ML20153H485
| ML20153H485 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1988 |
| From: | Baker E, Conway J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20153H435 | List: |
| References | |
| REF-QA-99901107 99901107-88-01, 99901107-88-1, NUDOCS 8809090204 | |
| Download: ML20153H485 (9) | |
Text
ORGANIZATION:
KILBOURN ENGINEERING COMPANY MILWAUKEE, WISCONSIN REPORT INSPECTION INSPECTION NO.: 99901107/88-01 DATE: 7/11-15/88 ON-SITE HOURS Ad CORRESPONDENCE ADDRESS:
Larry Beitzinger, President Kilbourn Engineering Company 9226 W. F1,sgg Avenue Milwaukee, Wisconsin 53225 ORGANIZATIONAL CONTACT: Anthony Mikovec, QA Coordinator TELEPHONE NUMBER:
(414) 446-6500 NUCLEAR INDUSTRY ACTIVITY:
Fasteners ASSIGNED INSPECTOR:
M
-N O S UJ.T.Conway, Pro am Development and Reactive Date nspection Sect (PDRIS)
OTHER INSPECTOR:
T. Tinkle (consultant)
APPROVED BY:
E. T. Baker, Chief, PDRIS, Vendor Inspection Branch Date INSPECTION BASES AND SCOPE:
A.
BAS,E_S :
10 CFR Part 50, Appendix B and 10 CFR Part 21.
S B.
SCOPE:
The inspection was conducted to perform a prograntnatic evaluation of Gie irnplementation of Kilbourn Engineering's (KE) QA program as it relates to the fabrication of fasteners for nuclear facilities.
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ORGANIZATION:
KILBOURN ENGINEERING COMPANY MILWAUKEE, WISCONSIN a
REPORT INSPECTION N0.:
99901107/88-01 RESULTS:
PAGE 2 of 9 A.
VIOLATION:
Contrary to Section 21.31 of 10 CFR Part 21 a review of purchase orders (P0) to vendors revealed that while 10 CFR Part 21 was imposed upon KE, KE did not impose 10 CFR Part 21 requirements on P0s 10046 (February 3,1988) to Conam Inspection,10062 (February 22,1988)to American Bolt Corporation, and 10065 (February 26, 1988) to S. K.
Williams.
(88-01-01)
B.
NONCONFORMANCES:
1.
Contrary to Subsection NCA-3867.4(a) of Section 111 nf the ASME Code and laragraph 3.S of Section 6.1 of the Quality System Manual (QSM), KE diu not include the chemical product anslysis which was perforr.ed by Schevers Laboratories (SL) on Certified Material Test Repurts (CMTRs) dated February 24, 1986 to Consumers Power and August 17, 1987 to Cleveland Electric Illuminating Company.
(88-01-02) 2.
Contrary to Criterion XVII of Appendix B to 10 CFR Part 50, paragraph S.1.3.1 of Section 2.1. of the QSM, and paragraph 3.1.
of Section 11,1 of the QSM, KE was unable to provide lead auditor qualification records for the Production Manager (PM) who perforced an audit of SL on June 10, 1986.
(88-02-03) 3.
Contrary to Criterion IX of Appendix B to 10 CFR Part 50. Sub-section T-170 of Section V of the ASME Code, and Section 9.6 of SNT-TC-1A, KE did not have a copy of written practice No.
99-CNTP-002, dated April 15, 1982, for Conam Inspecticn who provices NDT Level III services for KE, (88-01-04) 4.
Contrary to Criterion VII of Appendix B to 10 CFR Part 50 and paragraph 3.3 of Section 3.1. of the QSM, KE issued P0 8049, dated July 5, 1983 to Starrett for calibration services without Starrett being on the Quality Suppliers List (QSL).
(88-01-05)
C.
UNRESGLVED ITEM:
None D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
None.
This was the first inspec, tion of this facility.
1 ORGANIZAT10N:
KILBOURN ENGINEERlhG COMPAn:
MILWAUKEE, WISCONSIN REPORT INSPECTION N0.:
99901107/88-01 RESULTS:
PAGE 3 of 9 E.
OTHER FINDINGS AND C0!HENTS:
1.
Kilbourn Engineering KE has been in business since the mid 1930's and started marketing threaded products for the nuclear power industry in 1977 at which time they developed and implemented their initial quality system program and received Quality System Certificates (QSC) from ASME.
KE manufacturers and supplies threaded fasteners to both non-nuclear and nuclear customers.
in 1987, the nuclear business was approxi-mately 40-percent of the total sales.
The majority of fasteners supplied for nuclear customers are manufactured in accordance with the requirements of Section !!! of the ASME Code.
KE currently holds ASME QSC-509 and QSC-510 for a Material Manufacturer and Material Supplier, respectively, of ferrous and nonferrous threaded fasteners at their facility located in Milwaukee, Wisconsin.
Both certificates expire on October 17, 1989.
KE obtains a number of services from outside sources under the control of their QA program.
Conam Inspection has been delegated the responsibility to perform NDE Level 111 services.
Heat treating is performed by Lindberg Heat Treating Company and Treat-All Metals. Anderson Laboratories does mechanical testing and chemical analyses are conducted by SL. All these vendors were audited and on KE's QSL.
Raw material, primarily round and hexagonal bar stock, is procured as either qualified or unqualified material. Qualified material is purchased from vendors who appear on the QSL. Vendors, including both suppliers and manufacturers, are qualified if they hold a valid QSC from ASME or if KE's QA Department has approved the vendor via an audit. Quality requirerrents are invoked on P0s for qualified material.
Based on a review of numerous P0s, KE also involves 10 CFR Part 21 requirements on these orders.
Unqualified material is obtained as cwcercial grace from vendors who are not on the QSL.
Neither quality nor 10 CFR Part 21 requirements are invoked on these P0s. When qualified raw material is used, KE's CMTR cites material test data documented on the CMTR from the manufacturer.
If unqualified material is used. KE upgrades the stock material in accordance with Subsection 3867.4(e) of Section !!! of the ASME Code.
This includes taking a sample from each piece of material from a given heat number and subjecting it to chemical analysis and mechanical testing.
A stated KE policy is to provide CMTRs to their customers for all nuclear safety-related fastener orders including 1-inch and
ORGANTZAT10h:
KILBOURN ENGINEERING COMPANY MILWAUKEE., WISCONSIN REPORT INSPECTION NO.:
99901107/88-01 RESULTS:
PAGE 4 of 9 smaller fasteners for which the ASME Code allows certificates of compliance in lieu Of CMTRs.
KE considers this provides additional assurance of material quality to their nuclear customers.
In addition to stamping the grade ano the manufacturer's identification sya.bol onthe fastener, KE in 1984 implemented the stamping of a heat code on all nuclear safety-related fasteners larger than 1/2-inch nominal size.
If requested by the customer, the heat code (three alphabetical symbols) is also stamped on smaller l
sizes.
KE does not routinely stamp the heat code on their commercial orders.
2.
Calibration of Measuring and Test Equipment (M&TE)
The inspector reviewed Section 7.1 "Control of Measuring and Test Equipment" of the QSM, procedure 2.1, and calibration records to assure M&TE is properly controlled and calibrated.
It was noted that two OD micrometers (S/Ns 101 and 102), thread gages (S/N 200), thread micrometer (S/N 301), and a master set of Jo-Blocks (5/N 500) were calibrated on the frequency documented in the card file system. A calibration certificate indicated that the Jo-Blocks were calibrated by Starrett, and the reference standards were trace-able to the National Bureau of Standards.
3.
Control of Purchased Material and Services The inspector reviewed Section 3.1., "Control of Purchased Material and Services," of the QSM and various records to assure that material and services were purchased from qualified vendors.
i Nineteen external audits covered a time period from May 1981 to August 1987 and with the exception of one audit were performed with a checklist by the QA Manager.
The PM performed a qualit'i-cation audit of SL in June 1986.
This audit was used to maintain the vendor on the QSL for a number of months until the validity i
of the PM's lead auditor qualifications were questioned during an l
ASME audit.
Based on ASME's concern, KE removed SL from the QSL until another audit was performed by the QA Manager.
i It was noted that annual aucits were conducted of two material manufacturers and six service vendors.
The following vendors were audited: SL - testing (May 1985 through August 1987),
Anderson Laboratories - testin (July 1984 through July 1986).
j Accurate Gage - calibration (Ju y 1987), Lindberg-heat treating (July 1986 ano July 1987),, Treat-All Metals-heat treating (May 1985 and July 1986), Conam Inspection-NDE (July 1982 through
ORGANIZATION:
KILBOURN ENGINEERING COMPANY MILWAUKEE, WISCONSIN REPORT INSPECTION NO.: 99901107/88-01 RESULTS:
PAGE 5 of 9 Septeerev 1R7), Carpenter-traterial (May 1981 through April 1950),
and Un1verssi Cyclops /C Temo..aterial (April 1982 through December f
1984 and September 1986).
Thare was no documented evidence that KE had p?rf9nred an audit of Starrett who supplied the master Jo-b bci h?3 and subsequent u Tibration services (see Nonconformance 80 al-05,.
The auditui idification records for the QA Manager appeared to meet the ream.e.
i,*.s of % 51 N45.2.23, but there were no qualifi-cu ion recora. foi che FM.
(see Nonconformance 88-01-03)
Procurement documents to 19 vendors (11 material and 8 services) were selected to determine if tech.ical and quality requirements were includeo in P0s.
The 11 material vendors included Hub, Hy-Alloy Steels, Universal Cyclops, J. T. Ryerson, A. M. Castle, Pressure Vessel-Nuclear Steels, American Bolt, Carpenter Technology, Co;,m weld, E. M. Jorgensen, and Contral Steel and Wire.
The P0s were dated from March 1981 through February 1988.
Testing services were obtained from Anderson Laboratories and SL; Accurate Gage and Starrett provided calibration sources; heat treating was done by Lindberg Heat Treating (LHT) ano Treat-All Metals (TAM);
Conam Incpection did NDE; and S. K. Williams performed cadmium plating.
F0s to service vendors were dated from May 1981 to February 1988. All the Pos contained appropriate technical requirements (e.g., Sections 11 and III of the ASME Code) and quality requirements (e.g., work to be performed under a QA program approved by KE). With the exception of three P0s to Conam, American Bolt, and S. K. Williams; the remaining P0s passeo on the requirements of 10 VFR Part 21 to the vendors (see Violation 88-01-01).
A stamp, initial, and date indicated that QA reviewed and approved each P0.
A review of six QSLs from 1983 through 1987 inoicated that all 19 vendors were on the QSL.
KE also performs a receipt inspection of incoming material to assure it confoms to the P0 requirements and is adequately identified.
A review of several "Material Receiving Report-Nuclear" indicated that KE was verifying the chemical and physical requirements of the material specification and also identifying the material with a color code and a stamped trace (heat) code.
Each report was accepted by QC and reviewed by QA.
KE had copies of QA or QC Manuals for the following vendors:
SL, Accurate Gage, Anderson Laboratories. TAM, LHT, Conam Inspection, Cyclops-Cy Temp Specialty Steel, and Carpenter Technology.
Copies
ORGANIZATION:
KILBOURN ENGlNEERING COMPANY MILWAUKEE, WISCONSIN I
REPORT INSPECTION NU.: 99901107/88-01 RESULTS:
PAGE 6 of 9 of QSCs (Materials) were on file for Pressure Vessel - Nuclear Steels (No. 366 expiration date March 5, 1988), HUB (No. 332, expiration date April 28,1990), and Copperweld (No. 348, expir-ation cate October 20,1984).
4.
Qualified Material Storage Area During a plant tour of the manufacturing area in the presence of the PM, the qualified material storage area was inspected.
It was noted that various sizes of round ano hexagonal bar stock of different material grades are organized in racks.
Each piece of bar stock was color coded on both ends to identify the material grade.
The following grades (color code) were found in the storage racks:
1018/1020 carbon steel (yellow), 4140 alloy steel (white),1042/1045 carbon steel (green), and all stainless steel (blue).
In addition, each piece of stock material was stamped with a heat code (three alphabetic symbols). Approximately 40 different codes were stamped on the stored material.
A review of the Log Book for nuclear and non-nuclear material indicated that the material identified by the 40 heat codes was supplied and manufactured by domestic companies.
For each order the Log Book identified the material grade, heat code, supplier and manufacturer, heat number and KE's P0 and shop order numbers.
In addition to the heat codes for the nuclear material in stock, another 35 heat codes were identified for nuclear orders placed from 1983 to the present.
The material was manufactured by domestic sources including Pepublic Steel, Carpenter Technology, LTV, and Joslyn Stainless Steel.
5.
Control of Special Processes The inspector reviewed Section 6.1 "Special Process and Test Control" of the QSM and applicable records to assure that special process such as NDE and heat treating are controlled in accordance with the requirerrents of the QA program. A letter dated October 13, 1967 from KE's Vice President to Nuclear Energy Services.
l Conam Inspection Division (Conam) authorized Mr. B. Creech to act as the NDE Level 111 individual on behalf of KE.
It was noted'that Conam performed Ostrasbnic (UT) and magnetic particle (MT) examination on several orders for nuclear fasteners from KE.
Conam procedures 59-MT-014 and E9-UT-105 for MT and UT, respec-tively, were on file.
I ORGAN 1ZAT10N:
KILBOURN ENGINEERING COMPANY MILWAUKEE, WISCONSIN REPORT INSPECTION NO.:
99901107/88-01 RESULTS:
PAGE 7 of 9 The qualification records for four examiners (1-Level 111 and 3-Level II) who had performed h0E were reviewed.
The records consisted of a certification of personnel qualifications, test results (general, specific, and practical) ano copies of eye examinations. The records appeared to be consistent with the requirements of SNT-TC-1A.
P0s 9705 (November 19, 1986) and 9380 (January 22,1986) to Conam referenced their written practice No. 99-ChTP-002 dated April 15, 1983.
KE did not have a copy of this written practice on file (see Nonconformance 88-01-04).
KE utilizes two vendors - LHT and TAM - to perform heat treating when required by the material specification. Both vendors were audited by KE and were on their QSL.
It was noted that 34 heat treat procedures (17 from LHT and 17 from TAM) were stamped approsed, initialed, and dated by KE.
6.
Docun,entation Packages (DP)
The inspector reviewed approximately 75 DPs (1-1982, 10-1983, 14-1984, 1-1955, 18-1986, 9-1987, and 23-1988) for fastener orders. A DP normally(consisted of the customer P0; KE's huclear Order Analysis Sheet NOAS), Production and Route Sheet (PRS),
Certification of Compliance and CMTR; and the manufacturer's CMTR. With the exception of 8 orders, the remaining 67 P0s were for bolts and/or nuts to Section 111 of the ASME Code, and the requirements of 10 CFR Part 21 were invoked on the P0s.
The NOAS, which initiates procuretrent activities and is prepared by the PM or the QA Coordinator, defines all necessary requirements (e.9., meterial specification, required heat treatment, testing and hDE, stamping / identification, and special coating) and is reviewed and approved by the QA Manager. The QA Manager approves the PRS (i.e., "traveler") which identifies sequential operational steps and establishes inspection and hold points for a controlled mar.ufacturing process.
The nuclear orders went to the following customers:
1982 - Niagara Mohawk (1) 1983 - Wisconsin Electric (WE) (10) 1984 - Carolina Power & Light (1)
- Da1ryland Power Cooperative (1)
- Alabama Power (1ron (CTI) (1) 1)
- Chicago Tube &
- Colt Industries (3)
- WE (7)
ORGANIZATION:
KILBOURN ENGINEERING COMPANY MILWAUKEE, WISCONSIN
~
REPORT INSPECTION NO. :
99901107/88-01 RESULTS:
PAGE 8 of 9 l
1985-ColtIndustries(2) 1)
1986 - Consumers Power (
- Detroit Edison (3)
- Dresser Manufacturing)(OM) (1)
- Hardware Specialty (1
- Comonwealth Edison (CE) (2)
- Cleveland Electric Illuminating (CEI) (2)
- WE (6) 1987 - Carrier Corporation (1)
- CTI (1)
- CEI (1)
- CE (1)
- Union Pump (1)
- Henry Pratt (1)
- WE (3) 1988 - Lonergan (3)
- DM (1)
- CTI (5)
- Henry Pratt (1)
- General Electric (1)
- Union Pump (2)
- Toledo Edison (6)
In the majority of cases, KE purchaseo material from qualified supplies / manufacturers such :is J. T. Ryerson, Central Steel and Wire, Copperweld, Hy-Alloy, Carpenter Technology, CyTemp Specialty Steel, Pressure Vessel-Nuclear Steels, HUB, and E. M. Jorgenson.
These vendors were either audited by KE or had a QSC (Materials) attesting to the fact that the material was supplied and manu-factured under a QA program which meet the requirements of sub-section NCA-3800 of Section 111 of the ASME Code.
When KE purchased "stock" material from a vendor, KE proceeded to upgrade the material in accorcance with subsection hCA-3867.4(e).
A chemical analysis and mechanical tests were performed on each piece of stock material.
SL and Anderson Laboratories performed the chemical and rechanical tests, respectively.
In two cases, it was noted that KE did not report on their CMTR chemical product analysis perforr.ed by SL in February 1986 and August 1987 (see Nonconformance 88 01-02).
This matter was discussed with the PM who stated that KE did not routinely report product analysis results on their C,MTRs.
ORGANIZATION:
KILBOURN ENGINEERING COMPANY MILWAUKEE, WISCONSIN
~
REPORT INSPECTION NO.:
99901107/88-01 RESULTS:
PAGE 9 of 9 F.
PERSONNEL CONTACTED:
- L. Beitzinger, President
- A. Makovec, Production Manager i
- Attended exit meeting l
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