9 e f

~

u n

6 g

] g g

.[

g,,i 94

+

nHoA1Til g e

y j $ k b k $.

h 1 44 ii-4 8 4 4 1

3 c

J 5

5 u N N 9 W O O N O O O

O 04

] :D i.j

=

2

-t D J Q

O h A D $ e cc &

b N

k O a

W 9 M

g go,

i.> +

$p!! h h h hS $ $ $ S $$k;E-[ffe f) c g

3. a e v a n n w o usia

e 4

t l

d

's en N

8, aC E

O

^

\\

\\

k

.)

'NO o b

==

2"

$ {e x

g -w -

t1 e -

b N

Ss E

.d O

C 5

58o w

0 o

i.,

4 3

3 i,,

• 3, 3 a iiiiisi

,k 9

,1

,=

b E g*

E 5,

8 5

Fs, t

8 8

=E

=

a g

tes a

! 7 u G 8.5 EllM g

C ei l 3 H F}isil e

s ti

s A

~3& ss23 0

iii et x.

p eSosod; E. 8 Mg 34238C 0

-r--

TELEPHONE (492)4a7 703o

(_ u. s Ua Ee TOOL E Oles INC.

f 4030 ROUTE 8 e ALUSON PARK, PENNSYLVANIA 15101 t

June 9, 1987 I

United States Nuclear Regulatory Commission Vendor Inspection Branch Division of Reactor Inspection & Safeguards Office of Nuclear Reactor Regu1& tion Washington, DC 20555 Attn:

Mr. Ellis W. Marschoff, Acting Chief Re:

Docket #9901082/87-01

,e Gentlemen:

In response to the inspection report referenced above and submitted to U.S. Tool & Die, Incorporated on May 12, 1987, we submit the following:

APPENDIX A VIOLATION fl -

a review of documentation packages for spent fuel storage racks fabricated under ASME Code Section III, Subsection NF revealed that while 10 CFR Part 21 was imposed on U.S. Tool &

Die, Incorporated (UST&D) by their customers, UST&D did not specify that 10 CFR Part 21 requirements would apply on Purchase Orders UST&D COMMENT a)

The applicability of,the reporting requirements of 10CFR21 has been placed on UST&D by its various Clients who recognize these requirements do not pertain to material purchased as a commercial product (as defined in 10CFR21)

Only af ter receipt of commercial products at UST&D and dedication to the specific basic component by UST&D are the reporting requirements'in effect.

(Leitters from the various Client's and the Atomic Industrial Forum's Cor:mittee Position Paper expanding on this position were presented to the NRC inspectors during the inspection).

Based on these documents the imposition of 10CFR21 is not applicable to the following Purchase Orders: 986-60802,

-81208, and #87-70132 to West Penn Laco; $87-70115 to Wald Star; #86-61112, -70103, and 687-70118 to Alloy-Oxygen Wald Supply; 486-61218 to Metal Goods; and 486-60921,

~ ~ w -,aso, i c <> -

49%

487-70130, and -70208 to Williams & Company.

rDR 4A99 H nvusTo e

ri g

99901052 PDR k

2-b)

Per project specifications,10CFR21 was not applicable to P.O.682-1051 to Commercial Fasteners; #82-1032 to Allegheny t

Ludlum; #86-60620 to Industrial Service Cen^,er and therefore not imposed on the vendors.

c)

On both the original and revision il of P.O.483-1387 to Sandvik, the applicability of 10CFR21 is noted on Page 2 of 2.

d)

P.O.tB6-60208 to Columbia Electric and $84-1701 aid 484-1679 to Do All Pittsburgh were for service to commercial type tools.

P.O.686-61228 to Cromie Machine and Tool was for subcontracting machining of UST&D supplied material.

10CFR21 should have been noted on this Purchase Order.

CORRECTIVE ACTION for Item (d)

A revision to the Purchase Orders 986-60208 to Columbia Electric; 484-1701 and #84-1679 to Do All Pittsburgh; and #86-61228 to Cromie Machine & Tool will be issued and include the reporting requirements of 10CFR21.

g A review of 10CTR21 and UST&D's procurement procedures will be made with all personnel processing purchase orders to prevent recurrence.

This Corrective Action will be completed by June 30, 1987.

Internal audit activities will prevent recurrence.

VIOLATION 02 -

"... USTED failed to post Section 206 of the Energy Reorganization Act of 1974. (87-01-02)"

UST&D COMMENT Section 206 of the Energy Reorganization Act of 1974 was posted during the inspection as confirmed by Item 14 (page 13) of the NRC Inspection Report.

CORRECTIVE ACTION Corrective Action has been completed.

Internal audit activities will prevent'iecurrence.

~.

APPENDIX B NONCONFORMANCE il in-process examinations were not being performed at the South Shop per the "Production Work Routing and Inspettion Plan," Drawing 8601-0, Revision 1, for the spent fuelf racks being manufactured for the LaSalle project. (87-01-03 "

UST&D COMMENT In-process examinations not performed at the South Shop were performed at the North Shop prior to installation of the cells into the final rack assembly.

CORRECTIVE ACTION A change has been made in Production supervisory personnel at the South Shop.

Complete in-process examination records have been started as of March 25, 1987 at the South Shop.

To prevent recurrence, a training session will be held with all Quality Control personnel to review the requirements of the in-process examination and Production Work Routing & Inspection Plan procedures.

This review will be complete by June 30, 1987.

NONCONFORMANCE 42

"... two undersize welds were identified by the NRC inspectors on a fuel rack which had been inspected and found acceptable by UST&D Quality Control. (87-01-04)"

UST&D COMMENT Upon discovery, a weld pass was added to the undersize welds found by the NRC inspector.

The balance of the welds on the respective subassambly were checked by the Quality Control Manager and found to be of the proper size.

CORRECTIVE ACTION A review of the use of weld gauges and, weld acceptance criteria will be made with Quality Control personnel by June 30, 1987 to prevent recurrence.

m,.

.,,,y-_gm.

t "4"

NONCONFORMANCE $3 i

a review of measuring and test equipment (M&TE) and calibration records revealed the following:

a)

Documented evidence was not available to verify t$at the calibrationintervalforMETEwasestablishedinprocedures.

boxmandrelsforthehKewaunee, b)

The four inner diameter (ID)

Vermont Yankee, and LaSalle projects in the South f abrication shop were not identified with a permanent unique S/N applied by vibro-etching or with a durable label.

c)

A calibration interval was not established in the "Cardex" system for the modified ID box mandrel for the LaSalle project in the North isbrication shop. (87-01-05)"

UST&D COMMENT Corrective Action has been or will be taken as follows:

e a)

As delineated in UST&D's calibration procedure, the cali.bration go intervals are established in t5e "Cardex" system but will be incorporated into an Appendix to Procedure 12.1.

This addition to the procedure will be made by June 30, 1987.

b)

Although the box gauges were identified with the project name painted on and the sizes of the various gauges precludes use on other than what they were made, each box gauge has been given a unique serial number.

A durable label with this serial number on it has been attached to the appropriate box gauge.

c)

The calibration interval for all box gauges has been established.

This modified box gauge for the LaSalle project is being checked prior to and after use on each rack.

CORRECTIVE ACTION To prevent recurrence, Quality Control personnel will participate in a training session to review UST&D's calibration procedure.

This training session will be conducted by June 30, 1987.

ee M

g S

e 1

e

~ -.,,.

-n

NONCONTORMANCE 64

"... a review of 43 purchase orders for materials and services related to spent luel racks fabricated under ASME Code Section III, Subsection NT indicated that quality requirements (e.g.,

Quality Assurance Program) werenotpassedontovendprs..."

UST&D COMMENT a)

P.O.686-60746, -60813, -60814 and -61228 to Cromi Machine

& Tool were for machining USTED supplied material.

Material traceability has been maintained and 1004 receipt inspection performed by UST&D of the machined parts.

Crode Machine follows UST&D Quality Assurance / Quality control Program and is on our Approved Vendor List based on these criteria.

b)

P.O.686-61218 to Metal Goods was for material ordered for handling equipment and therefore not subject to Quality Assurance / Quality Control requirements.

c)

P.O.682-1051 to Commercial Fasteners and P.O.482-1032 to Allegheny Ludlum was for material for a DOE project.

The project specifications did not require imposition c2 the 10CFR50 Appendix 3 requirements.

di P.O.986-60802, -81208, and $87-70132 to West Penn Laco, P.O.682-1311 and 83-1387 to Sandvik, P.O.487-70ll5 to Wald Star and P.O.985-51023 to Techalloy does not include furnishing material to their Quality Assurance / Quality Control Program.

However, a review of the Material Test Reports for the material ordered shows the material has been furnished by ASME Certificate Holders and in accordance with their appropriate Quality Assurance / Quality Control Program.

e)

P.O.486-70103 te Alloy Oxygen does impose furnishing material in accordance with their Quality. Assurance / Quality control Program by the notation of "Q" material.

This notation is Alloy-Oxygen's terminology for their Quality Assurance /

Quality Control Program, f)

Columbia Electric Manufacturing and Do All Pittsburgh are manufacturers of commercial grade tools with certificates of conformance for calibration of said tools traceable to the National Bureau of Standards.

CORRECTIVE ACTION Revised P.O.086-60802, and 687-70132 to West Penn Laco;

1. 82-1311 and 083-1387 to Sandvik; 687-70115 to Wald Star; and 495-51023 to Techalloy will be issued and include the i

requirement to furnish material per their Quality Assurance.

j Quality Control Program.

To prevent any question of imposing a quhlity program requirement, personnel involved in the purchasing policy will receive training by June 30, 1987 on the procurement l

requirements of UST&D's Quality Assurance Program.

v

-e-

,w

.w,.,

-e y--w-r.,

NONCONTORMANCE 45 a review of purchase orders indicated that P.O.487-70118 to Alloy Oxygen Welding supply for stainless steel weld filler metal did not contain a delta-ferrite determination statement',

and P.O.446-60610 to WALCO Corporation for markers and tape was not signed / initiated and dated by Quality Assurance personnel.

(87-01-07)"

ti UST&D COMMENT 4

The weld wire ordered from Aller-Oxygen Welding Supply is of a composition that by its nature f ar exceeds the delta-ferrite minimum requirements of Alba Section III, Subsection NT.

The purchase order to WALCO.did g.st throv.gn the Quality Assurance / Quality Cor.ttol system without the proper signature.

CORRECTIVE ACTION S.

Revised purchase e:6ers will be {ssued with the proper j

requirements and cigastures.

i l

These actio</tz will te Tovered in the training saision for purchasi?g pursonnel to be conducted by June 30, 1987 1

to prevent recurronGo.

NONCO'NTORMANCZ 96 1

a document (d stoc% ure/ instruction did not i

it was noted that exist to 'centrol tnols

't ~g., wire brushes, grinding wheels, hammers,

etc.) that were d>2igntwed for use only o's stainless steel material.

(87-01-081" UST&D COSMENT The vast =*jGrity of Work dGhs at USTSD is with stainless steel, however,somecarkl1stselwolk'napb4PQdone.

It has been UST&D's standard operating procedure c'ter the years to paint tools used on carbon steel.

This yrshedure has never been put into writing.

1 CORRECTIVE ACTION s

Instructions will be written to the Producl. ion Department to, paint tools used on carhe.n flojects dad'.; train 4ng session will be held with Production personnel to sganze ytinted tools will not be permitted for 'ase on stainless s't6el.

j This Corrective Action will be completed tar June 30, 1517.

1 l

~

.. ~

.._.s,..-..__

NONCohTORMANCE 4 7

"... Procedure 10.3 does not provide the Quality Control Inspector appropriate quidance indicating the required random sample quantities or percentages needed to ensure a representative sample during in-process examinations.

(87-01-09)"

r USTED COMMENT f

f As part of the in-process inspection, material tra sability is maintained on a 100% basis; all cells are gaged to assure proper dimensions are maintained; and as a minimum, machined parts with critical dimensions are "first piece" inspected, and spot checked on a 10% random sampling basis.

If any d.iscrepancy is revealed by this inspection, a minimum of 10 previously fabricated pieces are checked.

Any discrepancy found in these 10 pieces will require a 100% inspection of all pieces.

CORRECTIVE ACTION

• e Procedure 10.3 will be revised to include the above 3,

quantitative acceptance criteria and training will be conducted with Quality Control personnel by June 30, 1987 to review this change.

NONCOUFCAMANCE i8

"... marking procedures used by the South shop Quality Control inspector for in-process examinatien do not clearly identify items or components which have satisfactorily passed the required examinations or who examined the part.

(87-01-10)"

UST&D COMMENT Corrective Action will be taken in the form of training of Quality control personnel to indicate performance of inspection by initialing the pieces inspected when ather records will not be generated.

This training will occur by June 30, 1987.

e ee h

5

?

~B-NONCONTORMANCE #9

... vendor evaluations had not been performed on Do All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D.

(87-01-11)"

UST&D COMMENT e

t These pieces of equipment were purchased under the Quality Assurance / Quality Control Program of the prior own rship of UST&D.

Historic data records for Columbia Electric Manufacturing and Do All Pittsburgh were availabla at the time of the NRC inspection.

UST&D's Procedure 12.1 (Para 2.7.1) states that a manufacturer of measuring / test equipment can be considered pre-qualified to calibrate their equipment.

Certification has been provided by these manufacturers that the calibration methods and equipment used is traceable to the National Bureau of Standards.

CORRECTIVE ACTION A re-evaluation will be conducted on these two vendors by August 15, 1987 NONCONTORMANCE fl0 i

training records did not exist for two UST&D shop amployees.

(87-01-12)"

UST&D COMMINT The two machinists have been empicyed by UST&D for over 15 and 20 years and training had not been documented.

CORRICTIVE ACTION Corrective Action will include training of employees to their activities and documentation will be completed by June 30, 1987.,

i

UST&D COMMENT This purchase order was issued to Industrial Fervice Center with a provision that no material be shipped until Industrial Service Center was audited by UST&D.

The first shipment of material ordered by this purchase order was received by UST&D on April 8, 1986.

CORRICTIVE ACTION

)

A training session will be conducted with procurgment personnel by June 30, 1987 to review purchasing getivities.

U.S. Tool & Die, Incorporated feels that the above Corrective Action will satisfy the Violations and Nonconformances uncavared by this y

NRC inspection.

Sincerely, U.S. TOOL &, II, INC.

Michael Rodgers President MJRegb a e l

f 1

e q'

. 4' S se

l Commonwealth Edison Company i

ATTN: Mr. Cordell Reed i

Vice President i

Post Office Box 767 Chicago, Illinois 60690 Wisconsin Public Service Corporation ATTN: Mr. D. C. Hintz Manager, Nuclear Power Post Office Box 19002 Green Bay, Wisconsin 54307 Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy, Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Bechtel Energy Corporation ATTN: F*

Robert Baremore

'r.oject supplier, Quality supervisor 5400 Westheimer Ct P. O. Box 2166 Houston, Texas 77252-2166 ic EAM MR TW WW CT FR 4

s

,,e

( f\\ C I 3

)

.....,'o, UNITED STATES i

,e f j NUCLEAR REGULATORY COMMISSION r

a W LSHINGTON, D. C. 20555

=

o%

/

July 28, 1987 Docket No. 99901082/87-01 U.S. Tool and Die, Incorporated ATTN: Mr. Michael J. Rodgers President 4030 Route 8 Allison Park, Pennsylvania 15101 Gentlemen:

j Thank you for your letter dated June 9, 1987, which described the corrective action U.S. Tool and Die, Incorporated (USTAD) has and will implement in response to the Notice of Violation and Items of Nonconformance identified in Inspection Report No. 99901052/87-01, dated May 12, 1987. Your response and corrective action for Notice of Violation 87-01-02, and Items of Nonconfomance 87-01-04, 87-01-05, 87-01-07, 87-01-08, 87-01-09, 87-01-10, and 87-01-12 appear to be adequate and no additional information is requested. The following items, however, require additional information to determine the adequacy of the UST&D l

response and corrective action.

Part a) of the response to Notice of Violation 87-01-01 states that after receipt of comercial grade material at UST&D and dedication to the specific basic component by UST&D, the reporting (requirements of 10 CFR 21 are in effect.

This is in accordance with 10 CFR 21.3 c-1). Please provide a description of UST&D's dedication process that is used to upgrade cosmercial grade products for use as basic components and a sample of the documentation iglementing the dedica-tien process for P0s 86-60002 -81208, -61112, -70103 -61218 -60921, 87-70132,

-70115, -70118 -70130, and -70208. For part b) of that response, please provide pertinent sections of the project specifications which address the applicability of 10 CFR 21 to P0s 82-1051. -1032, and 86-6020. Part c) states that 10 CFR 21, is imposed on page 2 of PO 83-1387 to Sandvik. Please provide a copy of P0 65-1387.

It should be noted that the NRC has not taken a position on th1 Atomic Industrial Forum's Comittee Position Paper, "Recoseended Practices for Procurement of Replacement / Spare Parts for Nuclear Power Plants." Also, in addition to imposing 10 CFR 21 on UST&D, customers igese ASME Code Section III, Subsection NF and 10 CFR 50, Appendix B in their P0s and specifications. UST&D must comply with 10 CFR 21 whenever a specification unique to the nuclear industry (e.g., ASME Section III; 10 CFR 50, Appendix B; 10 CFR 21; etc.) is invoked in the customer's P0.

The response to Item of Nonconformance 87-01-03 states that in-process examinations not performed at the South Shop were performed at the. North Shop prior to installa-tion of the cells into the final rack assembly. Please provide assurance that thetypesofin-processexamsperformedattheNorthShopmettherequirements of "Production Work Routing and Irspection Plan," Drawing 8601-D, ano Procedure 14.1.

~,ci Kg J f;3

\\

. g; j w v

o.,

U.S. Tool and Die, Incorporated July 28, 1987 i

The respense to Item of Nonconfomance 87-01-06 is incomplete in that PO 82-1068 to Capitol Pipe and Steel and PO 86-81208 to West Penn Laco were not addressed in the response.

It was stated in part a) of the response' that Cromie Machine follows UST&D's QA/QC program.

Please provide assurance of this and what controls are implementee to ensure the UST&D QA/QC program is be$ng followed at Cromie Machine. Part e) of the response states that "Q" on P0s to Alloy Oxygen implies imposition of their QA/QC program on that P0. Please provice assurance that the individual issuing the P0 acknowledges what special notations are required on certain P0s which impose QA/QC progrars. C of Cs and CMTRs document the final products acceptability, however, this type of documentation does not ensure the implementation of a QA/QC program.

For part f), please provide assurance that QA/QC programs were implemented at Columbia Electric Manufacturing and Do All Pittsburgh and these types of manufacturers have QA/QC programs in place.

The response to Item of Nonconformance 87-01-11 stated that Historic Data Records are available for Columbia Electric Manufacturing and Do All Pittsburgh; please provide these reports. A copy of the NRC position regarding audits of suppliers who offer calibration services for measuring and test equipment that they manufacture is enclosed for your infomation.

One final note on the response to Item of Nonconfomance 87-01-13, the training given to procurement personnel should include measures to ensure that the "no shippi.ng until aucit is performed" clause is added to the P0 as needed.

If you have any questions concerning these requests for additional infomation, please contact Ms. Claudia Abbate at (301) 492-4776 or Mr. James Stone at (301)492-9661.

Sincerely, Ellis W. Merse

. Acting Chief Vendor Inspecti Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation

Enclosure:

As stated

o AUG 2 41993 8ingham-Willamette Company ATTN:

Mr. J. L. Wood Quality Assurance Supervisor P. O. Box 1024T Portland, OR 97210 Gentlemen:

1

SUBJECT:

QA PROGRAM REQUIREMENTS FOR SUPPLIERS OF CALIBRATION SERVICE The Wood /Potapovs letter dated July 25, 1983, requested the Commission's concurrence with Singham-Willamette Company's (8WC) position (ref. Rove /Barnes letter dated January 11, 1982) on the audit requirements of suppliers of calibration services.

The Olvision of Quality Assurance, Safeguards, and Inspection Programs (QASIP) in the Office of Inspection and Enforcement was contacted to obtain an official NRC position on the above subject.

The following information states the NRC position received from QASIP, and the position addresses the following three types of suppliers of calibration services:

, 1.

Suppliers who offer calibration services for measuring and test equipment not manufactured by them.

2.

Suppliers who offer calibration services for measuring and test

~

equipm/ent that they manufacture.

3.

National Bureau of Standards.

With regard to whether a quality assurance program satisfying the provisions of ANSI N45.2 is required of these three types of suppliers, our position is as follows:

The suppliers noted in types 1 and 2 above are required to have a quality assurance program to the extent necessary to assure the quality of the safety-related service and product provided.

This means that the appropriate QA criteria of Appendix B to 10 CFR Part 50 and the appropriate provisions of the implementing standard, ANSI N45.2, should be applied consistent with the activities undertaken in the generation of the service and product; e.g., design, procurement, manufteturing, testing, etc.

In the case of the type 3 supplier, the National Bureau of Standards, it is not necessary for the purchaser to assure that this organization have a quality assurance program that meets the applicable requirements of Appendix 8 to 10 CFR Part 50 and ANSI N45.2 since it is a nationally recognized laboratory with proven abilities and disciplines.

p '? d I ]

J'<

~

' e.

... e

\\

Bingham Willamette Company

-2*

i With regard for the need of preaward evaluation and postaward audits for these three types of suppliers, our position is as follows:

A preaward evaluation and postaward audits are required for the types 1 and C suppliers.

It should be noted that the results of pre-award evaluations that have been performed on the same supplier by another purchaser working to a QA program that satisfies Appendix B to 10 CFR Part 50 may be shared among purchasers; e.g., utilization of the CASE register.

I A preaward evaluation and postaward audits are not required for work performed at the National Bureau of Standards.

Please accept my apology for the delay in responding to BWC's 1982 letter.

If you have any questions on the above comments, please contact Jim Conway (817) 860-8236 or Ian Barnes (817) 860-9176.

Sincerely,

)

. original l'C"d C. J. H AkK' Uldis Potapovs. Chief Vendor Program Branch d

e o

O 1

1

e A> This request for information was approved by OMR under clearance number 3150-0011 which expires December 30, 1989.

Comments on burden and duplication may be directed to the Office of Managonent and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D. C.

P0503.

Sincerely,

/s/

Walter R. Rutler Directnr Project Directorate I-?

Division of Reactor Proiects I/II

Enclosure:

As stated cc:

See next page DISTRIBUTION Docket File NRC PDR LPDR PDI-2 Reading SVaroa BBoger WButler M0'Brien S8rewn GRivenbark OGC-WF EJordan JPartlow ACRS (10)

PDI-2/PM PDI ?/D SRrown:m WButler 1,,

s /za88 3 M /88