ML20155E415

Notice of Nonconformance from Insp on 880801-05. Nonconformance Noted:Nuclear Raw Matl Stored in Hold Area W/Govt Level 1 Matl & Lack of Evidence That Spherical & Cylindrical Stds Used to Calibr Optical Compactor

ML20155E415
Person / Time
Issue date:	10/07/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20155E361	List: ML20155E356 ML20155E406 ML20155E415 ML20155E423
References
REF-QA-99901108 99901108-88-01, 99901108-88-1, NUDOCS 8810120278
Download: ML20155E415 (6)

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APPENDIX B B&G Manufacturing Company Docket No. 99901108/88-01 ,

NOTICE OF NONCONFORMANCE During the inspection conducted August 1 through 5, 1988, the implementation of a the QA program at the BGM facility in Hatfield, Pennsylvania was reviewed with respect to the manufacture of fasteners for nuclear fai:ilities. The applicable QA requirements are 10 CFR Part 50, Appendix B, and BGM's Quality Assurance Kanual (QAM), dated April 27, 1988. 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. Subsection NF-2610 (b) of Section III of the ASME Code states, in part, "The requirements of NCA-3867.4 shall be met as required by NF-2130."

Subsection NF-2130 (a) states, in part, "All material used in the con-  ;

struction of component supports shall be certified." ,

Subsection NCA-3867.4 (e) requires that a material manufacturer, who certifies material made from stock (i.e., produced by a manufacturer whose Quality System Program has not been qualified under NCA-3800)

upgrade the stock material by performing a chemical analysis and other testing to meet all the requirements of the specification.

Contrary to the above, BGM supplied stock material to Anchor Darling on P0s 25265 (October 30, 1987), 25099 (July 28, 1987), and 24923 (May 12, 1987) and stated on Certificate of Compliances (CofC) that the material met Section III (CofC, dated December 8, 1987), Section ill - Subsection NF-2610 (May 27, 1987), and Section 111 - Subsections NCA-3800 and NF-2610 (Aug.st 27, 1987) without performing the actions necessary to upgrade the material. (88-01-03) ,

i 2. Criterion Vill, "Identification and Control of Materials, Parts, and Components" of Appendix B to 10 CFR Part 50 requires that items be iden-tified to prevent the use of incorrect items.  ;

i Paragraph 16.1 of Specification SA-193 of Section 11 of the ASME Code I states, in part, "...the manufacturer's toentification mark shall be stamped on the top of the head of bolts...."

l Paragraph 11.1 of Specification SA-194 of Section 11 of the ASME Code 1 states, "All nuts shall bear the manufacturer's identification work."

BGM uses a "J" for their identification mark which is registered with ASME. I Contrary to the above, BGM acted as a material supplier on two Section 4

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111 (P0 ation orders to Anchor MC 101529, dated Darling Decemberand requested

29,1986)(a)LakeErieScrewCor stamp finished A193 Grade B-7 bolts with a "JB7" and (b) Nittetsu Shoji America (P0 AC 6377, dated 801os2o270

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t November 17,1986) stamp finished A194 Grade 2H nuts with a "J2H."

(88-01-04)

3. Criterion IV, "Procurement Document Control" of Appendix B to 10 CFR Part L 50 requires that procurement documents impose a QA program upon the vendor, j Subsection NCA-3866.3 of Section III of the ASME Code states, in part,  !

, "Documents for procurement of material and subcontracted services shall  ;

l. include requirements to... assure their compliance xith this Section*III." l Subsection NCA-4143.4 of Section III of the t.SME Code states, in part,  !

... procurement documents shall require suppliers to provide a Quality  !

Assurance Program consistent with...this Section." j Contrary to the above, the requirement for a vendor to have an approved  :

QA program was not stated on P0 Nos. 50858, 50916, 50247, 50042, 50498, i and 50220 to LT; and 50699 and 50700 to J. W. Rex. (88-01-05)  !

j 4 Criterion VI!!, "Identifkation and Control of Materials, Parts, and l Components" of Appendix B to 10 CFR Part 50 requires that material be l l identified and controlled to prevent the use of incorrect or defective t j material.  ;

i Paragraph 2.3.1 of Procedure QA!-122, "Rau Material for Nuclear Appli- l 4 cations," dated December 1, 1978, states, in part, "NUCLEAR raw material  ;

' shall be stored in a separate location completely segregated from other t j raw material."  !

Paragraph 3.7 of Section 015. "Material Control" of the QAM states, in y part, "Positive identification of all raw material will be apparent on j each piece... The color coding will appear on both ends of each bar " ,

} . t l Contrary to the above, it was noted that: (a) nuclear raw material was i stored in a hold area with U.S. Government Level I material, and (b) one t i piece of nuclear bar stock (heat No. 21901) was not identified with a  ;

color code. (88-01-06) i j

5. Criterion XII, "Control of Measuring and Test Equipment" of Appendix B l j to 10 CFR Part 50 requires that measuring and testing devices are properly ,

i controlled, calibrated, and adjusted at specified periods.  !

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Subsection NCA-3868 of Section !!! of the ASME Codo states, in part, l "Calibration shall be against measurement standards which have known

relationship to national standards..."

j Paragraph 3.6.1.1 of Section 007 of the QAM states, in part, "Reference 3 standards will be calibrated by a conynercial facility... Government Labora-I tory or the National Bureau of Standards."

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Paragraph 3.4.1 of Section 007 "Control of Measuring and Test Equipment" i of the QAM states, in part, "The prescribed calibration interval for each I

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item is as listed... Hardness Tester - 12 months.. 0ptical Comparator -

12 months...."

Contrary to the above, documented evidence was not available to show that >

(88-01-07):

(a) The heat treating furnace ("Electra") used for precipitation hardening of stainless steels and the 24-hour hardness tests was calibrated or under the controls of the calibration progran1._

(b) The spherical and cylindrical standards used to calibrate the optical  !

comparator prior to use were calibrated.

(c) The "Deltronic" optical comparator was calibrated by an approved i

vendor.

. (d) The hardness tester (S/N 218 currently assigned to the Newage hard-ness tester) was calibrated during 1985. 3

6. Criterion VII, "Control of Purchased Material, Equipment, and Services" of Appendix B to 10 CFR Part 50 requires that material and services be purchased from qualified vendors. t l Paragraph 3.4.1.1 of Section 008, "Purchasing Control" of the QAM states.

in part, "Quality Assurance will maintain a supplier's quality history consisting of the following... External Audit (Vendor Quality Survey)...."

! Paragraph 3.1.1 of Section 008 of the QAM states, in part, "An Approved  :

Vendor List is a list of vendors qualified to furnish material or service  !

for nuclear applications...." i

, t Paragraph 3.1.2.2.1 of Section 008 of the QAM states, in part, "Purchasing willplaceorderswithvendors[on)ApprovedVendorList(AVL)...."

l Contrary to the above, it was noted that: (88-01-08) .

(a) North Penn Polishing and Plating did chrome plating on PO 50214 l (July 7,1986), but they had never been audited by BGM nor were they  ;

on the AVL.

, (b) Page Wilson has calibrated two Wilson hardness testers since 1982, 4

but they were not on the AVL until April 1988.

(c) Professional Calibration (fonnerly Richardson) has calibrated the Tinius Olsen on on annual basis since June 1981, but they were not on the AVL until June 1988.

Criterion IX, "Control of bpecial Processes" of Appendix B to 10 CFR Part 7.

50 requires that special processes such as nondestructive testing be i controlled.

j Subsection NCA-3864.2 of Section !!! of the ASME Code requires that all

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nondestructive examination (NDE) personnel be qualified in accordance with Subsection NX-5521.

Paragraph 5521 cf Subsection NX requires that personnel performing NDE be qualified in accordance with SNT-TC-IA.

Section 9.6 of SNT-TC-IA states, in part "Personnel certificatione and copies of the employer's written practices shall be maintained on file...."

Section 9.6.1 of SNT-TC-IA states, in part, "The qualification records of the certified individuals shall be maintained by the employer and shouid include the following:...(4) statement indicating satisfactory completion of training in accordance with the employer's written procedure...(10) signature of employer's designated representative...."

Contrary to the above, it wi.s noted that: (88-01-09)

(a) BGM has not established a written practice covering all phases of certification of NDE personnel nor did BGM have a copy of the written practice for Laboratory Testing (LT) who provides Level III services.

(b) The qualification records of nine examiners from LT did not contain a statement that the individual had been trained in accordance with LT's written practice.

(c) The identification or signature of LT's Level !!! representative was not on file.

8. Criterion V, "Instructions, Procedures, and Drawings" of Appendix B to 10 CFR Part 50 requires that activities affecting Quality are prescribed by I documented instructions or procedures.

I Contrary to the above, instructions or procedures did not exist for: )

(a)tensileandprooftestingusingtheTiniusOlsentestequipment, '

(b) hardness measurements using the Wilson and Newage hardness test.

equipment, and (c) receipt and final inspections. (88-01-10)

9. Criterion !!, "Quality Assurance Program" of Appendix B to 10 CFR Part 50 requires that personnel performing activities affecting quality be indoc-trinated and trained.

Paragraph 3.2 of Section 024, "Indoctrination and Training" of the QAM states, in part "Each supervisor shall be indoctrinated into the require-ments of the QA program...by the Quality Assurance Manager."

Contrary to the above, the Panager of Nuclear Sales and the Foreman - 1 Sectior. !!! of Packaging / Hardness Testing were not indoctrinated and  ;

trainedintherequirementsoftheQAprogram(88-01-11). i

10. Criterion XVII, "Quality Assurance Records" of Appendix B to 10 CFR Part 50 requires that sufficient records be maintained to furnish evidence of i activities affecting quality, and the records should be identifiable and retrievable.

5-Paragraph 3.7.1 of Section 005, "Records," of the QSM states, in part, "All... documentation...will be maintained on file for a minimum of seven (7) years."

Paragraph 3.7.1.1 of Section 005 of the QSM states, in part, "All documen-tation (including applicable purshase orders...) Upon completion of the c 2 order the above documentation...will be attached to the shop oroers and maintained on file."

Contrary to the above, BGM was unable to provide a_PO to Page Wilson who calibrated two hardness testers (S/Ns 218 and 219) in April 1988, or PO 30674 (date and vendor unknown) for material (Heat No. 21901). (88-01-12)

11. Criterion XVII, "Quality Assurance Records" of Appendix B to 10 C/R Part  !

50 requires that inspection and test records identify the inspector. '

Contrary to the above, LT's CofC for magnetic particle (MT) and visual (VT) ,

examinations performed on nuclear orders did not identify the examiner /  :

inspector for lab repore. Nos. M-172. -286 -1261 -2546 -2633, and -4647; P-430. -974. -1010, and -4748; and T-4653. (88-01-13)

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SUBSECTION 223b 0F THE ATOMIC ENERGY j ACT OF 1954, AS AMENDE0 Any individual director, officer, or employee of a firm constructing.

. or suoplying the components of any utilization facility required to be licensed under Section 103 or 104 b. of this Act who by act or crission, e it. connection with such construction or supply, knowingly and willfully violates or causes to be violatad, any section of this Act, any rule, t egulation, or order issued thereunder, or any license condition, which violation results, or if undetected could have resulted, in a significant l impairment of a basic component of such a facility shall upon conviction, be subject to a fine of not more than $25,000 for each day of violation, or to imprisonw nt not to exceed two years, or both. If the convictich is for a violation corritted after a first conviction under this subsection, ,

punishmnt shall be a fine of not more than $50,000 per day of violation, j or imprisonment for not more than two years, or both. For the purposes of this subsection, the tem ' basic component' means a facility structure, syster, coeponent or part thereof necessary to assure--

(1) the integrity of the reactor coolant pressure boundary. '

(2) the capiti11ty to shut-down the facility and maintain it in a safe shut-down condition, or (3) the captbility to prevent or mitigate the consequences of j accidents which could result in an unplanned offsite release of Quantities of fission products in excess of the limits established by the Corrission.

The provisions of this subsection shall be procinently pcsted P. c:,ct. site where a utilization facility required to be licensed under Section 103 or 104 b of this Act is under construction and on the precises of each plant where components for such a facility are fabricated. .

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