ML20213G165
| ML20213G165 | |
| Person / Time | |
|---|---|
| Issue date: | 05/12/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17054D592 | List: |
| References | |
| REF-QA-99901082 99901082-87-01, 99901082-87-1, NUDOCS 8705180157 | |
| Download: ML20213G165 (6) | |
Text
.
=
APPENDIX B U.S. Tool and Die, Incorporated Docket No. 99901082/87-01 NOTICE OF NONCONFORMANCE During an inspection conducted March 23-27, 1987, the implementation of the Quality Assurance (QA) Program at the UST&D facilities in Allison Park and Glenshaw, Pennsylvania was reviewed with respect to the fabrication of spent fuel storage racks.
Appendix B,10 CFR Part 21, and UST&D's QA Program Man dated Jaruary 20, 1986.
that certain activities at the UST&D facilities were not conducted inBa accordance with these commitments.
These items are listed below.
1.
Criterion X of Appendix B to 10 CFR Part 50 requires, in part, that a program for inspection be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures and drawings.
Section 14.3C of the UST&D QAPM, requires, in part, that. in-process examination or surveillance be conducted by Quality Control personnel to verify dimensions and that fabrication methods used by production are in accordance with the contract documents and industry practice.
Section 3.3 of Procedure 14.1, " Production Work Routing and Inspection Plan," Revision 0, requires, in part, that Quality Control perfom all inspections, in-process examinations, testing verification, etc. noted on the flow chart (the " Production Work Routing and Inspection Plan") in accordance with the apprcpriate procedures and that no production activi-ties progress past these points until Quality Control has perfomed their duties.
Contrary to the above, in-process examinaticns were not being performed at the south shop per the " Production Work Routing and Inspection Plan,"
Drawing 8601-0, Revision 1, for the spent fuel racks being manufactured for the LaSalle project.
(87-01-03) 2.
Criterion X of Appendix B to 10 CFR Part 50 requires, in part, that a program for inspection of activities affecting quality be established and executed to verify conformance with the documented instructions, procedures and drawings.
Section 10.2A of the UST&D QAPM requires, in part, that all shop inspections / examinations / monitoring are performed by qualified Quality Control personnel and in accordance with written procedures.
01
~
Section 2.2.1 of Procedure 10.4, " Final Inspection," Revision 1, requires, in part, that verification.of the physical dimensions of the shipping piece with the approved shop drawing dimensions be performed.
C:atrary-to-the above, two undersize welds were identified by the NRC inspectors.on a fuel rack which had been inspected and found acceptable by.UST&D Quality Control.
(87-01-04) 3.
Criterion XII of Appendix-B to 10 CFR Part 50 requires, in part, that measures be established to assure that tools, gages, instruments and other measuring and testing devices used in activities affecting quality-are properly controlled maintain accuracy., calibrated and adjusted at specified periods to Section 12.28, of the UST&D QAPM requires, in part, that the interval of calibration for each item be established in procedures.
Section 2.4 of UST&D Procedure 12.1, " Control of ' Inspection Measuring Equipment,"_ Revision 2, requires, in part, that each piece of inspection equipment be assigned a pennanent unique serial number which will be applied to the equipment by vibro-etching or with a durable label.
Section 2.6 of Procedure 12.1 requires, in part, that a "Cardex" system be used to log calibration information and this record card include among other criteria, the calibration interval.
Contrary tr +he above, a review of measuring and test equipment (M&TE) and calibro. sn records revealed the following:
Documented evidence was not available to verify that the a.
calibration interval for M&TE was established in procedures.
b.
The four inner diameter (ID) box mandrels for the Kewaunee, Vermont Yankee, and LaSalle projects in the south fabrication shop were not identified with a permanent unique S/N applied by vibro-etching or with a durable label, A calibration interval was not established in the "Cardex" c.
system for the modified ID box mandrel for the LaSalle project in the north fabrication shop.
(87-01-05) 4.
Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that to the extent necessary, procurement documents require subcontractors to provide a quality assurance program consistent with the pertinent provisions of this appendix.
Section 2.2A of the QAPM requires, in part, that the UST&D Quality Assurance Program be developed to comply with the requirements of ANSI N45.2 and ANSI /ASME NQA-1-Quality Assurance Program Basic Requirements.
.g.
The QA sections of the technical specifications for the Kewaunee, Vermcr.t ANSI /ASME NQA-1 upon UST&D. Yankee, and LaSalle projects impo Section 5 of ANSI N45.2-1977 and Section 4 (Basic Requirements) of ANSI /
ASME KQA-1-1983 indicate that PCs shall require suppliers / vendors to hav a QA program consistent with the applicable requirements of the standard.
Contrary to the above, a review of 43 P0s for materials and services related to spent fuel racks fabricated under ASME Code Section III, Subsection NF indicated that quality requirements (e.g., QA Program) were not passed on to vendors for the following P0s:
and -61228 to Cromie Machine and Tool; E6-60208 86-60746, -60613, -60814 to Columbia Electric Manufacturing; 84-1701 and -1679 to Do All Pittsburgh; 82-1068 to Capitol Pipe and Steel Products; 82-1051 to Comercial Fasteners; 86-60E02,
-81208, and 87-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 85-51023 to Techalloy; 82-1311 and 83-1387 to Sandvik; 87-70115 to Weldstar; 86-70103 to Alloy-0xygen Weld Supply; and 66-61218 to Metal Goods.
(87-01-06) 5.
. Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure quality are suitably included or referenced in the documents for procurement.
Section 4.2B of the QAPM requires, in part, that purchase orders for material delineate all applicable requirements of the contract documents.
Section 2.2 of Procedure 4.1, " Procurement Document Control," Revision 5, requires, in part, that procurement documents reference all design specification requirements applicable to the items being purchased.
Section 5.3 of NES Specification No. 83A2256, " Specification for the Fabrication and Inspection of the Vermont Yankee Nuclear Power Station Spent Fuel Storage Racks," Revision 0, requires that all weld filler metals meet the requirements of Section III, Subsection NF including delta ferrite determination.
Section 4.4B of the QAPM requires, in part, that the quality assurance manager or his designee review and approve purchase orders prior to issuance to the vendor.
Sections 3.2 and 4.1 of Procedure 4.1 require that all P0s be reviewed and approved by QA.
Contrary to the above, a review of P0s indicated that PO 87-70118 to Alloy-Oxygen Welding Supply for stainless steel weld filler metal did not contain a delta ferrite determination statement, and PO 86-60610 to WALC0 Corporation for markers and tape was not signed / initialed and dated by QA personnel.
(87-01-07)
6.
Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that activities affecting quality be prescribed by documented instructions, procedures or drawings.
Section 5.2B of the QAPM and Section 6.0 of ANSI N45.2-1977 requires, in part, that all activities affecting quality be prescribed and accomplished with appropriate documented procedures.
Contrary to the above, it was noted that a documented procedure / instruction did not exist to control tools (e.g., wire burshes, grinding wheels, hammers, etc.) that were designated for use only on stainless steel (87-01-08) material.
7.
Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
- Section 5.2B of the QAPM requires, in part, that, as applicable, procedures, instructions, and/or drawings will include quantitative and qualitative acceptance criteria.
Section 2.2 of Procedure 10.3, "Inprocess Examination," Revision 3, defines in-process examinations as periodic, random sampling type checks and or surveillance to detemine that the shop is providing material, parts, subassembifes, pieces, and/or components which comply with UST&D QA/QC program and project requirements.
Contrary to the above, Procedure 10.3 does not provide the QC inspector
-appropriate guidance indicating the required random sample quantities or percentages needed to ensure a representative sample during in-process
. examinations.
(87-01-09) 8.
Criterion XIV of Appendix ~ B to 10 CFR-Part 50 requires, in part, that measures _be established to indicate, by the use of marking, the status of inspections and tests performed upon individual items, and that these measures provide for identification of items which have satisfactorily passed required inspections and tests, where necessary, to preclude inadvertent bypassing of such inspections and tests.
Section 14.2A of the QAPM requires, in part, that record of in-process i
examination or surveillance be noted on the part/ component / subassembly, i
Section 2.3 of Procedure 10.3, "Inprocess Examination," Revision 3, requires, in part, that documentation is not re examinations; however, each part, subassembly, quired for in-process piece and/or component which is in-process examined be physically marked or documented as being examined by UST&D personnel performing the examination.
=-
iy
(
, Section 3.2 of, Procedure 10.3 requires, in part, that-QA/QC personnel mark each
.the piece, piece in-process examined with a unique marking to indicate by whom..
part, sub-assembly and/or component has been examined and Contrary to the above, marking-procedures used by the south shop QC inspector for in-process examination do not clearly. identify items or who examined the part.or. components which have satisfactorily passed (67-01-10) 9.
Criterion -VII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that purchased material, equipment and services confom to the procurement documents, and that the effectiveness of the control of quality by contractors and subcontractors be assessed at intervals consistent with the importance, complexity, and quantity of the product or services.
Section 7.2B of the QAPM requires, in part, that vendors be evaluated and approved based on their capability to provide material, equipment and/or services.
Section 1.1.1 of Procedure 7.2, " Evaluation 'of Vendors," Revision 1, requires, in part, that vendor evaluations be conducted to provide confi-dence_in the vendor's QA Program for meeting the quality requirements.
Contrary to the above, vendor evaluations had not been performed on 3
Do All Pittsburgh and Columbia Electric. Manufacturing who provide t
calibration services for UST&D.
(87-01-11) 10.
Criterion II of Appendix B to 10 CFR Part 50 requires,;in part,.that the quality assurance program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
ming quality activities be trained in the requirements o gram as applicable to their activity and that their qualification, indoctri-nation, and training be controlled to obtain suitable proficiency.
Section 2.1 of Procedure 2.3, " Training," Revision 3, re in the requirements of UST&D's QA Program as applicable to their activity.
Contrary to the above, training records did not exist for two UST&D shop employees.
(87-01-12) 11.
Criterion VII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that purchased material, equipment and services conform to the procurement documents.
..,,y
---.-.m..-
..<----,.,....,y--,
.,. - - ---,,w.
Section 7.2B of the QAPM requires, in part,' that vendors sha and approved _ based on their capability to provide materia services.
ae Section 2.1 of Procedure 7.2, " Evaluation o requires,-
quality related. materials and/or' services prior to, or within 14 d issuance of a purchase order.
Contrary to the above, P0 86-60143, dated February 14, 1986 was placed March 12-13, 1986.with Industrial Service Center while the evaluatio (87-01-13) w
.---wwr--g e-u-