ML20155E423
| ML20155E423 | |
| Person / Time | |
|---|---|
| Issue date: | 09/20/1988 |
| From: | Baker E, Conway J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20155E361 | List: |
| References | |
| REF-QA-99901108 99901108-88-01, 99901108-88-1, NUDOCS 8810120282 | |
| Download: ML20155E423 (13) | |
Text
. _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
i ORGANIZATION:
B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INLPECTION INSPECTION NO : 99901108/88-01 DATE: August 1-5, 1988 ON-SITE HOURS:
66 CORkt.SPONDENCE ADDRESS:
Kenneth Edmonds, General Manager B&G Manufacturing Company 3067 Unionville Pike Hatfield, Pennsylvania 19440 ORGANIZATIONAL CONTACT: James Sands, QA Manager TELEPHONE NUMBER:
(215) 822-1925 NUCLEAR INDUSTRY ACTIVITY:
Fasteners ASSIGNED INSPECTOR: hN. [l\\QJh_
[-/Y86 T. Conway, PrAgram Development and Reactive Date Inspection Seddion (PDRIS)
OTHER INSPECTOR:
T. Tinkle (consultant)
APPROVED BY:
6 CV i'DW E. T. Baker, Chief. PDRl'S, Vendor Inspection Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix B and 10 CFR Part 21.
B.
SCOPE:
The inspection was conducted to perform a programmatic evaluation of the implementation of B&G Manufacturing's (BGM) QA program at is relates to the fabrication of fasteners for nuclear facilities.
j 4
1 PLANT SITE APPLICABILITY:
Not identified.
8810120202 001007 01foy99EMV*
ORGANIZATION:
B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.:
99901108/88-01 RESULTS:
PAGE 2 of 12 A.
VIOLATIONS:
i 1
1.
Contrary to Section 21.31 of 10 CFR Part 21, a review of purchase orders (P0) to vendors :cvealed, that while 10 CFR Part 21 was imposed upon BGM, BC iid not impose 10 CFR Part 21 requirements on P0s 50858 (March 13, 1987), 50916 (March 30, 1987), 50667 (December 17, 1986), 50742 (January 20, 1987), 50695 (December 29, 1980), 50743 (January 20,1987),52055(February 16,1988),51100 (May 15, 1987), 51394 (September 10, 1987), 50728 (January 14,1987),
50064 (May 6, 1986), 50247 (July 21r 1986), 50090 (May 12, 1986),
50042 (April 29, 1986), 50498 (October 24, 1986), 50263 (July 23, 1986), 50570 (November 14, 1986), 50220 (July 7, 1986), and 50398 (September 19,1986) to Laboratory Testing (LT); 50699 (December 29, 1986), 50700 (December 29, 1986), and 51370 (August 25, 1987) to J.W.
Rex; 50214 (July 7, 1986) to North Penn Polishing and Plating; 52147 (March 3, 1988), 52688 (June 13, 1988), and 52270 (March 28, 1988) to Gage Laboratories; and 52614 (June 13, 1988) to Professional Calibration.
(88-01-01) 2.
Contrary to Section 21.6 of 10 CFR Part 21, an inspection of four posting areas indicated that the requirements 10 CFR Part 21 were not satisfied and furtherwore, Procedure No. QAl-125, dated December 1, 1978 or a notice was not posted in any of the locations.
(88-01-02) 1 B.
NONCONFORMANCES:
1.
Contrary to Subsections NF-2610, NF-2130, and NCA-3867 of Section !!!
of the ASME Code, BGM supplied stock material to Anchor Carling on l
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 111 (CofC, dated December 8, 1987), Section !!! - Sub-section NF-2610 (May 27, 1987) and Section !!! - Subsections NCA-3800 and NF-2610 (August 27,1987).
(88-01-03) 2.
Contrary to Criterion VI!! of Appendix B to 10 CFR Part 50, Paragraph 16.1 of Specification SA-193 and Paragraph 11.1 of Specification SA-194, BGM acted as a material supplier on two Section Ill orders to Ar.chor Darling and requested:
(a) Lake Erie Screw Corporation (P0 MC 101529, dated December 29,1986) stamp finished A193 Grade B-7 bolts with a "JB7" and (b) Nittetsu Shoji America (P0 AC 6377, dated November 17,1986) stamp finished A194 Grade 2H meets with "J2H."
(88-01-04) 3.
Contrary to Criterion IV of Appendix B to 10 CFR Part 50 and Subsections NCA-3866.3 and NCA-4134.4 of Section !!! of the ASME Code, the requite-ment for a vendor to have an approved QA program was not stated on PO
ORGAN 1ZAT10N:
B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.:
99901108/88-01 RESULTS:
PAGE 3 of 12 Nos. 50858, 50916, 50247, 50042, 50498, and 50220 to LT; and 50699 and 50700 to J.W. Rex.
(88-01-05) 4 Contrary to Criterion Vill of Appendix B to 10 CFR Part 50, paragraph 2.3.1 of Procedure QAl-122, and paragraph 3.7_of Section 015 of the QAM, it was noted that:
(a) nuclear raw material was stored in a hold area with U.S. Government level I material, and (b) one piece of nuclear bar stock (heat number 21901) was not identified with a color l
code.
(88-01-06) 5.
Contrary to Criterion XII of Appendix B to 10 CFR Part 50, Subsection NCA-3868 of Section !!! of the ASME Code, and Paragraphs 3.4.1 and 3.6.1..' of Section 007 of the QAM, documented evidence was not avail-able 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 program.
(b) The spherical and cylindrical standards used to calibrate the
[
optical com?arator prior to use were calibrated.
(c) The "Deltronic" optical comparator was calibrated by an approved vendor.
(d) The hardness tester (S/N 218 currently assigned to the Newage hardness tester) was calibrated during 1985.
1 l
G.
Contrary to Criterion Vil of Appendix B to 10 CFR Part 50 and Para-graphs 3.4.1.1, 3.1.1, and 3.1.2.2.1 of Section 008 of the QAM, it was noted that:
(88-01-08) l (a) North Penn Polishing and Plating did chrome plating on PO 50214 i
(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, but they were not on the AVL until April 1988.
(c) Professional Calibration (formerly Richardson) has calibrated the Tinius Olsen on an annual basis since June 1981, but they were not on the AVL until June 1988.
7.
Contrary to Criterion IX of Appendix B to 10 CFR Part 50, Subsections I
HCA-3864.2 and NX-5521 of Section !!! of the ASME Code and Sections 9.6 and 9.6.1 of SNT-TC-1A, it was noted that:
(88-01-09) 1 l
l 1
ORGANIZATION:
B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.:
99901108/88-01 RESULTS:
PAGE 4 of 12 (a) BGM had not established a written practice covering all phases of certification of HDE personnel nor did BGM have a copy of the written practico for Laboratory Testing (LT) who provides Level III services.
(b) ThequalificationrecordsofnineexaminirsfromLTdidnotcon-tain a statement that the individual had been trained in accordance with LT's written practice.
(c) The identification or signature of LT's Level III representatives was not on file.
8.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, instructions or procedures did not exist for:
(a) tensile and proof testing using the Tinius Olsen test equipment. (b) hardness measurements using the Wilson and Newage hardness test equipment, and (c) receipt and final irspections.
(88-01-10) 9.
Contrary to Criterion !! of Appendix B to 10 CFR Part 50 and Paragraph 3.2 of Section 024 of the QAM, the Manager of Nuclear Sales and the Foreman - Section 111 of Packaging / Hardness Testing were not indoc-trinated and trained in the requirements of the QA program.
(88-01-11) 10.
Contrary to Criterion XV11 of Appendix B to 10 CFR Part 50 and para-graphs 3.7.1 and 3.7.1.1 of Section 005 of the QAM, BGM was unable to provide a PO to Page Wilson who calibrated two hardness testers (S/Ns 218 and 219) in April 1988, or P0 30674 (date and vendor unknown) for material (heat No. 21901).
(88-01-12) 11.
Contrary to Criterion XVII of Appeadix B to 10 CFR Part 50, LT certi-fications for magnetic particle (MT) and visual (VT) examinations per-formed on nuclear orders did not identify the examiner / inspector for lab report Nos. M-172. -286 -1261 -2633, and -4647; P-430 -974,
-1010, and -4748; and T-4653.
(88-01-13)
I C.
UhRESOLVE0 ITEMS None D.
STATUS OF PREVIOUS FINDINGS None. This was the first inspection of this facility.
ORGANIZATION: B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901108/88-01 RESULTS:
PAGE 5 of 12 E.
OTHER FINDINGS AND COMMENTS 1.
BGM BGM has its roots in a business originally started shortly aft 6r World War II.
BGM developed and implemented a quality system to provide nuclear safety-related fasteners starting in December 1977.
Fasteners are produced under two systems. One system is used to process standard conn.ercial orders. The other system is documented by the QAM and written procedures, and it is used to produce nuclear safety-related orders, U.S. Government Level I orders, and other orders with special quality requirements. The forward of the QAM states that the QA pro-gram is designed to satisfy the requirements in specification MIL 45208A and the guidelines of Section III of the ASME Code.
Some testing and all heat treatment required for nuclear orders as well as calibration services are performed by vendors under the control of BGM's QA Program. Heat treating is perfomed by J.W. Rex, and Labora-tory Testing perfoms NDE which is primarily MT and VT.
Page Wilson, Gage Laboratory, and Professional Calibration calibrate several measuring and testing devices and/or equipment.
2.
Manufacturing Facility The manufacturing facility includes approximately three hundred machines to produce fasteners via cutting, machining, or forming from metal bars.
Equipment includes automatic threaders, screw machines, and bolt formers for production runs.
Threads are produced using any of the three different operations:
cutting, rolling, or single pointing.
Secondary operations such as grinding, drilling, slotting, and milling ar6 also performed.
Fastener material includes carbon /
alloy /stainlest, steels and nickel, copper, and aluminum alloys.
The fasteners are produced in a range from wire size to over four inch diameter.
During several visit. of the facility in the presence of QA department personnel, it was observed that a number of quality-related activities are perfortred without written procedures or instrMions. The activi-ties included receipt and final inspection and testing (proof load, tensile, and hardness).
(SeeNonconformance 88-01-10)
The nuclear raw material hold area was also inspected.
It was noted that both nuclear raw material and U.S. Government Level I material are stored behind the same fenced enclosure.
Level I material was found to be grouped in one geographic area, and the nuclear material was grouped in another geographic area.
The two geogra hic areas were
ORGANfZATION: B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVAHIA REPORT INSPECTION NO.: 99901108/88-01 RESULTS:
PAGE 6 of 12 adjocent to one another with no physical barrier between them. There were 12 different items identified with a nuclear tag. One piece of material (heat No. 21901) with a nuclear tag was found to be stored in the same area as the Level I material, and it was not marked with a color code.
(See Nonconformance 88-01-06}_
During one of the visits in the presence of a QA Technician, it was noted that four boxes of tagged festener parts were found on shelves outside the shop office.
These boxes were identified with yellow tags stamped nuclear.
The technician determined that none of the boxes con-tained material for a nuclear order.
The QA department initiated cor-rective action, and the boxes were retagged with other tags during the course of the inspection.
3.
Stock Material During the review of nuclear orders from 1981 to the present, it was noted that BGM supplied stock or uncertified material on three orders for Anchor Darling (AD) (See Nonconformance 88-01-03). A summary follows:
(a) On PO 25265 (October 30,1987), AD ordered 430 1/2-inch - 13 x 2-inch long SA-193 Grade B7 hex head cap screws to be processed and certified in accordance with ASME Section 111. Subsection NCA 3800 and BGM's quality program as qualified by AD on April 3, 1987.
It was noted that "NCA-3800" was marked out and "NF-2610" was writter, in the margin and initialed by "TB."
BGM's P0 MC 101529 (December 29,1986) was placed'with Lake Erie Screw Corporation (LESC) for seven different lengths of 1/2 - 13 bolts.
The quantities ranged from 7,500 to 12,500 for each item.
1 The P0 stated "Finished hex bolts, stamped J37, with 1/64-inch washer faced, ASTM A193 Grade B 7" (See Nonconfoimance 88-01-04).
The CMTR dated March 10, 1987 from LESC did not reference Section 111 of the ASME Code.
BGM's CofC da ced Decerber 8,1987 to AD certified that the material "complies in full with all purchase order and specification requirerents" including "ASME Section !!!,
1980 Edition, Sumner 1981 Addenda."
l (b) AD ordered 200 3/8-inch - 16 SA-194 Grade 2H nuts (100-hex and 100-hex jam) on PO 25099 (July 28.1987).
The material was to be pro-cessed and certified in accordance with ASME Code !!!, Subsection NCA-3800, BGM's quality program, and Subsection NF 2610. BGM i
ORGANIZATION: B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION N0.: 99301108/88-01 RESULTS:
PAGE 7 of 12 purchased 250 finished SA-194 Grade 2H nuts (125-hex and 125-hex jam) from Texas Bolt Company (TBC) on P0 AC 103255 (August 7, 1987).
TBC's CMTR, dated August 21, 1987, only referenced "ASTM A194 Grade 2H."
On a CofC dated August 27, 1 987, BGM certified that the material "complies in full with all purchase order and specification requirements" including "ASME Section 111, 1980 Edition, Sunner 1981 Adcenda, Subsection NCA-3800, Subsection hF-2610."
(c) Four items (20 3/4-inch - 10 and 201-inch - 8 SA194 Grdde 2H nuts; 28 3/4-inch - 10 x 7-inch long and 2 1 1/4-inch - 8 x 5 1/2-inch long SA-193 Grade B7 bolts) were ordered by AD on PO 24923 dated May 12, 1987.
The P0 referenced Section III, Subsections NCA-3800 and NF-2610, and BGM qualifica QA program.
Items 3 and 4 were purchased from TBC on P0 AC 102339 (May 19, 1987). The PO referenced bolts - ASTM A193 B7 and nuts - ASTM A194 Grade 2H -
both "connercial quality."
BGM's P0 AC 6377 (November 17,1986) was placed with Nittetsu Shoji America (NSA) for four items which ranged in quantities f rom 4,860 to 189,000.
For all the items the P0 stated "ASTM A194 2H Heavy Hex Nuts, stampec J2H" (see Nonconformance 88-01-04).
BGM's PO 6397 (January 13,1987) to Nedschroef Corporation (NC) was for three items which ranged in quantities from 81,000 to 207,900.
For all the items, the P0 stated "ASTM A194 Grads 2H heavy hex nuts stamped 'N2H'."
The CMTRs from TBC (May 15,1987),
NSA (January 24,1987) a Japanese company, and NC (March 11,1987) a Dutch company only referenced ASTM standards (i.e., st'ock i
material).
The CofC (May 27,1987) from BGM to AD certified to Subsection NF-2610 of Section 111 of the ASME Code for the i
finished nuts purchased from the foreign companies.
l It was noted that BGM had never audited LESC, TB, NSA, and NC, and the four vendors were not on BGM's. AVL.
l 4.
h0E The inspector was told by the QA Manager that BGM utilizes LT to provide Level !!! services.
With the exception of qualification I
4 records of certified individuals from LT, there was no documented evidence that LT was delegated the authority to provide these services.
In addition, BGM did not have a written practice for all phases of certification of NDE personnel nor have a copy of LT's written practice,
(See None.onformance 88-01-09)
ORGANIZATION: B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901108/88-01 RESULTS:
PAGE 8 of 12 The inspector reviewed the qualification records for nine exa;niners (one - Level III, seven - Level II, one - Level I) from LT. The docu-mentation included a Certificate of Examination Record which included the grades for the general, specific, and practical examinations and visual examination results and the instructor _and date. A copf of the latest vision test was a part of the results.
With the exception that the qualification records did not contain a statement that each examiner satisfactorily completed training in accordance with LT's written prac-tice, the records appear to satisfy the requirements of SNT-TC-1A.
LT's procedures for MT and VT used on nuclear orders for BGM were reviewed.
There was not documented evidence that BGM has approved HP-III-1 Revision 2. "Standard Magnetic Particle Examination Pro-cedure" and VT-III-1 Revision 0, "Visual Examination Procedure." LT certified the MT and VT inspections on a CofC. *he CofC gave a descrip-tion of the fasteners inspected, referenced Section III of the ASME Code and was signed by the President of LT. However, the CofC did not identify the examiner / inspector who performed the inspection.
(See Nonconformance 38-01-13) 5.
Calibration of Measuring and Test Equipment (M&TE)
The inspector reviewed Section 7. "Control of Measuring and Test Equipment" of the QAM and calibration records to assure M&TE is pro-perly controlled and calibrated.
The following M&TE (with S/N) were 1
inspected for calibration status:
Deltronic Optical Cocparator (P) two Jo Blocks (1154000/1154003), two pitch micrometer standards (1154014/1154015), onethreadwirestandard(1154023), three plug gages (P26A/P199/P202A), two ring gages (P5312-Hi/Lo), two thread com-parator (C-350-C-1094/48038C). Tinius Olsen (202), heat treat furnace l
(not identified), Wilson hardness tester (219), and Newage hardness tester (218). The two pitch micrometer standards were calibrated in July 1987, and the remaining items were calibrated from April 1988 through July 1988.
BGM's Chief Test Inspector indicated that the Deitronic Optical Con-parator was installed and calibrated by the manufacturers during the j
past few months. A review of PO 2400 (February 26, 1988) for the equipment and the applicable AVL showed that the manufacturer was not an approved calibration service vendor.
The Chief Test Inspector also stated that the heat treat furnace is not covered by the calibration program (See Nonconformance 88-01-07).
This furnace is used for con-ducting the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hardness-tests as well as heat treating certain types of precipitation hardening stainless steels.
I
ORGANIZATION: B&G MANUFACTU3ING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901108/88-01 RESULTS:
PAGE 9 of 12 Three calibration control cards for the Wilson hardness tester (S/N 219), hardness tester (S/N 218), and Tinius 01:en tester (S/N 202) were reviewed.
It was noted that Page Wilson (PW) has cali-brated tester No. 219 since 1985 on an annual basis, and Richardson has calibrated tester No. 202 since 1981 on an_ annual basis, but neither vendor was on the AVL until 1988. There was not documented evidence to show that tester No. 218 was calibrated in 1985.
(See Nonconformance 88-01-08)
Certificates for the last calibration of five M&TE were reviewed. They included tester hos. 218 and 219 (calibrated by PW), tester No. 202 (calibrated by Professional Calibration (PC)), and plug gages, Jo Blocks, and wire standard (calibrated by Gage Laboratories). The reference standards were traceable to the National Bureau of Standards.
6.
Documentation Packages (0P)
The inspector reviewed approximately 155 DPs for safety-related orders.
A DP normally consisted of the customer's Request for Quotation, P0, drawings, and specific order requirements. BGM documents included price quotation, CMTR, CofC, PCs to vendors of material and services, Job Pro-gress Report (i.e., "traveler), instruction and Inspection Check Sheet, material tags and labor only procedures, shipping and receiving proce-dures for outside services, Gage Check Sheet, shipping procedure, thop order, Shop Operation and Time Sheet, and shipping papers. Vendor documents consisted of CofC, CMTR, and heat treat charts. A breakdown of the safety-related orders is as follows:
27 to 8 customers in 1981, 28 to 12 customers in 1982, 37 to 9 customers in 1983, 8 to 4 customers in 1984, 25 to 5 customers in 1985, 18 to 7 customers in 1986, 11 to 4 cuttomers in 1987, and one in 1988.
The customer P0s referenced a material specification (e.g., SA'-193) from Section !!, Section 111 Class 1, 2, or 3, and 10 CFR Part 21.
For the majority of the orders, BGM purchased certified bar stock from suppliers / manufacturers who had a QSC (Materials) or had been audited by BGH as having a QA program meeting the requirements of Subsection NCA 3800 of Section !!! of the ASME Code.
The bar stock was subsequently fabricated into finished fasteners.
Although the QA Manager stated that BGM had not recently upgraded any stock material in accordance with the requirements of Subsection NRC-3867.4 of Section 11! of the ASME Code, it was noted on one order from Brooks Instrement Division (P0190101, dated August 19,1982),
that BGM ordered commercial material from Carpenter Technology)and cet-tified the material for nuclear use by having J.W. Rex (Rex l
i
.a
ORGANIZATION: B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901108/88-01 RESULTS:
PAGE 10 of 12 perform mechanical testing and Henry Saither Laboratory conduct chemical analysis.
On some orders, BGM supplied finished fasteners obtained from other suppliers / manufacturers.
In a number of instances, the finishtd fasteners were purchased from a foreign manufacturer.
For Anchor i
Darling PO 24923 (May 12, 1987), BGM supplied finished nuts purchased from Nittetsu Shoji America and Nedschrc2f Corporation.
It was noted that BGM purchased finished nuts from Power and Engineered Products (PEPCO) who had a QSC (Materials).
PEPCO obtained the finished nuts from Joh Smit, a manufacturer located in Holland.
Finished nuts from Joh Smit were supplied by BGM on orders to Accurate Fasteners (P0 60605, dated November 12,1985), Masoneilan (P0s 42/80487, dated September 23, 1985 and July 26,1985), Chem Pump (P0s 82882/83708, dated February 14, 1985 and June 18,1985), and J.L. Morcio (P0 1161, dated May 27,1985).
7.
Control of Purchased Material and Services The inspector reviewed Section 8. "Purchasing Control" of the QAM and various records to assure that material and services were pur-chased from qualified vendors.
Fifteen external audits covering a time period from October 1984 to February 1988 were reviewed.
Each i
audit has a checklist and was conducted by one of four individuals.
The audit results were documented on QAl-101, "External Audits Vendor Quality Survey Repcrt." The following vendors were audited:
Rex -
heating treating, Gage Laboratory - calibration Carpenter Technology -
material, LT - testing, and E.M. Jorgensen (Philadelphia) - material.
BGP has not perfortred external audits of PW and PC (formally Richardson) since their calibration activities (hardness testers and Tinius Olsen te,.er) were accomplished at the BGM facility. Qualification records for the four individuals were on file, and the records for the QA Manager and a QA Technician appeared to meet the requirements of ANSI MS.2.23.
TheinspectorreviewedtwovenadrQAManuals. Ins dncuments were Gage Laboratory's "QA Manual," dated March 15, 1985 and LY's ' Quality System Program Manual " dated February 2, 1987. BGM did not have a copy of
]
the CA Manual for Rex, Carpenter Technology, anr' E.M. Jorgensen (Philadelphia).
BGM had on file a copy of the QSC (Materials) for five vendors - PEPC0 (No. 399 expired February 25,1983). E.M. Jorgensen (California) (No. 278 expires April 15,1989), Energy Steel and Supply j
(No. 511 expired October 17.-1989), Coulter Steel and Forge (No. 219
)
expires August 4, 1987), and Copperveld Steel (No. 348 expired October 20,1987).
=
ORGANIZATION: B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION i
N0.:
99901108/88-01 RESULTS:
PAGE 11 of 12 Thirteen AVLs from 1984 to the p) resent were reviewed, and nine vendors (three-material and six-service associated with nuclear orders were on an AVL at one time or another.
It was noted that North Penn Polish-inq and Plating (NPPP) did chrome plating in July 1986, but they were nc.. on the AVL.
In addition, PW and PC have performed calibration detivities since 1982 and 1981, respectively, but neither vendor was on the AVL until April 1988 and June 1988.
(See Nonconfomance 88-01-08)
Procurement documents to seven vendors were selected to detemine if technical and quality requirements were included in P0s. All the P0s contained cppropriate quality requirements (e.g., Sections 11 and III of the ASME Code), but six P0s to LT and two P0s to Rex did not have quality requirements (e.g., werk to be performed under a QA program approved by BGM) (See Nonconformance 88-01-05).
In addition, 27 P0s(19-LT, three Rex, one-NPPP, three-Gage Laboratory, and one-PL) did not contain 10 CFR Part 21 requirements (see Violation 88-01-01).
BGM was unable to retrieve two P0s - one for calibration services and one for material (See Nonconformance 88-01-12).
8.
Indoctrination and Training The inspector reviewed training records for approximately 14 individuals.
Training entries ranged from October 1982 for three persons in the QA department through May 1988 for four other persons in the QA department.
The record review pertained to the President, three inspectors, one foreman, one purchasing supervisor, and eight persons from the QA department. BGM could not provide training records for two individuals who are engaged in quality-related activities (See Nonconformance 88-01-11) 9.
10 CFR Part 21 The inspection reviewed procedure QAl-125, dettd June 1, 1981 for implementing 10 CFR Part 21 requirements.
The procedure addresses actions to be taken by BGM in the event a subvendor provides a notice 1
concerning a defect in a safety-related item. The procedure does not address actions to be taken by BGM in the event a defect is identified as a result of activities by BGM.
Compliance with posting requirements was also evaluated. Documents were found posted in four different locations. A sumary of the postings follows:
(a) Three copies of 10 CFR Part 21 (dated March 31, 1987, January 10, 1983, and September 6, 1983) were posted on the wall outside the i
shop office.
ORGANIZATION:
B&G MANUFACTURING COMPANY HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901108/88-01 RESULTS:
PAGE 12 of 12 (b) A copy of Section 206 was posted on the wall outside the restroom.
(c) Two copies of 10 CFR Part 21 (dated January 10, 1983, and September 6, 1983) were posted on the wall outside the Section 5 foreman's office.
(d) Two copies of 10 CFR Part 21 (dated January 10, 1983 and September 6, 1983) were posted on the wall in the lobby.
The four postings were not in compliance with the requirements of 10 CFR Part 21 (See Violation 88-01-02).
A review of numerous BGM P0s to venoors of nuclear material and services revealed that BGH did not invoke the requirements of 10 CFR Part 21 1.. the subject P0s(See Violation 88-01-01).
It should be noted that IE Information Notice 87-15, dated March 25, 1987, reminded licensees and vendors that Subsection 223b of the Atomic Energy Act of 1954 as amended is also required to be posted. A copy of the Subsection 223b is enclosed.
F.
PERSONNEL CONTACTED:
- R. Edmonds, President J. Sands, QA Manager
- M. Parker, QA Technician
- E. Deeny, QA Technician E. Ziemons, Chief Inspector
- K Edmonds, General Manager
- Attended exit meeting
SUBSECTION 223b 0F THE ATOMIC [NERGY ACT OF 1954. A5 AMENDED Any individual director, officer, or employee of a fire constrvcting, or supplying the components of any utilization fact?lty neuired to be licensed under Section 103 or 104 b. of this Act who by act or omission, a
it connection with such construction or supply, knowingly and willfull,*
violates or causes to be violated, any section of this Act, any rule, regulation, 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 o'such a facility shall, upon conviction, be subject to a fine of not more than $25,000 for each day of violation, or to imprisonrrent not to exceed two years, or both. If the conviction is for a violation corritted af ter a first conviction under this subsection, punishment shall be a fine of not more than $50,000 per day of violation, or imprisonment for not more than two years, or both. For the purposes of this subsection, the tem ' basic component' means a facility structure, system, cceponent or part thereof necessary to assure..
(1) the integrity of the reactor coolant pressure boundary, I'
(2) the capitility to shut down the f acility and maintain it in a safe shut-down condition, or (3) the captbility to prevent or r.itigate the consequences of 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 prorinently posted at each site where a utilization facility required to be licensed under section 103 or 104 b. of this Act is under construction and on the prerises of each plant where corponents for such a facility are fabr*. ted.
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