ML20234B069
| ML20234B069 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1987 |
| From: | Harper J, Stone J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20234B028 | List: |
| References | |
| REF-QA-99901093 99901093-87-01, 99901093-87-1, NUDOCS 8709180253 | |
| Download: ML20234B069 (8) | |
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ORGANIZATION: ALLIED NUT & BOLT COMPANY, INCORPORATED XIllG 0F PRUSSIA, PENNSYLVAfilA REPORT INSPECTION INSPECTION N0.: 99901093/87-01 DATES: 06/23-26/87 OH-SITE Hot lRn an CORRESPONDENCE ADDRESS: Allied Nut & Bolt Company, Incorporated 520 Hertzog Boulevard Post Office Box 670 King of Prussia, Pennsylvania 19406 ORGANIZATIONAL CONTACT: Gerald Korin, Quality Assurance !!anager TELEPHONE NUMBER: 215-275-2200 ,
NUCLEAR lhDUSTRY ACTIVITY: Material supplier - fastener components. l
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ASSIGNED INSPECTOR: -
f[f/f7
- d. C. Harper, Program Development and Reactive Date Inspection Section (PDRIS)
H OTHT.R INSPEC10R(S): A. J. Pjura, Brookhaven National Laboratory APPROVED BY: (h ,
dei J. C.(/ Stone, Chief, PDR15, Vendor Inspection Branch 7 o/p at6 INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR 50, Appendix B and 10 CFR Part 21.
B. SCOPE: The inspection at Allied Nut & Boit was conducted in order to review compliance with and the implementation of 10 CFR 50, Appendix B and 10 CFR Part 21.
PLAliT SITE APPLICABILITY: 50-354 (Hope Creek); 50-272 and 50-311 (Salem Units 1 and 2).
8709180253 870917 PDR OA999 EMVALNUT 99901093 PDR
ORGANIZATION: ALLIED NUT & BOLT COMPANY. INCORPORATED XING OF PRUSSIA, PENNSYLVANIA REPORT INSPECTION Nn - QQQninQ9/R7-01 RFEulTS- PAGF 7 nf n A. INSPECTION ISSUES:
The inspection at Allied Nut & Bolt (Al4B) was performed as a part of an ongoing VIB fastener evaluation program. The inspection was conducted to review ANB's compliance with and implementation of 10 CFR 50 Appendix B and 10 CFR Part 21.
B. ILSPECTION FINDINGS:
- 1. Violations
- a. Contrary to Section 21.6 of 10 CFR Part 21, ANB failed to post copies of Section 206 of the Energy Reorganization Act of 1974.
(87-01-01)
- b. Contrary to Section 21.31 of 10 CFR Part 21, ANB failed to pass the requirements of 10 CFR Part 21 on to certain sub-tier j vendors that supplied material for nuclear customer use.
(87-01-02)
- 2. Nonconformances
- a. Contrary to Criterion V of Appendix B to 10 CFR Part 50, and to the ANB QA hanual, QAP 2.0, paragraph 3.2, there was no objective evidence that ANB had procedures for training and qualifying personnel responsible for quality control and/or assurance activities. (87-01-03)
- b. Contrary to Criterion VII of Appendix B to 10 CFR Part 50 and to the ANB QA Manual, QAP 7.0, Pcragraph 2.3, ANB failed to perform a source evaluation of Pottstown Plating. (87-01-04)
- c. Contrary to Criterion XV of Appendix B to 10 CFR Part 50 and to the ANB QA Manual, QAP 15, Paragraph 3.4, ANB failed to note a final disposition on numerous nonconformance reports.
(87-01-05) 1 J
C. UNRESOLVED ITEMS:
None.
D. OTHER FINDINGS AND COMMENTS:
Allied Nut & Bolt (ANB) is a relatively small distributor of both ferrous and nonferrous fasteners. ANB does not manufacture fasteners or perform any special processes inhouse.
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ORGANIZATION: ALLIED NUT & BOLT COMPANY, INCORPORATED KING OF PRUSSIA, PENNSYLVANIA REPORT INSPECTION hn . QQQn1no1/A7-01 RESutTS: PAGF 1 nf R The inspection team evaluated the areas of Part 21 compliance, audits i performed by ANB (internal and external), ANB nonconforming material dispositions, calibration of measuring instruments, and training and indoctrination of personnel involved with quality. A total of 13 nuclear cocument packages were evaluated by the inspection team for compliance with customer purchase order requirements and applicable regulations (Part 21; 10 CFR 50, Appendix B).
- 1. Part 21 Issues The requirements of Part 21 were not imposed on certain of ANB's sub-tier vendors. The original P0's issued to ANB by the nuclear licensee imposed the requirements of Part 21 on ANB. (See violation 87-01-02.)
Original PO# Originating Sub-tier ANB PO#
Date Company Vendor Date P2-17927 10/30/86 Public Service Bristol Heat Q-8308 Electric & Gas Treaters 01/12/87 P2-17927 10/30/86 Public Service Lab Testing Q-8202 Electric & Gas 12/23/86 P2-17927 10/30/86 Public Service Lab Testing Q-8375 Electric & Gas 01/19/87 P2-17927 10/30/86 Public Service Pottstown Plating Q-8389 Electric & Gas 01/21/87 P2-17927 10/30/06 Public Service Pottstown Plating Q-8249 Electric & Gas 01/05/87 P1-147349 05/19/86 Public Service Carpenter 1798 Electric & Gas Technology Corp. 01/21/85 P0 P2-17927 from Public Service Electric & Gas (PSEG) was issued to ANB for approximately 1000 SA193B7 and SA194 Gr 2H fasteners.
Bristol Heat Treaters (BHT) performed the heat treating for the PSEG order. Lab Testing, Inc. supplied mechanical and chemical testing
! on Lab Report No. C-3538 for the PSEG order. At the time of the l
inspection both BHT and Lab Testing were on the ANB Approved Vendors List (AVL). Pottstown Plating supplied clad plating for 109 pieces 1/2 - 13 x 1 1/2 SA193 Gr 7 bolts, 105 pieces 3/8 - 16 x 1 SA193 i
e ORGAN!ZAT10N: ALLIED NUT & BOLT COMPANY, INCORPORATED
. KING OF PRUSSIA, PENNSYLVANIA REPORT INSPECTION No - QQQnin49/n7-n1 RESULTS: PAGF 4 nf n l
Gr 7 Hex Bolts, 105 pieces 1/2 - 13 x 2 1/2 SA193 Gr 7 Hex Bolts, 550 pieces 1/2 - 13 SA194 Gr 2H Hvy Hex Nuts, 105 pieces 1/2 - 13 x 1 SA193 Gr 7 Hex Bolts, 105 pieces 1/2 - 13 x 1 1/2 SA193 Gr 8 Hex Bolts. Pottstown Plating was not on the ANB AVL at the time the !
services were rendered for P0 Q-8249. (See nonconformance 87-01-04.)
P0 P1-147349 from PSEG was issued to ANB for a total of 30 A193 Gr 8 Bolts (30 PCS), and ASTM A194 Gr 8 nuts (20 PCS). Carpenter Technology Corporation supplied ASTM A193 Gr 8 bar to AMB. At the time of the inspection Carpenter was on the ANB AVL.
The following list is a summary of subcontractors that ANB employed to render services for parts supplied for nuclear safety related .
service. ANB did not impose the requirements of Part 21 on these i subcontractors.
PO#/Date Company Product PO Q6584 05/29/86 Lab Testing 1 - 8 Hvy Hex Nuts SA194 Gr 8 PO Q6570 05/26/86 Lab Testing 1" Test PCS 304SS PO Q6582 05/29/86 East Coast Metals 3 PCS 1 x 12' 304SS P0 Q6582 05/29/86 East Coast Metals 50 PCS 1 - 8 x 4" SA193 Gr 8 P0 Q6582 05/29/86 East Coast Metals 10 PCS 1 - 8 x 6 1/4 SA193 Gr 88 P0 Q7831 11/06/86 Lab Testing 5/8 - 11 Hvy Hex Nuts SA194 Gr B7 P0 Q8021 12/02/86 Lab Testing 3/4 - 10 Hvy Hex Nuts SA194 Gr 8 P0 09157 04/22/87 Gage Lab Corp. Thread plug gage calibration ;
PO Q8402 02/06/87 Gage Lab Corp. Thread plug gage calibration Gage Lab Corporation is ANB's sole supplier of calibration services for micrometers, verniers, ring gages and plug thread gages.
Calibration The calibration of micrometers, vernier gages plug and ring thread gages were checked. A detail evaluation was made on the technical basis for calibration of 72 plug and ring thread gages, three 0-1" micrometers, two 1-2" uierometers, one'2-3" micrometers and two vernier gages. At the time of the inspection, all measuring equipment were properly calibrated and up to date in calibrations. ;
The technical basis for calibration of the measuring equipment was determined adequate.
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ORGANIZATION: ALLIED HUT & BOLT COMPANY, INCORPORATED l '
KING 0F PRUSSIA, PENNSYLVANIA REPORT INSPECTION Nn - occnino1/R7-01 RESULTS: PAGE 5 of 8 I
- 3. Nonconforming Material Nonconforming Material Report (NCR)
Criterion XV of 10 CFR 50, Appendix B, requires review and disposi-tion of nonconforming items in order to prevent their inadvertent use or installation. During a review of some 43 NCR's for the years 1984-86, numerous NCRs were found to have no disposition, but had a written explanation of action.under the remarks section (see nonconformance 87-01-05). NCRs 151, 160, 161, and 166 were written because of erroneous or missing certifications. A review of the purchase order files for each indicated that the proper certifica-tions were supplied to ANB prior to shipment.
NCR #157 dated March 26, 1984 described a problem with Cardinal l Industrial Products Company (CIPC) 1/2 - 13 x 2 SA193 Gr B7 Heavy Hex Bolts purchased by P0-Q1645 (125 PCS). The description of the nonconformance by the ANB QC Supervisor was " Bolt marked with B7-L 7 Mfg / trace C/V reviewed spec SA-193 & SA-320 found nothing about acceptability of grade markin,gs." A final disposition of accept as is, rework, downgrade, scrap or return was never determined by a check mark to complete the form (see nonconformance 87-01-05).
CIPC sent ANB a letter on March 1984 which describes the bolt head markings. In summary, CIPC explained that the dual head markings were their attempts to develop a program of product simplification.
This program involves parts that are run for one material specifi-cation but they simultaneously meet all the requirements of a second material specification. Therefore, in keeping with the marking requirements of the bolting specifications, CIPC included grade markings for each specification on the bolt head. CIPC claimed they were advised that there is nothing which prohibits multiple marking )
of bolts in cases where bolting products are manufactured to fully )
comply with more than one specification. CIPC concluded that their J certification for the bolts purchased on ANB P0 #Q1645 were in full I compliance with sal" Grade B7 since they had a mark of C for Cardinal, U as a heoc code, B7 for the material specification and L7 for SA320 Grade L7 which the product fully complies with. ANB accepted CIPC explanation and closed out the nonconformance with QC supervisor's signature approval. .
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ORGANIZATION: ALLIED NUT & BOLT COMPANY, INCORPORATED KING OF PRUSSIA, PENNSYLVANIA i
REPORT INSPECTION Hn.- 4Q401041/R7-01 RESULTS: PAGF 6 of 8
- 4. Corrective Action Request (CAR)
As part of the ANB annual review of NCR's, they evaluate previous years' audit findings for trends that may be adverse to quality. If adverse trends are found, the QC supervisor is required to issue a CAR. From review of several CARS, it was noticec that CIPC was the only company reported to have excessive nonconformances by ANB's QC supervisor (CAR dated September 1, 1983). In 1983, the QC super-visor issued a CAR regarding adverse trends with CIPC material to the ANB President, specifically, PO-Q 1098 for 2500 PCS 1/2 x 2 1/2 SA193 Gr B7 studs. The CAR description of the discrepant condition reads as follows, "The material was purchased from Sumitomo on Cardinal P0 13308. Sumitomo bought the steel bars from Diado and they were heat treated by Hayasi Sieko. Hayasi Sieko's report indicates tempering performed at 1080*-1150*F. Cardinal's report indicates tempering temperature to be 1150*F. ASTM requires 1100* minimum for Gr B7 material ordered by Allied." As corrective action ANB inquired about and received a telex confirming actual :
tempering temperatures from Sumitomo. The tempering temperatures were confirmed to be in the acceptable range. Sumitomo was instructed i in the future to submit actual tempering temperatures versus a temperature range to ANB.
- 5. Audits
- a. Internal QAP 18, Revision 1, requires ANB to perform internal audits on a quarterly basis to verify conformance to the provisions of the QA manual. These quarterly audits evaluate each QAP program procedure over the course of a twelve month period.
The 1983, 86, and 87 quarterly audit packages were reviewed for completeness and validity. Ten quarterly audit packages were i reviewed.
In all cases the ANB audit checklist was complete and approved by the ANB President. Also, in all cases, the formal report was submitted to the President within 10 days,
- b. External The ANB approved vendor's list (AVL) was reviewed. From cross-referencing suppliers identitied on purchase orders with the AVL, it was apparent that Pottstown Plating was not on the ANB AVL.
l ORGANIZATION: ALLIED NOT & BOLT COMPANY, INCORPORATED
- KING OF PRUSSIA, PENNSYLVANIA REPORT INSPECTION Hn_- 44001003/R7-01 RESULTS: PAGE 7 of 8 (See nonconformance 87-01-04.) Pottstown Plating provided plating services for ANB under P0 Q8389 dated January 21, 1987, I and P0 Q8249 dated January 5, 1987. ]
l P0 Q8389 required clad plating of 109 PCS of 1/2 - 13 x 1 1/2, SA193 I Gr B7 and P0 Q8249 required plating of 970 PCS of SA193 Gr B7, SA194 !
Gr 2H bolts and nuts. In both cases, the plated nuts and bolts were j to be supplied to Public Service Electric & Gas per their P0 P2-179275 1 dated October 30, 1986. Further, QAP 9.0, Revision 1, paragraph 2.1 states: "When standard products are modified to meet speciai customer requirements and the work is subcontracted, the subcontractor is required to have a quality program, approved by Allied, which provides for control of manufacturing processes." ANB indicated that Pottstown Plating facility had a satisfactory historical performance, however, a formal audit had never been performed.
- 6. Training and Indoctrination No procedure or instructions were in place that specifically addressed how Allied's corporate training requirements were to be implemented with respect to the requirements found in ANSI N45.2.6. Further, ANB certification process only addresses the qualifications of personnel performing inspection activities, and not those of auditors.
(See nonconformance 87-01-03.)
Personnel folders of the General Manager, Quality Assurance Manager, Quality Control Supervisor, and individuals assigned as inspectors were examined with respect to their individual training. It was determined that each individual was, in fact, qualified to perform
'their assigned qual.ity related activity. For example, individuals passed inspection courses sponsored by the American Society for Quality Control, and have industrial backgrounds sufficient to meet j the Level requirements of ANSI N45.2.6. Further, the QA Manager and ,
) QC Supervisor both have met the auditing qualifications of ANSI l h45.2.23, yet A111ed's QA program does not commit to this standard I or any alternative.
Personnel certification forms, as described in ANB QAP 2.0 were found ,
in each individual's folder attesting to his familiarity with the l l
requirements of the QA manual, yet there was no objective written l evidence that the individuals had been indoctrinated on the QA manual )
and its latest revisions. Interviews with the QC supervisor indicated )
that he was aware of the requirements of the QA manual's latest l revision.
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ORGANIZATION: ~ ALLIED. NUT & BOLT COMPANY, INCORPORATED l
' ' KING OF PRUSSIA, PENNSYLVANIA 1 4 '
REPORT Ih3PECTI0l!
Nn _q,g4QninM /A7-01 RESULT L , PA0E 8 of 8 .
- 7. l Plpnt Tour q ANB is a distributor of fasteners, therefore, manufacturing and l parformancs of special processes do not take place at the warehouse. i ANS has a segregated, fenced in, locked and ider.tified area, clearly )
' designated for ASbE material. i The material ir, the area was tagged with a white tags indicating !
ANB QC approved material. The tags indicate P0 number; item number, inspector and date. Six tagged items were compared with their status on file. The folinwing information from the stetus tags were ,
' cross-referenced with the applicable P0s. No discrepancies were found.
Cert #/Date :
PO#/nate Heat / Description ,Tr a c e_ On file _qAApproval Vendor J 4
Or2159 01P453' T70 184281 Yes Texas ,
03/28/85 1-1/8-) HHN Bolt l M194 G2A 0-2159 D36361. ADG 02/22/85 Yes A&G C1/28/85; 1-1/FB HHN Engineering l Q-2544 D45923 /,hc 05/17/85 ~Yes A&G '
05/23/85 3/4 HHN Engineering 0 4802 -B18369 DH4 0047018 Yes Cardinal 12/10/85 1/8 HHN SA194 ,
Gr 7 ]
0-9113 C6X267 HDD 06/01/87 Yes A&G OE/13/07 1-1/4-8 HHN Engineering l Gr 7 Q-9402 C49284 AMA 06/11/87 Yr:s A&G 06/18/.B7 1/2-13 HA Engineering l E. PERSONS CONTACTEJD*:
Jeroine };osenstock John Jan Francisco, Jr.
S. Deleo I G. S. Korin 1 Al Pjura l
- Present at the exit meeting.
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