ML20237G230
| ML20237G230 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/24/1987 |
| From: | Wigginton D Office of Nuclear Reactor Regulation |
| To: | Fay C WISCONSIN ELECTRIC POWER CO. |
| References | |
| NUDOCS 8709020158 | |
| Download: ML20237G230 (3) | |
Text
_
l August 24, 1987 Docket Nos. 50-266 DISTRIBUTION:
and 50-301 Docket Files!
NRC PDR Local PDR PDIII-3 r/f DWigginton Mr. C. W. Fay, Vice President DWagner Nuclear Power Department PKreutzer Wisconsin Electric Power Company 231 W. Michigan Street, Room 308.
Milwaukee, Wisconsin 53201
SUBJECT:
QUALITY OF SPENT FUEL RACKS FABRICATED B) U. S. TOOL AND DIE AND ITS PREDECESSOR The U. S. Nuclear Regulatory Commission conducted an inspection of the U. S. Tool and Die facilities in Allison Park and Glenshaw, Pennsylvania, on March 23-27, 1987. During this inspection, it was found that the implementation of the U. S. Tool and Die QA program failed to meet certain NRC requirements. The most serious of these appeared to be a breakdown in the QA/QC program concerning in-process examination and weld inspection. This breakdown resulted in cracked or missing welds. A copy of the inspection report (dated May 12,1987) sent to U. S. Tool and Die, Inc., is enclosed (Enclosure 1).
U. S. Tool and 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 program 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 undertne 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.
j
$F Es SEkP a
' This request for information was approved by OMB under clearance number 3150-0011 which expires December 30, 1989.
Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management, Room 3208, New Executive Office Building, Washington, D. C. 20503.
Sincerely, David L. Wigginton, Acting Director Project Directorate III-3 Division of Reactor Projects
Enclosures:
As stated cc: See next page l
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i i
j]
Office:
LA/PDHI-3 PYTPlilII-3 PD/PDIII-3 Surname: PV/euszer DWagner/tg DWigginton 08/ 3/87 08/2187 08/p/87 Date:
4 E-_--_--_--____--______________
i l
Mr. C. W. Fay Point Beach Nuclear Plant
. Wisconsin Electric Power Company Units 1 and 2 cc:
Mr. Bruce Churchill, Esq.
Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.W.
Washington, DC 20037 Mr. James J. Zach, Manager Point Beach Nuclear Plant Wisconsin Electric Power Company l
6610 Nuclear Road 1
Two Rivers, Wisconsin 54241 Town Chairman Town of Two Creeks Route 3 Two Rivers, Wisconsin 54241 Chairman Public Service Commission of Wisconsin Hills Farms State Office Building Madison, Wisconsin 53702 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Office of Executive Director for Operations l
799 Roosevelt Road Glen Ellyn, Illinois 60137 Resident Inspector's Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two P.ivers, Wisconsin 54241 1
I N.
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'e UNITED STATES
, #',i
+ j' NUCLEAR REGULATORY COMMISSION Jf WASGCTON. D. C. 20655 g
t May 12, 1987 kW fit. F00C10S?/S7-01
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l U.S. Tool and Die, Incorporated ATTh: Mr. Michael J. Rodgers President 4030 Route 8 Allison Park, Pennsylvania 15101 Gentlemen:
I 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,shopqualityassurance(QA)implementationandquelity 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 j
failed to meet certain NRC requirements. The.most serious of these w aarc.
i to be the breakdown in the OA/0C crocran concernins tuprocess tMmination aM weld fnspection. No in-process examinations or weld inspections were being performrc 16 'the initial stages of fuel storage rack fabrication.
Additionally, two undersize fillet welds were identified by the NRC inspector i
after the welds had been inspected and accepted by the UST&D inspector. Several l
other noncenformances were identified in the areas of measuring and test equipment, procurement, and training, while two violations were identified i
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 i
to the pertinent requirements are identified in the en:losures to this letter,"
l 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 I
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.
p M. M y A
l.
6 U.S. Tcoi and Die, Incorporated May 12, 1987
}
Yoc are also requested to submit a similar written statement for each item which appears in the enclosed Nctice of lionconfomance.
f The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Bud 5Et as required by the Paperwork Reduction Act of 19E0, PL 96-511.
In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Documant Room.
I Should yo; have any questions concerning this inspection, we will be pleased f
to ciscuss ther with you.
)
Sincerely, 9
lis W. Merscho;.
Acting Chief
-r Vendor Inspection ranch Divisior, cf Reactor Inspection and Safeguarts Office of Nuclear Reactor Reguistion 1
Enclosures:
1.
Appendix A-f;otice of Viciation 2.
Appendix E-httice of Nonconformance 3.
Appendix C-Inspection Report No. 99901082/E7-01 l
4.
Apperdix D-Inspection Data Sheets (6 pages) cc:
Commonwealth Edison Company 4
ATTN:
Mr. Cordell Reed Vice President l
Pcst Office Box 767 Chicago, Illinois 60690 l
Wisconsin Public Service Corporation ATTii: Pr. D. C. Hintz hanager, Nuclear Power Eost Office Box 19000 Green Bay, Wisconsin 54307 Vemont Yankee Nuclear Power Corporation ATTN: Mr. Warren P.14urphy, Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vemont 05301
(
APPEND 1x A U.S. Tool and Die, Incorporated Docke' No. 99901082/E7-01 NOTICE OF V10LAT10t As a 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 and categorized in accordance with the ARC Enforcement Policy,10 CFR Part 2. Appencix 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 cccument for a basic component specifies, when applicable, that the provisiers of 10 CFR Part 21 apply.
Contrary to the abcve, a review of documentation packages fcr spent fuel stcrage racks fabricated under ASME Code Section III. Subsection NF revealed that while 10 CFR Part 21 was imposed en U.S. Tool and Lie, Incorporated (UST&D) by their customers, UST&D did net specify that 10 CFR Part 21 requirements would apply on Purchase Orders (PO) 86-CC208 to Columbia Electric Manufacturing; 84-1701 and -1679 to to All Pittsburgh; 86-61228 to Cromie Nachine and Tool; 82-1051 to Comercial Fasteners; 60-60802, -81208 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 Keld Star; 86-61112, -70103 and 87-70118 to Alley-Oxygen Weld Supply; 86-E1218 to Metal Goods; and 00-60921, 87-70130 and -70208 to killiams 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 CFR Part 21, Section 200 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.
L Contrary to the above, UST&D failed to post Section 206 of the Energy Reorganization Act of 1974 (87-01-02)
This is a Severity level V violation (Supplement VII).
} c fgGl
APPENDIX E i
U.S. Tool and Die, Incorporated D::ket he. 999010CE/E7-01 hCTICE OF NONC0hf0RMANCE Durirg ar inspection cenducted March 23-27, 1987, the implementation of the Quality Assurance (CA) Program at the UST8D facilities in Allison Park and Glenshaw, Pennsylvania was reviewed with respect to the fabrication of spert fuel stcrage racks. The applicable QA Program requirements are 10 CFR Fart 50, Appendix B, 10 CFF Part 21, and UST&D's QA Program Manual (QAPM), Revision 2, dated Jervery 20, 1986.
Based on the results of this inspection, it appears that certain activities *at the U5160 f acilities were not conducted in acccrdance with these corritments. These items are listed below.
1 3.
Criterien X of Appencix B to 10 CFR Part 50 requires, in part, that a prograr fer inspection be established and executed by or for the creenizaticr. performing the activity to verify confortnance with the documented irstet-tions, procedures and drawings.
Section 14.3C cf the UST&D QAPM, requires, in part, that in-process examination or surveillance be conducted by (uality Control persennel to verify dimensions and that fabrication methods used by production are in i
accordance with the contrect documents and industry practice.
I s
Section 3.3 of Procedure 14.1, " Production Work Routing and Inspection i
Plan," Revision 0, requires, in part, that Quality Control perfore all I
l inspections, in-process examinations, testing verification, etc. noted or the flow chart (the " Production Work Routing and Inspection Plan") in 1
acccrdance with the appropriate procedures and that no production activi-ties progress past these points until Quality Control has perforced their duties.
Contrcry te the above, in-process examinations were nct beine performed
(
l at the south shcp per the " Production Work Routing and Inspecticn Plan,"
I Drawing 8601-0 Revision 1, for the spent fuel racks being manufacture l
for the LaSalle project.
(87-01-03)
P.
Criterior. X of Appendix B to 10 CFR Part 50 requires, in part, that a p,rogram for inspection of activities affecting quality be established and e>ecuted to verify conforrance with the documented instruction.s.
procedures and drawings.
Sec tic,r 10.2A of the UST&D QAPh requires, in part, that all shcp inspections / examinations / monitoring are performed by qualified Quality Control personnel and in accordance with written procedures.
Q$$$)
\\.
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 perfomed.
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.
Criterien XII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that tools, gages, instruments and other i
measuring and testing devices used in activities affecting quality are l
properly controlled, calibrated and adjusted at specified periods to ma4rtain accuracy.
Section 12.2B, of the UST&D QAPM requires, in part, that the intervt.i of calibration for each item be established in procedures.
e Section 2.4 of UST&D Frocedure 12.1,
- Control of Inspection Measuring Ecuipment," Revision 2, requires, in part, that each piece of inspection equipment be assigned a permanent unique serial number which will be y
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, Vemont 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.
l c.
A calibration interval was not established in the "Cardex" l
systet for the modified ID box mandrel for the LaSalle project in the north fabrication shop.
(87-01-05) 4.
Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that to the extent necessary, procurement documents require subcontractors to provide a quality assurance program consistent with the pertinent provisions of this appendix.
Section 2.2A of the QAPM requires, in part, that the UST&D Quality Assurance Program be developed to comply with the requirements of ANSI N45.2 and ANSI /ASME NQA-1-Quality Assurance Program Basic Requirements.
l, The QA sectior:s c' the technical specifications for the Kewaunee, Venncnt Yankee, and LaSclie projects impose the requirements of ANSI N45.2 and/or At:SJ/ASME t:CA-1 upon USTED.
Section 5 of ANSI N45.2-1977 and Section 4 (Basic Requirements) of At:SI/
1 ASME NCA-1-1963 indicate that PCs shall require suppiters/ vendors to have a OA program consistent with the applicable requirements of the standard.
Contrery to the above, a review of 43 P0s for materials and services related to spent fuel racks fabricated under ASME Code Section III, Subsection NF indicated that quality requirements (e.g., QA Program) were not pessed on to vendors for the following P0s:.B6-60746. -60613, -60814 and -61220 to Cromie Machine and Tool; E6-60200 to Columbia Electric Manufacturing; C4-1701 and -1679 to Do All Pittsburgh; 82-1066 to Capitol Pipe and Steel Products; 82-1051 to Comercial Fasteners; 86-60E02,
-C12C6, and 07-70132 to West Penn Laco; 82-1032 to Allegheny Ludium Steel; EE-51023 to Techalloy; 22-1311 and 03-1387 to Sandvik; 87-70115 to Welcstar; C6-70103 to Alloy-Oxygen Weld Supply; and 66-61216 to Metal Goc'd s.
(87-01-CC) 5.
Criterion IV of Appendix B to IC CFR Part 50 requires, in part, that measures be estat;1ished 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 l
material delineate all applicable requirements of the contract documents.
Section 2.2 of Procedure 4.1,
- Procurement Document Control." Revision 5, requires, in part, thbt procurement documents reference all design I
specificaticr requiremer.ts applicable to the items being purchased.
Section 5.3 uf NES Specification No. 83A2256~, " Specification for the l
Fabrication ard Inspection cf the Vennent Yankee huelear Power Station Spent Fuel Storage Racks, Revision 0, requires that all weld filler metals met the requirements of Section III, Subsection NF including deltr. ferrite determination.
Section 4.4B of the QAPM requires, in part, that the quality assurance minager or his designee review and approve purchase orders prior to issuance to the vendor.
Sections 3.2 and 4.1 of Procedure 4.1 require that all PCs be reviewed and approved by QA.
Contrary to the above, a review of P0s indicated that PO Bi-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.
(67-01-07) e=**
w
/
4 Criterion V of Appendix B to 10 CFR Part 50' requires, in part, thht E.
activities effectinc quality be prescribed by documented instructions, procedures or drawings.
Section 5.2B of the QAPM and Section 6.0 of ANSI N45.2-1977 requires, in part, that all activities affecting quality be prescribed and accomplished with appropriate documented procedures.
Contrary to the above, it was noted thct a documented procedure / instruction did not exist to control tools (e.g., wire burshes, grindin5 wheels, hammers, etc.) that were designated for use only on stainless steel material.
(87-01-08)
Criterion V of Appendix E to 10 CFR Part 50 requires, in part, that l
7.
instructicrs, procedures or drawings shall include appropriate quantitative i
or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Sectier 5.2B of the QAPM requires, in part, that, as applicable, procedures, instructions, and/or drawings will include quantitative and qualitative acceptance criteria.
Section 0.2 of Procedure 10.3, "Inprocess Examination," Revision 3, defines in-process examinations as periodic, random sampling type checks and or 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 randon sample quantities or percentages needed to ensure a representative sample during in-process examina ticr:s.
(87-01-09)
E.
Criterior. XIV of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to indicate, by the use of marking, the status of inspections and tests perfor17,ed upon individual items, and that these reasures 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 examined by UST&D personnel performing the examination.
i
. Section 3.2 of Procedure 10.3 requires, in part, that 0A/QC personnel mark each piece in-precess examined with a unique marking to indicate the piece, part, sub-assembly and/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 E to 10 CFR Part 50 requires, in part, that measures be established to assure that purchased material, ecuipment 9.
and services conform to the procurement documents, and that the effectiveness of the control of quality by contractors and subcontractors be assessed at intervals consistent with the importance, complexity, I
and queritity of the product or services.
7.2E of the QAPM requires, in part, that vendors be evaluated and e
Sectict approved tased en their capability to provide material, equipment and/or services.
Section 1.1.1 of Procedure 7.2, " Evaluation of Vendors," Revision 1, requires, in part, that vendor evaluations be conducted to provide confi-dence in the vendor's QA Progran for meeting the quality requirements.
Contrary to the above, vendor evaluations had not been performed on Co All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D.
(87-01-11) l I
Criterion 11 of Appendix B to 10 CFR Part 50 requires, in part, that the 10.
quality assurarce program provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
Section 2.5 of the OAPM requires, in part, that all UST&D personnel perfor-ming quality attivities be trained in the requirements of UST&D's QA Pro-gram as applicable to their activity and that their qualification, indoctri-natien, and traf ring be controlled te obtain suitable proficiency.
5.ectico 2.1 of Procedure 2.3, " Training," Revision 3, requires, in part, that all UST&O personnel performing quality related activities be trained in the requirements of UST&D's QA Program as applicable to their activity.
I Centrary to the above, training records did not exist for two UST&D shop 1
i l
employees.
(87-01-12)
Criterion VII of Appendix B to 10 CFR Part 50 requires, in part, that 1
11.
measures be established to assure that purchased material, eqaipment and services conform te the procurement documents.
l l
l
. Section 7.2E of the QAPM re. quires, in part, that vendors shall be evalue'ted 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 proposed new vendors furnishing quality related materials and/or services prior to, or within 14 days of, issuance of a purchase order.
Contrary to the above, PO 86-60143, dated February 14, 1986, was placed with Industrial Service Center while the evaluation was performed March 12-13, 1900.
(87-01-13) c
.v-
- ?
.____.___m__
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CPL;.:Z AT: Jt;;
U.S. TOOL AND CIE ALLISON PARK, PENNSYLVANIA l
REr0F1 INSPECTION INSPECTION NO..
09901082/E7-01 DATES:
03/23-27/P7 Oh-STTF W PC-M i
CORRESPONDENCE ADDRESS:
U.S. Tool and Die ATTN: Mr. Michael T. Rodgers President 4030 Route 8 Allisor, Park, Pennsylvania 15101 GRGAhlIATIONAL CONTACT: Mr. Frank E. Witsch TELEPH01:E EUMBER:
412 aF7-7030 NUCLEM IhDUSTRY ACTIVITY:
Fabricator of spent fuel storage racks.
a.
e ASSIGhED INSPECTCP:
h(ubJrm N 6
9 Claudia M. Abbate, Frogr~am' Development anc) Reactive ate InspectionSection(PDRIS)
OTHEF. INSFECTORS: James T. Conway, PDRIS Kenneth G. A pinwall, Consultant APFP.0VED BY:
[XD 7
l Jafes C Stone, Chief, FDRIS, Vendor Inspection Branch ate INS;ECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50 Appendix B, 10 CFR Part 21.
L.
SCOPE: Observe the fabrication and testing processes regarding the fabrication of spent fuel storage racks. Welding, nondestructive testing, perser.nel training, quality control inspection, procurement, shop QA implementation and quality records were reviewed.
PLANT SITE APPLICABILITY:
Callaway, Ginna, Kewaunee, M alle 2,~Nine Mile Point 2, Seabrook, Shorehart, Temor.1 i m ee. ) T Creek wF N
tt
ORCAhj2AT:Ch:
U.S. TOOL AflD DIE ALLISON PARK, PENNSYLVANIA INSPECTION REPORT PAGE 2 of 15 h0.: 99901CE2/87-01 RESULTS:
A V10LAT10hS:
Contrary to Section 21.31 of 10 CFR Part 21, a review of documentation i
3.
packages fer spent fuel storage racks fabricated under ASME Cooe Section III, Subsection NF 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 Purchase Orders (PO) 86-60208 to Columbia Electric Manufacturing; 84-1701 and
-1679 tc Do All Pittsburgh; 86-61228 to Cromie Machine & Tool; 82-1051 to Connercial fatteners; 86-60802, -81208 and 87-70132 to i
West Penn Laco; 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; 66-61218 te Metal Goods; and 86-60921, 87-70130 and -70208 to Williaes and Company.
(87-01-01)
This is a Severity Level V violation (Supplement VII).
i.
Contrary to Secticn 21.6 of 10 CFR Part 21. UST&D failed to post Section 206 of the Energy Reorganization Act of 1974.
(87-01-02)
This is a Severity level V violatien (Supplement VII).
8.
NONCONFORMANCES:
Contrary to Criterion X of Appendix B to 10 CFR Pert 50, Section 1.
34.3C cf the UST&L Quality Assurance Prograr Manual (QAPN),
Revision 2, and Section 3.3 of Procedure 14.1,
- Production Work Routing ar.c Inspection Plan," Revision 0, no in-process examinations were being performed at the south shop per the " Production Work Routing and Inspection Plan," Drawing 8601-0. Revision 1, for spent (67-01-03) l fuel racks being fabricated for the LaSalle project.
Contrary to Criterien X of Appendix B to 10 CFR Part 60, Section 2.
10.2A of the USl&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.
J 12.28 of the UST&D QAPh, Revision 2, and Secticns 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:
ORGAh1 F ICh U.S. TOOL ANO DIE ALLISON PARK, PENNSYLVANIA REPORT INSPECTION NO.:
999030E2/87-01 RESULTS:
PAGE 3 of 15 Documenteo 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 Pandrels for the Kewaunee, Vermont Yankee, and LaSclle 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 celebration interval was not established in the "Cardex" c.
system for the modified ID Box Mandrel for the LaSalle project in the north fabrication shop.
(87-01-05) 4 Centrary to Criterion IV of Ap'pendix B to 10 CFR Part 50, Section c.
2.2A of the QAPM, Revision 2 Section 5 of ANSI N45.2 and Section 5 (Easic Requirements) of ANSI /ASME NCA-1, a review of 40 P0s for materials ano services related to spent fuel racks fabricated unoer ASME Code Section III Subsection NF indicated that quality requirements (e.g., QA Program) were not passed on to vendors for the following PCs: 66-60746, -60813. -60814, and -61228 to Cromie Machine ano Tool; 86-6028 to Columbia Electric Manufacturing; 84-1701 and -1679 to Do All Pittsburgh; 82-1068 to Capitol Pipe &
Steel Products; S2-1051 to Connercial Fasteners; 86-6082 -81208, anc B7-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 85-51023 to Techa11cy; B2-1311 and 83-1387 to Sandvik; 87-70115 to Keldstar; BE-70103 to Alloy-Oxygen Weld Supply; and 86-61218 to Metal Goods.
(87-01-06) 5.
Contrary to Criterion IV of Appendix B to 10 CFR Part 50, Sections 4.EE 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 66-60610 to WALCO Corporation for markers and tape was not signed /initicled and dated by QA personnel.
(87-01-07) 6.
Contrary to Criterion Y 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 control tools (e.g., wire brushes, grinding wheels, hammers, etc.).
that were designated for use only on stainless steel material.
(87-01-08)
{
d
ORGah12ATI0t.:
U.S. TOOL Af;D DIE ALLIS0t; PARK, PENNSYLVANIA REPORT INSPECTI0t; tiO. : 99901082/87-01 RESULTS:
PAGE 4 of 15 7.
Contrary to Criterion V of Appendix B to 10 CFR Part 50. Section 5.2B cf the UST&D QAFM, Revision 2, and Section 2.2 of Pr'ocedure 10.3, "Inprocess Inspection," Revision 3, Procedure 10.3 does not provide the QC inspector appropriate guidance indicating the recuired ranc;cm sample quantities or percentages needed to ensure a representative sample during in-process examinations.
(87-01-09) 6.
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, marking procedures used by the south shop QC inspector for in-process I
examir.ation do not clearly identify items or components which have,
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 7.2E of the UST&D QAPM, Revision 2, and Section 1.1.1 of Procedure 7.2, " Evaluation of Vendors," Revision 1, vendor evaluaticos had not been perforrned 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, ne training records existec; for twc UST&D shop employees.
(67-C1-12) 11.
Contrary to Criterion VII of Appendix B to 10 CF'R Part 50, Section 7.2E of the UST&D QAPM, Revision 2, and Section 2.1 of Procedure 7.2, " Evaluation of Vendors," Revision 1, PO 86-60143, dated February 14, 1986, was placed with Industrial Service Center prior to the vendor evaluation which was perfomed March 12-13, 1986.
(67-01-13)
C.
UNRESOLVED ITEMS:
horie.
l L.
STATUS GF PREVIOUS It:SFECTI0t< FIf; DINGS:
hone. This was the first NRC/VIB inspection of this facility.
)
GRGANIZATICr..
L'.S. TOOL AhD DIE ALLISON PARL, PENNSYLVANIA l
REFCR1 INSFECTION NO.: 999C1002/E7-01 RESULTS:
PAGE 5 of 15 E.
INSPECTION FINDINGS Att OTHER COMP.ENTS:
l 1.
Entrance and Exit Meetings An entrance meeting was conducted on March 23, 1987 at the Allison Park, Pennsylvania office of UST&D. The purpose and scope of the inspection were discussed during this meeting. UST&D has two l
fabrication shops. The south shop, located in Glenshaw, Pennsylvar.ia, recehes the material and fcrms and welds the individual cells.
The north shop, located in Allison Park, Pennsylvania, assembles er.d welds the cells into fuel storage racks and performs the final inspection.
During the exit meeting conducted on March 27, 1987, the inspection findings and observations were discussed with UST&D personnel.
2.
Scent Fuel Racks,huclear Since 1982, UST&D has fabricated spent fuel racks for six commercial nuclear customers (see Table 1, page 15). Three projects are currently in progress: LaSalle 2 Kewaunee and Vermont Yankee. The customer's design is being used for the Vern.ont 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 for Verront Yankee. A number of cells have been fabricated fer Kewaunee, but they have root been assembled into a completed rack.
The NRC inspector reviewed the customer's procurement packages for the nine projects including a detailed review of the P0s and/or the techr.ical specifications fer four projects: hine Mile Point 2, Verr 4nt iankee, rewaunee and LaSalle 2.
For all four projects, it was notet that the requirements of 10 CFh Part.50 Appendix 5 and 10 CFR Part 21 were referenced in the P0s and/cr specifications.
The huclear Energy Services'(hES) specification for the Vermont Yankee project referenced the 1900 Edition of Sections 11. III (Subsecticn NF), V and IX of the ASME Code, whereas the 1977 Edition i
of the same Sections were. listed as applicable' documents in the
)
Store and Webster,(StW) specification for the Nine Mile Point 2 project.
NCE personnel were to be trained and quclified per ShT-TC-1A, and inspectors were to be qualifier. to AhSI N45.2.6.
Weld filler metal:wts to be in accordance with Subsection NF of Section III and specification AWS A5.9.
In general -the material specifications included ASTN A240, A276, and A564.
Cleaning w.
N_
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DRGAN12AT10fa U.S. TOOL AND DIE ALLISON PARK, PEhh5YLVAhlA I
1 REPOR; INSPECTION NO.: 99902082/57-01 RESULTS:
PAGE 6 of 15 requirements were noted as Class B of ANSI N45.2.1; and handling, peckeging, ard shipping were to meet the Level C requirements of Ah51 M5.2.2.
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 4
certificate of conformance from UST&D.
.S.
Plant Tour The inspectors toured the north and south fabrication facilities at.
various times in the company of UST&D officials. Receipt inspection, press forming 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.
j During the plant tours, it was noted by the inspector that one harmer had a painted handle. UST&C personnel infonned 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.
l ftonconformance 87-01-08 was identified in this area.
4.
Production Work Routing & Inspection Plan (PWRIP) j i
A PWRIP, which is similar to a
- shop traveler," is generated by l
the Pro. ject hanager for each nuclear job. The PWRIP is laid out l
es an E-sire drawing and identifies, for both the north and south l
shops, each production operation, CC inspection /in-process examinations, and customer witness points and mandatory hold points.
Several notes pertaining to the requirements cf the customer *S spe.cification, inspections including documentation, and hold. points are also included.
Item No. 7 of the PWRIP states that "documen-i tation is not always required" for in-process examinations. This l
does not agree with Section 14.2 of the QAPM which states, in part,
- Inspection repcris will document all inspections and testing delineated on the Production Work Routing 3 Inspe: tion Plan." The 4
4&%
l e _ - _- ____
ORGAN:7J" Ob:
U.S. TOOL AhD ole ALLISON PARK, PENNSYLVAh!A 1
REPORT INSPECTION hC.: 999C10E2/E7-01 RESULTS:
PAGE 7 of 15 f
PWP!P, including changes, is approved by the Engineering and QA
{
departments.
The PWRIP cane into effect upon the generation of the QAPM in December 1981, and the dccument was used on all the nuclear prcjects beginning with Wolf Creek. The inspector reviewed and verified that a PhhlP existed for the nine nuclear projects since 19C2.
During the inspection of shop activities, USTI.D Drawing 6601-0, Revision 1, " Production Work Routing and Inspection Plan," for the LaSalle project was reviewed. After the individual cell is tack-welded and jetline welded together, an in-process examination j
and weld inspection were to be perfomed. These two activities are outlined in Procecures 10.3 and 10.5 respectively.
3 l
When documentaticr or inspection reports were requested for the in-process exerinetions ar.c weld inspections, none existed. No in-process examinations were 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.
l Upcr further review of the procedure, it was noted that in-process I
exarinctions were defined as periodic random sampling type checks to determine that the shop is providing material which complies with the UST O QA/QC progran requirements. The shop QC personnel were ur,able 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 ord oues net ensure a censistent number of in-process exan.inations emong the different inspectors.
honconformance S7-01-05 was identified in this area.
i in addition, Procedure 10.3 does not require documentation of the in-process exaniinations, however, each aart nay be physically 1
marked after an in-process examination its been performed. The option of marking components to indicate completion of an in-process l
examination is used by the south shop QC inspector. However, the nrk used is a check mark made on the component surface with a 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 hew to distinguish the inspector's markings from other manufacturing l
markings.
i i
a i
a
ORGAh12 A110fi:
U.S. TOOL AND DIE ALL150h PARK, PEKf;5YLVAf;IA h
1 J
REPORT INSPECTICf liO.: 99901082/S7-01 RESULTS:
PAGE 8 of 15 Nonconforr.ance 67-01-10 was identified in this area.
5.
Welcing and Welding P.achines Welding being perfomed on spent fue1 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 werk area, preheat and interpass temperature centrol, compatibility of WPSs to production werk and compliance with WPS essential anc nonessential variables.
e Welding machines were ioentified with a unique identification nurber for verification cf amperage and voltage requirements.
Automatic weldin5 equiptrent had attached documentation to alert y
the welding operators of emperage and volta 5e ranges and tolerances for the thickness of the material being used.
In addition, each marvel welding machine contained a ccr. trolled record showing each j
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 reccrds.
ho iters of nonconfomance or unresolved items were identifiec in this area.
E.
Keld Insoettien Final inspection of the completed spent fuel storage racks is cutlined in Procedure 10A, Revision 1 and includes a verification of the physical dimensions of the completed rack to the approved shop drawing dimensicns.
l During the inspection of completed fuel storage racks for the LaSalle i
prcject, visual and dirrensional checks of fillet welds on fuel rack pedestal mounting padt were perfomtd by the NRC inspector. Drawing E601-10, Revision 4, was used for the inspection. During the inspection, two fillet welds on the mountir.g ped were found to be 1ess than the one-quarter inch weld specified on the crawing. The rack was identified as USTED rack number 11 (Commonwealth Edison racknumber2FC160). A review of the final ir.spection checklist revealeo that these welds had been inspected and fcund acceptable by the UST&D QC inspector.
OFGAhl2AT10h:
U.S. TOOL AND OIE ALLISch PAPK, PENNSYLVANIA REPCRT INSPECTION NO.:
599C10EE/E7-01 RESULTS:
PAGE 9 of 15 Pricr to the exit meeting, the helds were repaired. The new welds were exarined by UST&C QC personnel and found acceptable. The NRC inspector verifieo that the welds were acceptabic per the drawir.g.
henconf orma nce 87-01-04 was identified in this area.
l 7.
Welder Qualifications and Training The welder qualifications to applicable Welding (Procedure Specifi-caticr.s (LPS), Procedure Qualification Records PQR) and design specification requirements were reviewed. Eech welder record included l
~
bis unique welder identification number, the WPS to which he was qualified and the supporting PQRs.
Training records for four weleers were reviewed. The records documented which trair.ing
~
sessicr. the welders attended and the date (see Section 16 of this 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 KFS, have practical experience and perform two test samples prior The records of e'ght welders quclified i
to prcducticn welding.
to WPS 52 were reviewed and found in compliance with the require-nents mentioned above.
i The review of welder qualifications and trainin5 resulted in nc items of nonccnformance er unresolved items; however, training was minimal in that welders are trained only to the WPSs and there is no evidence that welders are trained te new revisions of WPSs.
E.
Keld Filler f.ateriel Control A review of weld filler materiel control was performed using USTAD Procedure 9.2, Revision 4.
The areas which were examined included:
I weld filler material storege areas, storage of filler material, markirs cf material (straight and spools), assignment of material inventory control (MIC) numbers and issuar.ce/ return renords. These items were inspected at the weld filler materini issuance stttions at both the north and south shops. The rev4ew of weld filler material centrol indicated that Procedure 9.2 was being implemented.
No items of nonconformar.ce or unresc1ved items were identified in this area.
i
ORULIZATIOh:
U.S. TOOL AND DIE ALLIS0h PAFK, PENh5YLVANIA REFCF.T INSPECTION NO : 999010E2/87-01 RESULTS:
PAGE 20 of 15 i
g.
nondestructive Examination (LDE) Personnel Qualifications The HEE qualification records were reviewed using UST&D Procedure 2.5, Revisicr. 1.
Certifications and qualifications of the UST&C Lesel III NDE consultant, the QC Manager and two QC inspectors were.
reviewed. Prior training hours; general, practical, and specific tests, including the amount of questions per discipline and test results; ar.d a verification of annual eye examinations received by the personnel were reviewed. Records of training and indoctrination of personnel to the NDE procedures and pro 5 ram were also reviewed.
The review of documentation for NCE personnel qualifications resulted in no items of nonconformance or unresolved items; hcwever, documented evidence cf training of NDE personnel was mir.imal.
10.
Control of Measuring and Test Ecuipment (MTLE)
The NEC inspector reviewed applicable sections of the QAPM, one I
procedure and calibration records to determine whether M6TE was properly identified, controlled and calibrated at specifiec 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 creas.
kith the exceptier. of four ID box mandrels, the inspected equipment contained a vibro-etched 5/N. The four mandrels were for the Kewaunee, LaSalle and Vermcht tankee projects and were located in the south shop. A Cardex system, which is. maintained by the QC Man 6per, is used to record calibration information. Each carc identifies the type of equipment includir.g 5/N, calibration date, calibration frequency, the standard used, and the icentity of the individual performing the calibration.
Equipment examined at the south shop included a vernier caliper, two r.icrometers, one thickness gage, one width gege, one tong test anneter, and four ID box mandrels. At the north shop, one tcng test anmeter, three micrometers, one dial thickness gage, one vernier caliper, one bcre gage, one radius gage set, one inside micrometer l
I set, one optical comparator, one box mandrel (LaSalle project) and three micrometer standards were examined.
In addition, the calibration status of the eight welding machines in the north shop was checked. The information contained on the calibration stickers on the items was in agreement with the applicable card.
ORG t t 12 Al '.0h -
U.S. TOOL AND DIE ALLIS0h PARL, PENNSYLVANIA i
EP0p-IhSPECTICL 0.: 99901062/E7-01 RESULTS:
PAGE 11 of 15 i
The two AC-DC tong test ammeters (S/N AX-48975 and -58261) are sent te Columbie Electric manufacturing (CEh) for calibration every two Test reports from CEM indicated that the equipment was years.
calibrated in February 1900 with standards traceable to the National Bureau of Standards (NBS). A Certificate of Calibration from Dc All Pittsburgh indicated that a master gage block set (S/N C-4) was 3
It was calibrated in October 15C4 with standards traceable to NBS.
noted that a document did not exist to identify the specific equipnent covered by the calibration program including the calibration frequency of such equipment.
l' honccnformance 87-01-05 was identified in this area.
e 11.
Procurement Document Control Fnrty-three P0s to 15 reaterial manufacturers / suppliers, four P0s to a machining vendor, three P0s to two vendors for calibration services, and one PD to a plating vendor were reviewed to assure I
that applicable technical and QA program requirements were included I
or referenced in the P0s. With the exception of one order, all the PCs were initialed and dated by a QA individual. The PD in question was No. 66-60610, dated June 6, 1986, to WALCO Corporation for felt tip markers and ruclear grade cloth tape.
Nineteen P0s did not invoke the requirements of 10 CFR Part 21 upon vendors - eight P0s l
to four manufacturers / suppliers of weld wire, three PCs to two I
calibration service vendors, one PO tc a machining vendor, one F0 to a supplier of festeners, and six P0s to manufacturers / suppliers of stainless steel In addition, the requirement that a vendor have e OA pregram which was approved by UST&0 was not included in nineteen P0s to vendors - fnur PCs to Cromis Machine and Tool, one PC to Colurtie Electric Manufacturing, two P0s to Do All Pittsburgh, one PD to Capitol Pipe 1 Steel Products, one PO to Comercial Fasteners, three P0s to West Penn Laco, one P0 to Allegheny Ludlum, one PC to Techa11cy, two PDs to Sandvik, one FO to Weldster, one PO to Alloy-e 0xygen Weld Supply and one PO to Metal Goods.
It was also notec s
thet for PD 87-70118,, dated January 16, 1987, to Alloy-Oxygen Welding Supply for 2006 ASME Section II SFA 5.9 Type 312 filler metal did not contain a "oelta ferrite determination statement.
Violation 67-01-01 and Ncnconformances 67-01-06 and E7-01-07 were identified in this area.
- 12. Documentation Packaces (DP) l A DP did not exist for the Yemont Yankee and Kewaunee projects as finished racks were not yet completed for these projects. The j
1
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U.S. TOOL At;C DIE ALL150h PARK, PENNSYLVAh1A i
INSPECTION REPORT PAGE 12 of 15 h0.: 99901082/E7-01 RESULTS:
l l
inspector reviewed three DPs for Rack M120-24 for Wolf Creek ec Racks he. 5 and 9 for LaSalle.
For Wolf Creek, the DP consisa of a Bechtel Engineering and Cue 11ty Verification Document; Mat, ial 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 included. A bechtel Supplier Deviation Disposition Request and a
{
UST&D henconformance Report and Verticality Test Report were also part cf the package.
In additien, 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.
The LPs for the two LaSalle racks consisted of the following:
Documentation Checklist, Shop Bill of Eaterial (SEM), CMTRs, UST&D CofC,WeldExaminat'onRecords,FinalInspectionChecL11sts(FIC).
Deviatier./ Variance Requests Qualified Welders List, and a C of C for the boraflex. The SBM listed the material inventory control (MIC) number as well as the material specification and supplier fer each item (e.g., bcx half, bottom plate, pedestal body, etc.).
The FIC verified that the following activities were accomplished on a finished rack:
dimensional verification, MIC No. verification, visual weld inspection, cleanih5, marking, boraflex verification, and the mandrel insertion test, ho items of nonconformance or unresolved items were identified in this area.
- 13. Vendor Evaluations The NRC inspector reviewed the evaluations UST&D perfonned en its vendors and how approved vendors remain on the Approved Vendors List. This process is outlined in Procedure 7.2, " Evaluation of Vencors," Revision 1, dated March 12, 1987.
l Eleven vendor evaluation packages were reviewed. The packages cor.tained the original survey or audit checklist of the vendor and reevaluations of the vendor. The reevaluations consisted of a I
Vendor Evaluation Questionnaire and a historical quality perfomance data review.
1 i
4 OkGAhlIAT10N:
U.S. TOOL AhD DIE ALLISON PARK, PENNSYLVAt:IA REFOR-INSPECTION NO : 999010E2/57-01 RESULTS:
PAGE 13 of 15 During the review,'it was noted that Do All Pittsburgh and Colurbia manufacturing Electric, who supply calibration services, have net been evaluated by UST&D, nor has a historical e,uality performance date record been maintained en either ver. dor. Also during the review, it was noted that Industrial Service Center had been audited by UST&D March 12-13, 1986, 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 P0 as required by Secticn 2.1 of Procedure 7.2.
hencer.formances E7-01-11 er: 87-01-13 were identified in this eres.
la.
During the inspection, the NRC inspectors examined areas for the l'
posting of 10 CFF Part 21 at both fabrication shops.
It was noted that 10 CFR Part 21, USTIC Frocedure 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 21.0 of 10 CFR Part 21 and UST&D Procedure 16.2, " Reportable Detects and Noncompliance (huclear Projects) 10 CFR 21," Revision 2 dated March 12, 1987, require Section 206 to be posted. Prior to the exit meeting, Section 206 and other applicable documents were posted at both shops.
Violation 87-01-02 was identified in this area.
~
15.
Trcining l
The NRC inspector reviewed UST&C Procedure 2.*, ' Training," Revision 3, dated March 23, 1966. The procedure requires all USTED personnel performing quality related activi'* '
be trained as applicable to their activity. The procedure al..
4uires that training records be maintained.
The NP.C inspector reviewed 13 employee training records and trainirs session records. The employee training records identify what trair.ing the employee has received while the tra1ning session records identify t:bo attended the trainir.g. the date and an c.utlire of the subjects which were covered during the training.
During this review it was noted that two machinists empicyed 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 training, was present for a retired employee; several training
ORGAt;IZATICt.:
U.S. TOOL AND DIE ALLISON PARK, PENNSYLVA?.'IA PEPCRT INSPECT 10tl NO. : 999CICS2/E7-01 RESULTS:
PAGE 14 of IL records were incomplete in that hire dates ano 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 fcr a lengthy amount of time.
Noncer.fomance E7-01-12 was identified in this area.
I
- 26. Audits The t;RC inspectors reviewed four internal audits. The Internal Freject haragenent Audit, dated May 29, 1986, the Production Audit, dated August 23, 1956, the QA/QC Audit, dated November 12, 1900, and the Engineering Department Audit, dated March 4,15C7, were reviewed.
Each eudit included a checklist, an audit report (summary of results),
and was performed by a qualified auditor. The audits which were resiewed were perfomed ar.c cocumented in accordance with Procedure 18.1,
- Audits.* Revision 5, dated March 12, 1987.
t;c itets of afomance or unresolved items were identified in this area.
F.
FER50t:5 C0tTACTED:
P. Srinks, QC Manager, South Shop F. DeSirrions, Foreman, horth Shop K. Dickson, Director of Manufacturing E. Jablonsky, QC Inspector. North Shop L. Karenboyer, Welder
- R. Linder, Manager of Engineering
- E. March, Vice Chaiman of the Boerd, Chief Executive Officer E. Reinhart, QC Mar.ager, North Shop J Rhoden, Project hanager F. Rhodes, Vice Presider.t, Manufar.turing R. Rudisill, Welder
- M. Rodgers, President R. Stewart, Machinist
- B. Wachter, Vice President, Engineering ar.d Research i
K. Weber, Assistant Project Manager
- F. Witsch, (A hanager
'Attenced Exit Meeting
1 l
LRCANIZATION:
U.S. TOOL AND DIE ALLISON PARL, PENh5YLVANI A INSPECTION REFORT PAGE 15 of 15 00.: 99901CE2/87-01 RESULTS:
TABLE 1 4
i I
1 Number of Date Utijity/AE Project Type Racks / Positions Completed SNLPP6 Wolf Creek PWR-MDR 12/1328 19E2-Kerses Gas 6 her,-Poison Electric /Eechtel e
SNUPP5 Cellewty PWR-MDR 12/132E 1902
~
Unier, Electric /
Non-Poison Bechte' Lonc Isicoc Shorehan BWR-Non 15/17C0 1983 Poison 8/756 Lighting /Stcr.e W6ter Flux 2/144
& Webster Trap Control Rods Public Services Seabrook hew Fuel 3/90 19E3 Company Storage Racks hiagere Mohewk hire Mile II BWR-MDR Stone L kebster Poison 17/2530 1964 l
10/1519 l
Rochehter Ges a Ginne Mcdified 6/420 1984 l
l PWR Checker-Electric board to l
Poison Racks t
Corcor.wealti LeSalle 11 BWR Poison 20/4073 In Pro 9ress Edisor Wiscon$inPublic Service Corp.
Kewaunee PWR Poison 4/360 In Pregress Nuclear Energy Verr.ont Services Yankee BWR Poison 10/2820 In Pregress J
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U. S. TO O L S. DIE, INC.
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t030 ROUTE 8 e ALUSON PARK, PENNSYLVANIA 15101 t
I June 9, 1987 United States Nuclear Regulatory Commission vendor Inspection Branch Division of Reactor Inspection & Safeguards Office of Nuclear Reactor Regulhtion Washington, DC 20555 Attn:
Mr. Ellis W. Merschoff, Acting Chief Re:
Docket 99901082/87-01 r
Gentlemen:
In re.sponse to the inspection report referenced above and submitted to U.S. Tool & Die, Incorporated on May 12, 1987, we submit the following:
APPENDIX A l
VIOLATION i1 -
... 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 &
Die, Incorporated (UST&D) by their customers, UST&D did not specify that 10 CFR Part 21 requirements would apply on Purchase Orders..."
UST&D 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 dedication to the specific, basic component,by UST&D are the reporting requirements in effect.
(Letters from the various Client's and the Atomic Industrial Forum's. Committee m
Position Paper expanding on this position were presented to the NRC inspectors during the inspection).
Based on these documents the imposition of 10CPR21 is not applicable to the following Purchase Orders: 986-60802,
-81208, and #87-70132 to West Penn Laco; 487-70115 to Weld Star; i86-61112, -70103, and (87-70118 to Alloy-Oxygen Weld Supply; #86-61219 to Metal Goods; and #86-60921, f87-70130, and -70208 to Williams & Company.
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Per project specifications,10CFR21 was not applicable to:
P.O.#82-1051 to Commercial Fasteners; #82-1032 to Allegheny i
Ludlu=; #86-60620 to Industrial Service Center and therefore not imposed on the vendors.
c)
On both the original and revision $1 of P.O.983-1387 to Sandvik, the applicability of 10CFR21 is noted on fPage 2 of 2.
d)
P.O.486-60208 to Columbia Electric and $84-1701 add #84-1679 to Do All Pittsburgh were for service to commercial type tools.
l P.O.986-61228 to Cromie Machine and Tool was for subcontracting machining of UST&D supplied material.
10CFR21 should have been noted on this Purchase Order.
CORRECTIVE ACTION for Itam (d) 1 A revision to the Purchase Orders $86-60208 to Columbia p
Electric; # 84-1701 and 184-1679 to Do All Pittsburgh; i
and $86-61228 to Cromie Machine & Tool will be issued and include the reporting requirements of 10C/R21.
i y
A review of 10CFR21 and UST&D's procurement procedures
)
will be made with all personnel processing purchase j
orders to prevent recurrence.
This Corrective Action will be completed by June 30, 1987, i
Internal audit activities will prevent recurrence.
VIOLATION 82 -
"... UST&D failed to post Section 206 of the Energy Reorganization i
Act of 1974. (87-01-02)"
UST&D COMKENT Section 206 of the Energy Reorganization Act of 1974 was posted during the inspection as confirmed by Item 14 (page 13) of the NRC Inspection Report.
CORRECTIVE ACTION
~
Corrective Action has been completed.
Internal audit activities will prevent' recurrence.
_.-_______________._____J
1 l
1 4
i APPENDIX B l
NONCONTORMANCE $1
... 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 fuel racks being manufactured for the LaSalle project. (87-01-03 "
UST&D COMMENT l
In-process examinations not performed at the South Shop were 3
performed at the North Shop prior to installation of the l
3 cells into the final rack assembly.
CORRICTIVE ACTION A change has been made in Production supervisory personnel at the South Shop.
Co=plete 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 $2
"... 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)"
UST&D COMMENT l
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 an3,yeld acceptance criteria will be made with Quality Control personnel by June 30, 1987 to prevent recurrence.
NONCONTORvJd;CE $ 3
... a review of measuring and test equipment (M&TE) and calibration records revealed the following:
a)
Documented evidence was not available to verify t$at the calibration interval for M&TE was established in rocedures.
b)
The four inner diameter (ID) box mandrels for the LKewaunee, Vermont Yankee, and LaSalle projects in the South' fabrication shop were not identified with a permanent unique S/N applied by vibro-etching or with a durable label, c)
A calibration interval was not established in the "Cardex" system for the modified ID box mandrel for the LaSalle project in the North fabrication shop. (87-01-05)"
UST&D COM.V.ENT Corrective Action has been or will be taken as follows:
.e a)
As delineated in UST&D's calibration procedure, the calibration intervale are established in the'"Cardex" system but will be
_g 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, eacn box 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 ZaSalle project is being checked prior to and after use on each rack.
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.
S s e ee gb 9
I NONCONTORMANCE 44
"... 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..."
i UST&D COMMENT a)
P.O.086-60746, -60813, -60814 and -61228 to Cromit Machine
& Tool were for machining UST&D supplied material.
Material traceability has been maintained and 1004 receipt inspection Cromie Machine performed by UST&D of the machined. parts.
follows UST&D Quality Assurance / Quality Control Program and is on our Approved Vendor List based on these criteria.
l b)
P.O.086-61218 to Metal Goods was for material ordered for handling equipment and therefore not subject to Quality Assurance / Quality Control requirements.
e c)
P.O.982-1051 to Commercial Fasteners and P.O,482-1032 to Allegheny Ludlum was for material f;m a DOE project.. The j
project specifications did not require imposition of the 10!!TR50 Appendix.B requirements.
di P.O.086-60802, -81208, and #87-70132 to West Penn Laco, P.O.fB2-1311 and 83-1387 to Sandvik, P.0.9 87-70115 to Weld Star and P.O.#85-51023 to Techalloy does not include 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.086-70103 to Alloy Oxygen does impose furnishing material in accordance with their Quality Assurance / Quality Control Program by the notation of "Q" material.
This notation is Alloy-Oxygen's terminology for their Quality Assurance /
Quality Control Program.
f)
Columbia Electric Manufacturing and Do All Pittsburgh are manufacturers of commercial grade tools with certificates of conformance for calibration of said tools traceable to the National Bureau of Standards.
CORRECTIVI ACTION Revised P.O.486-60802, and 087-70132 to West Penn Laco;
- 82-1311 and 683-1387 to Sandvik; 087-70115 to Weld star; and #85-51023 to Techalloy will be issued and include the requirement to furnish material per their Quality Assurance, Quality Control Program.
To prevent any question of imposing a quklity progrrm i
requirement, personnel involved in the purchasing policy will receive training by June 30, l$87 on-the procurement requirements of UST&D's Quality Assurance Program.
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6-l NONCONTORMANCE #5
"... a review of purchase orders indicated that P.O.687-70118 to Alloy Oxygen Welding Supply for stainless steel weld filler metal did not contain a delta-ferrite determination statament',
and P.O.fB6-60610 to WALCO Corporation for markers and tape was not signed /inir.iated and dated by Quality Assurance personnel.
(87-01-07)"
ti UST&D COMMENT 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 NT.
The purchase order to WALCO did get through the Quality Assurance / Quality Control system without the proper signature.
CORRECTIVE ACTION i
S Revised purchase orders will be issued with the proper requirements and signatures.
These actions will be covered in the training session for purchar,ing personnel to be conducted by June 30, 1987 to prevent recurrence.
NONCdNTORMNCE f6 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 i
into writing.
CORRECTIVI ACTION Instructions will be written to the Production Department to, paint tools used on carbon projects and a training session will be held with Production 7ersonnel to assure painted tools will not be permitted for use on stainless steel.
This Corrective Action will be completed !ur June 30, 1987._
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NONCOhTORMANCE 97
... Procedure 10.3 does not provide the Quality Control Inspector appropriate quidance indicating the required random sample quantities or percentages needed to ensure a representative sample during in-process examinations.
(87-01-09)"
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UST&D COMMENT f
Aspartofthein-processinspection,materialtrafassure eability is maintained on a 100% basis; all cells are gaged to-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 previcusly fabricated pieces are checked.
Any discrepancy found in these 10 pieces will require a 100% inspection of all pieces.
COhAECTIVE ACTION Procedure 10.3 will be revised to include the above quantitative acceptance criteria and training will be f
-r, conducted with Quality Control personnel by June 30, 1987 to review this change.
1 NONCOUFORMANCE i8 1
"... 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 pieces inspected when other records will not be generated.
This training will occur by June 30, 1987.
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m 9
I 9
-B-NONCONFORMANCE 49
"... vent.or evaluations had not been performed on Do All Pittsburgh and Columbia Electric Manufacturing who provide calibration l
services for UST&D.
(87-01-11)"
i
(
UST&D COMMENT t
e These pieces of equipment were purchased under the Quality Assurance / Quality Control Program of the prior own rship of j
2 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 l
of measuring / test equipment can be censidered pre-qualified to calibrate their equipment.
Certification has been provided by these manufacturers that 4
the calibration methods and equipment used is traceable to l
the National Bureau of Standards.
Nr CORRECTIVE ACTION A re-evaluation will be conducted on these two vendors
{
by August 15, 1987.
l l
NONCONFORMANCE #10
"... training records did not exist for two UST&D shop employees.
(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.,
I i
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i UST&D COMMENT This purchsso ordar was issusd to Industrial Sorvico Conter with a provision that no material be chippsd until Industrial Service Center was audited by USTED.
The first shipment of material ordered by this purchase order was received by UST&D on April 8, 1986.
CORRECTIVE ACTION A training session will be conducted with procur pent personnel by June 30, 1987 to review purchasing getivities.
i U.S. Tool & Die, Incorporated feels that the above Corrective Action will satisfy the Violations and Nonconformances uncovered by this l
l NRC inspection.
Sincerely, i
U.S. TOOL &, IE, INC.
/
Michael Rodgers President
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Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 l
Chicago, Illinois 60690 Wisconsin Public Service Corporation ATTN: Mr. D. C. Hintz Manager, Nuclear Power Post Office Box 19002 l
Green Bay, Wisconsin 54307 l
Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy, Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Bechtel Energy Corporation l
ATTN: Mr. Robert Baremore l
Project Supplier, Quality Supervisor I
5400 Westheimer Ct P. O Box 2166 Houston, Texas 77252-2166 ic:
EAM MR TW w
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UNITED STATES j
NUCLE AR REGULATORY COMMISSION
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j W ASHINGT ON, D. C. 20555 s
f July 28, 1987
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Docket No. 99901082/87-01 U.S. Tool and Die, Ir.corporatec ATTN:
Mr. Michael J. Rodgers l
President l
4030 Route 6 Allison Park, Pennsylvania 15101 i
Gentlemen:
Thank you fcr your letter dated June 9, 1987, which described the corrective action U.S. Tool and Die, Incorporated (UST&D) has and will implement in 1
i response to the hetice of Violation and Items of Nonconformance identified in Inspection Report No. 99901052/87-01, dated May 12, 1987. Your response and i
corrective acticn for Notice of Violation 87-01-02, and Items of henconfomence l
87-01-04, 87-01-05, 87-01-07, 87-01-08, 87-01-09, 87-01-10, and 87-01-12 appear l
to be adequate and no additional information is requested. The following items, I
'I however, require additional information to determine the adequacy of the UST&D response and corrective action.
1 Part a) of the response to Notice of Violation 87-01-01 states that after receipt l
cf comercial grade material at UST&D and dedication to the specific basic I
component by UST&D, the reporting requirements of 10 CFR 21 are in effect. This l
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 commercial grade products for use i
l 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, -70116, -70130, and -70208. For part b) of that response, please provide pertinent sections of the project specifications which address the applicability of 10 CFR 21 to P0s BE-1051, -1032, and 86-6020. Part c) states that 10 CFR 21.
is imposed on page 2 of P0 83-1367 to Sandvik. Please provide a copy of P0 E5-1387.
1 1
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 impose ASME Code Section III Subsection NF and 10 CFR 50, Appendix 8 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 l
P0.
The response to Item of Honconformance 87-01-03 states-that in-process examinations not performed at the South Shop were performed at the Horth Shop prior to installa-tion of the cells into the final rack assembly. Please provide assurance that i
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 14.1.
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U.S. Tool and 044 Incorporated f July 28, 1987 The responst to Itei of Nonconformance 87-01-06 is incomplete in that P0 82-1068 'to Capito1 ~ Pipe and Steel and PO 86-8120S to West Penn Laco were not addressed in the response.
It was stated in part a) of the response' that 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 PO. Please provice 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 document 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 Electric manufacturing and Do All Pittsburgh and these types of manufacturers have QA/QC programs in place.
~
The response to Item of honconformance 87-03-11 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 calitiration services for measuring and test equipment that they manufacture 43 crc 1csed 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 shippi.ng until aucit is perfomed" clause is added to the P0 as needed.
If you have any questiens con:erning 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 i
Enclosure:
As stated f
o' t
AUG 2 41333 Bingham-Willamette Company ATTN:
Mr. J. L. Wood 1
Quality Assurance' Supervisor
.s P. O. Box 1024T
.k Portland,' OR 97210 l
Gentismen:
SUBJE C' T: QA PROGRAM REQUIREMENTS FOR SUPPLIERS OF CALIBRA
-\\
, J The Wood /Potapevs letter dated Jufy 25, 1983, requested the Commission's concurrence with Bingham-Willarnette Company's (BWC) position (ref. Rove /Sarnes letter dated January 11, 1982) r,n the audit requirements of suppliers of calibration services.
~
The Division of Quality Assurance, Safeguards, and Inspection Programs (QASIP) in the Office of Inspection and Enforcement was contacted to obtain an official "i
NRC positten on thri above schject..The following information states the NRC 5
position reieived from QASIP, and the hosition addresses the following three types of sugliers of calibration services:
. 1.
sSuppliers who offer calibration services for seasuring and test poipmentnotmanuf#:turedbythem.
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m 2.
Suppliers who offar calibration services for measuring and test 4
equipment that they manufacture.
39
'B-3 National Bureau of Star. cards,
,a st' With regard to whether a quality assurance program satisfying the provisions of 2
/
ANSI N45.2 is required of these three types of suppliers, our position is as follows:
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1 Thesuppliersnotedindypes'1and2abovearerequiredtohaveaquality~
a A:ssurance program to the exttet necessary to assure the quality of the
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safety-related service and product provided.
This means that the appropriate QA criteria of Appradix 8 to 10 CFR Part 50 and the appropriate s
provisions of the implementing ^ctandard, ANSI N45.2, should be applied consistent wdri the activities undertaken in the generation of the service l
a:4d product; a.g., design, procurement, manufacturing, testing, etc.
_In the case of the type 3 supp'fer?, the National Bureau of Standards, it is not necessat?/ for the purthUdr to assure that this organization have a gjtlity assurrarW program that Eee'te the applicable requirements of N
c 4pendix 8 tt, !q CFR Part 50 and ANSI N45.2 since it is a nationally recognized laboratory with proven abilities and disciplines.
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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:
1 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 1
to 10 CFR Part 50 may be shared among purchasers; e.g., utilization of I
the CASE register.
)
A preaward evaluation and postaward audits are not required for work performed at the National Bureau of Standards.
i Please accept my apology for the delay in responding to BWC's 1982 letter.
If yoJ have any Questions on the above comments, please contact Jim Conway (817) 860-8236 or Ian Barnes (817) 860-9176.
Sincerely, j
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- c. J. HAkU Uldis Potapovs, Chief Vendor Program Branch e
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