ML20237G801

Requests Info Re Quality of Spent Fuel Racks Fabricated by Us Tool & Die & Predecessor,Including Extent to Which Mfg Qa/Qc Program Relied Upon to Assure Rack Quality.Response Requested within 60 Days of Ltr Receipt

ML20237G801
Person / Time
Site:	Wolf Creek
Issue date:	08/20/1987
From:	Calvo J Office of Nuclear Reactor Regulation
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 8709020416
Download: ML20237G801 (3)

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+ o UNITED STATES NUCLEAR REGULATORY COMMISSION g ,r WASHINGTON. D. C. 20555 August 20, 1987 k*...*

Docket No. 50-482 Mr. Bart D. Withers President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation u Post Office Box 411 Burlington, Kansas 66839

SUBJECT:

QUALITY OF SPENT FUEL RACKS FABRICATED BY U. S. TOOL AND DIE AND ITS PREDECESSOR The U. S. Nuclear Regulatory Commission conducted an inspection of the U. S.'s Tool and Die facilities in Allison Park and Glenshaw, Pennsylvania, on .

March 23-27, 1987. During this inspection, it was found that the impleme'nta- s tion 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 con-cerning 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 V. 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, provide the following information:

1. Describe the extent to which the U. S. Tool and Die QA/QC program i was relied upon to assure rack quality;

2. 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. 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.

8709020416 070820 PDR

& ADOCK 05000482 PDR

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Mr. Bart D. Withers This request for information was approved by OMB under clearance number 3150-0011 which expires December 30, 1989. Comments on burden and duplication i may be directed to the Office of Management and Budget, Reports Management, {

Room 3208, New Executive Office Building, Washington, D. C. 20503.

Sincerely,

\hl Jose A. Calvo, Director Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects

Enclosures:

As stated cc w/ enclosures:

See next page 1

DI IBUTION 06cket File NRC PDR Local PDR PD4 Reading F. Schroeder P. Noonan P. O'Connor JCalvo l OGC-Bethesda E. Jordan J. Partlow ACRS (10) I PD4 Plant File LTR NAME: TOOL AND DIE LETTER 8/18 l

1 PD4/L4 PD4/PMf PD4/D PNoona P0' Connor: s r JCalvo j 8//7/87 8/li/87 8/zo/87 I I

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.a Mr. Bart D. Withers Wolf Creek Generating Station 3 Wolf Creek Nuclear Operating Corporation Unit No. 1 l CC' l j

-Jay Silberg, Esq. Mr. Gerald Allen Shaw, Pittman, Potts & Trowbridge Public Health Physicist "

i 1800 M Street, NW Bureau of Air Quality & Radiation Washington, D.C. 20036 Control Division of Environment ,

Chris R.' Rogers, P.E. Kansas Department of Health Manager, Electric Department and Environment Public Service Commission Forbes Field Building 321 P. O. Box 360 Topeka, Kansas 66620 l-Jefferson City, Missouri 65102 Mr. Gary Boyer, Plant Manager Regional Administrator, Regi0n III Wolf Creek Nuclear Operating Corp.

U.S. Nuclear Regulatory Commission P. O. Box 411 799 Roosevelt Road Burlington, Kansas. 66839 Glen Ellyn, Illinois 60137 ,

Regional Administrator, Region IV Senior Resident Inspector / Wolf Creek U.S. Nuclear Regulatory Commission c/o U. S. Nuclear Regulatory Commission Office of Executive Director P. 0. Box 311 for Operations Burlington, Kansas 66839 611 Ryan Plaza Drive, Suite 1000 .

Arlington, Texas 7601)  ;

Mr. Robert Elliot, Chief Engineer Utilities Division Mr. Otto Maynard, Manager Licensing Kansas Corporation Commission Wolf Creek Nuclear Operating Corp.

4th Floor - State Office Building P. O. Box 411 Topeka, Kansas 66612-1571 Burlington, Kansas 66833 l

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. ENCLOSURE 1 l UNITED STATES

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y .', - NUCLEAR REGULATORY COMMISSION usmc10N, D. C. 20555 l _2f

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' May 12, 1987 -

It(w' !t FCCC10E2/E7-01 U.S. Toc *i and Die, Incorporated ATih: Mr. Michael J. Rodgers President 4030< Route 8 A11h on Park, Pennsylvania 15101 Gentlemen:

• 1his refers to the inspection conducted by Ms. C. Abbate ard Messrs. J. Corey ,

' and K Asti nwall of this office on March 23-27, 1987, of your facilities in Allison Park and Glenshaw, Pennsylver,ia 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 6nd testing The areas proces:es of spent fuel storage racks at U.S. Tool and Die (UST&D).

which were covered included welding, nondestructive examination, personnel training, procurement, shop quality assurance (QA) implementation and quality records, Areat 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, end observations by the inspectors.

During the inspection, it was found that theThe.most implementation serious of of your theseQA program a,ppeart failed to meet certain NRC requirements.

to be the breakdown in the DA/0C procran concernini 2Trocess tumination

! are weld inspection. No in-process examinations or weld inspections were bemg perfoTT.Teu ih'the initial stages of fuel storage rack fabrication.

Additionally, two undersize fillet welds were identified by the NRC inspectorSeveral af ter the welds had been inspected and accepted by the UST&D inspector.

other noncenfomances 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 The specific findings and references pesting requirements of 10 CFR Part 22.

te tN.. pertinent requirements are identified in the enclosures to this letter, The enclosed Notice of Violation is sent to you pursuant You to are the required provisions to of Section 206 of the Energy Reorganization Act of 19M.

submit tc> this office within 30 days from the date of this letter a written statement containir.g: (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 Consideration actions may be and preventive measures were or will be completed.

given to extending your response for good cause shown.

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'. . ! Tcoi anc Die, Incorporated -2* Hay 12, 1987 I

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You are also requested to submit a similar written statement for each item which appears in the enclosed Nctice cf idnconfomance, s

s ite responses requested by this letter Ers!nQt ' subject to the clearant;c pre:edures of the Office of Manager.ert and '6udset as required by the'feperwork Fetuction Act of 1900, PL 96-511. 3 l

ir, cccordance 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 ARC's Fublic Document Room.

$tc21d yo have any questions :oncerning this inspection, we will be plebsed to oiscuss ther with you.

Sincerely, f

lis t!.1Herschof Acting Chief i

-r Vendor Inspection ranch Division of Reactor Inspection ar.d Safeguarc3 Office of Nuclear Reactor Regulation

Enclosures:

1. Appendix. A-l;otice of Violation

7. Appendix E-Netice of Nonconfomance

3. Appendix C-Inspection Report No. 99901082/E7-01

t. , Aprer. dix D-Inspection Data Sheets (6 pages)'

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cc- Cornonwealth Edison Company ATTii: Mr. Cordell Reed Vice President Pcst Office be). 767 Chicago, lilinois 60690 Wisconsin Public Service Corporation ATTI: Pr. D. C. Hintz j harager, Nuclear Fower l Fost Office Box 19000 ,

Green Bay, Wisconsin 54307 l

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Vemont Yankee Nuclear Fower Corporation ATTis: Mr. Warren P.14urphy, Vice President and Manager of Operations RD 5, Sox 169 Ferry Road Brattleboro, Vermont 05301

L APPENDIX A c'.S.: Tool and Die, incorporated 00cLet flo. 99901082/07-01 NOTICE OF V10LAT107:

As a result of the inspection conducted on March 23-27, 1987 and in accordance .j with Sect (on 20f of the Energy Reorganization Act of 1974 and its implementing regulatio1, 10 CFR Part 21, the followir.g violations were identified and categorized in accordance with the HEC Enforcement Policy.10 CFR Part 2. Appencix C.

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Sectiar 21.31 0' 10 CFR Part 21 requires, in part, that each corporation subje:t to the regulations in this part assure that each procurement decur ent for a basic component specifies, when applicable, thtt the

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pror siers of 10 CFR Part 21 apply. >

" Contrary to the abeve, a review of documentation packages for spert fuel storage racks fabricated under ASME Code Section 111. Subsection NF

-' reveeled that while 10 CFR Part 21 was imposed en U.S. Tool and Lie, Incorporated (UST&O) by their customers, UST&D did r.ct specify)that86-00208 10 CFR Part 21 requirements would apply on Purchase Orders (PO to ColucMt Electric Manufacturing; 841701 and -1679 to to All Pittsburgh; 86-62228 to Cromie Machine and Tool; 82-1051 to Comercial fasteners; 66-60802, -01208 and 87-70132 to West Penn Laco; 82-1032 to Allegheny Ludlum Steel; 36-60620 to Industrial Service Centers; 83-1387 to Sandvik; 87-70115 to Weld Star; 86-61112, -70103 and 87-70118 te Alloy-Oxygen Weld Suply; 80-E121E to Metal Goods; and CC-60921, 87-70130 and -70208 to hilliers 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 206 cf the Enercy Reorganization Act cf 1974 and procedures adcpted pursuant tothereguYationsof10CFRPart21. If posting of the regulations or i i 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 f ailed to post Section 206 of the Energy '

Reorganization Act of 1974. (87-01-02) 1 This is a Severity Level V violation (Supplement VII).

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o APPENDIX $

U.S., Tool and Die, Incorporated R:W, he. 909010!?/E7 41 hCTICE Of tiOfiCLisFORMAfiCE Osri* g er inspccticr conducted March 23-27, 1987, the implemer,tation of the Qua'ity Assurance (CA) Program at the UST&D facilities in Allison Fark and 61ershaw, Penr.sylvania was reviewed with respect to the fabrication of spert fuel stcrage racks. The applicable QA Program requirements Manual (QAPM), are 10 CFR Part2,50 Revision

- date:

Appe-di> .

Jeruary0,10 20,CFF 1986,Part ?1, and UST&D's QA PrograrBesed on the results of this inspec ttat certain activities at the U5l&D f acilities were not conducted in l acccrdance with these commitments. These items are listed below.

Criterion X of Appencix B to 10 CFR Part 50 requires, in part, that a {

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progra- for ir.spection be established and executed by or for the '

crganizaticr. performing the activity to verify conformance with the ,'

documer.ted instructions, procedures and drawings.

Section 14.3C cf the UST&E QAPM, requires, in part, that in-process examination or surveillance be conducted by Quality Control personnel to verify dimensions and that fabrication methods used by production are in accordance with the contract documents and industry practice.

Section 3.3 of Procedure 14.1, " Production Work Routing and Inspection Plan," Fevision 0, requires, in part, that Quality control perform all inspections, in-process exan.inations, testing verification, etc. notee on the flow chart (the

• Production Work Routing and Inspection Flan") in >

accordance with the,,epprcpriate procedures and that no production activi- I ties progress past these points until Quality Control has perfomed their duties.

Contrt.ry te the above, in-process examinations were nct being perforr.ed at the south shop per thi " Production Work Routing and Inspecticn Plan,"

Dreving 8601-0, Revision 1, fer the spent fuel racks being inanufactureo for the LaSalle project. (67-01-03)

?. Criterior, X of Appendit B to 10 CFR Part 50 reouires, in part, that e prograr, for inspection of activities affecting quality be established and executed to verify confomance with the documented instructier.s.

procederts and drawings.

Sectic,n 10.2A of the UST&L CAPh requires, in part, that all shcp inspections / examinations / monitoring are perfomed by qualified Quality Control personnel and in accordance with written procedures.

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-s 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. l 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 Cnntrol. (87-01-04) l i

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3. Criterien XII of Appendix B to 10 CFR Part 50 requi-es, in part, thtt measures be established to assure that tools, gages, instruments and other {

rneasuring and testing devices used in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to ce d rtein accuracy.

Section 12.2B, of the UST&D QAFM requires, ir. part, that the interval f

of calibration for each item be established in procedures. , l

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4 Section 2.4 of U5i&D Procedure 12.1, " Control of Inspection Measuring J Equipment," Revision 2, requires, in part, that each piece of inspection y

equipr.ent be assigned a pemanent unique serial number which will be f 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 infomation and this record card include among ether criteria, the calibration interval.

I Contrary to the above, a review of measuring and test equipment (NATE) and calibration records revealed the following:

a. Docur.ented evidence was not available to verify that the calibration interval for M&TE was established in procedures.

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b. The fo$r inner diameter (ID) box mandrels for the Kewaunee, Yement Yankee, and LaSalle projects in the south fabrication shop were not identified with a permanent unique S/N applied j by vibro-etching or with a durable label. i I

c. A calibration interval was not established in the "Cardex" )

syster for the modified ID box mandrel for the LaSalle i project in the north fabrication shop. (87-01-C5)

4. Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that to the extent necessary, procurement documents require subtentractors to provide a quality assurance program consistent with the pertinent l provisions of this appendix.

L Section 2.2A of the QAPM requires, in part, that the UST8D Quality Assurance Program be developed to comply with the requirements of l j

ANSI N45.2 and AN51/ASME NQA-1-Quality Assurance Program Basic Requirements.

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i The GA sections of the technical specifications for the Kewaunee, Venncnt Yankee, and LeSc11e projects impose the requirements of ANSI N45.2 end/or At.5 U ASVE LCA-1 upor, L'5TLD. 1 J

and Section 4 (Easic Requirements) of AESI/

Sectico 5 of ANSI N45.2-1977 l ASFI PCA-1-19E3 indicate that PCs shall require suppliers / vendors to have l e CA program consistent with the applicable requirements of the standard. i Contrery to the atove, a review of 43 P0s for materials and services i related to spent fuel racks fabricated under ASME Code Section 111, ,

Subsf ction NF indicated that quality requirements (e.g., QA 86-60746, Program)

-60613. -60214were not pessed on to vendors for the following P0s:

and -fit 20 to Cromie Machine and Tool; E0-60208 to Colurtia Electric .

Manufacturing; C4-1701 and -1679 to Do All Pittsburgh; E2-1066 to Capitol l

- Pipe erd Steel Products; E2-1051 to Corrnercial fasteners; 86-60E02, , '

-C1205, and 07-70132 to West Fenn Laco; 82-1032 to Allegheny Ludlum

• Steel; 25-51023 to Teche11oy; E2-1311 and 03-1387 to Serdvik; 87-70115 to 1 Weldstar; C6-70103 to Alloy-Oxygen Weld Supply; and 66-6121E to Fetal

-e Goods. (57-01-06)

5. Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that apriicable regulatory requirements, desi5n bases, and other requirements which are necessary to assure quality are suitably included or referenced in the docurents for procurement.

Section 4.2E of the OAPM requires, in part, that purchese orders for meterial delirecte all applicable requirements of the contract documerts.

Section 2.2 of Procedure 4.1, " Procurement Document Cottrol," Revision 5  !

• rec,uires, in part, th61 procurement documents reference all design specification requirements applicable to the items beirs purchased.

Sectien 5.3 of NES Specification No. 83A2256,

• Specification for the Fabrication and Inspection of the Vennont Yankee huclear Power Station Spent fuel Storage Racks " F.evision 0, requires that all weld filler metals rneet the requirements of Section III, Subsectier, KF including delte ferrite determination.

Stction 4.4B of the QAPP requires, in part, that the quality essurance marager cr his designee review and approve purchase orders prior to issber.ce to the vendor.

Sections 3.2 and 4.1 of Procedure 4.1 require that all PCs be reviewec' and approved by QA.

Contrary to the above, a review of P0s indicated that P0 87-70118 to Alloy-Oxygen Welding Supply for stainless steel weld filler metal 86-60610 to WALCO did net contain e delta ferrite determination statement, and PO Corporation for markers and tape was not signed / initialed and dated by QA personnel. (87-01-07)

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Criterion V of Appendix B to 10 CFR Part 50' requires, in part, that'  ;

activities affecting quality be prescribed by documented instructions, procedures or drawings.

Section 5.2B of the QAPM and Section 6.0 of ANSI N45.2 1977. requires, in part, that all activities affecting quality be prescribed and accomplished I with appropriate docutented procedures. f Contrary to the above, it was noted that a documented procedure / instruction i didnotexisttocontroltools-(e.g.,wireburshes,grindingwheels, hamners, etc.) that were designated for use only on stainless steel meterial. (87-01-08)

L Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that

- instructicrs, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determin Ug that important "

o- activities have been satisfactorily accomplished.

Section 5.2B of the QAPM requires, in part, that, as applicable, procedures, instructions, and/or drawings will include quantitative and qualitative acceptance criteria.

Section 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 prograr and project requirements.

Contrary to the above, Procedure 10.3 does not provide the QC inspector appropriate guidance indicating the required random sample quantities or percentages needed to ensure a representative sample during in-process examinations. (67-01-09)

E. Criterion XIV of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to indicate, by the use of marking, the status of inspections and tests performed upon individual items, and that these reasures provide for identification of items which have satisfactorily passed required inspections and tests, where necessary, te preclude inadvertent bypassing of such inspections and tests.

Secticn 14.2A of the QAFM requires, in part, that record of in-process

' examination or surveillance be noted on the part/ component / subassembly, f

Section I.3 of Procedure 10.3, "Inprocess Examination,' Revision 3, I requires, in part, that documentation is not required for. in-process examinations; however, each part, subassembly, piece and/or component f which is in-process examined be physical'y marked or documented as being examined by UST&D personnel performing the examination.

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Section 3.2 of Procedure 10.3 requires, in part, that QA/QC personnel mart each piece in-process examined with a unique marking to indicate the piece, part, sub-assembly and/or componer.t has been examined and by whor. i Contrary to the' above, marking procedures used by the south shop QC l 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) 5.

Criterion Y11 of Appendix B to 10 CFR Part 50 requires', in part, that measures be established to assure that purchased u.aterial, equipment and services conform to the procurement documents, and that the effectiveness of the control of quality by contractors and subcontractors

- be assessed et intervels consistent with the importance, complexity, ,

and quantity of the product or services.

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Sectier. 7.2B of the OAPM requires, in part, that venders be evaluated and n approved tered on their capability to provide material, equipment and/or services.

Section 1.1.1 of Procedure 7.2, " Evaluation of Vendors " Revision 1, requires, in part, that vendor evaluations be conducted to provide confi-dence in the vendor's QA Program for meeting the quality requirements.

Contrery to the above, vendor evaluations had not been performed on De All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D. (87-01-11) 1[. Criterion 11 of Appendix B to 10 CFR Part 50 requires, in part, that the quality assurance program provide for indoctrination and training of personrel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Section 2.5 of the QAPM requires, in part, that all UST&D personnel perfor-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 treining be centro 11ed to obtain suitable proffetency.

Srctice 2.1 of Procedure 2.3, " Training,* Revision 3 requires, in part, that all USil0 personnel performing quality related activities be trained in the requirements of UST&D's QA Program as applicable to their activity.

l Ccntrary to the above, training records did not exist for two UST&D-shop employees. (87-01-12)

Criterion Y)] of Appendix B to 10 CFR Part 50 requires, in part, thet i

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measures be established to assure that purchased material, equipment and services conform to the procurement documents. .

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l Sectior 7.2E of the QAPM requires, in part, that vendors shall be evaluated f and approved based on their capatility 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 purchese order.

Contrary to the above, PO 86-60143, dated February 14, 1986, was placed with Industriel Service Center while the evaluation was performed Merct 12-13, 19EE. (87-01-13)

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4 0 I C5 L ..';;E Jt;: L'.S.100L AND CIE ALLISCh PARK, PENT;SYLVANIA hErCF1 INSPECTION INSPECTION NO.. C99030E?/E7-01 DATES: 03/?3-27/P7 Ot.stTF Kt'os. Sin COR;.ESDChDENCE ADDRESS: U.S. Tool and Die ATTN: Mr. Michael T. Rodgers President 4030 Route 8 A111sor, Park, Pennsylvania 15101 ORGAh12Alict;AL CONTACT: Mr. Frank E. Witsch TELErH0! E f:UhPER: 412 aP7-7030 NUC' . ELF 1hDUSTRY ACTIY]TY:

FaLricator of spent fuel storage tact ,

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.s mum: Jam ASS:GhED INSPECT 0P: D/bI1A M Claudia M. Abbate, k TrogrTim' Development and Reactive6 ate 9

Inspection Section (PDRIS)

OTHER lhSFICTOES:

ames T. Conway, PDR15 Kenneth G. A pinwall, Consultant APPP.0VED BY: 4 . XD IP 7 {

ete Jafes C.~ Stone Chief PDR]S, Vendor Inspection Branch {

It.5:ICT30h BASES AND SCOPE:

1. BASES: 10 CFR Part 50 Appencix B,10 CFR Part 21.

C. -SCOPE: Otserve the fabrication and testing processes regarding the f abrication of spent fuel storage racks. Welding, nondestructive testing, perser.nel training, quality control inspection, procurement, shop QA implementation and quality records were reviewed.

Callaway, Ginna, KewauneT, , Fine Mile PLANT SITE APPLICA51LITY:

Point 2, Seabrook Shoreham, Temora i mee, WjlTlreek 3 7q - ;q\,

/,(i u g_ 1 , . t-ms- e- .m s

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U U.'. 2 W Ch: L'.5. TOOL Af;C DIE ALL150N PARK, pet:l:5YLVANI A INSPECTION PEPOPT RESULTS:

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99901CE2/E7-01 -

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1. Ccntrary to Secticn 21.31 of 10 CFR Part 21, a review of documentation packages for spent fuel storage racks fabricated under ASME Coce Section 111. Subsection KF revealed that while 10 CFR Part 21 was imposed on U.S. Tool & Die (UST&O) by their customers UST&D did not specify that 10 CFR Part 21 requirements would apply og Purchase Orders (PO) 86-6020B to Columbia Electric Manufacturing; 84-1701 and

-1679 to 00 All Pittsburgh; 86-61228 to Cromie Machine & Tool; 82-1051 to Comercial Fasteners; 86-60802, -81208 and 87-70132 to West Penn Laco; E2-1032 to Allegheny Ludlum Steel; B6-60620 to

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Industrial Service Centers; 83-1387 to Sandvik; 87-70115 to Weld

1. Star; 86-61112 -70103 and 87-70118 to Alloy-Oxygen Weld Supply; 66-61218 to Metal Goods; and 86-60921, 87-70130 and -70208 to Williers and Company. (87-01-01)

This is e Severity Level V violation (Supplement V11). l

2. Contrary to Secticn 21.6 of 10 CFR Part 21, UST&D failed to post (87-01-02)

Section 206 of the Energy Reorganization Act of 1974.

This is a Severity level V violation (Supplement Vil).

E. h0NC0hf 0Py.ANCE S :

1. Contrary to Criterien X of Appendix B to 10 CFR Part 50..Section 14.3C cf the UST&0 Quality Assurance Prograr Manual (QAPM),

Revision 2, and Section 3.3 of Procedure 14.1, ' Production Work F. outing ar.c Inspectien Plan," Revision 0, no in-process examinations  ;

were being perfomed at the south shop per the ' Production Work  !

Routing and Inspection Plan," Drawing 8601-0 Revision 1, for spent fuel racks being fabricated for the LaSalle project. (E7-01-03) i

2. Contrary to Criterien X of Appendix B to 10 CFR Part 50 Section t 10.2A of the U51&O QAPM, Revision 2, and Section 2.2.1 of Procedure

- 10.4, Final Inspection," Revision 1, two undersize welds were identi-1 fied by the NRC inspectors on a fuel rack which h6d been inspected and fcund accept 6ble by UST&O Quality Control. (87-01-04)

3. Contrary to Criterion X11 of Appendix B to 10 CFR Part 50, Section 12.2B of the UST&O QAPh. Revision 2, and Sections 2.4 and 2.6 of Frocedure 12,1,

• Control of Measuring and Test Equipment,' Revision 1 2, a review of measuring and test equipnient (M&TE) and calibration records revealed the following: f

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r REPDFT lhSPECTION RESULTS: PAGE 3 of 15 00.: 99c01002/67-01

a. Docur.enteo evidence was not available to verify that the calibration interval for M&TE was established in procedures,

b. The four inner diameter (10) Box Mandrels for the Kewaunee, Vermont Yankee, and LaSalle projects in the south fabrication shcp were not identified with a perranent unique S/N applied by vibro-etching or with a durable label.

c. A celebration interval was not established in the " Carder."

system for the modified ID Box Mandrel for the LeSalle project

- in the north fabrication shop. (87-01-05) r 2 Centrary to Criterion IV of Appendix B to 10 CFE Part 50, Section 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 and services related to spent fuel racks fabricated under ASME Code Section Ill, Subsection NF indicated that quality requirements (e.g., QA Pro 5 ram) were not passed on to vendors for the following PCs: 86-60746, -60813, -60814, and -61226 to Cromie Machine and Tool; 8C-6028 to Columbia Electric Manufacturing; 84-1701 and -1679 to Do All Pittsburgh; 82-1068 to Capitol Pipe &

Steel Products; 82-1051 to Commercial fasteners; 86-6082, -81208, are E7-70132 to Kest Penn Laco; 82-1032 to Allegheny Ludlum Steel; 85-51023 to Techa11cy; E2-1311 and 03-13B7 to Sandvik; 87-70115 to Leloster; E6-70103 to Alloy-Oxygen Weld Supply; and 66-61218 to Metal Goods. (67-01-06)

5. Contrary to Criterion IV of Appendix B to 10 CFR Part 50 Sections 4.IE end 4.4B of the QAPX, Revision 2, Sections 2.2, 3.2 and 4.1 of Procedure 4.1,

• Procurement Docurent Control," Revision 5, and Section 5.3 of NES Specification he. 83A2256, a review of PCs indicated that PO 87-70118 to Alloy Oxygen Welding Supply for l

stainless steel weld filler metal did not contain a delte ferrite i determination statement, and PO 66-60610 to WALCO Corporation for l

rerkers and tape was not signed /initicled and deted by QA personnel.

. (67-01-07)

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 h45.2, 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) i i

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I 041' : ~ Ai ! Of.: U.S. TOOL AND DIE ALL150h PARK, PEhh5YLVANIA REPC-RT INSPECTION .

PAGE 4 of 15 j 999C1082/87-01 RESULTS:

kD.:

k l I

7. Contrary to Criterior. Y 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 net provide the QC inspector appropriate guidance indicating the rec,ufred ranc;cm ,

sample quantities or percentages needed to ensure a representative j sample during in-process examinations. (87-01-09)

E. 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 1 Procedure 10.3, "Inprocess Inspection," Revision 3, merking l

. procedures used by the south shop QC inspector for in-process

' examination do not clearly identify items or components which have i 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 evaluatier.s had not been perfonned on Do All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D. (87-01-11)

10. Contrary to Criterion II of Appendix B to 20 CFR Part 50 Section 2.5 of the UST&D QAPK,' Revision 2, and Section 2.1 of Procedure 2.3,

" Training," Revisior 3, nc training records existec for the UST&D shop employees. (67-01-12)

21. Contrary to Criterion Yll of Appendix B to 10 CFR Part 50, Section 7.25 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 perfonned March 12-13, 1986.

(87-01-13)

C. UNRESOLVED ITEMS:

None.

L. STATUS OF PREVIOUS IL5f ECT10h F1hCINGS:

hone. 1his was the first NRC/ VIE inspection of this facility. ,

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' j 0 R G M , 3 H Ct.. U.S. TOOL AhD DIE '

ALLISON PARh, PENh5YLVANIA PEPCAT INSPECTION RESULTS: ,PAGE 5 of 15 t.0. : 999C10E2/87-01 E. IhSPECTICNFlHD1hGSANCOTHERCOMr.Eh15:

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 fabrication shops. The south shop, located in Glenshaw, Pennsylvtr.f a, receives the material and fctms and welds the individual cells.

The north shop, located in Allison Park, Pennsylvania, assembles r.

ar.d welds the cells into fuel storage racks and performs the final *

'- inspection. During the exit meeting conducted on March 27,'1967,

1. the ir.spectier. findings and observations were discussed with UST&D persenr,el.

2. Srer.t Fuel Racks - huclear Since 1982, UST&C has fabricated spent fuel racks for six comercial nuclear customers (see Table 1, page 15). Three projects are currently in progress: LaSalle 2, Kewaunee and Yennont 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 for Verront Yarlee. A number of cells have been fabricated f or Kewaunee, but they have not 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 technical specifications fer four projects: hine Mile Point 2, Verr.cnt iankee, Kewaunee and LaSalle 2. For all four projects, it was noted that the requirements of 10 CFR Fart 50, Appendix B and 10 CFR Part 21 were referenced in the P0s and/or specifications.

The huclear Energy Services (NES) specification for the Vennont Yankes project referenced the 1900 Edition of Sections !!, 111 (Sutsection NF), V and IX of the ASME Code, whereas the 1977 Edition

- of the sanc Sections were listed as applicable documents in the Store and hebster (SlW) specification for the Nine Mile Point 2 project. ECE personnel were to be trained and quclified per SLT-TC-1A, and inspectors were to be qualified to AhSI N45.2.6.

Weld filler metal was to be in accordsnce In with Subsection general, the material NF of Secticn III and specification AWS AS 9.

specifications included ASTM A240, A276, and A564. Cleanin5 I

f

ORGA'. ;;A11 Ch . U.S. TOOL AND DIE ALLISON PARK, PEhh5YLVANIA REP 0F. INSPECTION RESULTS: PAGE 6 of 15 NO.: 99901082/67-01 requirements were noted as Class B of ANSI N45.2.1; and handling, packagirg, ard shipping here to meet the Level C requirements of AhSI hts.2.2. Record retention was in accordance with ANSI N45.2.9 l and typical documents shipped to the custoner included: certified material test reports for stainless steel and weld material, heat treatment certifications (17-4 PH paterial), NCE reports, inspection reports, nonconferr.ance reports, repair and rework repcrts, ar.d a certificate of conformance from UST&D,

. 3. Plent Tour The inspectors toured the north and south fabrication facilities at *

• varicus times in the company of UST&D officials. Receipt inspection, press ferming of stainless steel sheet and welding of cells were activities ncted in the south shop. Items witnessed in the north 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 hamrer had a painted handle. UST&C personnel informed the inspecter that the peintee tools are used on projects which involve stainless steel while the unpainted tools ere used on projects which involve carbon steel. There was no decuretted instruction / procedure to centrol the use of painted and unpainted tools.

I henconferr.ance 87-01-08 was identified in this area.

4. Production Verk Routinc & Inspection Plan (PWRIP)

A PWRIP, which is similar to a " shop traveler," is generated by the Project hanager for each nuclear job. The PRRIP is laid out es an E-size drawing and identifies, for both the north and south shops, each production operation, CC inspection /in-process

" exaroinaticos, and customer witness points and mandatory hold points.

Several octes pertaining to the requirements of the customer's specification, inspections including dccuntentation, and hold Jcints are also included. Item No. 7 of the PRRIP 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,

• Inspection repcris will document all inspections and testing delineated on the Production Verk Routing & Inspection Plan.* The f

l I

07.G.'." T ;0h: U.S. TOOL AhD DIE ALLISON PAPK, PEhhSiLVAhlA .

2 l

l

--- INSPECTION RESULTS: PAGE 7 of 15 999MOR/E7-01 PWFIP, 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 document was used on all the nuclear <

prcjects becinning with Wcif Creek. The insp6ctor reviewed and verified that a PkhlP existed for the nine nuclear prcjects since IPC2.

During the inspection of shop activities, UST&D Drawing 8601-0, Eevision 1,

• Production Work Routing and Inspection Plan," for

- the LaSL11e project was reviewed. After the individual cell is l t

teck-welded and jetline welded together ari in-process examination e .^*

and weld inspection were to be perforried. These two activities '

• are cutlined in Procecures 10.3 and 10.5 respectively. s

" khen documentaticr. or inspection reports were requested for the l

in-process examinations ar.c weld inspections, none existed. No '

in-process examinations were being perforred on the fuel racks in the initial stages of fabrication at the south shop.

Nonconformance 87-01-03 was identified in this area. 1 Uper further review of the procedure, it was noted that in-process q exar.inations were defined as periodic randem sampling type checks to l determine that the shop is providing meterial which complies with )

the UST&D QA/QC program requirements. The shop QC persontel were unable to defin'e, quantitatively or with a percer.tage, the number of ]

periodic rardom sampling type checks to be performed by the inspector.

Procedure 10.3 is inadequate in that it does not give sufficient instructions tc the QC inspector as to what quantity a random sample is ar.d oues nct ensure a censistent number of in-process exaniinations among the different inspectors.

honconforriance 87-01-Og was identified in this area.

In addition, Procedure 10.3 does not require documentation of the

~

in-process exan.inations, however, each part rnay be physicallyThe marked af ter an in-process exarnin6 tion has been perforued.  ;

option of marking components to indicate completion of an in-process  !

examination is used by the south shop QC inspector. However, the l

mark used is a check snark enede on the compcnent surface with a marking pen. Several similar marks are also made on the component ,

i surface during manufacturing. There is ne instruction or guidance in Procedure 10.3 for the QC inspector or other shop personnel on hcw to distinguish the inspector's markings from other tranufacturing .

l markings.

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/

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f CEGn: A110h: U.S. TOCL AND DIE' I ALLISON PARK, PEKt;SYLVANI A INSPECT 10tl REPDF.T PAGE 8 of 15 )

99901082/67-01 RESULTS: = l HO.: _

Nonconfomance 67-01-10 was identified in this area.

5. Welcing and Keldine Machines Welding being perfomed on spent fuel storage racks for the LaSalle and Vermont Yankee projects was observed. Three welders were The performing production work at the time of the inspection.

followir,g items were reviewed during the inspection: presence of Kelding Procedure Specifications (VPS) at the work area, preheat end interpass temperature control, compatibility of WPSs to production wcrk and compliance with KPS essential and nonesser,tial 7 variables.

e Welding machires were ioentifited with a unique identification ,

number for verification of anperage and voltage requirements.

, Automatic welding equipment had attached documentation to ciert the welding operators of amperage and voltage ranges and tolerances In addition, each l for the thickness of the material being used.  ;

marvel weloing machine conteined a ccr. trolled record showing each welder who used the machine, date of use, and WPS used. This record is used as a sumery of weld performances for welder qeclification records.

Ne items of isonconfcmance er unreso'ived items were identifiec in this area.

C. Weld Inspection Final inspection of the completed spent fuel storage racks is outlined ir. Pro:edure 10.4, Revision 1, and includes a verification cf the physical dimensions of the co:r.pleted rack to the approved shop dfawing dimensions.

During the inspection of completed fuel storage racks for the LaSalle prcject, sisual and dimensional t.hech of fillet welds on fuelDrawine rack

- pedestal rcunting pads were perfomed by the NRC inspector.

8601-30, Revision 4, was used for the inspection. During the inspection, two fillet welds on the mounting pad were found tc be less than the one-quarter inch weld specified on the drawing. The rock was identified asAUST&D review rack number of the 11 (Comenwealth final inspection checklist Edison rack number 2FC160).

revealec that than welds hh6 been inspected and fcund acceptable by the UST&D QC inspector.

m - - - - - - - _ _ - _ _ __

OFC hi2A110h: U.S. TOOL ANC DIE ALL150h PAPK, PEhMSYLVANIA i- i I

l sp cki 1NSPECTICH hn.: 999010EE/07.01 PESULTS: jDAGE9of25_,j Pricr to the exit meeting, the velds were repaired. The new welds were examined by UST&C QC perscnnel and found acceptable. The NRC inspector verified that the welds were acceptable per the drawing.

henconf o rmance 87-01-04 hts identified in this area.

7. Welder Qutlificatier.s and Training The cations welder (LPS),qualifications Procedure Qualification to applicable Welding Records (Procedure Specifi-PQR)anddesign specification requirements were reviewed. Each w'lder e record in:luded

~

51s unigve helder identification number, t're WPS to which he was qualified and the supporting PQRs. Training records for four keloers were reviewed. The records docurented which training

' sessicr, the welders attended anc the date (see Section if of this repert).

1 The USTLD QA program requires that all personnel qualified to WCS 53 for autor,atic spot / fusion welding be trair.ed to the applicable 1

KFS, have practical experience and perform two tyst samples prior to prcduction welding. The reccrds of e'ight welders qualified to WPS E3 were reviewed and found in compliance with the require-ments mentioned obove.

The review of welder qualifications and trainin5 resulted in oc items of nonconformance or unresolved iters; however, training was minimal in thet welders are traintd only to the WPSs and there is no evidence that welders are trained to new revisions of kP5s.

L, Feld Filler faterial Control A review of wald filler material control was performed using UST&D Procedure 9.2, Revisson 4. The areas which were examined included:

weld filler material storage areas, storage of filler material, f

' markirt of meteriel (straight and spools), assignmer t of .r.aterial These

~

itventory control (M3C) numbers and issuar.ce/ return records.

iters were inspected at the veld filler material issuance stations at both the north and south shops. The review of weld filler I material centrol indicated that Procedure 9.2 was being implemented.

No items of nor. conformer.ce or unresclved items were identified in this area.

i

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'ORG'!d2AT10h: U.S. TOOL AND DIE ,

ALL150h PARK, PENNSYLVAhl A .

INSPECTION '

.kEFCR- PAGE 10 of 15 RESULTS:

NO.: 95901002/67-01 L 9. Nondestructive Examination (NDE) Personnel Qualifications The ht,E qualification records scre reviewed using UST&D Procedure 2.5, Revision 1. Certifications- and qualificatiet.s of the USTAD Level III NDE consultant, the QC Manager and two QC inspectors here ,

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 to the personnel were reviewed. Records of training and indoctrination of personnel to the NDE procedures and program were also reviewed.

' The reviet, of documentation for EDE personnel qualifications

'# resulted in nc ite .s of nonconformante or unresolved items; however, -

l documented evidence cf training of NDE persennel was n.ir.imal.

3C. Control of Measuring and Test Equipment (MTLE)

The ARC inspector reviewed applicable sections of the QAPM, one prccedure anc calibration records to deterrine whether M&TE was properly identified, controlled and calibreted at specified intervals. Inspecticn 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 exceptier. of four 10 box mandrels, the insp:cted eculpmert contained a vibro-etcheo 5/N. The four m6ndrels were for the Kewaunee, LaSalle and Vermont Yankee projects and were located in l

' the south shop. A Cerdex system, which is. maintained by the QC Manager, is used to record calibration information. Each card identifies the type of equipment including S/N, calibration date, calibration frequency, the standard used, and the icentity of the individual performing the calibration.

Equipment examined at tbc south shop includeo a vernier caliper, two n itror,tters , one ahickness gage, ete width gege, one tong test

- trceter, and four 10 bex mandrels. At the north shop, one tcts test ameter, three p.icrometers, one dial thickness gage, one vernier celiper, one bcre gagte, one radius gage set, one inside micrometer set, one cptical comparator, ont box mandrel (LaSalk project) and three n,icremeter standards were examined. In addit on, the calibration status of the eight welding machines in the north shop was checke6, The information contained on the calibration stickers on the items was in agreement with the applicable card.

I

' I l

l OPG4 :2Al'Oh- U.S. TOOL AND DIE ALLIS0h PARh, PENNSYLVANIA A j

r 1 PEPOP~ IhSPECTICL RESULTS: ,PAGE 11 of 15 j NO.: 99901062/67-01 The two AC-DC tong test ameters (S/N AX-48975 anc -58261) are sent tc Coluntia Electric Manufacturing (CLh) for calibration every two years. Test reports from CEM indicated that the equipment was calibrated in February 1900 with standards tracentle to the National Bureau of Standards (NBS). A Certificate of Calibration from Oc All Pittsburgh inoicated that a inester gage block set (S/N C-4) was calibrated in October 1504 with standards traceable to NBS. It was noted that a document dic not exist to ider,tify the specific equipment covered by the calibration program including the calibration frequency of such equipment.

henconformance 87-01-05 was identified in this area.

e '

11. Procurement Document Cortrol_ ,

Fnrty-three P0s to 15 material manufacturers / suppliers, four PCs to a machining vendor, three P0s to two vendors for calibration services, and one PO to a plating vendor were reviewed to assure that applicable technical and QA program requireunts were included or referenced in the P0s. With the exception of one order, all the P0s were initialed and dated by a OA individual. The P0 in question was No. 66-60610, dated June 6,1966, to KALCO Corporation for felt tip markers and nuclear grede cloth tape. Nineteen PCs did not invoke the requirements of 10 CFR Part 21 upon vendors - eight P0s to four mar.ufacturers/ suppliers of weld wire, three PCs to two calibration service vendors, one PO tc a n.achinir.g verdor, one F0 to a suplier of fasteners, and six P0s to manufacturers / suppliers of stair,less steel. In adc;ition, the requirement that a vendor have e QA pregram which has approved by UST&D was not included in nineteen P0s te vendors - four P0s to Cremie Machine and Tool, one PC to Colurtia Electric Manufacturing, two P0s to Do All Pittsburgh, one P0 to Capitol Pipe & Steel Products, one P0 to Connercial Fasteners, three P05 to West Penn Laco, one PG to Allegheny Ludlum, one PC to Techc11cy, two P0s to Sandvik, one F0 to Weld:ter, one PO to Alloy-Oxygen Weld Supply and one PO to Metal Goods. It was also noteo 2 ti.tt for PO 87-70118, deted January 16, 1987, to Alloy-Oxygen Welding Supply for 200d ASME Section II SFA 5.9 Type 312 filler metal cid not contain a *oelta ferrite detertrination steterent.

Violation 87-01-01 and Nonconformances 07-01-06 and 87-01-07 were j

identified in this area.

12. Documentation Packsges fDP)

A DP did not exist for the Yemont Yankee and Kewaunee projects as ,

finished racks were not yet cortpleted for these projects. The l i

OFCAh::ATIch: U.S. TOOL ANC DIE ALLIS0h PARK, PENNSYLVAhl A x

INSPECT 10N PEPORT RESULTS:

,PAGE 12 of 15 NO.: 999010E2/E7-01 w_

inspector reviewed three DPs for Rack M120-24 for kolf Creek and For Wolf Creek, the DP consisted Racks he. S 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 l Connercial Fasteners for fasteners. Several forms 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

1. 05750 Nonconformance Report and Verticality Test Report were also e part of the package. In addition, a UST&D C of C noted that all materials used in the fabrication of the reference rack assembly .

y conformed to Bechtel specification 10466-C-175.

The LPs for the two LaSalle racks consisted of the folicwing: l Documentation Checklist, Shop Bill of Material (SEM), CMTRs UST6L C of C, Weld Examination Records Final Inspection Checklists (FIC),

Levietion/ Variance Requests, Qualified Welders List, and a C of C ,

for the boraflex. The SSM listed the materin1 inventory control l

(MIC) number as well es 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 or a finished rack: diniensional verification, MIC No. verific6 tion, r

visual weld inspection, cleaning, marking, boraflex verification, l

anc 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 performed en its vendors and how approved vendors remain on the Approved Vendors

- List. This process is outlined in Procedure 7.2, " Evaluation of Vendors, Revision ), dated March 12, 1987.

Eleven vendor evaluation packages were reviewed. The packages contained the original survey or audit checklist of the vender and '

reevaluations of the vendor, The reevaluations consisted of a Vendor Evaluation Questionnaire and a historical quality performance d:ta review.

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i l.. i i CEGW.3710N: U.S. TOOL AhD DIE ALL150h PARK, PENNSYLVANIA l INSPECTION REFOR* PAGE 13 of 15 RESULTS:

NO.: 99901CE2/S7-01 l

l During the review,'it was noted that Do All fittsburgh and Colurbia manufacturing Electric, who supply calibration services, have net been evaluated by UST&D, nor has a historical e,uality perforniance data record been reintained en either ver. dor. Also during the review, it was noted that Industrial Service Center had been audited by UST&D Ma rch 12-13, 1986, while PO 86-60143 to Industrial Service Center had been placed February 14, 1986. This evaivation was not perforced within the specified 14 days of issuance of the P0 as required by Secticn 2.1 of Procedure 7.2.

hencenformances 27-01-11 and 87-01-13 were identified in this area.

A la. JOCFRPart21 h '

During the inspection, the NRC inspectors examined areas for the

"' pesting of 10 CFR Part El at both fabrication shops. It was noted that 10 CFR Part 21, USTIC frocedure 16.2 and Public Law $6-295 Act 4 of June 30, 1960, Section 223 were posted, but Section 206 of the t

Energy Reorgerizatio. Act of 1974 was not posted at the south shop.

Section 21.0 of'10 CFR Part 21 and UST&D Procedure 16.2, " Reportable Defects and Noncompliance (fiuclear Projects) 10 CFR 21," Revision 2, dated March 1%, 1987, require Section 206 to be posted. Prior to-the e)it meeting,'Section 206 and other applicable docu wits were posted at both shops.

Viclation 87-01-02 was identified in this area.

II. Trcining The NRC inspector reviewed U$T&D Procedure 2.3, ' Training," Revision 3, dated March 23, 1966. The procedure requires all 05T60 personnel l j

performing quality related activites to be trained as applicable to their activity. The procedure also requires that training records l l

be triaintained. \

i Tht NRC inspector reviewed 13 employee training records and training

~

sess'on records. The employee training records identify what trairing the employee has received while the training session records identify v.bo attended the training, the date and an outline of the subjects which were covered during the tr61ning. .

During this review it v$s 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 training, was present for a retired en.ployee; several training

- - . ,J

ORGAf.:Z AllCf.: U.S. TOOL AND 0.2 l ALLIS0h PARK, PEhh5YLVAf:IA l

INSFLt TION PEFCP.T RESULTS: PAGE 14 of 15 l NO.: 99901062/87-01 records were incomplete in that hire dates and training sessior, subjects were misi.ing; and two employees were trained outside the 45 day limit for new empicyees. In addition, UST&D only trains its personnel to the quality control procedure which the employeeThe will be using without an overall QA/QC program training session.

personnel are not trained to new res 'sions 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 a lengthy amount of time.

Nonconformance E7-01-12 was identified in this area. *

+- 16. Audits The NRC inspectors reviewed four internal audits. The Internal Project Managenent Audit, dated May 29, 1986, the Production Audit, i dated August 13, 1966, the QA/QC Audit, dated November 12, 1900, and the Engineering Department Audit, dated March 4,15C7, were reviewed.

Each audit included a checklist, an audit report (semary of results), '

and was performed by a qualified auditor. The audits which were reviewed were perforned and cocumented in accordance with Procedure 18.1, Audits," Revision 5, dated March 12, 1987, hc itets of nonconformance or unresolved items were identified in this area.

F. PERSONS CONTACTED:

P. Brinks, QC Manager, South Shop F. DeSimons, Foreman, horth Shop W. Dickson, Director of Venufacturing E. Jeblonsky, QC Inspector, North Shep L. terenboyer, Welder

• R. Linder, Manager of Engineering

• E. Merch, Vice Chairman of the Board, Chief Executive Officer E. Etinhart, QC Mu.ager, North Shop J Phoden, Project hanager F. Rhodes, Vice President, Manufacturing R. Fudisill, Welder

• M. Rodgers, President R. Stewart, Machinist

• B. Wachter, Vice President, Engineering and Research K. Weber, Assistant Project Manager

• F. Witsch, (A Manager

'Attenced Exit Meeting

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0F CP,: 2AT]Oh: U.S. TOOL AhD 01E ALL150h PARh, PEhh5YLVANI A 1  ;

INSPECTION i REFCM RESULTS:

PAGE 15 of 15 h0.: 99901CE;/87-01 TABLE 1 i

l Number of Date Racks / Positions _ Completed Utility /AE Project Type i

PWR-MDR 12/1328 1982 ShLFPS Wolf Creek hen-Poison karsas Gas &

Electric /Eechtel l PWR-MDR 12/132E 1902 i SPTUS Cellev:0

• t

' Unier, Electric / Non-Poison l Bechte' 1983 f Shorehan BWR-Non 15/17C0 '

" Lon; Islenc Poison S/756 Lighting /Stene

& Webster K6ter Flux 2/144 Trap Control Rods l New Fuel 3/90 1983 Public Services Seabrook Storage Co: pany Racks hiegare Mohawk hir.e Mile 11 BWR-MDR 1984 Poison 17/2530 Ster.e l kebster 10/1519  ;

i 6/420 1984 Roche ner Gas & Ginne Modified PWR Checker-Electric board to  ;

Poison Racks

)

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ENCLOSURE 2

~

L TELEPHONE (412)487-7030 ,

W. S. TQQL EL DIE, INC. _

[' 4030 ROUTE S e ALUSON PARK. PENNSYLVANIA 15101 f ,

t June 9, 1987 0 i

i United States Nuclear Regulatory Commission Vendor Inspection Branch l Division of Reactor Inspection & Safeguards Office of Nuclear Reactor Regulition Washington, DC 20555 Attn Mr. Ellis W. Merschoff, Acting Chief Re: -Docket $9901082/87-01

's Gentlemen ,

1. In response to the inspection report referenced above and submitted to-U.S. Tool & Die, Incorporated on May 12, 1987, we submit the

- following:

APPENDIX A VIOLATION f l -

" ... a review of documentation packages for spent fuel storage racks f abricated under ASME Code Section III, Subsection NT revealed that while 10 CTR Part 21 was imposed on U.S. Tool &

Die, Incorporated (DST &D) by their customers, UST&D did not specify . that 10. CTR" Part. 21 requirements would apply on '

Purchase Orders ...

l UST&D COMMENT a) The applicability of,the reporting requirements of 10CTR21 ,

has been placed on UST&D by its various Clients who l recognize these requirements do not pertain to material purchased as a commercial product (as defined in 10CTR21) 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. (Litters from the various Client's and the Atomic Industrial Forum's Committee -

Position Paper expanding on this position were presented to the NRC inspectors during the inspection) .

Based on these -documents the imposition of 10CTR21 is not applicable to the following Purchase Orders: 686-60802,

-81208, and $87-70132 to West Penn Laco; 487-70115 to Weld Star; 486-61112, -70103, and 487-70118 to Alloy-Oxygen Weld Supply: 686-61218 to Metal Goods; and 486-60921, 487-70130, and -70208 to Williams & Company.

irrs.m =cm m W0, 4,p%1 j

e' b) Per project specifications, 10CTR21 was not applicable to:

P.O.082-1051 to Commercial Fasteners; $82-1032 to Allegheny Ludlum; 486-60620 to Industrial Service Center and therefore not imposed on the vendors. .

c) On both the original and revision #1 of P.O.883-1387 to Sandvik, the applicability of 10CTR21 is noted onPage 2 of 2. ,

5 d) P.O.f86-60208 to Columbia Electric and 684-1701 arid 484-1679 to Do All Pittsburgh were for service to commercial type tools.

P.O.486-61228 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 Item (d)

A revision to the Purchase Orders 886-60208 to Columbia p Electric; 884-1701 and 184-1679 to Do All Pittsburgh; and 686-61228 to Cromie Machine & Tool will be issued y

and include the reporting requirements of 10CTR21.

A review of 10CTR21 anc 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.

V,IOLATION (2 -

". . . UST&D f ailed to post Section 206 of the Energy Reorganization Act of 1974. (87-01-02)"

UST&D COMMENT 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.

I e .

APPENDIX B NONCONFORMANCE il .

... in-process examinations were not being performed at the South Shop' per the " Production Work Routing and Int,pettion Plan," Drawing 8601-0, Revision 1, for the spent fuel 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.

e- .

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 62

"... 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. (d7-01-04)"

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 , veld acceptance _

i criteria vill be made with Cuality Control personnel by June 30, 1987 to prevent recurrence.

I 1

a NONCONTORMANCE 63

... 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 calibrationintervalforM&TEwasestablishedinprocedures.

b) The four inner diameter (ID) box mandrels for thefKewm nee, Vermont Yankee, and LaSalle projects in the South f ab: . cation 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 COMMENT Corrective Action has been or will be taken as follows: ,

+r a) As delineated in UST&D's calibration procedure, the calibration ye intervals are ' established in the "Cardex" system but will be 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 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 af ter 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. -

f 4 y e es l

dO f eM

c s

140!;CONTORMANCE 4 4 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.O.086-60746, -60813, -60814 and -61228 to Cromii Machine

& Tool were for machining UST&D supplied material. Material traceability has been maintained and 100% 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.686-61218 to Metal Goods was for material ordered for handling equipment and therefore not subject to Quality Assurance / Quality control requirements.

c) P.O.682-1051 to Commercial Fasteners and P.O.482-1032 The to l +.

Allegheny Ludium was for material for a DOE project.

project specifications did not require imposition of the 10CTR50 Appendix B requirements.

dl 3.0.186-60802, -81208, and 687-70132 to West Penn Laco,

- P.O.982-1311 and 83-1387 to Sandvik, P.O.187-70115 to Weld l

Star and P.O.f85-51023 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 . t B 6 -7 010 3 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 Manuf acturing 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. .

CORRECTIVE ACTION Revised P.O.486-60802, and (87-70132 to West Penn Laco;

1. 82-1311 and 483-1387 to Sandvik 487-70115 to Weld Start.

and 485-51023 to Techa11oy will be issued and include the requirement to furnish material per their Quality Assurance.

Quality Control Program.

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 requirements of UST&D's Quality Assurance Program.

---

._-_m_ ___ __

I I

NONCONTORMANCE 85

... a review of purchase orders indicated that P.O.4 87-70ll8 to Alloy Oxygen Welding Supply for stainless steel weld filler metal did not contain a delta-ferrite detennination statament',

and P.O.fB6-60610 to WALCO Corporation for markers and tape was not signed / initiated and dated by Quality Assurance personnel.

(87-01-07)" t i

UST&D COMMINT The veld 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.

. CORRECTIVE ACTION g.

Revised purchase orders will be issued with the proper j 1

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.

I NONCO'NFORMANCE 46 it was noted that a documented procedure / instruction did not l j

cxist to control tools (e.g . , wire brushes , grinding wheels , hammers ,

etc.) that were designated for use only on stainless steel material.

(67-01-08)"

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 Departme'nt to, 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.

___]

1;ONCONTOM R;CE $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 <2 examinations. (87-01-09)" t UST&D COMMENT f l

l As part of the in-process inspection, material traceability is l

maintained on a 100% basis; all cells are gaged to assure I proper dimensions are maintained; and as a minimum, machined parts with critical dimensions are "first piece" inspected, and spot checked on c 10% random sampling basis.

If any discrepancy is revealed by this inspecticn, a minimum of 10 previously fabricated pieces are checked. Any discrepancy found in these 10 pieces will require a 100% inspection of all pieces.

CORRECTIVE ACTION Procedure 10.3 will be revised to include the above .

1, quantitative acceptance criteria and training will be conducted with Quality control personnel by June 30, 1987 to review this change.

NONCOUTORMANCE 4 8

" . . . 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.

O e

e ee

l V

• NONCONFOR..ANCE 49

" ... Vendor evaluations had not been performed on Do All Pittsburgh ,

and Columbia Electric Manufacturing who provide calibration , {

services for UST&D. (87-01-11)"  !

l UST&D COMMENT r l k

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

~

% the calibration methods and equipment used is traceable to the National Bureau of Standards.

Tr CORRECT!'C ACTION

. A re-evaluation will be conducted on these two vendors by August 15, 1987.

NONCONTOR.vR;CE 110

"... training records did not exist for two UST&D shop e=ployees.

(87-01-12)"

UST&D COMV.ENT The two machinists have been employed by UST&D for over 15 and 20 years and training had not been documented.

CORRECTIVE ACTION j Corrective Action will include training of employees to their activities and documentation will be completed by June 30, 1987.,

y G6 l

UST&D CO.P.ENT ice Cantor A

This purchase order was issued to Industrial Serv il Industrial with a provision that no material be shipped untThed first shipment of by Service Center was audited by UST&D. i material ordered by this purchase order was rece ve UST&D on April 8, 1986.

CORRECTIVE ACTION p ent A training session30, will1987 be conducted with procur to review purchasing yeativities.

personnel by June f

. ctive Action U.S. Tool & Die, Incorporated feels that the abovevered Correby this y will satisfy the Violations and Nonconformances unco NRC inspection.

Sincerely, U.S. TOOL &j IE, INC.

e Plchael Rodgers

• President MJR:gb O

Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice Presidant Post Office Box 767 Chicago, Illinois 60690 Wisconsin Public Service Corporation ATTUs Mr. D. C. Hintz Manager, Nuclear Power Post Office Box 19002 Green Bay, Wisconsin 54307 Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy, Vice President

' and Manager of Operations

• RD 5, Box 169 -

rerry Road '

s Brattleboro, Vermont 05301 -

i Bechtel Energy Corporation ATTN: Mr. Robert Baremore Project Supplier, Quality Supervisor 5400 Westheimer Ct P. O. Box 2166 Houston, Texas 77252-2166 ic: EAM MR S TW WW CT TR i

1

- - , r-

q - - - - -

• ENCLOSURE 3 9 s, ge uso I, .* 'e

', UNITED sT ATEs NUCLE AR REGULATORY COMMISSION

[

e usHmotoN. p. c. Posss July 28, 1987 Docket ho. 9990.1082/87-01 U.S. Tool and Die, Incorporated ATTN: Mr. Michael J. Rodgers President 4030 Route 8 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 No. 9990106E/87-01, dated May 12, 1987. Your response and corrective acticn for Notice of Violation 87-01-02, and Items of Nonconformence 67-01-04, 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 s) of the response to Notice of Violation 87-01-01 states that 6fter receipt of comercial grade material at USTAD and dedication to the specific basic This component is in accordance by UST&D, the reporting with 10 CFR 21.3 c-1).(requirements Please provideofa10 CFR 21 are description in effect.

of UST&D's dedication process that is used to upgrado comercial grade products for use as basic components and a sample of the documentation implementing the dedica-tion process for P0s 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 of 10 CFR 21 to Pos 81-1051, -1032, and 86-6020. Part c) states that 10 CFR 21, is imposed on page 2 of PO 83-1387 to Sandvik. Please provide a copy of P0 65-1387.

It should be noted that the NRC has not taken a position on the Atomic Industrial Fornm's Comittee Position Paper, " Recommended Practices for Procurement of Replacement / Spare Parts for Nuclear Power Plants." Also, in addition to imposing 10 CFR 21 on UST&O, customers impose ASME Code Section III, Subsection NF and 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 P0. . . . .

The response to Item of Nonconformance 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 t~ en final rack assembly. Please provide assurance that the types of in-process exams performed at the North Shop met the requireraents of." Production Work Routing and Inspection Plan," Drawing 8601-D, and Procedure 14.1.

I U

- (

P l U.S. Tool and Die, incorporated July 28, 1987 ,

The response to Item of Nonconformance 87-01-06 is incomplete in that PO S2-1068'to Capitol Pipe and Steel and FO 86-81206 to West Penn Laco were not l 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 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 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 kant,facturing and Do All Pittsburgh and these types of manufacturers have QA/QC programs in place.

.' The response to Item of Nonconformance 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 87-01-33, the tra4ning given to procurement personnel should include measures to ensure that the "no shippi.ng until avoit is performed" clause is added to the P0 as needed.

If you have any questions concerning these requests for additional infomation, please contact Ms. Claudia Abbate at (301) 492-4776 or Mr. James Stone at (301)492-9661.

Sincerely, Ellis W. Merse , Acting Chief Vendor Inspecti Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation  ;

Enclosure:

As stated I

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0 Bingham-Willamette Company ATIN: Mr. J. L. Wood Quality Assurance Supervisor .

P. O. Box 1024T Portland, OR 97210 1

Gentlemen:

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SUBJECT:

QA PROGRAM REQUIREMENTS FOR SUPPLIERS OF CALIBRATION SERVICES l

The Wood /Potapovs letter dated July 25, 1983, requested the Commission's concurrence with Bingham-Willamette Company's (BWC) position (ref. Rove /Barnes 1etter dated January 11, 1982) on 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 hRC position on the above subject. The following information states the NRC position received from QASIP, and thep 'osition addresses the following three types of suppliers of calibration services:

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Suppliers who offer calibration services for measuring and test equipment not manufactured by them. ,,

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, 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.? is required of these three types of suppliers, our position is as follows:

The suppliers noted in types 1 and 2 above are required to have a quality essurance program to the extent necessary to assure the quality of the safety-related service and product provided. This means that the appropriate QA criteria of Appendix B to 10 CFR Part 50 and the appropriate provisions of the implementing standard, ANSI N45.2, should be applied (onsistent 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 is not necessary for the purchaser to assure that this organization have a quality assurance program that meets the applicable requirements of Appendix B to 10 CFR Part 50 and ANSI N45.2 since it is a nationally recognized laboratory with proven abilities and disciplines.

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't. t Bingham villamette Ccmpany *2-  !

With regard for the need of preaward evaluation and postaward audits for these three types of suppliers, our position is as follows- I

- 1 A preaward evaluation and post 6 ward 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 l 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

s. (817) 860-8236 or Ian Barnes (817) 860-9176.

Sincerely, originst sic"d C.J. HA'L Uldis Potapovs Chief Vendor Program Branch

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