ML20237G182
| ML20237G182 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/24/1987 |
| From: | Wigginton D Office of Nuclear Reactor Regulation |
| To: | Schnell D UNION ELECTRIC CO. |
| References | |
| NUDOCS 8709020138 | |
| Download: ML20237G182 (3) | |
Text
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'NUGS4tgy Docket No. 50-483 DISTRIBUTION:
PDIII-3 r/f Mr. Donald F. Schnell DWigginton I
Vice President - Nuclear TAlexion Union Electric Company PKreutzer Post Office Box 149 St. Louis, Missouri 63166
Dear Mr. Schnell:
l
SUBJECT:
QUALITY OF SPENT FUEL RACKS FABRICATED BY U. S. TOOL AND DIE AND ITS PREDECESSOR l
The U. S. Nuclear Regulatory Commission conducted an inspection of the U. S. Tool l
and Die facilities in Allison Park and Glenshaw, Pennsylvania, on March 23-27, l
1987. During this inspection, it was found that
't-implementation of the I
U. S. Tool and Die QA program failed to meet certain NRC requirements. The most i
serious of these appeared to be a breekdown in the QA/QC program concerning in-process examination and weld inspection. This breakdcun resulted in cracked or missing welds. A copy of the inspection report (dated May 12,1987) sent to l
l U. S. Tool and Die, Inc., is enclosed (Enclosure 1).
U. S. Tool and l
l Die's corrective actions were described in a response dated June 9, 1987 (Enclosure 2). NRC's review of the corrective actions were detailed in a letter to U. S. Tool and Die dated July 28, 1987 (Enclosure 3).
Because the inspection findings raise questions concerning the fabrication of spent fuel pool racks and it is our understanding that U. S. Tool and Die (or its predecessor, believed to be Wachter Engineering) racks have been purchased for your facility, please provide the following information.
1.
Please describe the extent to which the U. S. Tool and Die QA/QC progrem was relied upon to assure rack quality; 2.
Please describe your in-factory and/or receipt inspection of the racks; 3.
What findings were made during your receipt inspection of the racks; and 4.
If your receipt inspections found deficiencies in the racks, what corrective actions were taken.
5.
Please describe any additional actions or examinations you plan to undertake to assure that your racks meet the original design and regulatory requirements.
Please provide your response within 60 days of your receipt of this letter.
I eg998cl N E E
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This request for information was approved by OMB under clearance number
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3150-0011 which expires December 30, 1989. Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management, i
Room 3208, New Executive Office Building, Washington, D. C. 20503.
j Sin
- ely, DavidL.khnton,ActingDirector Project Directorate III-3 Division of Reactor Projects
Enclosures:
As stated cc: See next page l
1 1
Office:
LA/PDIII-3 PM/PDIII-3 PD/PDIIr-3 Surname: PKreutzer TAlexion/tg DWigginton Date:
08/,/87 08/2.i/87 08/>i/87 i
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Mr. D. F. Schnell Callaway Plant Union Electric Company Unit No. 1 cc:
J. O. Cermak, CFA Inc.
Mr. Barth D. Withers 4 Professional Dr., Suite 110 President and Chief Gaithersburg, MD 20879 Executive Officer Wolf Creek Nuclear Operating Gerald Charnoff, Esq.
Corporation Thomas A. Baxter, Esq.
P. O. Box 411 Shaw, Pittman, Potts & Trowbridge Burlington, Kansas 66839 2300 N Street, N. W.
Washington, D. C.
20037 Mr. Dan I. Bolef, President Kay Drey, Representative Mr. G. L. Randolph Board of Directors Coalition General Manager, Operations for the Environment Union Electric Company St. Louis Region Post Office Box 620 6267 Delmar Boulevard Fulton, Missouri 65251 University City, Missouri 63130 U. S. Nuclear Regulatory Commission Resident Inspectors Office RR#1 Steedman, Missouri 65077 Mr. Alan C. Passwater, Manager Licensing and Fuels Union Electric Company Post Office Box 149 St. Louis, Missouri 63166 Manager - Electric Department Missouri Public Service Comission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator U. S. NRC, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources P. O. Box 176 Jefferson City, Missouri 65102 1
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l b [* ps us UNITED STATES
^g 38 NUCLE AR REGULATORY COMMISSION
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W AsmNOTo N. D. C. 20555 k%...+'
May 12, 1987 ItM ft. eeCC10S?/E7-01 U.S. Tool and Die, incorporated ATTh:
Mr. Michael J. Rodgers President 4030 Route 8 Allison Park, Pennsylvania 15101 Gentlemen:
This refers to the inspection conducted by Ms. C. Abbate and Messrs. J. Conway and K. Aspinwall of this office on March 23-27, 1987, of your facilities in Allison Park and Glenshaw, Pennsylvania and to the discussions of our findings with you and members of your staff at the conclusion of the inspection.
The purpose of this inspection was to observe the fabrication and testing processes of spent fuel storage racks at U.S. Tool and Die (UST&D). The areas which were covered included welding, nondestructive, examination, personnel training, procurement, shop quality assurance (QA) implementation and quality records. Areas examined during the inspection and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspectors.
During the inspection, it was found that the implementation of your QA program failed to meet certain NRC requirements. The.most serious of these.appurc.
to be the breakdown in the OA/0C orocram concerning 1Ti-Trocess nimination 8f4 weld inspection. No in-process examinations or weld inspections were being7erformEc 16 'the initial stages of fuel storage rack fabrication.
Additionally, two undersize fillet welds were identified by the NRC inspector after the welds had been inspected and accepted by the UST&D inspector. Several other noncenformances were identified in the areas of measuring and test equipment, procurement, and training, while two violations were identified in the areas of specifying 10 CFR Part 21 on procurement documents and the posting requirements of 10 CFR Part 21. The specific findings and references te the pertinent requirements are identified in the enclosures to this l e t te r."
The enclosed Notice of Violation is sent to you pursuant to the provisions of Section 206 of the Energy Reorganization Act of 1974. You are required to submit to this office within 30 days from the date of this letter a written statement containing:
(1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed. Consideration may be given to extending your response for good cause shown.
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U.i Tcoi ene Die, Incorporated May 12, 1987 Yoc are also requested to submit a similar written statement for each iter which appears in the enclosed Nctice of Nonconfomance.
The responses requested by this letter are not subject to the clearance precedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 19EO, FL 96-511.
In accordance with 20 CFR 2.790 of the Corrission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Pubiic Document Room.
Stocid you have any questions concerning this. inspection, we will be pleased to ciscuss ther with you.
Sincerely, lis W. Herschof Acting Chief n
Vender Inspection 4 ranch Division of Reactor Inspection and Safeguarcs Office of Nuclear Reactor Regulation
Enclosures:
1.
Appendix A-Notice of Violation 2.
Appendix B-hetice of Nonconformance '
3.
Appendix C-Inspection Report No. 99901082/E7-01 4.
Appendix D-Inspection Data Sheets (6 pages) cc-Corconwealth Edison Company ATTN: Mr. Corcell Reed Vice President Pcst Office box 767 Chicago, Illinois 60690 Wisconsin Public Service Corporation ATTh:
Pr. D. C. Hintz
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kanager, Nuclear Power Eost Office Box 19002 Green Bey, Wisconsin 54307 Vemont Yankee Nuclear Power Corporation i
ATTN: Mr. Warren P. Murphy, Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Yemont 05301 t
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APPENDIX A s
U.S.. Tool and Die, Incorporated Docke. No. 9eS010S2/07-01 NOTICE OF VIOLATION As e result of the inspection conducted on March 23-27, 1987 and in accordance with Section 206 of the Energy Reorganization Act of 1974 and its implementing regulation,10 CFR Part 21, the following violations were identified end categorized in accordance with the NRC Enforcement Policy 10 CFR Part 2, Appendix C.
1.
Section 21.31 of 10 CFR Part 21 requires,' in part, that each corporation subject to the regulations in this part assure that each procurement document for a basic component specifies, when applicable, thtt the provisiers of 10 CFP. Part 21 apply.
i s.
Contrary to the abeve, a review of documentation packages for spent fuel storage racks fabricated under ASME Code Section III Subsection NF revealed that while 10 CFR Part 21 was imposed on U.S. Tool and Die, Incorporated (USTLD) by their customers, UST&O did net specify that 10 CFR Part 21 requirements would apply on Purchase Orders (PO) 86-00208 to Columbia Electric Manufacturing; 84-1701 and -1679 to Lo All Pittsburgh; 86-61228 to Cromie Machine and Tool; 82-1051 tor Comercial Fasteners; 86-60802, -01208 and 87-70132 to West Penn Lace; 82-1032 to Allegheny Ludlum Steel; 86-60620 to Industrial Service Centers; 83-1387 to Sandvik; 87-70115 to Weld Star; 86-61112, -70103 and 87-70118 to Alloy-Oxygen Weld Supply; 86-6121E to Metal Goods; and 00-60921, 87-70130 and -70208 to Miliams and Company.
(87-01-01)
}
This is a Severity Level V violation (Supplement VII).
2.
Section 21.0 of 10 CFR Part 21 requires, in part, that each corporation post current copies of the regulations of 10 CFP. Part 21, Section 206 cf the Energy Reorganization Act cf 1974 and procedures adopted pursuant to the regulations of 10 CFR Part 21.
If posting of the regulations or the procedures is not practical, the licensee may, in addition to posting Section 206, post a notice which describes the regulations / procedures.
Contrary to the above, UST&D failed to post Section 206 of the Energy Reorganization Act of 1974.
(87-01-02) i This is a Severity Level V violation (Supplement VII).
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l APPEriDIX B U.S. Tool and Die, Incorporated Dorket Nc. 999010C2/E7-01 f,0TICE Of tiOfiC0fiTORMANCE Luritg ar. inspcetion conducted March 23-27, 1987, the implementation of the Quality Assurance (CA) Program at the UST&D facilities in Allison Park and 61enshaw, Pennsylvania was reviewed with respect to the fabrication of spent fuel stcrage racks. The applicable QA Program requirements are 10 CTR Fart 50, Appendix B, 10 CFF Part 21, and UST&D's QA Prograr Manual (QAPM), Revision 2, 20, 1986. Based on the results'of this inspection, it appears dated Jarvery that certain activities at the U5l&D f acilities were not conducted in accordance with these corritments. These items are listed below.
Criterion X of Appencix B to 10 CFR Part 50 requires, in part, that a J.
prograr. for inspection be established and executed by or for the i
crganizaticr. performing the activity to verify confortr.ance with the documented instructions, procedures and drawings.
Section 34.3C cf the UST&C QAPM, requires, in part, that in-process examination or surveillance be conducted by Quality Control personnel to i
verify dimensions and that f abrication methods'used by production are in f
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 appropriate procedures and that no production activi-ties progress past these points until Quality Control has perfomed their duties.
Contrary te the above, in-process examiretiens were not being performed at the south shop per the " Production Work Routing and Inspectien Plan,*
Drawing 8601-0, Revision 1, for the spent fuel racks being manufacture for the LaSalle project.
(67-01-03)
Criterior, X of Appendix B to 10 CFR Part 50 requires, in part, that e 2.
p,rogram for inspection of activities affecting quality be established and e>ecuted to verify conferrance with the documented instructions, procedures and drawings.
Section 10.EA of the UST&D QAFh requires, in part, that all shcp inspections / examinations / monitoring are performed by qualified Quality Control personnel and in accordance with written procedures.
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Iv 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.
Centrary 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, calibrated and adjusted at specified periods to ma'rtain accuracy.
Section 12.2B, of the UST&D QAPM requires, in part, that the interval of calibration for each item be established in procedures.
e-Section 2.4 of UST&D Procedure 12.1, " Control of Inspection Measuring Equipment," Revision 2, requires, in part, that each piece of inspection
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equipment be assigned a permanent 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 to the above, a review of measuring and test equipment (M&TE) and calibration records revealed the following:
a.
Documented evidence was not available to verify that the calibration interval for M&TE was established in procedures.
b.
The four inner diameter (ID) box mandrels for the Kewaunee, Yemont 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.
systet for the modified ID box mandrel for the LaSalle project in the north fabrication shop.
(87-01-CE) 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.
i f The QA sectioris cf the technical specifications for the Kewaunee, Vermcnt Yankee, and LaSclle projects impose the requirements of ANSI N45.2 and/or At!!/ASFE NCA-1 upon USTED.
Section 5 of ANSI N45.2-1977 and Section 4 (Basic Requirements) of ANSI /
ASME r!0A-1-19E3 indicate that P0sshall require suppliers / vendors to have a QA program cor.sistent 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 AStiE Code Section III,.
Subsection NF indicated that quality requirements (e.g., QA Program) were not passed on to vendors for the following P0s: 86-60746 -60813 -60814 and -61228 to Cromie Machine and Tool; 66-60200 to Columbia Electric Manufacturing; B4-1701 and -1679 to Do All Pittsburgh; 82-1068 to Capitol Pipe and Steel Products; B2-1051 to Comercial Fasteners; 86-60EC2,
-C1206, and 07-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 25-51023 to Techalloy; E2-1311 and 03-1387 to'Sandvik; 87-70115 to.
Welester; 06-70103 to Alloy-Oxygen Weld Supply; and 66-61216 to Eetal Goods.
(67-01-06)
Criterion IV of Appendix B to IC CFR Part 50 requires, in part, that 5.
measures be established to assure that applicable regulatory requirements, desi5n bases, and other requirements which are'necessary to assure quality are suitably included or referenced in the documents for procurement.
Section 4.2E of the QAPM requires, in part, that purchase orders for material delineate all applicable requirements of the contract documents.
Section f
- of Prneadure 4.1, " Procurement Document Control," Revision 5, requires, in part, Wt procurement documents reference all design specification requiremer.ts applicable to the items being purchased.
Section 5.3 of NES Specification No. E3A2256, " Specification for the Fabrication and Inspection cf the Vermont Yankee huclear Power Station Spent Fuel Storage Racks," Fevision 0, requires that all weld filler metals meet the requirements of Section III. Subsection NF including deltt ferrite determination.
Section 4.4B of the QAPM requires, in part, that the quality assurance manager er 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 WALCO Corporation for markers and tape was not signed / initialed and dated by QA personnel.
(27-01-07)
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' J Criterion V of Appendix B to 10 CFR Part 50' requires, in part, that 6.
activities affecting quality be prescribed by documented instructions.
procedures or dravings.
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 ebove, it was noted thct 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 material.
(87-01-08) i Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that 7.
instructices, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important
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activities have been satisfactorily accomplished.
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Section 5.2B of the QAPM requires, in part, that, as applicable.
i 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 J
surveillance to determine that the shop is providing material, parts, subassemblies, pieces, and/or components which comply with UST&D QA/QC progran 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-pre, cess examinations.
(87-01-09)
Criterion XIV of Appendix B to 10 CFR Part 50 requires, in part, that E.
measures be established to indicate, by the use of marking, the status of inspections and tests perfomed 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.
Secticn 14.2A of the QAPM requires, in part, that record of in-process examination or surveillance be noted on the part/ component / subassembly.
Section 2.3 of Procedure 10.3, *Inprocess Examination,' Revision 3, requires, in part, that documentation is not required for in-process examinations; however, each part, subassembly, piece and/or component which is in-process examined be physically marked or documented as being exanined by UST&D personnel performing the examination.
[
o Section 3.2 of Procedure 10.3 requires, in part, that QA/QC personnel mert each piece in-process examined with a unique marking to indicate the piece, part, sub-assembly.snd/or component has been examined and by whor.
Contrary to the above, marking procedures used by the south shop OC inspector for in-process examination do not clearly identify items or components which have satisfactorily passed the required examinations or who examined the part.
(67-01-10)
Criterion VII of Appendix B to 10 CFR Part 50 requires, in part, that S.
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, complaity, and quantity of the product or services.
Sectier. 7.2B of the QApM requires, in part, that vendors be evaluated and approved tased on their capability to provide material, equipment and/or
-r services.
Section 3.1.1 of Procedure 7.2, " Evaluation of Vendors," Revision 1, requires, in part, that vendor evaluations be tonducted to provide confi-dence in the vendor's QA Progran for meeting the quality requirements.
Contrary to the above, vendor evaluations had not been performed on Do All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D.
(87-01-11)
Criterion II of Appendix B to 10 CFR Part 50 requires, in part, that the 10.
quality assurance program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and.u intained, Section 2.5 of the QAPM requires, in part, that all UST&D personnel perfor-o ring quality activities be trained in the requirements of UST&D's QA Pro-gram as applicable to their activity and that their qualification, indoctri-nation, and training be controlled to obtain suitable proficiency.
S.ection 2.1 of Procedure 2.3, " Training," Revision 3, requires, in part, that all UST C personnel performing quality related activities be trained in the requirements of UST&D's QA Program as applicable to their activity.
Centrary to the above, training records did not exist for two UST&D shop employees.
(87-01-12)
Criterion VI? of Appendix B to 10 CFR Part 50 requires, in part, that 11.
measures be established to assure that purchased material, eqsipment and services conform to the procurement documents.
0 Section 7.2E of the QAPM requires, in part, that vendors shall be evaluated and approved based on their capability to provide material, equipment and/or services.
Section 2.1 of Procedure 7.2, " Evaluation of Vendors," Revision 1, requires, in part, that an evaluation.be made on preposed new vendors furnishing quality related materials and/or services prior to, or within 14 days of, issuance of a purchase order.
86-60143, dated February 34, 1986, was placed Contrary to the above, PO with Industrial Service Center while the evaluation was performed March 12-13, 19E6.
(87-01-13) e
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O CPE,. HAT: Jt;.
U.S. TOOL AND CIE ALLISCN PARK, PEN!;SYLVANIA REcCH INSPECTION INSPECT 10t; NO..
09901082/E7-01 DATES: 0?/?3-27/F7 Ch-SITF FWDC-lin CO?.RESDONDENCE ADDRESS:
U.S. Tool and Die ATTN: Mr. Michael T. Rodgers President
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4030 Route 8 A11isor, Park, Pennsylvania 15101 ORGAhl2AT10r:AL CONTACT: Mr. Frank E. Witsch TELEPH0t!E t.' UMBER:
41 M F7-7030 f
NUCLEAF IhDUSTRY ACTIVITY: Fabricator of spent fuel storage racks.
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ASSIGhED INSPECTOR:
h/L I1A_ M 6
1 Claudia M. Abbate, Frogram' Development and Reactive ate Inspection Section (PDRIS) j OTHER INSPECTORS: James T. Conway, PDRIS I
Kenneth G. A pinwall, Consultant APPROVED eY:
bXM I M/ 7 Jafes C. Stone, Chief, FDRIS, Vendor Inspection Branch
'Da'te II;S*ECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50 Appencix B, 10 CFR Part 21.
L.
SCOPE: Observe the fabrication and testing processes regarding the fabrication of spent fuel storage racks. Welding, nondestructive testing, persennel training, quality control inspection, procurement, shop QA implementation and quality records were reviewed.
PLANT SITE APPLICABILITY:
Callavey, Ginna, Kewaunee. Q Salle 2. Nine Mile 4
Point 2, Seabrook, Shoreham, Temora wn,ee lio~lTCreek
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ORF Ah]2AT:Ct.:
U.S. TOOL At;D LIE ALLISON PARK, PEfftlSYLVANI A INSPECTION REPDRT PAGE 2 of 15 tiO. : 999MCE2/S7-01 RESULTS:
A V10LAT10 tis:
Contrary to Secticn 21.31 of 10 CFR Part 21, a review of documentation 1.
packages for spent fuel storage racks fabricated under ASME Coce Section III, Subsection KF revealed that while 10 CFR Part 21 was imposed on U.S. Tool & Die (UST&D) by their customers, UST&D did not specify(that 10 CFR Part 21 requirements would apply on Purch PO) 86-60208 to Columbia Electric Manufacturing; 84-1701 and Orders
-1679 to Do All Pittsburgh; B6-E1228 to Cromie Machine & Tool; 82-1051 to CotTnercial Fasteners; 86-60802, -81208 and 87-70132 to
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West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 86-60620 to Industrial Service Centers; 83-1387 to Sandvik; 87-70116 to Weld Star; 86-61112 -70103 and 87-70118 to Alloy-Oxygen Weld Supply; 86-6121E te Metal Goods; and 86-60921, 87-70130 and -7020B to Williams and Company.
(87-01-01)
This is a Severity Level V violation (Supplement VII).
Contrary tc Secticn 21.6 of 10 CFR Part 2k, UST&D failed te post 2.
Section 20E of the Energy Reorganization Act of 1974.
(87-01-02)
This is a S verity level V violatien (Supplement VII).
B.
h0NCONFORMANCES:
Contrary to Criterion X of Appendix B to 10 CFR Part 60, Section 1.
14.3C cf the US7AL Quality Assurance Prograr Manual (QAPM),
Revision 2, and Section 3.3 of Procedure 14.1, " Production Work Ecuting anc Inspecticn Plan," Revision 0, no in-process examinations were being performed at the south shop per the
- Production L'crk Routing and Inspection Plan," Drawing 8601-0, Revision 1, for spent fuel racks being fabricated for the LaSalle project.
(67-01-03)
Contrary to Criterien X of Appendix 8 to 10 CFR Part 60, Section 2.
10.2A of the US7&D QAPM, Revision 2, and Section 2.2.1 of Procedure 10.4,
- Final Inspection " Revision 1, two undersize welds were identi-fied by the NRC inspectors on a fuel rack which had been inspected and fcund acceptable by UST&D Quality Control.
(87-01-04)
Contrary to Criterion XII of Appendix B to-10 CFR Part 50, Section 3.
12.2B of the UST&D QAPh, Revision 2, and Sections 2.4 and 2.6 of Frocedure 12.1, " Control of Measuring and Test Equipment," Revision 2, a review of measuring and test equipp.ent (M&TE) and calibration records revealed the following:
ORGAh12A~)CN U.S. TOCL AND DIE ALLISON PARK, PEhNSYLVALIA REPDFT INSPECTION NO.: 999010E2/87-01 RESULTS:
PAGE 3 of 15 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 shcp 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) a.
Centrary to Criterion IV of Appendix B to 10 CFR Part 50 Section o
2.2A of the QAPM, Revision 2, Section 5 of ANSI N45.2 and Section 5,
(Easic Requirements) of ANSI /ASME NQA-1, a review of 40 P0s for materials anc :;ervices 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 PCs: 86-60746. -60813, -60814, and -61228 to Cromie Machine end Toul; 80-6028 to Columbia Electric Manufacturing; 84-1701 and -1679 to Do All Pittsburgh; B2-1068 to Capitol Pipe &
Steel Products; 82-1051 to Comercial Fasteners; 86-6082, -81208, anc 87-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; B5-51023 to Techa11cy; 82-1311 and E3-1387 to Sandvik; 87-70115 to Weldstar; BE-70103 to Alloy-Oxygen Weld Supply; and 86-61216 to Metal Goods.
(87-01-06) 5.
Contrary to Criterion IV of Appendix B to 10 CFR Part 50. Sections 4.2E and 4.4B of the QAPM, Revision 2. Sections 2.2, 3.2 and 4.1 of Procedure 4.1, " Procurement Document Control," Revision 5, and Section 5.3 of NES Specification No. 83A2256, 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 06-60610 to WALCC Corporation for markers and tape was not signed /initicled and dated by QA personnel.
(87-01-07) 6.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 5.2B of the QAPM, Revision 2, and Section 6.0 of ANSI N45.2, it was noted that a documented procedure / instruction did not exist to coritrol tools (e.g., wire brushes, grinding wheels,.hanrrers, etc.)
that were designated for use only on stainless steel material.
(87-01-08) 1 MbWep %
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ORGAM EAT 10L:
U.S. TOOL AND DIE ALLISON PARK, PENN5YLVANIA REPCRT INSPECTICN NO.: 99901062/87-01 RESULTS:
PAGE 4 of 15 7.
Coritrary to Criterion V of Appendix B to 10 CFR Part 50. Section 5.2B cf the UST&D QAPM, Revision 2, and Section 2.2 of Procedure 10.3, "Inprocess Inspection," Revision 3, Procedure 10.3 does not provide the QC inspector appropriate guidance indicating the ree.uired ranc~cm sample quantities or percentages needed to ensure a representative sample during in-process examinations.
(87-01-09) 8.
Contrary to Criterion XIV of Appendix B to 10 CFR Part 50, Section 14.2A of the UST&D QAPM, Revision 2, and Sections 2.3 and 3.2 of Procedure 10.3, "Inprocess Inspection," Revision 3, fr.arking procedures used by the south shop QC inspector for in-process examination do not clearly identify items or components whic.h have 5
satisfactorily passed the required examinations or who examined the
- part.
(07-01-10) 9.
Cor.trary to Criterion VII of Appendix B to 10 CFR Part 50, Section 7.2B of the UST&D QAPM, Revision 2, and Section 1.1.1 of Procedure 7.2,
- Evaluation of Vendors," Revision 1, vendor c uluations had not been performed on Do All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D.
(87-01-11) 10.
Contrary to Criterien II of Appendix B to 20 CFR Part 50, Section 2.5 of the UST&D QAPM, Revision 2, and Section 2.1 of Procedure 2.3,
" Training," Revision 3 no training records existec for twe UST&D shop employees.
(67-01-12) 11.
Contrary to Criterion VII of Appendix B to 10 CFR Part 50, Section 7.EE of the UST&D QAPM, Revision 2, and Section 2.1 cf Procedure 7.2, " Evaluation of Vendors," Revision 1, P0 86-60143, o
dated February 14, 1986, was placed with Industrial Service Center prior to the vendor evaluation which was performed March 12-13, 1966.
(87-01-13)
C.
UNRESOLVED ITEMS:
None.
C.
STATUS OF PREVIOUS INSFECTION FINDINGS:
hone. 1his was the first KRC/VIB inspection of this facility.
ORGANIZAT10t.
L'.S. TOOL AND DIE I
ALLISON PARN, PENNSYLVANIA REPCRT INSPECTION NO.: 999CIC02/E7-01 RESULTS:
PAGE 5 of 15 E.
INSPECTION FINDINGS ANC OLHER COWENTS:
1.
Entrance and Exit teetings An entrance meeting was conducted on Narch 23, 1987 at the Allison Park, Pennsylvania office of UST&D. The purpose and scope of the inspection were discussed during this meeting. 05T&D has two fabrication shops. The south shop, located in Glenshaw, Pennsylvar,ia, receives the material and fcrms and welds the individual cells.
The north shop, locateo in Allison Park, Pennsylvania, assembles ar.d welds the cells into fuel storage racks and performs the final
~
inspection.
During the exit meeting conducted on March 27, 1957, the inspection findings and observations were discussed with UST&D personnel.
-r 2.
Spent Fuel Racks - huclear Since 1982, UST&D has fabricated spent fuel racks for six commercial nuclearcustomers(seeTable1,page15). Three projects are currently in progress: LaSalle 2 Kewaunee and Vermont Yankee. The customer's design is being used for the Vermont Yankee and Kewaunee projects, while UST&D's design is being used for the LaSalle project. To date, only five prototype cells have been fabricated J
for Vement Yankee. A number of cells have been fabricated fer Kewaunee, but they have not been assembled into a completed rack.
The NRC inspector reviewed the customer's procurement packeges for the nine projects including a detailed review of the P0s and/or the technical specifications fer four projects: hine Mile Point 2, Vermont iankee, Kewaunee and LaSalle 2.
For all four projects, it was noted that the requirements of 10 CFR Part 50, Appendix B and 10 CFR Part 21 were referenced in the P0s and/or specifications.
The huelear Energy Services (NES) specification for the Yement Yankee project referenced the 19E0 Edition of Sections II, III (Subsection NF), Y and IX of the ASME Code, whereas the 1977 Edition of the same Sections were listed as applicable documents in the Stor.e and Webster (Stk') specification for the Nine Mile Point 2 project.
EDE personnel were to be trained and quclified per SNT-TC-1A, and inspectors were to be qualified to AhSI N45.2.6.
Weld filler metal was to be in accordance with Subsection NF of Section III and specification Ak'S ~AS.9.
In general, the material specifications included ASTM A240, A276, and A564.
Cleaning
J ORGA!;12AT ICN.
U.S. TOOL AND DIE ALLISON PARK, PENhSYLVANI A REPORi INSPECTION NO :
g9902082/S7-01 RESULTS:
PAGE 6 of 15 requirements were noted as Class B of ANSI N45.2.1; and handling, packaging, and shipping were to meet the Level C requirements of AhSI h45.2.2.
Record retention was in accordance with ANSI N45.2.9 and typical documents shipped to the customer included: certified material test reports for stainless steel and weld material, heat treatment certifications (17-4 PH material), NCE reports, inspection reports, nonconformance reports, repair and rework repcrts, and a certificate of conformance from UST&D.
3.
Plant Tour
]
9 l *'l The inspectors toured the north and south fabrication facilities at various times in the company of UST&D officials.
Receipt inspection, press ferming of stainless steel sheet and welding of cells were activities noted in the south shop.
Items witnessed in the north
-r shop included machining, installation of poison material (i.e.,
boraflex strips), welding of support plates, PT examination, welding of racks, in-process inspection, cleaning and final inspection.
During the plant tours, it was noted by the inspector that one hammer had a painted handle. UST&C personnel informed the inspector that the paintee tools are used on projects which involve stainless steel while the unpainted tools are used on projects which involve carbon steel. There was no documented instruction / procedure to centrol the use of painted and unpainted tools.
henconformance 87-01-08 was identified in this area.
4 4.
Production Work Routing & Inspection Plan (PWRIP)
A PWRIP, which is similar to a " shop traveler," is generated by i
the Project hanager for each nuclear job. The PWRIP is laid out as an E-size drawing and identifies, for both the north and south I
shops, each production operation, CC inspection /in-process exan.inations, and customer witness points and mandatory hold points.
Several rotes pertaining to the requirements of the customer's specification, inspections including documentation, and hold points are also includtd.
Item No. 7 of the PWRIP states that "documen-tation is not always required" for in-process examinations. This does not agree with Section 14.2 of the QAPM which states, in part, "Ir.spection reports will document all inspections and testing delineated on the Production Work Routing & Inspection Plan." The i
ORG W T ;0h:
U.S. TOOL AhD LIE ALLISON PARK, PENNSYLVANIA I
REPORT INSPECTION hC.:
999010E2/E7-01 RESULTS:
.PAGE 7 of 15 PWE!P, including changes, is approved by the Engineering and QA The PWRIP cane into effect upon the generation of the departments.
QAPM in December 1981, and the document was used on all the nuclear prcjects beginning with Wolf Creek. The inspector reviewed and verified that a PWhlP existed for the nine nuclear projects since 2002.
During the inspection of shop activities, UST&D Drawing 8601-0, Revision 1, " Production Work Routing and Inspection Plan," for the LaSalle project was reviewed. After the individual cell is teck-welded and jetline welded together, an in-process examination 4
and weld inspection were to be perfonned. These two activities are outlined in Procecures 10.3 and 10.5 respectively.
When documentation or inspection reports were requested for the No in-process exerinations r.c weld inspections, none existed.
in-process examinations >
'e being performed on the fuel racks in the initial stages of fabrication at the south shop.
Nonconformance 87-01-03 was identified in this area.
Uptn further review of the procedure, it was noted that in-process exaninctions were defined as periodic random sampling type checks to determine that the shop is providing material which complies with the UST&D QA/QC progran requirements. The shop QC personnel w re unable to define, quantitatively or with a percentage, the number of periodic random sampling type checks to be performed by the inspector.
Procedure 10.3 is inadequate in that it does not give sufficient instructions to the QC inspector as to what quantity a random sample is ar.d cues net ensure,a censistent number of in-process exan.inations among the differer,t inspectors.
henconformance 87-01-09 was identified in this area.
In addition, Procedure 10.3 does not require documentation of the in-process examinations, however, each part may be physically The marked after an in-process examination has been performed.
option of marking components to indicate completion of an in-process examination is used by the south shop QC inspector. However, the mark used is a check mark made on the corr.ponent surface with a f
marking pen. Several similar marks are also made on the component surface during manufacturing. There is no instruction or guidance in Procedure 10.3 for the QC inspector or other shop personnel on how to distinguish the inspector's markings from othtr manufacturing l
markings.
l l
I i
i ORGAh!2M10N:
U.S. TOOL AND DIE ALLISON PARK, PENNSYLVANIA A I
REPORT INSPECTICN HO.: 99901082/67-01 RESULTS:
PAGE 8 of 15 Nonconformance 57-01-10 was identified in this area.
5.
Keldinc and Keldine Machines l
Welding being perfomed on spent fuel storage racks for the LaSalle and Vermont Yankee projects was observed. Three welders were performing production work at the time of the inspection. The following items were reviewed during the inspection: presence of Kelding Procedure Specifications (WPS) at the work area, preheat and interpass temperature centrol, compatibility of WPSs to production work and compliance with WPS essential ard nonessential j
variables.
e Welding machines were icentified with a unique identification nutber for verification of amperage and voltage requirements.
Automatic welding equipment had attached documentation to alert
. ~
the welding operators of amperage and voltage ranges and tolerances for the thickness of the material being used.
In addition, each manual welding machine contained a ccr. trolled record showing each welder who used the machine, date. of use, and WPS used. This record is used as a summary of weld performances for welder qur.lification records.
No items of nonconformance or unreso196d items were identifiec in this area.
6.
Keld Inspection Final inspection of the completed spent fuel storage racks is outlined in Procedure 10.4, Revision 1, and includes a verification cf the physical dimensions of the completed rack to the approved shop drawing dimensions.
{
During the inspection of completed. fuel storage racks for the LaSalle prcject, visual and dimensional checks of fillet welds on fuel rack pedestal mounting pads were perfortned by the NRC inspector. Drawing 8601-30, Revision 4, was used for the inspection. During the inspection, two fillet welds on the mounting pad were found to be less than the one-quarter inch weld specified on the drawing. The i
rack was identified as UST&D rack number 11 (Comenwealth Edison rack number 2FC16C). A review of the final ir.spection checklist reve61ec that these welds h6d been inspected and fcund acceptable by the UST&D QC inspector.
4 l
OFGAhl2A;10h:
U.S. TOOL AND DIE ALLIS0h PAPK, PENNSYLVANIA REPCRT INSPECTION NO.: 99901082/E7-01 RESULTS:
FAGE 9 of 15 i
j
=
Prict to the exit meeting, the welds were repaired. The new welds were examined by UST&D QC personnel and found acceptable. The NRC
)
inspector verified that the welds were acceptable per the drawing.
j Nonconformance 67-01-04 was identified in this area.
7.
Welder Qualifications and Training The welder qualifications to applicable Welding (Procedure Specifi-cations (WPS), Procedure Qualification Records PQR) and design specification requirements were reviewed.
Each welder record included f
bis unique welder identification number, the WPS to which he was qualified and the supporting PQRs.
Training records for four welders were reviewed.
The records documented which training sessicn the welders attended and the date (see Section 16 of this j
repert).
j
{
The UST&D QA program requires that all personnel qualified to WPS 53 for automatic spet/ fusion welding be trained to the applicable WFS, have practical experience and perfom two test samples prior i
to prcduction welding.
The records of eight welders qualified to WPS E3 were reviewed and found in compliance with the require-ments mentioned above.
The review of welder qualifications and training resulted in nc items of nonconfomance or unresolved items; however, training was minimal in that welders are trained only to the WPSs and there is no evidence that welders are trained to new revisions;of KPSs.
L.
Weld Filler Material Control A review of weld filler material control was perfomed using UST&D Procedure 9.2, Revision 4.
The areas which were examined included:
)
I weld filler material storage areas, storage of filler material, markir.g of material (straight and spools), assignment of material inventory control (MIC) numbers and issuance / return records. These items were inspected at the weld filler material issuance stations at both the north and south shops. The review of weld filler material centrol indicated that Procedure 9.2 was being implemented.
~
No items of nonconfomance or unresolved items were identified in this area.
i ah we
~p-L
l 1
i ORGAhl2AT10h:
U.S. TOOL AND DIE ALLIS0N PARK, PENNSYLVANIA j
i REFCRT INSPECTION NO.: 999010E2/67-01 RESULTS:
PAGE 10 of 15 g.
Nondestructive Examination (NDE) Personnel Qualifications The hCE qualification records were reviewed using UST&D Procedure 2.5, Revision 1.
Certifications and qualificatter.s of the UST&D Level III NDE consultant, the QC Manager and two QC inspectors were
(
reviewed.
Prior training hours; general, practical, and specific i
tests, including the amount of questions per discipline and test results; ar.d a verification of annual eye exatrinations received by the personnel were reviewed. Records of training and indoctrination of personnel to the NDE procedures and program were also reviewed.
a.
The review of documentation for KDE personnel qualifications resulted in no items of nonconformance or unresolved items; however, documented evidence of training of NDE personnel was n.ir.imal.
n 10.
Control of Measuring and Test Equipment (MTLE)
The NRC inspector reviewed applicable sections of the QAPM, one procedure and calibration records to detemine whether N&TE was properly identified, controlled and calibrated at specified intervals.
Inspection areas in the north and south fabrication shops were inspected to review the calibration status of gages and measuring instruments found in these areas.
With the exception of four ID box mandrels, the inspected equipment contained a vibro-etcheo S/N. The four mandrels were for the Kewaunee, LaSalle and Vermolit Yankee projects and were located in the south shop. A Cardex system, which is mintained by the QC Manager, is used to record calibration information. Each card a
identifies the type of equipe.ent includir.g S/N, calibration date, celebration frequency, the standard used, and the identity of the individual perfoming the calibration.
Equipment examined at thi. south shop included a vernier caliper, two n.icrometers, one thickness gage, one width gege, one tong test ameter, and four ID box mandrels. At the north shop, one ter.9 test ameter, three micrometers, one dial thickness gage, one vernier caliper, one bore gage, one radius gage set, one inside micrometer set, one optical comparator, one box mandrel (LaSalle project) and three r.icremeter standards were examined.
In addition, the calibration status of the eight welding machines in the fiorth shop was checked.
The information contained on the calibration stickers on the items was in agreement with the applicable card.
1 ORGAM2Al'.Ch-U.S. TOOL AND DIE ALLIS0h PAFJ... PENNSYLVANIA A-1 I
p' IhSPECTICh 999010b2/E7-01 RESULTS:
PAGE 11 of 15 The two AC-DC tong test ammeters (S/N AX-42975 and -58261) are sent te Columbia Electric Manufacturing (CEh) for calibration every two 4
Test reports from CEM indicated that the equipment was years.
calibrated in February 1900 with standards traceable to the National BureauofStandards(NBS). A Certificate of Calibration from Do All Pittsburgh indicated that a master gage block set (S/N C-4) was l
calibrated in October 15C4 with standards traceable to NBS.
It was 1
noted that a document die not exist to identify the specific j
equipment covered by the calibration program including the calibration frequency of such equipment.
Nonconformance 87-01-05 was identified in this area.
11.
Procurement Document Control Forty-three P0s to 15 material manufacturers / suppliers, four P0s to a machining vender, three P0s to two vendors for calibration i
services, and one PO to a plating vendor Were reviewed to assure that applicable technical and QA program requirements were included or referenced in the P0s. With the exception of one order, all the P0s were initialed and dated by' a QA individual. The PO in question was No. 66-60610, dated June 6,1986, to WALCO Corporation for felt tip markers and nuclear grade cloth tape.
Nineteen P0s did not invoke the requirements of 10 CFR Part 21 upon vendors - eight P0s to four manufacturers / suppliers of weld wire, three P0s to two calibration service vendors, one PO tc a machining vendor, one PG to a supplier of festeners, and six P0s to manufacturers / suppliers of-stainless steel.
In adcition, the requirement that a vendor have a OA program which has approved by UST&L was not included in nineteen P0s to vendors - four P0s to Cromie Machine and Tool, one PG to Colurtia Electric Manufacturing, two P0s to Do All Pittsburgh, one PO to Capitol Pipe & Steel Products, one PO to Comercial Fasteners, three P0s to West Penn Laco, one P0 to Allegheny Ludlum, one PO to Techa11cy, two P0s to Sandvik, one PO to Weldstar, one PO to Alloy-1 Oxygen Weld Supply and one PO to Metal Goods.
It was also noted that for PO 87-70118, dated January 16, 1987, to Alloy-Oxygen i
Welding Supply for 2006 ASME Section 11 SFA 5.9 Type 312 filler metal did not contain a oelta ferrite determination" statement.
Violation 87-01-01 and Nonconformances 07-01-06 and 87-01-07 were identified in this area.
- 12. Documentetton Packages (DP)
A DP did not exist for the Yemont Yankee and Kewaunee projects as finished racks were not yet completed for these projects. The
1 OFCAh12ATICN:
U.S. TOOL At;C DIE ALL150h PARK, PENf;5YLVAt.1A r
INSPECTION I
REPORT PAGE 12 of 15 LO.: 999010E2/E7-01 RESULTS:
inspector reviewed three DPs for Rack M120-24'for Wolf Creek and For Wolf Creek, the DP consisted Racks he. 5 and 9 for LaSalle.
of a Bechtel Engineering and Cuality Verification Document; Material Certification Data Sheet; CMTRs from Eastern Stainless Steel, Allegheny Ludlum Steel, and Colt Crucible for stainless steel products; a CMTR from Sandvik, who is a certificate holder, for ER 308 L weld wire; and a certificate of conformance (C of C) from Comercial fasteners for fasteners.
Several foms for box identifi-cation / inspection, bottom plate identification / inspection, lead-in guide assembly to rack, and visual weld inspection reports were A Bechtel Supplier Deviation Disposition Request and a included.
UST&L henconformance Report and Verticality Test Report were also part cf the package.
In addition, a UST&D C of C noted that all materials used in the fabrication of the reference rack assembly confomed to Bechtel specification 10466-C-175.
y The DFs for the two LaSalle racks consisted of the folicwing:
Documentation Ctscklist, Shop Bill of Material (SEM), CMTRs, UST&D C of C, Weld Examination Records, Final Inspection Checklists (FIC).
Deviation / Variance Requests, Qualified Welders List, and a C of C The SBM listed the material inventory control for the boraflex.
(MIC) number as well as the material specification and supplier fer each iten (e.g., bcx half, bottom plate, pedestal body, etc.).
The FIC verified that the following activities were accomplished or a finished rack:
dimensional verification, MIC No. verification, visual weld irspection, cleaning, marking, boraflex verification, and the mandrel insertion test.
ho items of nonconformance or unresolved items were identified in o
this area.
- 13. Vendor Evaluations The NRC inspector reviewed the evaluations UST&D perfomed on its vendors and how approved vendors remain on the Approved Vendors This process is outlined in Procedure 7.2,
- Evaluation of List.
Vendors," Revision 1, dated March 12, 1987.
The packages Eleven vendor evaluation packages were reviewed.
contained the original survey or audit checklist of the vendor and The reevaluations consisted of a reevaluations of the vendor.
Vendor Evaluation Questionnaire and a historical quality performance data review.
l OhGM.12AT10N:
U.S. TOOL AhD DIE ALLISON PARK, PENNSYLVANIA INSPECTION EEFOR-PAGE 13 of 15 NO.: 999010E2/67-01 RESULTS:
I During the review,'it was noted that be 111 Pittsburgh and Columbia i
manufacturing Electric, who supply calibration services, have net been evaluated by UST&D, nor has a historical quality perfomance data record been maintained en either vendor. Also during the review, it was noted that Industrial Service Center had been audited j
by UST&D March 12-13, 1956, while PO 86-60143 to Industrial Service Center had been placed February 14, 1986. This evaluation was not performed within the specified 14 days of issuance of the PD as resired by Sectien 2.1 of Procedure 7.2.
l honconformances E7-01-11 and 87-01-13 were identified in this area.
a.
la. JOCFRPart21 During the inspection, the NRC inspectors examined areas for the It was noted pesting of IC CFR Part 21 at both fabrication shops.
that 10 CFR Part 21, USTIC Procedure 16.2 and Public Law 96-295 Act of June 30, 1980, Section 223 were posted, but Section 206 of the Energy Reorganization Act of 1974 was not posted at the south shcp.
Section 21.6 of 10 CFR Part 21 and USTAD Procedure 16.2, " Reportable Defects and Noncompliance (Nuclear Projects) 10 CFR 21," Revision 2, dated March 12, 1987, require Section 206 to be posted. Prior to i
the exit meeting, Section 206 and other applicable documents were 1
posted at both shops.
l Violation E7-01-02 was identified in this area.
- 15. Trcinino The NRC inspector reviewed UST&D Procedure 2.3, " Training," Revision 23, 1956. The procedure. requires all UST&D personnel 3, dated March performing quality related activites to be trained as applicable to a
their activity. The procedure also requires that training records be maintained.
The NRC inspector reviewed 13 employee training records and training The employee training records identify what session records.
training the employee has received while the training session l
records identify who attended the training, the date and an outline of the subjects which were covered during the training.
During this review it was noted that two machinists employed in the shop had training record files, but had not received any training.
Also noted were the facts that a training record, with no documented I
i training, was present for a retired employee; several training I
ORGALIZ A11Cf.:
U.S. TOOL AND DIE ALLISON PARK, PENNSYLVAt:,1A REPORT Ih5FECTI0tl NO.:
999C1082/07-01 RESULTS:
PAGE 14 of IL records were incomplete in that hire dates and training sessior, subjects were missing; and two employees were trained outside the 45 day limit for new employees.
In addition, UST&D only trains its personnel to the quality control procedure which the employee will be using without an overall QA/QC program training session. The personnel are not trained to new revisions of the procedures nor is there any type of refresher training given to current employees after the initial training course and after they have been employed fer e lengthy amount of time.
Noncenfcmance E7-01-12 was identified in this area.
- 16. Aud M The NRC inspectors reviewed four internal audits. The Internal y
Freject har,agenent Audit, dated May 29, 1986, the Production Audit, deted August 13, 1966, the QA/QC Audit, dated November 12, 1900, and the Engineering Department Audit, dated March 4,1507, were reviewed.
Each audit included a checklist, an audit report (sumary of results),
and was perfomed by a qualified auditor. The audits which were reviewed were perfomed anc' cocumented in accordance with Procedure 18.1,
- Audits," Revision 5, dated March 12, 1987.
No items of nonconfomance or unrest,1ved items were identified in this area.
F.
PER50t:5 CONTACTED:
P. Brinks, QC Manager, South Shop F. DeSimons, Foreman, horth Shop W. Dickson, Director of Manufacturing E. Jablonsky, QC Inspector, North Shop L. Lerenboyer, Welder
- R. Linder, Manager of Engineering
- E. March, Vice Chaiman of the Board, Chief Executive Officer E. Reinhart, QC Mar.ager, North Shop J. Rhoden, Project h6 nager F. Rhodes, Vice President, Manufacturing R. Rudisill, Welder
- M. Rodgers, President R. Stewart, Machinist
- B. Wachter, Vice President, Engineering and Research K. Weber Assistant Project Manager
- F. Witsch, CA Manager
'Attenced Exit Meeting
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ALL150Y PARL, PENhSYLV/tlI A, y,s As4'
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I INSPECTION REP 0k1 RESULTS:
PAGE 15 of 15 KO.: 99901CE2/87-01
.c3
,d I
l'i TABLE 1 I
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- y t'
/r i
Number of ',
. Dele -
f j'/
1 Utility /AE_
Project Type P,a c ks /P6sitinns.
Cempleted St;t,PPS Wolf Creek PWR-MDR.
12/1328 ISEE'
/'
,,, y ',; /
hen-Poison..3 Kerses Gas &
i '1.
Electric /Eechtel l
?
'PWR-MDs.
'Q132E 1902 i
'9j e
SNUPPS T
Cellewy
')
hon-Poison
,rf<
Union E 4ctric/
t Ee chte' '
1 j
v
'Long Islaci' Shoreham BNR-Non 15/17'60
19E3
'l e
Poison B/75L
'/
Lighting /Stene k6ter Flux 2414iv ' '
d, e'
v
& Webster Trap Control jj-
, Rods y,e-Public Eervices Seabrook hew Fuel 3/90' 1983 Storage Company Racks I
hiagere Mohawk hir,e Mili Il
'EWP3NDR
'/
'17/2E30 1964
.I) Poison Stone 31ste,ter 10/1519 7
t 6
1984 1
"/420 Rochester Gas G Ginne
. Modi f f,e d
" PWR' Checker-Electric board to Paison Racks Correnwealt t.
LeSeila II BWR Poison 20/4073 In Progress Edisor i
Wisconsin Public Service Corp.
K' waunee PWR Poison 4/36D In Pregres:
Nuclear Energy Vermont NR Poison 10/2820 In Progress Services Yankee' t
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j TELEPHONE (412) 487-7o30 e
(_
N U. S. TO O L G. DIE, IN C.
os 4030 ROUTE B e ALUSDN PARK. PENNSYLVANIA 15101 t
June 9, 1987 United States Nuclear Regulatory Commission Vendor Inspection Branch Division of Reactor Inspection & Safeguards Office of Nuclear Reactor Regulation Washington, DC 20555 Attn:
Mr. Ellis W. Merschoff, Acting Chief Re:
Docket #9901082/87-01 1
Gentlemen:
In response to the inspection report referenced above and submitted to U.S. Tool & Die, Incorporated on May 1 2,. 1 9.8 7, we submit the following:
APPENDIX A 6
VIOLATION 41 -
... a review of documentation packages for spent fuel storage racks fabricated under ASME Code Section III, Subsection WF revealed that while 10 CFR Part 21 was imposed on U.S. Tool &
Die, Incorporated (UST&D) by their customers, UST&D did not specify that 10 CTR Part 21 requirements would apply on Purchase Orders..."
USTED COMMENT a)
The applicability of,the reporting requirements of 10CTR21 has been placed on UST&D by its various Clients who recognize these requirements do not pertain to material purchased as a commercial product (as defined in 10CFR21)
Only after receipt of commercial products at UST&D and 1
dedication to the specific basic component by UST&D are j
i the reporting requirements'in effect.
(Iitters from the various Client's and the Atomic Industrial Forum's Committee _
Position Paper expanding on this position were presented i
to the NRC inspectors during the inspection).
Based on these documents the imposition of 10CFR21 is not applicable to the following Purchase Orders: 486-60802, l
-81208, and #87-70132 to West Penn 1.aco; 487-70115 to l
Weld Star; t86-61112, -70103, and iB7-70118 to Alloy-Oxygen Weld Supply; #86-61218 to Metal Goods; and 486-60921, 487-70130, and -70208 to Williams & Company.
g[
b)
Per project specifications,10CTR21. was not applicable to:
P.O.082-1051 to Commercial Fastensrs; 682-1032 to Allegheny Ludium; #86-60620 to Industrial Service Center and therefore not imposed on the vendors.
c)
On both the original and revision il of P.O.483-1387 to Sandvik, the applicability of 10CFR21 is noted on f.Page 2 of 2.
d)
P.O.686-60208 to Columbia Electric and #84-1701 alId 484-1679 to Do All Pittsburgh were for service to commercial type tools.
l P.O.086-61228 to Cromie Machine and Tool was for subcontracting machining of UST&D supplied material.
10CFR21 should have been noted on this Purchase Order.
j CORRECTIVE ACTION for Item (d)
A revision to the Purchase Orders $86-60208 to Columbia y
Electric; 084-1701 and #84-1679 to Do All Pittsburgh; and #86-61228 to Cromie Machine & Tool will be issued and include the reporting requirements of 10CTR21.
y A review of 10CTR21 and UST&D's procurement procedures will be made with all personnel-processing purchase orders to prevent recurrence.
This Corrective Action will be completed by June 30, 1987.
Internal audit activities will prevent recurrence.
l VIOLATION f2 -
"... UST&D failed to post Section 206 of the Energy Reorganization Act of 1974. (87-01-02)"
l UST&D COFF.ENT I
Section 206 of the Energy Reorganization Act of 1974 was posted l
during the inspection as confirmed by Item 14 (page 13) of the I
NRC Inspection Report.
CORRECTIVE ACTION
~
~
Corrective Action has been completed.
Internal audit activities will prevent' recurrence.
1 i
j l
e APPENDIX B NONCONTORMANCE il
... in-process examinations were not being performed at the South Shop per the " Production Work Routing and Inspe6 tion Plan," Drawing 8601-0, ' Revision 1, for the spent fuelf racks being manufactured for the LaSalle project. (87-01-03 "
UST&D COMMENT In-process examinations not performed at the South Shop were performed at the North Shop prior to installation of the cells into the final rack assembly.
CORRICTIVE ACTION A change has been made in Production supervisory personnel at the South Shop.
Complete in-process examination records have been started as of March 25, 1987 at the South Shop.
To prevent recurrence, a training' session will be held with all Quality control personnel to review the requirements of the in-process examination and Production Work Routing & Inspection' Plan procedures.
This review will be complete by June 30, 1987.
NONCONTORMANCE 82
"... 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)"
o UST&D COMMENT Upon discovery, a weld pass was added to the undersize welds found by the NRC inspector.
The balance of the welds on the respective subassembly were checked by the Quality Control Manager and found to be of the proper size.
~
_ CORRECTIVE ACTION A review of the use of weld gauges and weld acceptance criteria will be made with Quality Control personnel by June 30, 1987 to prevent recurrence.
j NONCONFORMANCE $3 j
f
"... a review of measuring and test equipment (M&TE) and calibration records revealed the following:
(
s a)
Documented evidence was not available to verify that the calibration interval for METE was established in procedures, b)
The four inner diameter (ID) boxmandrelsforthejKewannee, Vermont Yankee, and LaSalle projects in the South' f abrication shop were not identified with a permanent unique S/N applied by vibro-etching or with a durable label.
c)
A calibration interval was not established in the "Cardex" i
system for the modified ID box mandrel for the LaSalle project in the North f abrication shop. (87-01-05)"
UST&D COMMENT Corrective Action has been or will be taken as follows:
e a)
As delineated in UST&D's calibration procedure, the calibration j
intervals are established in the "Cardex" system but will be
,p incorporated into an Appendix to Procedure 12.1.
This addition to the procedure will be made by June 30, 1987.
b)
Although the box gauges were identified with the project name painted on and the' sizes of the various gauges precludes use on other than what they were made, each box j
gauge has been given a unique serial number.
A durable label with this serial number on it has been attached to the appropriate box gauge.
c)
The calibration interval for all box gauges has been established.
This modified box gauge for the LaSalle project is being checked prior to and after use on each rack.
o CORRECTIVE ACTION To prevent recurrence, Quality Control personnel will participate in a training session to review UST&D's calibration procedure.
This training session will be conducted by June 30, 1987.
4 e
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..... ~..
i NONCONTORMANCE #4 i
a review of'43 purchase orders for materials and services related to spent fuel racks fabricated under.ASME Code Section III, Subsection NT indicated that quality requirements (e.g.,
Quality Assurance Program) werenotpassedontovendprs..."
UST&D COMMENT a)
P.C;486-60746, -60813, -60814 and -61228 to Crom16 Machine
& Tool were for machining UST&D supplied material.
Material traceability has been maintained and 1004 receipt inspection performed by UST&D of the machined parts.
Cromie Machine follows UST&D Quality Assurance / Quality Control Program and is on our Approved Vendor List based on these criteria.
b)
P.O.lB6-61218 to Metal Goods was for material ordered for handling equipment and therefore not subject to Quality Assurance / Quality Control requirements.
~
c)
P.O.tB2-1051 to Commercial Fasteners and P.O.682-1032 to Allegheny Ludlum was for material for a DOE project.
The project specifications did not require imposition of the 10CTR50 Appendix E requirements.
dl P.O 986-60802, -81208, and 687-70132 to West Penn Laco, P.O.982-1311 at:d 83-1387 to Sandvik, P.O.987-70ll5 to Wald Star and P.O.#65-51023 to Techalloy does not Lnclude furnishing material to their Quality Assurance / Quality Control Program.
However, a review of the Material Test Reports for the material ordered shows the material has been furnished by ASME Certificate Holders and in accordance with their appropriate Quality Assurance / Quality Control Program.
e)
P.O.686-70103 to Alloy Oxygen does impose furnishing material j
in accordance with their Quality Assurance / Quality Control Program by the notation of "Q" material.
This notation is Alloy-Oxygen's terminology for t. heir Quality Assurance /
Quality Control Program, f)
Columbia Electric Manufacturing and Do All Pittsburgh are j
manufacturers of commercial grade tools with certificates of conformance for calibration of said tools traceable to the National Bureau of Standards.
CORRECTIVE ACTION J
Revised P.O.486-60802, and 487-70132 to West Penn Laco; 482-1311 and #83-1387 to Sandvikt 487-70115 to Wald Star; and 485-51023 to Techalloy will be issued and include the requirement to furnish material per their Quality Assurance.
Quality Control Program.
l To prevent any question of imposing a quhlity program requirement, personnel involved in the purchasing policy will receive training by June 30, 1987 on the procurement i
requirements of UST&D's Quality Assurance Program.
'. ~~
NONCONTORMANCE #5 a review of purchase orders indicated that P.O.487-70ll8 to i
Alloy Oxygen Welding Supply for stainless steel weld filler j
metal did not contain a delta-ferrite determination statement',
1 and P.O.tB6-60610 to WALCO Corporation for markers and tape was
-l not signed /inir.iated and dated by Quality Assurance personnel.
(87-01-07)"
'ti UST&D COMMENT i
The weld wire ordered from Alloy-Oxygen Welding Supply is of a composition that by its nature far exceeds the delta-ferrite minimum requirements of ASME Section III, Subsection NF.
The purchase order to WALCO did get through the Quality Assurance / Quality Control system without the proper signature.
1 l
CORRECTIVI ACTION i
~
Revised purchase orders will be issued with the proper w
requirements and signatures.
These actions will be covered in the training session for purchasing personnel to be conducted by June 30, 1987 to prevent recurrence.
NONCdNFORMANCE (6
"... it was noted that a documented procedure / instruction did not exist to control tools (e.g., wire brushes, grinding wheels, hammers, etc.) that were designated for use only on stainless steel material.
(87-01-08)"
UST&D COMMENT The vast majority of work done at UST&D is with stainless steel, however, some carbon steel work has been done.
It has been UST&D's standard operating procedure over the years to paint tools used on carbon steel.
This procedure has never been put into writing.
{
CORRECTIVE ACTION
~
{
Instructions will be written to the Production Department to, i
paint tools used on carbon projects and a training session will be held with Production personnel to assure painted tools will not be permitted for use on stainless steel.
This Corrective Action will be completed by June 30,. 1987.,
l l
/.
\\
1
m
-1 NONCONTORMANCE #7
"... Procedure 10.3 does not provide the Quality Control Inspector appropriate guidance indicating the required random sample quantities or percentages needed to ensure a representative sample during in-process examinations.
(87-01-09)"
f UST&D COMMENT i
As part of the in-process inspection, material tra embility is maintained on a 1004 basis; all cells are gaged to. assure proper dimensions are maintained; and as a minimum, machined parts with critical dimensions are "first piece" inspected, and spot checked on a 10% random sampling basis.
If any discrepancy is revealed'by this inspection, a minimum of 10 previously fabricated pieces are checked.
Any discrepancy found in these 10 pieces will require a 100% inspection of all pieces.
l 1
CORRECTIVE' ACTION g
Procedure 10.3 will be revised to include the above quantitative acceptance criteria and training will be g
conducted with Quality Control personnel by June 30: 1987 to review this changs.
~
l NONCOUFORMANCE fB
"... marking procedures used by the South shop Quality Control inspector for in-process examination do not clearly identify items or components which have satisfactorily passed the required examinations or who examined the part.
(87-01-10)"
UST&D COMMENT Corrective Action will be taken in the form of training of Quality Control personnel to indicate performance of inspection by initialing the pieceu inspected when other records will not be generated.
This training will occur by June 30, 1987.
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4 ans I
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7.- -
.. ~... -.
NONCONTORMANCE 99
"... vendor evaluations had not been performed on Do All.Fittsburgh and Columbia Electric Manufacturing who provide calibration-services for UST&D.. (87-01-11)"
i UST&D COMMENT r
t These pieces of equipment were purchased under the Quality Assurance / Quality Control Program of the prior own rship of UST&D.
Historic data records for Columbia Electric Manufacturing and Do All Pittsburgh were available at the time of the NRC inspection.
UST&D's. Procedure 12.1 (Para 2.7.1) states that a manufacturer of measuring / test equipment can be considered pre-qualified to calibrate their equipment.
Certification has been provided by these manufacturers that -
5 the calibration methods and equipment used is traceable to the National Bureau of Standards.
3 CORRECTIVE ACTION A re-evaluation will be conducted'on these two vendors by August 15, 1987.
NONCOhTORMANCE i10 training records did not exist for two UST&D shop amployees.
(87-01-12)"
UST&D COMMENT The two machinists have been employed by UST&D for over 15 and 20 years and training had not been documented.
CORRECTIVE ACTION Corrective Action will include training of employees to their activities and documentation will be completed by June 30, 1987.,
e
-n____-_-__x._--_-...
_.n
. ~.. - - - -
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F UST&D COMMENT This purchase order was issued to Industrial Service Center with a provision that no material be shipped until Industrial The first shipment of Service Center was audited by UST&D.
material ordered by this purchase order was received by UST&D on April 8, 1986.
CORRECTIVE ACTION Atrainingsessionwillbeconductedwithprocurkment personnel by June 30, 1987 to review purchasing getivities,
f U.S. Tool & Die, Incorporated feels that the above Corrective Action will satisfy the Violations and Nonconformances uncovered by this y
NRC inspection.
Sincerely, U.S. Tool &,IE, INC.
,/
~
t Michael Rodgers President MJR:gb M
e men h
O e
a
y
(_______
Commonwealth Fdison Company ATTN: Mr. Corcell Reed Vice President Post Office Box 767 Chicago, Illinois 60690 1
Wisconsin Public Service Corporation l
ATTN: Mr. D. C. Hintz Manager, Nuclear Power Post Office Box 19002 Green Bay, Wisconsin 54307 Vermont Yankee' Nuclear Power Corporation ATTN: Mr. Warren P. Eurphy, Vice President and Manager of Operations 2D 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Bechtel Energy Corporation ATTN: Mr. Robert Baramore Project Supplier, Quality Supervisor 5400 Westheimer Ct P. O. Box 2166 Houston, Texas 77252-2166 ic:
I bcl 3
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UNITED STATES 5
NUCLE AR REGULATORY COMMISSION y
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/
July 28, 1987
?
Docket No. 99901082/87-01 U.S. Tcol and Die, Incorporated ATTN: Mr. Michael J. Rodgers President 4030 Route 6 Allison Park, Pennsylvania 15101 Gentlemen:
Thank you for your letter dated June 9, 1987, which described the corrective action U.S. Tool and Die, Incorporated (UST&D) has and will implement in response to the Notice of Violation and Items of Nonconformance identified in Inspection Report flo. 99901052/87-01, dated May 12, 1987. Your response and corrective action for Notice of Violation 87-01-02, and Items of Nonconformence 87-01-04, 87-01-05, 87-01-07, 87-01-08, 87-01-09, 87-01-10, and 87-01-12 appear to be adequate and no additional information is requested. The following items, however, require additional information to determine the adequacy of the UST&D response and corrective action.
Part n) of the response to Notice of. Violation 87-01-01 states that after receipt of comercial grade material at UST&D and dedication to the specific basic component by UST&D, the reporting (requirements of 10 CFR 21 are in effect.
This is in accordance with 10 CFR 21.3 c-1).
Please provide a description of UST&D's dedication process that is used to upgrade comercial grade products for use as basic components and a sample of the documentation implementing the dedica-tion process for Pos 86-60802, -81208, -61112, -70103, ~61218, -60921, 87-70132,
-70115 -70118, -70130, and -70208. For part b) of that response, please provide pertinent sections of the project specifications which address the applicability J
of 10 CFR 21 to P0s 82-1051, -1032, and 86-6020.. Part c) states that 10 CFR 21.
is imposed on page 2 of PO 83-1367 to Sandvik. Please provide a copy of P0 55-1387.
It should be noted that the NRC has not taken a position on the Atomic Industrial Forum's Comittee Position Paper, "Recomended Practices for Procurement of Replacement / Spare Parts for huclear Power Plants." Also, in addition to imposing 10 CFR 21 on UST&D, customers in. pose ASME Code Section 111 Subsection NF and a
10 CFR 50, Appendix B in their P0s and specifications. UST&D must comply with 10 CFR 21 whenever a specification unique to the nuclear industry (e.g., ASME Section III; 10 CFR 50, Appendix B; 10 CFR 21; etc.) is invoked in the customer's j
P0.
i The response to Item of Nu'nconformance 67-01-03 states.that in-process examinations not performed at the South Shop were performed at the North Shop prior to installa-tion of the cells into the final rack assembly. Please provide assurance that
]
the types of in-process exams performed at the North Shop met the requirements of " Production Work Routing and Inspection Plan," Drawing 8601-D, and Procedure i
14.1.
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i U.S. Tool and Die, Incorporated July 28, 1987 The response to item of Nonconformance 87-01-06 is incomplete in that P0 82-1068 to Capitol' Pipe and Steel and PO 86-8120E to West Penn Laco were not addressed in the response.
It was stated in part a) of the response' that I
Cromie Machine follows UST&D's QA/QC program. Please provide assurance of this and what controls are implemented to ensure the UST&D QA/QC program is being followed at Cromie Machine. Part e) of the response states that *Q" on P0s to Alloy Oxygen implies imposition of their QA/QC program on that P0. Please
)
provide assurance that the individual issuing the P0 acknowledges what special notations are required on certain P0s which impose QA/QC programs. C of Cs and CMTRs docur:ent the final products acceptability, however, this type of documentation does not ensure the implementation of a QA/QC program. For part
{
f), please provide assurance that QA/QC programs were implemented at Columbia i
Electric Manufacturing and Do All Pittsburgh and these types of manufacturers have QA/QC programs in place.
The response to Item of Nonconfomance 87-01-11 stated that Historic Data Records are available for Columbia Electric Manufacturing and Do All Pittsburgh; please provide these reports. A copy of the NRC position regarding audits of suppliers who offer calibration services for measuring and test equipment that they manufacture is enclosed for your information.
One final note on the response to Item of Nonconfomance 87-01-13, the training given to procurement personnel should include measures to ensure that the "no j
shippi.ng until aucit is performed" clause is added to the P0 as needed.
1 If you have any questions concerning these requests for additional information, please contact Ms. Claudia Abbate at (301) 492-4776 or Mr. James Stone at (301) 492-9661.
Sincerely.
Ellis W. Eerse f, Acting Chief Vendor Inspecti Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation
Enclosure:
As stated a
w-O
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1 l
Bingham-Willamette Company ATIN:
Mr. J. L. Wood
)
i Quality Assurance Supervisor
)
P. O. Box 1024T I
Portland, OR 97210 Centlemen:
I
SUBJECT:
QA PROGRAM REQUIREMENTS FOR SUPPLIERS OF CALIBRATION SERVICES The Wood /Potapovs letter dated July 25,'1983, requested the Commission's concurrence with Bingham-Willamette Company's (BWC) position (ref. Rove /Barnes j
letter dated January 11, 1982) on the audit requirements of suppliers of calibration services.
{
l
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The Division of Quality Assurance, Safeguards, and Inspection Programs (QASIP) in the Office of Inspection and Enforcement was contacted to obtain an official s
NRC position on the above subject.
The following information states the NRC
{
position received from QASIP, and the position addresses the following three types of suppliers of calibration services:
i
. 1.
Suppliers who offer calibration servi'ces for measuring and test equipment not manufactured by them.
2.
Suppliers who offer calibration services for measuring and test equipment that they manufacture.
3.
National Bureau of Standards.
With regard to whether a quality assurance program satisfying the provisions of ANSI N45.2 is required of these three types of suppliers, our position is as l
j follows:
The suppliers noted in types 1 and 2 above are required to have a qualith l
assurance program to the extent necessary to assure the quality of the safety related service and product provided.
This means that'the I
appropriate QA criteria of Appendix 8 to 10 CFR Part 50 and the appropriate 4
provisions of the implementing standard, ANSI N45.2, should be applied consistent with the activities undertaken in the generation of the service and product; e.g., design, procurement, manufacturing, testing, etc.
.In the case of the type 3 supplier, the National Bureau of Standards, it j
is not necessary for the purchaser to assure that this organization have a quality assurance program that meets the applicable requirements of Appendix 8 to 10 CFR Part 50 and ANSI N45.2 since it is a nationally i
recognized laboratory with proven abilities and disciplines.
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i m moOp y
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Bingham-Willamette Company,
With regard for the need of preaward evaluation and postaward audits for these three types of suppliers, our position is as follows:
A preaward evaluation and postaward audits are required for the types 1 and 2 suppliers, It should be noted that the results of pre-award evaluations that have been performed on the same supplier by
)
another purchaser working to a QA program that satisfies Appendix B to 10 CFR Part 50 may be shared among purchasers; e.g., utilization of the CASE register.
A preaward evaluation and postaward audits are not required for work performed at the National Bureau of Standards.
Please accept my apology for the delay in responding to BWC's 1982 letter.
If you have any questions on the above comments, please contact Jim Conway (817) 860-8236 or Ian Barnes (817) 860-9176.
j Sincerely,
)
mo sic"*d
- ons C.J.HAhW
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i Uldis Potapovs. Chief l
Vendor Program Branch a
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