ML20149M221

Notice of Nonconformance from Insp on 880111-14. Nonconformance Noted:Matl Not Purchased to Astm/Asme Spec, Chemical Composition Limits Incomplete & Actual Mechanical Property Limits Missing

ML20149M221
Person / Time
Issue date:	02/22/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20149M216	List: ML20149M215 ML20149M221 ML20149M233
References
REF-QA-99901075 99901075-88-01, 99901075-88-1, NUDOCS 8802250418
Download: ML20149M221 (2)

Text

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APPENDIX A Circleville Metal Works, Inc.

Docket No. 99901075/88-01 NOTICE OF NONCONFORMANCE i

During an inspection conducted on January 11-14, 1988, the implementation of ,

the Circleville Metal Works (CMW) Quality Assurance (QA) program at the  !

Circleville, Ohio facility was reviewed with respect to the fabrication of the I LHRL-120 spent fuel transportation cask. CMW-QAP-1, "Quality Assurance Program,"

Revision 0, dated December 4, 1986 and the CMW Quality Control Manual, Revision 1, i dated March 3,1986, describe the programs being implemented at CMW. Based on '

the results of this inspection and in ac:ordance with the NRC Enforcement Policy of 10 CFR Part 2, Appendix C, the following items of nonconformance were identified.

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1. Paragraph 71.115(b) of Subpart H to 10 CFR Part 71 states, in part, "The licensee shall have available documentary evidence that material and equipment conform to the procurement specifications prior to installa-tion or use of the material and equipment."

Paragraph 18.1 of the CMW Quality Assurance Program, CMW-QAP-1, Revision 0, dated December 4,1986, states, "The Fabricator shall be responsible for establishing measures to control materials, parts, or components which do not conform to the applicable codes, standards, drawings, or specifications to prevent their inadvertent use or installation."

J Paragraph 3.1 of the CMW Quality Control Manual, Revision 1, dated March 3,1986, states, in part, "This section deals with purchasing and receiving control of Code material which will assure that the material ordered and received is properly identified and has documentation including .

required material certifications or material test reports to satisfy Code  !

requirements as ordered. This control system shall assure that only the  !

intended material is used in Code work."

Section 2.0 of the Edlow International Company Quality Assurance Plan for Design and Fabrication of LHRL-120 Cask for Irradiated Hifar Fuel, Revision 4, dated September 9, 1987 and Codes and Standards Used in LHRL-120 Cask J

Design and Fabrication, dated October 15, 1987, state that the ASME BPV, Section 11 be used for "material specifications reference, i.e., ASTM  ;

specifications were used, but of those used they agree with Section II."

1 Contrary to the above, a Certification of Ctemical and Physical Properties forPurchaseOrder(PG) 87/2017-01/48 had tne following discrepancies ,

, associated with it (87-01-01):

1) The material was apparently not purchased to an ASTM /ASME specification.

The only designation on the PO was 6063T-6.

a C802250418 880222 PDR DA999 ENVCIRCL 99901075 DCD

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i . 2) The chemical composition limits were incomplete (no chromium or nickel values listed).

3) The actual mechanical property limits were missing.

4) This material had been purchased by Eggers Ridihalgh Partners (ERP) and issued to CMW for use in the basket assemblies. CMW issued and installed the material in two baskets without complete certifica-tion of properties and without the Quality Control Supervisor's (QCS) approval and signature on the certification. These two baskets have already been fabricated and shipped to Australia.

2. Paragraph 71.115(6) of Subpart H to 10 CFR Part 71 states, in part, "The licensee shall establish measures to assure that purchased material, equipment, and services, whether purchased directly or through contr-actors, conform to procurement documents."

Paragraph 3.1(a.1) of the CMW Quality Control Manual, Revision 1, dated March 3, 1986, states, "The QCS will examine and compare all Mill Test i Reports to ASME Section II. The QCS will then initial the test report l and place it in the Code file for review by the AI." .

Contrary to the above, although PO 40938-99-8-02-03 for 6061-T651 aluminum was purchased to specification QQ-A-200/B, the Certificate of Compliance (C of C) from Cressona Aluminum Company to Williams and Company was not l

actually reviewed to QQ-A-200/B. The C of C had been initialed and dated by the QCS and the material released for use (88-01-02).

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3. Paragraph 71.125 of Subpart H to 10 CFR Part 71 states, "The licensee shall establish measures to assure that tools, gages, instruments and other measuring and test devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified times to maintain accuracy within necessary limits."

l Sections 9.la and b of the CMW Quality Control Manual, Revision 1, dated March 3, 1986, state:

a) "The QCS is responsiM e for maintaining all test gauges and temperature gauges in proper working condition, b) Each test and temperature gauge will have a serial number assigned to it by the QCS. In the case of the gauges there will be a tag indicating the date it was last tested, the date when it will be l tested again, and the serial number."

Paragraph 5.4a of CMW Specification #2, "Liquid Penetrant Examination,"  ;

Revision 1, dated May 7, 1986, states: "As a standard technique, the

! temperature of the penetrant and the surface of the part to be processed l shall not be below 60*F nor above 125*F throughout the examination period.

t.ocal heating or cooling.is permitted provided the temperatures remain in l l the range of 60"F to 125*F during the examination period."  ;

l Contrary to the above, temperature goutes used to verify the tesperature )

of test material de.tng liquid penetrant tests and weld rod oven tempera- i

tores were not controlled under the CMW calibration system (88 01 03).

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