ML20207K944
| ML20207K944 | |
| Person / Time | |
|---|---|
| Issue date: | 07/28/1986 |
| From: | Abbate C, Jocelyn Craig NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20207K930 | List: |
| References | |
| REF-QA-99900751 NUDOCS 8607300139 | |
| Download: ML20207K944 (13) | |
Text
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA INSPECTION INSPECTION REPORT DATE: Aoril 14-18. 1986 ON-SITE HOURSt 113 NO.- 99900751/86-01 CORPESPONDENCE ADDRESS: RECO Industries, Inc.
ATTN: Mr. Stuart Point President Box 25189 Richmond, Virginia 23260 i
ORGANIZATIONAL CONTACT: Mr. Ronald Brooks TELEPHONE NUMBER: (804) 644-2611 NUCLEAR INDUSTRY ACTIVITY: Pressure vessels, heat exchangers ASSIGNED INSPECTOR: f01 N, kM 7 (g)
C.F. A5 bate, spec a' P~rojects Inspection Section ae (SPIS)
OTHER INSPECTOR R.L.('){Cilimberg, SPIS K.C. Leu, IS
/ 75 (> ,
APPROVED BY: ! x John W. Craig, Chief, SPIS, Vendor Program Branch Da t'e INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 71,10 CFR Part 21 B. SCOPE: Review the implementation of the REC 0 Quality Assurance (QA) program and compliance with the NRC requirements of 10 CFR Part 71 and 10 CFR Part 21 during the fabrication of transportation casks.
PLANT SITE APPLICABILITY: All nuclear power facilities which use transpor-tation casks fabricated by RECO Industries, Inc.
i O 5 00 i PDR
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA REPORT INSPECTION RESULTS: PAGE 2 of 8 NO ? 99900751/86-01 A. VIOLATIONS: .
None B. NONCONFORMANCES: ' l 1.- Contrary to paragraph 71.109 of Subpart H to 10 CFR Part 71, and Section 4 4 of CNSI specification number 24504-211-GPS, " General Procurement Specification for CNSI Type B Radwaste Transport Casks,"
Revision 0, dated June 26, 1985, RECO ordered. common pig lead instead of the specified chemical grade lead.
- 2. Contrary to paragraph 71.131 of Subpart H to 10 CFR Part 71 and Section 14.6000 of the RECO Quality Assurance Manual (QAM), Revi-sion 2, dated September 11, 1984, disposition of nonconformance report (NCR) number NS-2252-6 was made with the customer's verbal instead of written approval and disposition of NCR number NS-2252-7 was made without any type of customer approval. [
- 3. Contrary to paragraph 71.113 of Subpart H, to 10 CFR Part 71, and Section 5.1000 of the RECO QAM, purchase order 2884 had been incorrectly identified as 2844 on the Certificate of Conformance, Certificates of Examination, and Nonconformance Reports.
- 4. Contrary to paragraph 71.115 of Subpart H to 10 CFR Part 71, NUS Project Specification 5840-M-200, Revision 1, dated December 10, 1985, and Sections 6.4610 and 6.4620 of the REC 0 QAM, the purchased material for P0 N31681, dated March 12, 1986, was not receipt in-spected. In addition, a Certificate of Conformance from the sup-plier was requested in the Nuclear Utility Services (NUS) project specification; RECO incorrectly requested a Certified Material Test Report (CMTR) from the supplier which was not received.
- 5. Contrary to paragraph 71.103 of Subpart H to 10CFR Part 71 and Section 1.6000 of the RECO QAM,' REC 0 failed to revise the organi-zational chart in the QAM, Revision 2, dated September 11, 1984, to reflect recent organizational changes.
C. UNRESOLVED ITEMS:
None l
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA REPORT INSPECTION RESULTS: PAGE 3 of 8 NO.* 99900751/8&-01 D. STATUS OF PREVIOUS-INSPECTION FINDINGS:
- 1. (0 pen) Nonconformance (85-01, Item B.1):
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and Section 8.4120 of RECO Industries QAM, Revision 2, documented instructions from management were not available to assure that the weld rod auxi-liary storage oven temperatures are monitored at the start of each work shift.
The NRC inspectors verified that instructions had been added to Section 8.4120 of the 0A Manual which states that " Ovens shall be monitored at the start of each working shif t by the workcenter foreman as directed by management." However, the inspectors deter-mined that the temperatures are not being checked at the start of each shift. Nonconformance reports had not been written by RECO'to do'cument deviations from Section 8.4120 of the REC 0 QAM. This item, is considered open. l
- 2. (Closed) Nonconformance (85-01, Item B.2):
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and Section 1.6.1 of RECO Industries' QC procedure ES-164-III, Revision 4, there were no temperature indicators on the holding ovens for low hydrogen rods to assure that the required temperature range of 150-300*F was maintained.
The NRC inspectors verified that temperature indicators were inside each oven. This item is considered closed.
- 3. (Closed) Nonconformance (85-01, Item B.3):
Contrary to Section 17.1000 of Revision 2 of the RECO Industries QAM, checklists used in performing the QA internal audits did not contain provisions for the auditing of welding material control.
During the inspection, " Procedure for Internal Audits", Revision 6, dated March 19, 1985, was reviewed and the inspectors verified that the internal audit checklist contained a section for welding material control and the checklist was being used to perform internal audits.
This item is considered closed.
. - - - - ..__.,,-.x__, -- - -,
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA REFORT INSPECTION NO.: 99900751/86-01 RESULTS: PAGE 4 of 8 E. INSPECTION FINDINGS AND OTHER COMMENTS:
- 1. Entrance and Exit Meetings An entrance meeting was conducted on April 14, 1986, at the RECO Industries, Inc. office in Richmond, Virginia, during which the purpose and scope of the inspection were discussed. During the exit meeting, conducted on April 18, 1986, the inspection findings and observations were summarized.
- 2. Procurement of Lead f
During the review of the data package which covered transportation cask Model 8-120B (RECO Serial Number (SN) 2552) supplied to CNSI, purchase order (PO) number 437257, Revision 0, dated August 9, 1985, the NRC inspectors examined traceability documents for the lead used in the cask. CNSI specification number 24504-211-GPS, " General Procurement Specification for CNSI Type B Radwaste Transport Casks, f*
Revision 0, dated June 26, 1985, requires that ASTM-B-29 chemical grade pig lead be used for shielding. A review of REC 0 purchase order nurrber N25621, Revision 0, dated November 12, 1935, indicated that comiron pig lead was ordered from the Tara Corporation. However, the data package contained a certification dated November 28, 1985, that the material supplied to P.O. number N2562-1 is guaranteed to meet ASTM B29-79 specifications for corroding grade lead. When the NRC inspectors questioned the composition of the lead, RECO personnel provided a certified material test report (CMTR) from Spectrum Laboratories, Inc. which certified that the lead actually installed in the cask met the requirements of ASTM-B-29 for chemical grade pig lead as specified in CNSI specification number 24504-211-GPS.
The CMTR alleviated technical concerns regarding the lead, but REC 0 did not meet the CNSI procurement documentation requirements when standard pig lead was ordered instead of chemical pig lead.
Nonconformance 86-01-01 was identified in this area.
- 3. Nonconformance Reports (NCR)
The NRC inspectors reviewed seven NCRs involving the RECO SN-2552 transportation cask that was fabricated for CNSI P0 number 437257, Revision 0. The RECO CAM, Revision 2, dated September 11, 1984, requires that NCR disposition and approval be transmitted by printed communication techniques and copies be attached to the NCR form.
The NRC inspectors determined that disposition of NCR number NS-2252-6, dated February 13, 1986, was made with the customer's verbal
, , . . . _ . . ~ . - , . , - - - , - - , . - , . - - - , . - - - . - - - - . . . -
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA INSPECTION REPORT RESULTS:
PAGE 5 of 8 NO.- 99900751/86-01 15, 1986, approval only-and NCR number NS-2252-7, dated February was made without approval by the customer. NCR NS-2252-6 covered the substitution of 304 stainless steel for ASTM A-334 grade 3 steel. NCR NS-2252-7 reported the relocation of three top load J limiter ratchet binder clips from the locations specified on CNSI drawing number D-85-878.
Nonconformance 86-01-02 was identified in this area.
- 4. Audits:
Three full scope RECO internal audits were reviewed during the in-spection. Each audit contained an audit plan which was approved by QA/QC before the audit, the audit checklist, lists of the atten-dees of pre and post audit meetings, and Internal Audit Finding Reports. The Internal Audit Finding Reports are written by the pe'rson in charge of the area in which the deficiency was found and ,!
include a description of the finding, the cause of finding, the '
corrective action and the action taken to prevent recurrence.
The NRC inspectors determined that these audits were performed semi-annually and met the requirements of Section 17.000 of the REC 0 QAM, " Procedure for Internal Audits", ES-151, Revision 6, dated March 19, 1985, paragraph 71.137 of 10 CFR Part 71. Additionally, during the review of the audit checklists, the NRC inspectors veri-fied that a section for welding material control was included and that area was being audited. As a result of this review, Nonconfor-mance 85-01 Item B.3 is considered closed.
The The inspectors reviewed four REC 0 audits of subvendors.
audits were performed annually and consisted of a checklist of items to assure that the subvendor was implementing an appro-priate QA program. The external audits were performed by quali-fied personnel and met the requirements of Sections 6.2000 and 17.000 of the RECO QAM, and paragraph 71.115 of 10 CFR Part II.
Qualification records were also reviewed for four auditors and one lead auditor. Each auditor was qualified annually per the require-ments of Section 1.10.0000 of the QAM and " Procedure for the Quali-fication of Quality Assurance Program Audit Personnel", ES-208, dated April 26, 1983. The requirements which were fulfilled by each auditor included appropriate training, passing a written exam, and on-the-job training. The lead auditor met the following requirements:
successful completion of a written exam, minimum auditing experience, and an understanding of auditing techniques and industry codes, standards, and regulations.
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA REPORT INSPECTION ,
NO.- 99900751/P6-01 RESULTS: PAGE 6 of 8 e
- 5. Procurement Document Control _:
Section 5.0000, " Procurement Document Control" of the RECO QAM was reviewed with respect to the procurement requirements and procedures of the REC 0 QA program.
The NRC inspector reviewed P0s to material and service vendors. For each PO which was reviewed, the inspector verified that the require-ments specified in the P0 to RECO from the buyer were correctly passed on to RECO's subvendors. The inspector also verified that the materials and services were purchased from vendors on the RECO Approved Vendor List. During the review, the inspector determined that NUS P0 2884, dated November 1,1984 to REC 0 for one NUS10-135, Type B, Series 1, radioactive waste shipping cask had been incor-rectly entered as P0 2844 in the following documents: Certificate of Conformance on items supplied from RECO to NUS, dated June 28, 1985, Certificate of Liquid Penetrant Examination from RECO to NUS, dated, June 26, 1985, Certificate of Magnetic Particle Examination from RECO to NUS, dated June 26, 1985, four NCRs supplied to REC 0 from
honconformance 86-01-03 was identified in this area.
- 6. Receipt Inspection:
Section 3.0000 " Procurement Document Control", and Section 6.0000
" Control of Purchase Items and Services" of the RECO QAM were reviewed to determine the criteria used by RECO to control porchased material and services. Review of receipt inspection activities included RECO's purchase orders for Type A and Type B casks, CMTR's and Certificates nf Conformance for material supplied by the vendors.
Receipt inspection at RECO is performed on the back of a copy of the purchase order and CMTRs and Certificates of Conformance are reviewed to determir.e whether or not the material received corre-sponds to the material ordered.
During the review, the inspector determined that a requested CMTR was not available for RECO P0 N31681, dated March 12, 1986 to Betco Supply Co. for machine parts. It was also noted that a Certificate of Conformance should have been requested instead of a CMTR, in accordance with NUS project Specification 5840-M-200. In addition, the material listed on the P0 had not been receipt inspected.
Nonconformance 86-01-04 was identified in this area.
N
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA REPORT INSPECTION NO.- 99900751/86-01 RESULTS: PAGE 7 of 8
- 7. Calibration of Measuring and Test Equipment:
Section 11.0000 of the REC 0 QAM, " Control of Measuring and Test Equipment", RECO Calibration Procedure ES-132 and REC 0 recertifi-cation / calibration records were reviewed to detemine the adequacy of the RECO measuring and test equipment control program. Equipment observed during the inspection displayed a calibration sticker which contained a RECO S/N, the calibration date, next calibration due date and the calibrator's initial.
Calibration data reviews were performed on two central ovens (Ns-506309), three auxiliary ovens (Ns-601, 602s 603),fourwelding machines (Nx-754,767,769,745), two X-ray macnines (Ns-2, 4), one magnaflux machine (N-323), two pressure gages (Ns - 2, 5), one 120#
torque wrench (112) and one outside micrometer (N-321). The cali-bration data reviews consisted of reviewing and comparing the com-puterized master log calibration records to the calibration stickers on the equipment. The master log contains the calibration history f of the item and is used to determine and notify appropriate personndl of the next calibration due date. As a result of this review, the NRC inspectors determined that the calibration of measuring and test equipment was being performed in accordance with the procedure.
- 8. Radiation Shielding:
The NRC inspectors reviewed documentation to determine what radia-tion shielding requirements were applicable to RECO. CNSI purchase orders for Type B casks imposed the requirements of CNSI specification number 2450-211-GPS, Revision 0 on RECO. This specification requires that shielding be tested in accordance with the requirements of CNSI specification number 24504-186-002 " Gamma Scanning Specification for CNSI Model 8-120B Cask," Revision 3, dated May 14, 1984, and indi-cated that this procedure is applicable to all shipment casks for radioactive materials and radiation shields. Gamma scanning cali-bration reports, REC 0 Form QC-GS-1, document the results of gama scanning tests which measure the shielding integrity of the lead in the casks.
The NRC inspectors reviewed 13 calibration reports and 13 gamma scanning reports which documented the results of gama scanning performed on five casks. The results reported met the acceptance criteria in accordance with the requirements of RECO procedure number ES-203-LC, Revision 3. ,
I f m
ORGANIZATION: RECO INDUSTRIES, INC.
RICHMOND, VIRGINIA REPORT INSPECTION RESULTS: PAGE 8 of 2 NO.! 99900751/86-01
- \
l The NRC inspectors reviewed training records from 1983 to the present for three employees to determine whether personnel per-forming nondestructive testing had received the necessary training and qualifications. Qualification records were evaluated for these personnel and it was determined that they met the requirements of section 4 and 8 of the QAM. Personnel performing nondestructive testing were required to pass a written examination and were certified as level I, II, or III. REC 0 procedures were found to be in compliance with the guidelines of practice number SNT-TC-IA recommended by the American Society for Nondestructive Testing.
- 9. QUALITY ASSURANCE MANUAL:
The inspectors reviewed the RECO Nuclear Quality Assurance Manual, NQA-1, Revision 2, dated September 11, 1984 and determined the manual encompassed the criteria of 10 CFR Part 71 Subpart H. The or.ganizational chart, however, was not the latest revision and did not reflect recent organizational changes. This is contrary to f paragraph 71.103 of 10 CFR Part 71 and Section 1.6000 of the QA manual which state that the authority and duties of persons per-forming activities affecting quality assurance functions be clearly established and delineated in writing.
Nonconformance 86-01-05 was identified in this area.
F. Persons Contacted:
- R.E. Brooks, Corporate QA Manager
- L.C. Little, Project Manager R.D. Brooks, Purchasing Manager
- S.L. Braune, Engineering Manager
- S. Point, President
- J.A. Hagan, Vice President J.L. Dawson, Senior Vice President D. Lipscomb, Quality Control Inspector J. Palmore, Quality Control Manager B. Mayton, Inspector l
l
- Attended Exit Meeting l
l
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