ML20196C218
| ML20196C218 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20196C207 | List: |
| References | |
| REF-QA-99901307 99901307-98-01, 99901307-98-1, NUDOCS 9812020011 | |
| Download: ML20196C218 (12) | |
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I U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF IJUCLEAR REACTOR REGULATION Report No:
99901307/98-01 Organization:
ACCUTECH
Contact:
Steve Gauthier, Quality Assurance Manager (702)739-1966 Nuclear Activity:
Manufactures and supplies safety-related fasteners to NRC Licensees Dates:
October 26-29,1998 Inspectors:
- Bill Rogers, Lead Inspector, HOMB Richard McIntyre, HOMB Donald Naujock, EMCB i
Approved by:
Richard Correia, Chief j
Reliability and Maintenance Section Quality Assurance, Vendor inspection and Maintenance Branch l
Division of Reactor Controls and Human Factors 9812020011 981125 PDR GA999 EMV*****
Enclosure 99901307 PDR i
1 INSPECTION
SUMMARY
On October 26-29,1998, the U.S. Nuclear Regulatory Commission (NRC) performed an inspection at the ACCUTECH facility in Las Vegas, Nevada. The inspection was conducted to review selected portions of ACCUTECH's quality assurance (QA) program, and its implementation, and the applicable programs and procedures used to supply safety-related fasteners to NRC licensees. Specifically, the inspectors reviewed activities related to the corrective actions taken in response to violations (NOVs) and nonconformances (NONs) issued in previous inspections and the processes, procedures, and implementing activities associated with the heat treatments performed in the oven installed in October 1996. The inspectors noted that ACCUTECH had been sold by its previous owner, B&G Manufacturing Co. Inc.,
to Heartland Precision Fasteners Inc., in September 1998.
The inspection bases were:
10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."
10 CFR Part 21, " Reporting of Defects and Noncompliance."
2 STATUS OF PREVIOUS INSPECTION FINDINGS Violation 99901307/96-01-01 (Closed.)
Contrary to the requirements of 10 CFR Part 21 (Part 21), ACCUTECH hmJ determined that heat treatment lot TS7 contained defective fasteners but had not notified the NRC within two days or provided written notification within thirty days.
ACCUTECH had tested material from lot TS7, had determined that lot TS7 contained defective material, ar,d had documented this conclusion on ACCUTECH Form 17.002, " Reporting Defects and Noncompliance 10 CFR Part 21," which had been approved by the Branch Manager on March 28,1996. However, ACCUTECH had not notified the NRC by telephone or telefax and ACCUTECH had not provided the written Part 21 notification to the NRC until May 8,1996.
As corrective action, ACCUTECH had initiated Corrective Action Report (CAR)97-004 which required that training be performed on the reporting requirements of 10 CFR Part 21. The inspectors reviewed the training session records and current Part 21 activities and concluded that ACCUTECH's corrective actions had been adequate and closed Violation 99901307/96-01-01.
Violation 99901307/96-01-02 (Closed)
Contrary to the requirements of 10 CFR Part 21, ACCUTECH had not adequately evaluated the material in lots TS7 and K7 to determine if there were other potentially 2
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defective lots and whether additional evaluations were required, and had not adequately evaluated available information related to the heat treatment of lot K7 to identify the existence of an additional potentially defective lot (M2)
As corrective action, ACCUTECH had initiated CARS97-002 and 97-005 which required ACCUTECH to provide a Part 21 notification to the NRC for lot M2 and that training be performed on the requirements of 10 CFR Part 21 and SOP 17.002. The inspectors reviewed the training session records, the current Part '21 activities, and the March 10,1997, Part 21 notification to the NRC for lot M2.
The inspectors determined that ACCUTECH's corrective actions had been adequate and concluded that Violation 99901307/96-01-02 was closed.
Nonconformance 99901076/94-01-03 (Closed)
Nonconformance 99901076/94-01-03 was originally issued during a 1994 NRC inspection at Cardinal Industrial Products Corporation (CIPC). The corrective actions were reviewed by the inspectors during the November 1996 inspection at ACCUTECH (CIPC was renamed ACCUTECH following a change of ownership).
The nonconformance remained open following the November 1996 ACCUTECH inspection and required an additional response from ACCUTECH to address the crigina! concerns of Nonconformance 99901076/94-01-03 as described below.
Contrary to the requirements of Criterion Vil, " Control of Purchased Material, Equipment and Services," of 10 CFR 50, Appendix B, CIPC/ACCUTECH had not established a documented basis to substantiate that its destructive testing sampling plan for verifying critical characteristics provided reasonable assurance that dedicated commercial grade items met the applicable procurement document requirements.
The May 2,1997, ACCUTECH response had not addressed the sampling rationale provided by CIPC in 1994 -1995 correspondence to the NRC, but instead presented the "ACCUTECH Sample Plan Methodology" (ASPM) document for NRC review and acceptance. The response further stated that the ASPM generally inet or exceeded the sampling plan confidence level described in the NRC's draft technical report,
" Sampling Plans for Dedicating Simple Metallic Commercial Grade items at Nuclear Power Plants," dated February 1997.
In a December 18,1997, NRC response to the May 2,1997, ACCUTECH letter, the NRC staff stated that it had no; performed a technical and acceptance review of the ASPM document. However, the response provided comments on the portions of the ASPM document which had addressed the February 1997 NRC technical report. The December NRC response also stated that further information on the subject of sampling was contained in Draft Regulatory Guide DG-1070, " Sampling Plans Used for Dedicating Simple Metallic Commercial Grade items for Use in Nuclear Power Plants," dated September 1997. DG-1070 was an update to the February 1997 document and was available for public comment until January 30,1998.
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During the current inspection, ACCUTECH indicated that the ACCUTECH ASPM document had been superseded by SOP 7.002, "The Statistical Basis Used for ACCUTECH's Sampling Plans," Revision 1, dated April 20,1998, and SOP 12.001,
" Sampling Plans for Material Verification," Revision 10, dated September 29,1998.
SOP 7.002 described the statistical basis that supported ACCUTECH's sampling plans for nondestructive dimensional control. SOP 12.001, provided the destructive testing sampling plans for chemical and mechanical conformance to the material specifications. The primary basis for the destructive sampling plans was contained in ASTM F 1470, " Fastener Sampling for Specified Mechanical Properties and Perforrnance inspections." SOP 7.002 stated that the combination of both the nondestructive and destructive sampling plans provided the statistical basis for ACCUTECH's overall sampling plans which were stated to provide at least a 95 percent confidence level that 95 percent of the parts would be in compliance.
The inspectors also noted that the NRC was evaluating comments received on DG-1070 and had not issued any additional information or guidance on this sampling issue. In addition, EPRI Report NP-7218, " Utilization of Sampling Plans for CGI Acceptance," was currently being revised to address sampling sizes for destructive testing, consideration of safety function and safety significance when selecting a sample size, and lot homogeneity considerations. Until subsequent industry information on sampling or DG-1070 is issued as a Regulatory Guide, HOMB will not comment on specific vendor sampling plans for compliance to DG-1070 unless there are indications that inadequate material is being provided using the vendors sampling plans.
The inspectors determined that ACCUTECH's corrective actions had been adequate and concluded that Nonconformance 99901076/94-01-03 was closed.
Nonconformance 99901307/96-01-03 (Closed)
Contrary to the requirements of ASME NCA-3862.1(b) and NCA-3855.3 (b),
ACCUTECH provided Certified Material Test Reports (CMTRs) for ASME code material supplied to NRC licensees, but did not reference or include the mill heat analysis as an identified attachment.
The inspectors determined that since January 31,1997, ACCUTECH had been furnishing subcontracted supplier's mill certifications as an identified attachment to the CMTR as required by SOP 6.001, " Control Of Certifications," Revision 1, dated October 21,1998, and that ACCUTECH had only been supplying products with records which were complete and retrievable. In addition, all CIPC material which had remained in the ACCUTECH warehouse had been scrapped in October 1998 (following ACCUTECH's purchase by Heartland Precision Fasteners, Inc in September 1998). The inspectors determined that ACCUTECH's corrective actions had been adequate and concluded that Nonconformance 99901307/96-01-03 was closed.
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Nonconformance 99901307/96-01-04 (Closed)
Contrary to the requirements of Caterion Vil, " Control of Purchased Material, Equipment and Services," of 10 CFR 50, Appendix B, and Section 6.1, " Control of Certifications," of ACCUTECH's Quality Systems Manual (QSM) Second Edition, Revision 0, dated November 29,1998, ACCUTECH's QA Department had not provided adequate verification that material supplied to NRC licensees complied with the licensees' purchase order requirements. Specifically, ACCUTECH had not been able to demonstrate that suppliers of material had been surveyed and audited to verify their conformance with the above Appendix B requirements.
Since ACCUTECH had performed only limited physical testing of the material, and the sampling plan used for testing the material did not have a documented basis to demonstrate that the material supplied under the purchase orders (POs) was equivalent to material purchased from suppliers qualified under Appendix B requirements, ACCUTECH had performed additional testing to the material remaining in inventory from which the applicable PO items in question had been produced. The inspectors reviewed the results of the additional testing and the documentation that was sent to PECO and Wisconsin Electric describing this additional testing.
ACCUTECH also indicated that since January 31,1997, ACCUTECH had only been supplying products with records which were complete and retrievable and, in addition, the CIPC material that had remained in the ACCUTECH warehouse had been scrapped in October 1998. The inspectors determined that ACCUTECH's corrective actions had been adequate and concluded that Nonconformance 99901307/96-01-04 was closed.
Nonconformance 99901307/96-01-05 (Closed)
Contrary to the requirements of Criterion XVI, " Corrective Action," of 10 CFR 50, Appendix B, and SOP 17.001, " Corrective Action," Revision 5, dated November 15, 1995, CIPC had failed to identify two nonconformances described in NRC Inspection Report 99901076/94-01 as conditions adverse to quality and to process these nonconformances as CARS in accordance with the corrective action process.
The inspectors verified that SOP 17.001 required the QA Manager to process all issues identified as conditions adverse to quality as part of the corrective action process and to initiate CARS when required. In addition, the inspectors determined that ACCUTECH had appropriately implemented this requirement by identifying the violations and nonconformances described in Inspection Report 99901307/96-01 as conditions adverse to quality and processed them as CARS in accordance with the corrective action process. The inspectors determined that ACCUTECH's corrective actions had been adequate and concluded that Nonconformance 99901307/96-01-05 was closed.
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Nonconformance 99901307/96-01-06 (Close_qij Contrary to the requirements of Criterion V, " Instructions, Procedures, and Drawings,"
of 10 CFR 50, Appendix B, ACCUTECH QSM, Revision 0," Interface Activities for Material and Associated Documentation Which Has Not Been Legally Transferred From CardinalIndustrial Products Corporation (CIPC) to ACCUTECH," and SOP 22.001, " Transference of Material and Associated Document Between CIPC and ACCUTECH," Revision 2, dated November 15,1995, no documentation existed to verify that ACCUTECH had implemented SOP 22.001 since July of 1995 and to ensure that CIPC material and documents had been properly reviewed.
The inspectors determined that SOP 22.002, " Stock / Inventory Documentation Review Prior to Use," Revision 0, had been issued in March 1997 to ensure that all stock material and documentation for CIPC warehoused inventory was properly reviewed and approved by December 31,1997, that this review had subsequently been completed, and that the CIPC inventory had been segregated in a separate ACCUTECH warehouse. In addition, the inspectors also determined that CIPC inventory in ACCUTECH possession had been scrapped in October 1998 as documented on Nonconformance Reports 14099 and 14557. The in.spectors noted that SOP 22.002 was no longer an active procedure since all warehoused inventory reviews had been completed and the CIPC inventory had been scrapped. The inspectors determined that ACCUTECH's corrective actions had been adequate and concluded that Nonconformance 99901307/96-01-06 was closed.
Nonconformance 99901307/96-01-07 (Closed)
Contrary to the requirements of Criterion Vil, " Procedures," of 10 CFR 50, Appendix B, and ACCUTECH SOP 17.002 " Reporting of Defects and Noncompliance," Revision 6, dated November 15,1995, ACCUTECH had not documented the Part 21 evaluation of lot K7 on Form CF 17.002.
As corrective action, ACCUTECH had initiated Corrective Action Report (CAR)97-010 which required that training be performed on the reporting requirements of 10 CFR Part 21 and the use of ACCUTECH Form 17.002. The inspectors reviewed the training sessions records and current Part 21 activities and concluded that ACCUTECH's corrective actions were adequate and concluded that Nonconformance 99901307/96-01-07 was closed.
3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Heat Treatment Processes. Procedures and imolementatior.1 a.
Insoection Scoce During this inspection, the NRC inspectors reviewed celected furnace procedures and heat treatment documents and observed a furnace demonstration. The inspection 6
scope included ACCUTECH's Reheat Furnace No. 4 (RF4), which had started i
operation in October 1996.
b.
Observations and Findinos RF4 Furnace Descriotion ACCUTECH personnel described the RF4 as a double chamber heat and quench vacuum furnace manufactured by C.l. Hayes inc, Type VSQ. The front chamber contained an oil quench tank and the back chamber an insulated heating box with three top and three bottom heating elements. The chambers were connected with rails that supported a removable 45" wide by 38"long charge table. When loaded, the operator manually pushed the charge table into the heating box and after heat treating the table automatically withdrew to a position above the quench tank. The operator could automatically or manually release the load from the table into the quench tank.
The temperature in the heating box was monitored by three thermocouples (TC). The furnace TC (FCE TC) was a calibrated type S thermocouple connected to a calibrated Honeywell DCP 700 programmable temperature controller that controls the temperature inside the heating box. The FCE TC was located in the conter of one side of the box and extends several inches into the heating volume. Two inches above the FCE TC was an over temperature Type S thermocouple (OT TC) connected to a calibrated Honeywell DL200H. The DL200H controller automatically shut off power to the heating elements when the temperature in the box reached a predetermined set point. The temperature in the furnace load was monitored with a calibrated type K thermocouple (Load TC) placed in the coldest location within the load. The inspector noted that during operation the Load TC temperature would lag the FCE TC temperature, and that the FCE TC temperature would be less than the OT TC temperature. Both Load TC and FCE TC temperatures were recorded on a calibrated Honeywell DPR3000, strip chart recorder, j
ACCUTECH personnelindicated that the vacuum pump was capable of lowering furnace pressure,tc a range of 60 to 200 microns. The furnace vacuum was monitored with a Televac il vacuum controller which would automatically dicconnect i
power to the heating elements whenever the furnace vacuum exceeds 650 microns.
The function of the vacuum was to impede convection heat transfer and to minimize i
scale formation on heat treated parts. Heat transfer between the chambers must be i
controlled to minimizing thermal effects on the oil in the quench tank. The operator stated that if the door on the heating box was left ajar during the heating cycle,
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radiant heat escaping from the box would raise the oil's surface temperature which, in turn, would increase oil vapor pressure above the 650 micron shut off set point.
Control of the Heat Treat Process The inspectors reviewed ACCUTECH's heat treatment procedures, SOP 18.001,
" Standard Operating Procedure for Operation of the Vacuum Furnace," Revision 9, 7
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dated March 6,1998, and SOP 18.002, " Heat Treatment Equipment Calibration and Survey," Revision 7, dated March 6,1998, and selected process sheets. SOP 18.001 provided instructions to the operator on the type of information required for various furnace documents, the sampling for go-no go hardness tests, and general operation instructions. SOP 18.001 referenced other sources for more specific instructions, such as SOP 18.002 for calibrations and specification specific process sheets that provided soak time, coak temperature, and change in temperature requirements for different materials and part sizes. SOP 18.001 and associated referenced documents did not provide instructions for load distribution and charge weight.
SOP 18.002 provided instructions for verifying the accuracy of equipment used for controlling and recording furnace temperatures and for profiling temperature distribution inside the heating box. The inspectors reviewed the surveys ACCUTECH had used to profile furnace temperature distribution at various soak temperatures.
These surveys measured soak temperatures at nine locations inside the heating box under simulated operating conditions. ACCUTECH had defined simulated operating conditions as using two baskets, one on top of the other, with each basket containing approximately 225 pounds of four inch long tubes stacked two inches deep. The last set of surveys had been performed on May 7,1998, at soak temperatures of 800 F, 1000 F,1400'F, and 1900 F. These surveys showed a maximum temperature difference of 28'F at a soak temperature of 800 F and 20 F at a soak temperature of 1900 F. The 800'F and 1900*F surveys identified the coldest spot in the heating box as being in the lower back, thermocouple side of the box. The cold spots at 800*F and 1900'F were 793*F and 1895*F, respectively.
ACCUTECH personnel informed the inspectors that production loads processed through RF4 are processed with load weights and distributions similar to those used for the surveys. For example, if the operator estimated that the load weight for two baskets would exceed approximately 450 pounds, the operator splits the load into two lighter loads and added filler material to each basket until the load weight was approximately 450 pounds for each load.
Heat Treat Demonstration The inspectors observed a furnace demonstration on age hardening of four 2.0"-
BUNC heavy hex nuts made from ASME SB647 718 material that were being processed under Work Order (WO)100284. The furnace operator followed SOP 18.001 for general furnace operations and testings and specification specific
" Process Sheet AA" for heating parameters. The operator filled the charge baskets with filler material to simulate the load weight and distributions usd in the May 7,1998, furnace surveys. The four nuts and Load TC were placed in the lower basket at the same location that coincided with the cold spot in the heating box. The baskets were stacked two high on the charge table and pushed into the heating box.
After closing the heating box door and checking it for tightness, the furnace door was closed and vacuum initiated. While the furnace vacuumized, the operator entered heating parameters into the fumace controllers and completed the logs and documents required by SOP 18.001. The heating parameters consisted of an eight 8
hour soak at 1325*F followed by an 87.5*F per hour cool-down for two hours and soaked for an additional eight hours at 1150*F followed by a nitrogen gas cool-down to below 150 F. The operator removed the nuts from the furnace and performed go-no go hardness tests which were acceptable (44Rc).
Heat Treatment Documentation The inspector reviewed heat treatment documentation from fifteen work orders that had been processed through RF4. On five work orders, the inspector noticed that the Load TC temperatures exceeded the FCE TC soak temperatures by 5 F,10*F, 25*F,35 F, and approximately 100"F. ACCUTECH had issued Nonconformance 14339 when the Load TC was approximately 100 F above the FCE TC soak temperature. Neither SOP 18.001 or the specification specific process sheets provided guidance on this anomaly and ACCUTECH depended upon the operator's knowledge to identify nonconformances based on high Load TC temperatures.
Although no unacceptable material was identified, the inspector informed ACCUTECH's personnel that the Load TC temperatures, which exceeded the FCE TC temperatures, were near the load material's transition temperature which could produce rejectable material in the load. The inspector also determined that seven of fifteen work orders had their loads split at RF4 (for weight and distribution) which was in agreement with ACCUTECH's statement that charge load weights and distributions are maintained in a similar configuration to those used during the calibration surveys in SOP 18.002.
c.
Conclusion The inspectors noted that although an anomaly had occurred during subcritical anneal and temper soak temperatures, no unacceptable material had been identified.
The inspectors concluded that the implementation of furnace procedures and furnace operator skill appeared to produce satisfactory products with RF4.
3.1 Review of Wisconsin Electric May 4-8.1998. Audit (for NUPIC members) of ACCUTECH a.
Insoection scoog The inspectors reviewed the May 4-8,1998, Wisconsin Electric joint utility Audit Report 98-019 (Nuclear Utility Procurement issues Committee audit (NUPlC)) of ACCUTECH to assess ACCUTECH's corrective actions process.
b.
Observations and Findinas As part of the audit, the NUPIC team had reviewed ACCUTECH's corrective actions related to the past NRC inspection report findings and verified that corrective actions had been taken for all NRC findings. As a follow up to past dedication issues at ACCUTECH, commercial grade dedication sampling was reviewed. The NUPIC audit report concluded that the ACCUTECH sampling plan for dimensionalinspection of suppliers which were not on the approved vendor list (AVL) compared favorably with 9
l NRC draft Regulatory Guide DG-1070. It further stated that the plan was designed to ultimately obtain the 95/5 confidence level referenced in DG-1070 and in some cases the sample size was greater than required by DG-1070 while in other cases, less l
items were sampled. The audit report stated that this appeared to be a result of the l
ACCUTECH sampling p1 ds lower number of rejects allowed while still accepting the lot.
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l The audit report also stated that the sampling plan for m Arial and physical testing was less conservative than DG-1070 and takes credit for V,sual and dimensional inspections for ascertaining lot homogeneity. The testing sample size was based on the requirements of ASTM F1470 and if a more conservative approach was desired, additional testing at the customer's facility may be needed. The NRC inspectors did i
not see any procedural indication that ACCUTECH was still relying on visual and l
dimensional inspections for ascertaining lot homogeneity as stated in the Wisconsin l
Electric audit report and ACCUTECH confirmed that this was not the case. Finally, the audit report correctly described that latest correspondence between the NRC and ACCUTECH concerning the ACCUTECH sampling plan basis and identified the NRC comments with respect to the DG-1070 document and the ACCUTECH sample plan methodology.
In addition, the NUPIC audit report stated that "ACCUTECH still considers it Cardinal's responsibility to notify customers of problems with items bought and l
manufactured under Cardinal ownership," and that "they (ACCUTECH] will make a
" courtesy" notification to the affected customers." This position was not in agreement with the May 29,1997, NRC letter to ACCUTECH which stated that the NRC staff had concluded that ACCUTECH was incorrect in the interpretation of its responsibilities under Part 21 by characterizing them as " courtesy" actions; the Part 21 regulations require that the pertinent provisions of the regulations be implementad in the event of the discovery of a defect in a basic component; and that ACCUTECH was bound to take formal action pursuant to Part 21 and must do so because of the regulatory requirements it assumed due to its purchase of the CIP [ Cardinal] assets. Discussion with ACCUTECH management during the NRC inspection indicated that ACCUTECH was currently in agreement with the NRC position on Part 21 responsibility and did not agree with the position stated in the NUPIC audit report.
c. Conclusion
The inspectors concluded that NUPIC audit report 98-019, which documented the audit led by Wisconsin Electric, had mischaracterized two ACCUTECH positions related to sampling and Part 21 responsibility. However, NRC discussions with ACCUTECH management indicated that ACCUTECH's actual position on Part 21 was in agreement with NRC expectations and was acceptatjs. The inspectors also determined that ACCUTECH's position on sampling and verification of lot homogeneity was not as described in the NUPlC audit. (ACCUTECH's sampling process and the NRC's position on sampling is described in Section 2 of this inspection report in the portion titled "Nonconformance 99901076/94-01-03 1
(Closed).")
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- 4 PERSONS CONTACTED David Rose, President '
Joseph Casey, General Manager Steven Gauthier, Quality Assurance Manager Joseph Lee Conrad, Quality Assurance Supervisor t
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ITEMS OPENED, CLOSED, AND DISCUSSED Item Numb _qi Iygg Descriotions Closed 99901307/96-01-01 NOV Exceeding Part 21 Notification Timeliness Limit 99901307/96-01-02 NOV Inadequate Part 21 Evaluation 99901076/94-01-03 NON Inadequate Documented Basis for Destructive Sampling Plan 99901307/96-01-03 NON Incomplete Documentation Supplied to Customer 99901307/96-01-04 NON Inadequate Verification of Conformance
.99901307/96-01-05 NON inadequate Corrective Action 99901307/96-01-06 NON Inadequate Review of Materialin Warehouse Stock 99901307/96-01-07 NON Inadequate Documentation of Part 21 Evaluation i
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