ML20206M857
| ML20206M857 | |
| Person / Time | |
|---|---|
| Issue date: | 05/06/1999 |
| From: | Cwalina G NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20206M849 | List: |
| References | |
| REF-QA-99901339 99901339-99-201, NUDOCS 9905170069 | |
| Download: ML20206M857 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION J l
Report No: 99901339/1999201 j l
Organization: Basic-PSA, Inc. 'l
Contact:
Bill Louder, Quality Assurance Manager l (814) 266-8646 !
Nuclear Activity: Manufactures and supplies safety-related shock arrestors to NRC Licensees Dates: April 5-6,1999 Inspector: Bill Rogers, Reactor Engineer, lOMB Approved by: Gregory Cwalina, Acting Chiefd Reliability and Maintenance Section -
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- Quality Assurance, Vendor Inspection, Maintenance and Allegations Branch Division of inspection program Management Enclosure 9905170069 990506 PDR GA999 EMV***** "
99901339 PDR .
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1 INSPECTION
SUMMARY
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On April 5-6,1999, the U.S. Nuclear Regulatory Commission (NRC) performed an l inspection at the Basic-PSA, Inc., facility in Johnstown, Pennsylvania. The inspection was conducted to review selected portions of Basic-PSA's quality assurance (QA) ,
program, and its implementation, and the applicable programs and procedures used to supply safety-related shock arrestors to NRC licensees. Specifically, the inspector reviewed Basic-PSA's activities related to the maintenance of vendor controls and the ;
transfer of 10 CFR Part 21 responsibilities, from Pacific Scientific to Basic-PSA, )
following Basic-PSA's purchase of the safety-related shock arrestor product line from l Pacific Scientific in January 1997.
The inspection bases were: q 1
- 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."
l 2 STATUS OF PREVIOUS INSPECTION FINDINGS l
This was the first inspection of Basic-PSA. ;
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3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Control of Suppliers
- a. Inspection Scope The inspector examined procedures and representative records, interviewed personnel, and observed activities to verify that Basic-PSA took appropriate actions to maintain the qualification of vendors which had been previously qualified by Pacific Scientific and to verify that Basic-PSA took appropriate qualification actions to place or maintain vendors on the Basic-PSA approved suppliers list for new vendors added subsequent to the shock arrestor product line purchase.
- b. Observations and Findinas 4
The inspector determined that Basic-PSA had taken actions to independently develop an Approved Vendor List (AVL) specific to Basic-PSA and had not taken possession of the Pacific Scientific AVL. As a result, Basic-PSA had not been required to maintain the qualification of any vendors previously used by Pacific Scientific.
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The inspector reviewed Basic-PSA's current AVL, dated April 2,1999, which replaced the previous revision dated January 12,1999. The current AVL listed twenty-four i vendors which supplied commercial, American Society of Mechanical Engineers (ASME) Code, or nuclear (10 CFR Part 50, Appendix B) products or services. Those vendors providing ASME or nuclear products or services had been qualified within the previous two years by Basic-PSA.
- c. Conclusion The inspector concluded that Basic-PSA had not taken possession of the Pacific Scientific AVL and had instead taken adequate actions to develop a list of qualified suppliers. The inspector did not identify any concerns in this area.
3.2 10 CFR Part 21 Procedure
- a. Inspection scope The inspector examined procedures and representative records, interviewed personnel, and observed work activities to verify that the Basic-PSA 10 CFR Part 21 implementing procedure was in accordance with the requirements of 10 CFR Part 21.
- b. Observations and Findinas The inspector reviewed the Basic-PSA procedure BPI-26, " Procedure for Reporting Defects and Failures to Comply in Accordance with Regulations 10 CFR 21," dated j November 21,1997. BPI-26 was a detailed procedure which defined all pertinent references and clearly outlined the scope of related activities and the applicable j responsibilities. However, the procedure did not specify the requirement that I deviations be evaluated within sixty days of discovery or if the deviation cannot be evaluated within sixty days of discovery an interim report be submitted to the NRC within sixty days of discovery. In addition, the procedure did not specify that a director or responsible officer be informed within five working days of the completion of an evaluation which determined that a defect or failure to comply exists.
- c. Conclusion The inspector concluded that a weakness was identified in the Basic-PSA 10 CFR Part 21 implementing procedure which did not specify the applicable timeliness requirements for evaluating deviations, providing interim notification to the NRC, or informing responsible officer of defects of failure to comply. Basic-PSA indicated to the inspector that the Basic-PSA 10 CFR Part 21 implementing procedure would be revised to include the discussed timeliness requirements.
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y 3.3 10 CFR Part 21 Evaluations
- a. Inspection scope'- .
The inspector examined procedures and representative records, 'intervieweo personnel, and observed work activities to verify that Basic-PSA's 10 CFR Part 21 evaluations or notifications were in accordance with the requirements of 10 CFR .
Part 21 and the requirements of the Basic-PSA 10 CFR Part 21 implementing procedure. '
b; Qbservations and Findinas identification of the Deviation Review of the Basic-PSA 10 CFR Part 21 records indicated that there were no 10 CFR Part 21 records, maintained in accordance with BPI-26, indicating that 'no i deviations had been identified, or evaluations performed, since the 1997 purchase of -
the safety-related shock arrestor product line from Pacific Scientific. However, during discussions with Basic-PSA personnel and review of Basic-PSA's records related to vendor qualifications, the inspector determined that Basic-PSA had reviewed a technical issue concerning an indication that a sub-supplier did not have documentation to support that activities had been accomplished in accordance with '
the purchase order.
Basic-PSA had determined that An Metals Processing had provided a service to Pacific Scientific in the 1996 time period, which was prior to Basic-PSA's purchase of the safety-related shock arrestor line. All Metals Processing had been contracted by Pacific Scientific to coat several metal parts with a manganese phosphate coating which had been used in safety-related shock arrestors supplied to NRC licensees.
However, Basic-PSA had indication that All Metals Processing did not have documentation that the manganese coatings had actually been applied and that potentially a zinc phosphate coating had been applied in lieu of the manganese phosphate coating.
1 Purchase Order and Manufacturina Reauirements j Basic-PSA had contacted Pacific Scientific to determine the nature of the purchase orders from Pacific Scientific to All Metals Processing and the corresponding certifications and had retrieved the available manufacturing documentation from -
Basic-PSA's onsite records. j l
At Basic-PSA's request, Pacific Scientific had reviewed its electronic files, which j contained the information which Pacific Scientific had included to in its purchase :
- orders to All Metals Processing and the corresponding information which had been'.
included in the certifications from All Metals Processing to Pacific Scientific, and . -9 provided this information to Basic-PSA.' Based on a discussion with Pacific Scientific concerning the purchase order and certification information, Basic-PSA had y 4 U i
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determined that the documentation had not specified the requirements of 10 CFR i Part 50, Appendix B or 10 CFR Part 21 which indicated that All Metals Processing had l been a commercial grade supplier to Pacific Scientific. ;
i The inspector reviewed the applicable Pacific Scientific manufacturing and assembly outlines and procedures which Basic-PSA had maintained onsite and had used in the !
review of the coating issue. The review included Pacific Scientific l Manufacturing / Assembly Outline, Shop order 1-1930-1414040 dated June 14,1996, which applied to a capstan, part no. 1801421-01, one of the affected components.
Operation No. 70 of the Manufacturing / Assembly Outline stated 10 " Coat the entire . {
part in accordance with the PSCo (Pacific Scientific Methods and Process Standard] l No. 02.72, Type 4: Coat with Manganese Phosphate Per MIL-P-16232, Type M" and it j was noted that this had been accomplished with the Pacific Scientific Purchase Order K141404070 to All Meta!s Processing ,
The applicable Pacific Scientific procedure, PSCo 02.72, " Corrosion Protection for Ferrous Alloys," revision M, dated August 3,1994, specified the Type 4 as " Phosphate with Supplementary Treatment," which required that the component be coated with j Manganese Phosphate per MIL-P-16232, Type M, Class 1. In addition, the component was to have received a supplementary treatment by applying a heat cured solid film lubricant per MIL-L-8937. (The supplementary solid film lubricant (dry lubricant) was applied by Electrofilm Corporation.) The corresponding certification from All Metals Processing to Pacific Scientific for the capstan coating procedure, 4 Invoice no. 83413A, dated July 18,1996, specified that a mangar~e phosphate j coating was applied in accordance with PSCo 02.72, revision M,1ype 4. I Evaluation of the Deviation Basic-PSA had performed and documented a review of the manganese coating issue when it had first been identified in December 1998, prior to the NRC inspection.
Basic-PSA had determined that a manganese phosphate coating had been required on several components including an inertia mass, capstan, and torque carriers and that these components had been installed in safety related shock arrestors which had been supplied to NRC licensees.
Basic-PSA noted that although the manganese phosphate coating was required for corrosion protection there was no expectation of an increased susceptibility to corrosion, if a zinc phosphate coating had been applied in lieu of a manganese phosphate coating, for the following reasons:
. Zinc phosphate was nearly equivalent to manganese phosphate in corrosion protection in this application.
- . Additional corrosion protection was provided by the solid film lubricant applied per MIL-L-8937. i l
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. The parts affected were internal to the shock arrestor, isolated from the environment and experienced low stress (no rubbing to reduce coating effectiveness).
Basic-PSA concluded that with the addition of the dry lubricant (the MIL-L-8937 film) there would be essentially no difference between the manganese phosphate or the zinc phosphate coatings in regard to corrosion protection. As a result, Basic-PSA anticipated that there would be no differences experienced by the user when the shock arrestor was installed and operated.
Although Basic-PSA had performed the technical evaluation and had concluded that the deviation would not constitute a substantial safety hazard if it occurred, and had documented the evaluation in several records, these activities had not been accomplished in accordance with the requirements of BPl-26," Procedure for Reporting Defects and Failures to Comply in Accordance witn Regulations 10 CFR 21 " BPI-26 required that the deviation be documented on a Nonconfo mance Notice and that the evaluation and disposition documented and approved by the
, Quality Assurance Manager. Basic-PSA provided the appropriate Nonconformance Notice 103, dated April 7,1999, which documented the deviation, evaluation, and disposition of the deviation, to the inspector subsequent to the completion of the inspection.
c. Conclusion
The inspector concluded that Basic-PSA had performed an adequate technical evaluation of the deviation in accordance with the requirements of 10 CFR Part 21, had determined that the deviation would not constitute a substantial safety hazard if it occurred, and had determined that no additional reporting was required. However, the inspector also concluded that Basic-PSA had not adequately documented the i technical evaluation in accordance with the Basic-PSA 10 CFR Part 21 procedure and identified the inadequate documentation as a weakness in implementation of the Basic-PSA Quality Assurance program.
4 PERSONS CONTACTED Jack Matlock, President William Louder, Quality Assurance Manager Alejo Comacho, Product Engineer, P.E.
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