ML20151V607

Notice of Nonconformance from Insp on 880216-19. Nonconformance Noted:Trent Tube Facility Did Not Include Chemical Product Analyses Performed by Steel Mfgs &/Or Lab on Listed Certified Matl Test Repts for Nuclear Orders

ML20151V607
Person / Time
Issue date:	04/21/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20151V570	List: ML20151V565 ML20151V603 ML20151V607 ML20151V624
References
REF-QA-99902008 99902008-88-01, 99902008-88-1, NUDOCS 8805030119
Download: ML20151V607 (3)

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APPENDIX 8 Crucible Materials Corporation Trent Tube Division Docket No. 99002008/88-01 NOTICE OF NONCONFORMANCE During an inspection conducted February 16-19, 1988, the implementation of the .

QA program at the Trent Tube (TT) facility in East Troy, Wisconsin was reviewed with respect to the manufacture of tubing for nuclear facilities. The applicable QA requirements are 10 CFR Part 50 Appendix 8, and TT's Quality Systems Manual (QSM),datedApril 10, 1966. Based on the results of this inspection, it appears that certain activities were not conducted in accordance with these requirements. The following nonconformances were identified:

1. Criterion IV of Appendix B to 10 CFR Part 50, Subsection NCA 3866.3 of Section III of the ASME Code, and Section 5 of ANSI N45.2 require that procurement documents impose a QA program upon the vendor.

Section 1.1 of the QSM states, in part, "This manual documents the Quality System Program of the Trent Tube office and plants in East Troy, Wisconsin...It [ Manual] also meets those requirements of 10 CFR 50 Appendix 8 and ANSI N45.2 applicable to our operations."

Contrary to the above, the requirement for a vendor to have an approved QA program was not stated on P0s 54113 (December 30,1985) to Anderson Laboratories, 50005 (February 27,1985) to Conan, 58684 (January 22,1987),

to Instrumatics, 59715 (April 30, 1987) to Page Wilson, and 57224 (September 2, 1986) to Magnetic Analytical Corporation. (88-01-02)

2. Subsection NCA-3867.4(a) of Section 111 of the ASME Code states, in part, "The Certified Material Test Report [CMTR] shall include the actual results of all required chemical analyses.. ."

Section 8.9.5 of the QSM states, in part, "A CMTR will be furnished to the Trent customers and include...a product analysis...."

Section 19.5 of the QSM states, in part, "The CMTR shall include...the actual results of all required chemical analyses...."

Contrary to the above TT did not include the chemical product analyses which had been performed by steel manufacturers and/or a laboratory on the following CMTRs for nuclear orders: (88-01-03)

• Two to Joseph Oat Corporation for heat Nos. 360090 and 360314 on mill order No. NS-85027-6.

• Three to Joseph Oat Corporation for heat Nos. 230183, 340467 and 340911  ;

on mill order No. NS-80173-4.

99902008 DCD

'Two to Wisconsin Electric Power Company (WEPC) for heat No. 94164 on mill order Nos. 4N5-10364-7 and 3N5-10365-7.

• 0ne to Cuquesne Light Company (OLC) for heat No. 1G4894 on mill order No. N5-70005-5.

3. Section 7.3 of Procedure No. QCS-134, "General Requirenents for NDT Training and Certification," Revision 6 and Section 9.6.1 of SNT-TC-1A require that the qualification records of certified individuals be maintained ar.d include among other things, a statement indicating satisfactory completion of training in accordance with the employer's written practice.

Contrary to the above, a review of qualification records for 13 nondestructive examination (NDE) personnel revealed that the records for all the examiners did not contain a statement indicating satisfactory completion of training in accordance with TT's written practice No. QCS-134. (88-01-04)

4. Criterion II of Appendix B to 10 CFR Part 50 and Section !! of ANSI N45.2 state, in part, "The program shall provide for indoctrination and training of personnel perfoming activities affecting quality...."

Section 4.1 of the QSM states, in part, "The QA training program shall consist of a series of courses covering the requirements of this manual...."

Section 4.4 of the QSM states, in part "...the employee shall take QA training per 4.1. . . ."

Contrary to the above, a review of training records and training schedules for 1986 and 1987 indicated that TT failed to indoctrinate and train personnel perfoming activities affecting quality in the requirements of the QSM. (88-01-05)

5. SubsectionNCA-3867.4(e)ofSection!!!oftheASMECodeidentifiesvarious '

requirements for upgrading stock material for nuclear applications.

Section 8.9 of the QSM requires that material made from stock produced by a manufacturer whose quality system program has not been qualified under NCA-3800 be further tested (i.e., product analysis from each coil and all the other requirements of the material specification from specimens cut from the finished tube) for upgrading to nuclear.

Contrary to the above, TT failed to upgrade stock material used for safety related tubing on two orders from DLC (P0 No. 26559 dated February 4, 1985) and WEPC (P0 ho. C397325 dated November 11,1987). (88-01-06)

6. Criterion XII of Appendix B to 10 CFR Part 50 and Subsection NCA-3868 of Section 111 of the ASME Code require that measuring and test equipment te controlled and calibrated.

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. . 1 4 4 Section 17.5.1 of the QSM states, in part "Calibration shall be performed by the personnel or subcontractor designated on the "calibration card."

The calibrator shall perform the calibration...and shall enter results, sign of f and date the "calibration card" upon completion of the calibration."

Contrary to the above, a review of calibration records indicated that calibration cards for three pressure gauges (S/Ns 8325-4, 8247-7, and 1286) had not been updated to reflect current calibration status. (88-01-07)

7. Criterion II of Appendix B to 10 CFR Part 50 and Section 2 of ANSI N45.2 require that the QA program provide controls on activities affecting quality.

Section 6 of the QSM requires that a Process Engineer review and forward non-standard orders to the Manager Quality Control / Manager Technical Services for review and subsequent documentation of the results on a "Nuclear Review" form.

Contrary to the above, documented evidence was not available to show that a "Nuclear Review" form was generated for two nuclear orders from DLC (PO No. 28559 dated February 4, 1985) and WEPC (P0 No. C397325 dated November 11,1987). (88-01-08) l i

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