ML20237H269
| ML20237H269 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/27/1987 |
| From: | Joshua Wilson Office of Nuclear Reactor Regulation |
| To: | Dewease J LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8709030188 | |
| Download: ML20237H269 (3) | |
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UNITED STATES NUCLE AR REGULATORY COMMISSION
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1 August 27, 1987 Docket No. 50-382 Mr. J. G. Dewease Senior Vice President -
Nuclear Operations Louisiana Power and Light Company 317 Baronne St., Hail Unit 17 New Orleans, Louisiana 70160
Dear Mr. Dewease:
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 D. S.
Tool and Die facilities in Allison Park and Glenshaw, Pennsylvania, on March 23-27, 1987.
During this inspection, it was found that the implementa-tion of the U. S. Tool and Die QA prcgram 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 (1 Enclosure 2).
NRC'.s review of the corrective actions were detailed in a letter to V. 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:
l 1.
Describe the extent to which the U. S. Tool and Die QA/QC prograr 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 f
corrective actions were taken.
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5.
Describe any_ additional actions or examinations you plan to undertake to assure that your racks meet the original design and regulatory requirements.
Please orovide your response within 60 days of your receipt of this letter.
8709030188 870827 9
PDR ADOCK 05000382 O
PDR lo -
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- This request for information was approved by 0MB 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 Managerrent, Room 3208, New Executive Office Building, Washington, D. C. 20503.
Sincerely, i
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James H. Wilson, Project Manager Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects
Enclosures:
As stated cc w/ enclosures:
See next page 1
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DISTRIBUTION LD6cket File NRC PDR Local POR PD4 Reading F. Schroeder P. Noonan J. Wilson JCalvo OGC-Bethesda E. Jordan J. Partlow ACRS (10)
PD4 Plant File LTR NAME: TOOL AND DIE LTR. WATERFORD 3 PD4/LKQ/d JCalvo[J7C-PD4 PD4/0 PNoonan JWils sr 8d7/87 8/27/
8/27/87 t
5 Mr. Jerrold G. Dewease Waterford 3 Louisiana Power & Light Company CC:
W. Halcolm Stevenson, Esq.
Regional Administrator, Region IV Monroe & Leman U.S. Nuclear Regulatory Commission 1432 Whitney Building Office of Executive Director for New Orleans, Louisiana 70103 Operations 611 Ryan Plaza Drive, Suite 1000 Mr. E. Blake Arlington, Texas 76011 Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Carole H. Burnstein, Esq.
l Washington, D.C.
20037 445 Walnut Street New Orleans, Louisiana 70118 Mr. Gary L. Groesch Post Office Box 791169 Mr. Charles B. Brinkman, Manager New Orleans, Louisiana 70179-1169 Washington Nuclear Operations Combustion Engineering, Inc.
l Mr. F. J. Drummond 7910 Woodmont Avenue, Suite 1310 Project Manager - Nuclear Bethesdc, Maryland 10814 Louisiana Power & Light Company 317 Baronne Street Mr. William H. Spell, Administrator New Orleans, Louisiana 70160 Nuclear Energy Division j
Office of Environmental Affairs Mr. K. W. Cook Post Office Box 14690 Nuclear Support and Licensing Manager Baton Rouge, Louisiana 70898 Louisiana Power & light Company 317 Baronne Street President, Policy Jury New Orleans, Louisiana 70160 St. Charles Parris Mahnville, Louisiana 70057 Resident Inspector /Waterford NPS Post Office Box 822 Killona, Louisiana 70066 Mr. Ralph T. Lally Manager of Quality Assurance l
Middle South Servies, Inc.
Post Office Box 61000 New Orleans, Louisiana 70161 Chairman Louisiana Public Service Commission One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 i
ENCLOSURE 1
[ge. = % "'c, UNITED ST ATEs
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NUCLE AR REGULATORY COMMISSION I
W ASHIN G T O N. D. C. 20555
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May 12, 1987 i
Lew R:
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i U.S. Toc 1 and Die, Incorporated AT*h.
Mr. Michael J. Rodgers President 4C30 Route 8 Allison Park, Pennsylvania 15101 l
Gentic er.:
This refers to the inspection conducted by Ms. C. Abbate and Messrs. J. Conway ar.d K. Aspirwall of this office on March 23-27, 1987, of your facilities in Allison Park and Glenshaw, Pennsylvania and to the discussions of our findingf, with you and members of your staff at the conclusinn of the inspection.
+
.s 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 i
which were covered included welding, nondestructive examination, personcel trairing, procurement, shop quality assurance (QA) iniplementction'and quality records. Areas examined during the inspection and our findings are discussed i
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 ireplementation of your QA program failed to meet certain KRC requirements. The..most serious of these appaarc tc te the breaktiown in the DA/DC crocram concerning in-peers mmination W weTc inspection. No in-process examinattens or weld inspections were beirrg7erforwc in'the initial steges of fuel storege rack fabrication.
Additionally, two uncersi2e fillet welds were itsntified by the NRC inspector Several af ter the welds had been inspected and accepted by the UST&C inspector.
other noncenformances were identified in the areas of measuring end test equipment, procurement, and training, while two violations were identified in the areas of specifying 10 CFR Part 21 on procurement documents and the resting requirements of 10 CFR Part 21. The specific findings and references te tbrc. pertinent requirements are identified in the enclosures to this
- letter, The enclosed hotice of Violation is sent to ycu pursuant to the provisions of Section 206 of the Energy Reorganization Act of 1974.
You are required to subr,it to this office within 30 days from T.he date of this letter a written statement containing:.(1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed. Consideration may be given to extending your response for good cause shown.
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Tc:a ene Die, Irccrpcrated May 12,1967 You are also requested to submit a similar written statement for each item whict appears in the enclosed Nctice of Nonconformance.
The responses requested by this letter are not subject to the clearence prc:ederes of the Office of Managemert and Budget es required by the Paperwork l
Ret cticn Act of 1900, FL 96-511.
1 In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the er. closed inspection report will be pieced in the NRC's Pub'ic Document Room.
Stc id yo; have ary questions corcerning this inspection, we will be pleased to ciscuss ther with you.
l Sincerely, j'
lis W. Herschof / Acting Chief l
n Vendor Inspection 4 ranch Division of Reactor Inspection and Safeguarcs Office of Nuclear Reactor Result. tion
Enclosures:
1.
Apper. dix A-hetice of Violation 2.
Appendix E-hetice of Nonconformance 3.
Append 4 C-Inspection Report No. 99901082/E7-01 4,
A;;er. dix D-Inspection Data Sheets (6 pages) l l
cc-Com:nwealtt Edison Cor;ary ATTh: Mr. Cordell Reed Vice President Pcst Office ha 767 Chicago, liiinois 6069D Wisconsin Public Service Corporation l
ATih:
Pr. D. C. Hintz l
her.ager, Nuclear Power Fost Office Box 19000 Green Bay, Wisconsin 54307 Vemor.t Yankee Nuclear Power Corporation A1TN: Mr. Warren P. liurphy, Vice President er.d Manager of Operations RD 5, Box 169 Ferry Road l
Brattleboro, Vercont 05?01 l
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j APPENDIX A U.C. Tool and Die, Incorporated Do:Le. No. 90901082/E7-01 l
NOTICE OF VIOLATION 23-27, 1987 and in accordance l
As a result of the irspection conducted on March i
witt. Section 20f cf the Energy Reorganization Act of 1974 and its impler.enting regulatien,10 CFR Fart 21, the followirs violations were identified and categorized ir, accordance with the HEC Enforcement Policy,10 CFR Part 2, Appendix C.
Secticn 21.31 of 10 CFR Part 21 requires, in part thtt each corporation 1.
subject to the regulations in this part assure that each procurement cccument for a tesic component specifies, when applicable, that the r
previsiers of 10 CFF. Part 21 apply.
Contrary to the ebrve, a review of documentation packages fcr sper.t fuel l
stcrage rack's fabricatet under ASNE Code Section III, Subsection NF revealed that while 10 CFR Part 21 was imposed en U.S. Tool end Die, 2ncorrerated (UST&C) by their customers, UST&D did r.et specify)that J
86-00208 10 Cf E f art 21 requirements would apply on Purchase Orders (PO 84-1701 and -1679 to Ec All Pittsburgh; to Columbis Electric Manufacturing; S6-61228 to Cromie Machine and Tool; 82-1051 to Commercial Pasteners; EC-60802, -01208 and 87-70132 to West Penn Laco; 82-1032 to Allegheny Ludium Steel; 86-60620 to Industrial Sarvice Centers; 83-1387 to Sandvik, 87-70115 to Keld star; 86-01~112, -70R J and 87-70118 to Alloy-Oxygen Keld Sur;1y; 86-E121E to Metal Goods;)and CC-60921, 87-70130 and -70208 Miliars and Compny.
(87-01-01 inis is e Severity Level V violation (Supplenwnt VII).
Section 21,0 of 10 CFR Part 21 requires, in part, that each corporation 2.
post current copies of the regulations of 10 CFR Part 21, Section 206 cf the incrgy Peorgarization Act cf 1974 and procedures adopted pursuant If posting of the regulations or to the regulations of 10 CFR Part 21.
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, USTAD failed to post Section 206 ef the Energy Reergani:ation Act of 1974.
(87-01-02)
This is a Encrity Level V violation (Supplement VII).
Ac%-4-%55
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APPEND 11 6 i
U 5. Tool and Die, Ir.corporated Deck +t Nc. 999010E2/ET 01 1
1 I
hCTICE OF NONC0hf0RKANCE l
l Es i g ar. ins ctict cerducted March 23-27, 1987, the implementation of the
)
i OuP 'ty Assurance (CA) Progran at the UST&O facilities in Allison Park and Glershaw, Pennsylvania was reviewed with respect to the fabrication of spert j
The applicable QA Program requirements are 10 CFR Part 50, j
B,10 CFF Part 21, and UST&L's QA Prograr Manual (QAPM), Revision 2, fuei stcrage racks.
A;; e - di) detec Jarcery 20, 1966. Based on the results of this inspection, it arpears Mit certain activities at the U$l&D facilities were not conducted in j
accc rdance with tFese concitsents. These items are listed below.
I Criterion X of Appencix B to 10 CFR Part 50 requires, in part, that a 1.
prograr for irspection be established and executed by cr for the crgarizatitt perforcing the activity to verify conformance with the documented irstructier,s, procedures and dravings.
Section 14.3C cf the USTAL QAPM, requires, in part, that in-process ex mination Gr surveillance be conducted by Quality Control personnel to verify timensiens and thAt f abrication methods used by production are in accordance with the contract documents and industry practice.
Section 3.3 cf Procedure 14.1,
- Production Work Routing and Inspection Flan," Fevisitn 0, requires, in part, that Quality Control perfom all inspections, ir-process examinations, testing verification, etc. notec or, the flow chart (the *Freduction Work Routing ard Inspection Flan") in accorcance with the appropriate procedures and that no production activi-ties pregress past these points until Quality Control has perfomed their duties.
tc the above, in-process examinations were nct being performed Contrcr; at the south she; per the " Prot uction Work Routing and Inspecticn Plan,"
i Draving 8601-0, Resision 1, for the spent fuel racks being manufactured for the LaSalle project.
(87-01-03)
Criterior. X of Appendi> B to 10 CFR Part 50 requires, in part, that e 2.
prograr. for inspection of activities affecting quality be established and e>ecuted to verify conformance with the documented instructions, procedures and drawings.
Section 10.2A of the UST&D QAPh requires, in part, that till shcp inspections /eterinations/ monitoring are perfomed by qualif ted Quality t.ontrol personnel and in accordance with written procedures.
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Section 2.2.1 of Procedure 10.4, " Final Inspection," Revision 1, requires, in part, that verification of the physicel dimensions of the shipping piece I
with the approved shop drawing dimensions be performed.
Centrary to the above, two undersize welds were identified by the NRC inspcctors on a fuel rack which had bean <nspected and found acceptable ty UST&2 Quality Contr91.
(87-01-04)
Lriterien XII of Apper. dix B to 10 CFR Part 50 requires,111 part, that 3.
rneasures be established to a:sure that tools, gages, instruments and other r easuring and testing devices used in activities affecting quality are l
properly controlled, calibrated and adjusted at specified periods to madrtain accuracy.
Section 12.2B, of the UST&D QAFM requires, in part, that the interval cf calibration for each itcm be established in procedures.
Section 2.4 of UST&D Frocedure 12,1, " Control of Inspection Measurins Equipnent," Revision 2, requires, in part, that each piece of inspection l
l equipnent be assigned a pemanent unique serial _ number which will be l
l 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 infortnation and this record card include among other criteria, the calibration interval.
Contrary to the above, c review of measuring and test equipment (M&TE) and calibration records revealed the following:
Documented evidence wa> not available to verify that the a.
calibration interval for M&TE was esteb11shed in procedures.
The four inner diameter (ID) box mandrels for the Kewaunee, b.
Vermont Yankee, and LaSalle proje. cts in the south fabricatier shop 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.
syster. for the modified ID box mandrel for the LaSalle prcject in the north fabrication shop.
(87-01-05)
Criterien IV of Appendix B to 10 CFR Part 50 requires, in part, that 4.
to the extent necessary, procurement documents require subtentractors to provide a quality assurcnce 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 F. equi rements.
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, The GA sections of the technical specifications for the Kewaunee Vermcr,t unkee, and LaSclle projects impose the requirements of ANSI M5.2 and/or Af.!! // 5F'E f;C A-1 upon L'STED.
and Section 4 (Easic Requirements) of ANSI /
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$ection 5 cf AfiSi N45.2-1977 A5t'I "(A 1-15E3 incicate that PCs shall require suppliers /vt.ndors to have e CA program corsistent with the applicable requiremer.ts of the standard.
l Contrery to the above, a review of 43 P0s for materials and services relate # to spent fuel racks fbbricated under ASitE Soce Section 111,) were Subsection NF indicated that quality requirements (e.g., QA Program 86-60746, -606 not pessd on to vendors for the following P0s:
and -61Gi to Cromie Machine and Tool; 80-60200 to Columbia Electric 82-1068 to Capitol Marufecturing; E4-1701 and -1679 to Do All Pittsburgh; Pipe art Steci Products; 82-1051 to Commercial Fasteners; 86-6 CEC 2,
-01205, and 07-70132 to West Fenn Laco; 82-1032 to Allegheny Ludium Steel; 85-51023 to Techelloy; 82-1311 and 03-1387 to Sandvik; 87-70115 to l
Weldstar; C6-70103 to Alloy-Oxygen Weld Supply;.and 66-61210 to Metal l
Goods.
(E7-01-06)
Criterion IV of Appendix B to 10 CFR Part 50 requires, in part, that rneasures be established to assure that applicable regulatory requirements, 5.
design bases, and other requirements which are necessary to essure quclity are suitably inc1'aded or referenced in the documents for procurement.
j Section 4.2E of the QAPM requires, in part, thet purchase orders for t
material delireate all applicable requirements of the contract documents, Section 2.2 of Procedure 4.1,
- Procurement Document Control," Revision 5 requires, in part, th61 procurement documents reference all design i
specification requiremer.ts epplicable to the itets being purchased.
Sectier E.3 of NES Specification No. E3A2256, " Specification for the j
Fabrication and Inspection of the Yemont Yankee huclear Power Station i
Spent Fuel Storage Racks," F,evision 0, requires that all weld filler l
metals meet the requirements of Section III, Subsection EF including n itt ferrite determination.
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Sgetion 4.4B of the QAPl'. requires, in part, that the quality assurante J
manecer er his designee review and approve purchase orders prior to j
issuar.ce to the vendor, i
Sections 3.2 and 4.1 of Procedure 4.1 require that all PCs be reviewec:
and approved by QA.
87-70118 to l
Contrary to the above, a review of P0s indicated that PO Alloy-Oxygen Welding Supply for stainless steel weld filler metal did net 86-60610 to WALCC contain a delta ferrite determination statement, and FG Corporation for markers and tape was not signed / initialed and dated by QA personncl.
(F7-01-07) i
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Criterion V of Appendix B to 10 CFR Part 50' requires, in part, that activities af fecting quality be prescribed by documented instructions, E.
procedures or drawings.
Section 5.28 of the QAPM and Section 6.0 of ANSI Ns5.2-1977 requires, in l
part, that all activities af.fecting quality be preicribe.J and accomplished with appropriate dccutented procedures.
Contrary to the above, it was noted that a documented >rocedure/ instruction I
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did not exist to control tools (e.g., wire burshes, grinding wheels, hammers, etc.) that were designated for use only on stainless steel ccterial.
(87-01-08)
Criterion V of Appendix B to 10 CFR Part 50 requires, in part, that instructicrs, procedures or drawings shall include appropriate quer.titative 7.
or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
e Sectier. 5.2B of the QAPM requires, in part, that, as epplicable, procedures, instructions, and/or drawings will include quantitative J
ar.d qualitative acceptance criteria.
I 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 random sample quantities' or percer,teges needed to ensure a representative sample during in-process examina ticr:s.
(87-DI-09)
Criterion 11V of Appendix B to 10 CFR Part 50 requires, in part, that E.
measures be established to indicate, by the use of marking, the status of inspections and tests performed 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 byptssing of such inspections and tests.
Secticr.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 exan.inations; however, each part, subassembly, piece and/or component which is in-process examined be physically marked or documented as being examined by UST&O personnel performing the examination.
. Section 3.2 of Procedure 10.3 requires, in part, that QA/QC personnel mark each piece in-process 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 ir.spector for in-process examination do not clearly identify items or components which have satisfactorily passed the required examinations or whc examined the part.
(67-01-10) 9.
Criterion VII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that purchased material, equipment and services 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,
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and quantity of the product or services.
e Section 7.2E of the QAPM requires, in part, that vendors be evaluated and approved tased 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 Progran for neeting the quality requirements.
Contrary to the above, vendor evaluations hed not been performed on De All Pittsburgh and Columbia Electric manufacturing who provide calibration services for UST&D.
(87-01-11) 10.
Criterien 11 of Appendix B to 30 CFR Part 50 requires, in part, thet the quality assurance progran provide for indoctrination and training of personnel perforning activities affecting quality as necessary to assure that suitable proficiency is achieved anc 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 training be controlled to obtain suitable proficiency.
Sf ttior 2.1 of Procedure 2.3, " Training," Revision 3, requires, in part, that all USTLC personnel performing quality related activities be trained in the requirements of UST&D's QA Program as applicable to their activity.
Centrary to the atove, training records did not exist for two UST&D shop employee s.
(87-01-12) 11.
Criterion VII of Appendix B to 10 CFR Part 50 requires, in part, that measures be established to assure that purchased material, equipment and services conform to the procurement documents.
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. Section 7.2E of the QAPl4 requires, in part, that vendors shtIl be evaluated and apprcved based or. their capability to provide material, equipment and/or
- Services, Section 2,1 of Frocedure 7.E.
- Evaluation of Vendors, Revision 1, requires, in part, that ar evaluation be made er. proposed new vendors furnishing quelity related materials and/or services prior to, or within 14 days of, issuance of a purchase order.
86-60143, dated February 14, 1986, was placed Contrary to the above, PO with Industrial Service Center while the evaluation was performed F,aret 12-13, 19EC.
(87-01-13) e
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L'.5. 700t AND C1E ALL15Ch PAFK, PENNSYLVANIA KEr:F1 INSPECTION INSPECTION K.,
!99020E2/E7 01 DATES-03/?3-27/P7 OL-51TF bd'DR*
110,L I
~0::ESPChDENCE ADDRESS:
U.S. Tool and Die ATTh: Mr. Michael T. Rodgers President 4030 Route 8 Allison Prrk, Pennsy1yar.ia 15101 0FUhl2AliONAL CONTACT: Er, Frank E. Witsch T E L E ?H0!.E t.'UNE E R :
a12 aP7-7030 NJ C '. E M 1hDL'5TEi ACTIVITY:
Fabricator of spent fuel storage racks.
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ASSIGhED INSFECTCP: $0o$m N 6
9 Claudia M. Abbate, Frograra' Developmer.t and Reactive ate Inspection Section (PDR15)
OTFER 1h5FEC10R5:
James T. Conway, PDR15 Kenr.eth G. A pinwall, Consultant 8 # 7 A [.
^4 AFFE0VED SY:
Jafes C. Storie, Chief, PDRIS, Vendor Inspection Branch ate
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If.5;ECT10h EASES AND SCOPE:
A.
BASES:
10 CFR Part 50 Appencix B, 10 CFR Part 21.
E..
-5 COPE : Otserve the fabrication and testir.g processes regarding the fabricatier of spent fuel storage racks.
Welding, nondestructive testing, perser.nel training, quality control inspection, procurement, shop QA irplemer.tation and quality records were reviewed.
PLANT SITE APPLICABILITY:
Callaway, Ginne, Kewaunee, rplie 2, Nine Mile Pcint 2. Seabrock, ShorehLm, Ternora imee, WjlTTree[k
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U.S. TOOL AND DIE ALL150h PARK, PENI:5YLVAh1A i
1 INSPECTION PEPORT 60.:
999MCE2/E7-01 RESULTS:
,PAGE 2 of 15 A
\\ MLA710hS:
Contrary to Secticn 21.31 of 10 CFR Part 21, a reviev of documentation packages for spent fuel storage racks fabricated under ASME Cooe Section ))I, Subsection NF revealed that while 10 CFR Part 21 was imposed on U.S. Tool & Die (UST&D) by their customers, USTLD 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 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; 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 Williers and Company.
(87-01-01)
This is a Severity Level V violation (Supplement Yll).
Contrary to Secticn 21.6 of 10 CFR Part 21, UST&D failed to post 2.
Section 206 cf the Energy Reorganization Act of 1974.
(67-01-02)
This is a Severity level V violaticn (Supplement VII).
E.
h0NCONFOU'.ANCE S :
Contrary to Criterien X of Appendix B to 10 CFR Part 50, Section 1.
14.3C cf the UST&D Quality Assurance Prograr Manual (QAPK),
Revision 2, and Section 3.3 of Procedure 14.1, "Productier Work Routing ar.c Inspection Plan,* Revision 0, no in-process examinations were being performed at the south shop per the " Production Ecrk Routing and Inspection Plan,* Drawing 8601-0, Revision 1, for spent fuel racks being fabricated for the LaSalle project.
(67-01-03)
Contrary to Criterien X of Appendix B to 10 CFR Part 50, Section 2.
10.2A of the U5l&D OAPM, Revision 2, and Section 2.2.1 of Procedure 10.4,
- Final Inspection," Revision 1, twc 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 X11 of Appendix B to 10 CFR Part 50, Section 3.
12.2B of the UST&D QAPh Revision 2, and Sections 2.4 and 2.6 of Procedure 12.1, " Control of Measuring and Test Equipment,' Revision 4
l 2, a review of measuring and test equipnient (M&TE) and calibration j
1 records revealed the following:
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ORGaCaW U.S. TOCL AND DIE ALLISch PAFF, PEhhSYLVALIA r
REFCET 1hSPECT10N q
NO.:
99901002/87-01 RESULTS:
.PAGE 3 of 15
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Occur, entec evidence was not available to verify that the celebration intervel for M&TE was established in procedures, j
b.
The four inner diameter (ID) Box Mandrels for the Kewaunee, Vermont Yankee, and LaSalle projects in the south fabrication shcp were not identified with a permanent unique S/N applied by vibro-etching or with a durable label, A celebration interval was not establi:;hed in the "Cardex" c.
systen for the modified ID Box Mandrel for the LaSalle project in the north fabrication shop.
(87-01-05) 4 Centrary to Criterion IV of Appendix B to 10 CFR 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 raterials and services related to spent fuel racks fabricated under ASEE Code Section Ill, Subsection NF indicated that quality requirements (e.g., QA Program) were net passed on to vendors for the following PCs:
86-60746, -60813. -60814, and -61228 to Cromic l
Machine-and Tool; B6-6028 to Columbia Electric Manufacturing; 84-1701 and -1679 to Do All Pittsburgh; 82-1068 to Capitol Pipe &
Steel Products; B2-1051 to Comercial Fasteners; 86-6082. -81208, anc E7-70132 to Kest Penn Laco; 82-1032 to Allegheny Ludlum Steel; EE-51023 to Techelic); E2-1311 and 03-1387 to Sandvik; 87-70115 to Kelostbr; CC-70103 to Alloy-Oxygen Weld Supply; and 86-61218 to Metal Goeds.
(57-01-06) 5.
Contrary to Criterion IV of Appendix B to 10 CFR Part 50, Sections 4.IE 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 PCs indicated that PO 87-70118 to Alloy Oxygen Welding Supply for steinless steel weld filler metal did not centain a delta ferrite detern.ination statement, and PO 06-60610 to WALCC Corporation for merkers and tape was not signed /initicled and dated by QA perscnnel.
(E7-01-07) 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 / ins 1,ruction did not exist to control tools (e.g., wire brushes, grinding wheels, hamers, etc.)
that were designated for use only on stainless steci material.
(87-01-08) l
I
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ALLISON PA M, PENNSYLVANIA INSPECT 10N l
REPCF.T PAGE 4 of 15
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NO.:
999C1082/87-01 RESULTS:
i Contrary to Criterion V cf Appendix B to 10 CFR Part 50, Section 5.2B 7.
cf the UST&D QAFM, Revision 2, and Section 2.2 of Procedure 10.3, i
- Inprocess Inspection," Revision 3, Procedure 10.3 does not provide
.the QC inspector appropriate guidance indicating the recuired ran6cm sample quantities or. percentages needed to ensure a representative l
satple during in-process examinations.
(87-01-09)
)
i Contrary to Criterion XIV of Appendix B to 10 CFR Part 50 Section 5.
14.2A of the UST&D QAPM, Kevision 2 ' and Sections 2.3 and 3.2 of Procedure 10.3, "Inprocess Inspection," Revision 3 marking-procedures used by the south shrp QC inspector for in-process exatir.ation do not clearly identify iten:s er components which teve satisf actorily passed the required examinations or who examined the
- l
-part, (07-01-10) y
.l Cor.trary to Criterion VII of Appendix B to 10 CFR Fart 50, 9.
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 ev61u6ticr.s had not been perfortned 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 l
of the UST&D QAPK, Revision 2, and Section 2.1 of Procedure 2.3, l
" Training," Revision 3, no training records existec for the UST60 shop employees.
(67-01-12)
Contrary to Crittrion VII of Appendix B to.10 CFR Fart 50, 11.
Section 7.25 of the UST&D QAPM, Revision 2, and Section 2.1 cf 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.
i (87-01-13) 3 L.
UNRESOLVED ITEMS:
l N o'ne.
L.
STATUS CF PREVIOUS ILLFEC110N F1htlNGS:
hone. 1his was the first NRC/V1B inspection of this facility.
1
=
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s 3
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999C1002/E7-01 RESULTS:
PAGE 5 of 15 l
E.
IhiPECTICNFlhDIhGS/NCOTHERCOPEEN3:
1 1.
Entrance and Exit Meetings An entrance meeting was conducted on March 23, 1987 at the Allison 1
Park, Pennsylvania office of UST&D. The purpose and scope of the j
inspection were discussed during this meeting. UST&D has two fabrication shops. The south shop, located in Glenshaw, Pennsylvar.ia, receives the meterial and fcrms and welds the individual cells.
The north shcp, located in Allison Park, Pennsylvania, assembles i
ar.d welds the cells into fuel storage racks and performs the final j
l inspection.
During the exit meeting conducted on March 27, 1967, i
the inspectier, findings and observations were discussed with UST&D j
personnel.
i 2.
Srent 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 Yerrnont Yankee. The customer's design is being used for the Vern; cut Yankee and Kewaunee projects, while UST&D's design is being used for the LaSalle project.
To date, cnly five prototype cells hate been fabricated for Verront Yankee. A number of cells have been fabricated for Kewaunee, but they have not been 6st,embled into a completed rack.
l The NRC inspector reviewed the customer's procurement packages for the rine projects including a detailed review of the P0s and/or the technical specifications fer four projects: hine Mile Point 2 Vermont iankee, Kewaunee and LaSalle 2.
For all four projects, it I
was noted that the requirements of 10 CFR Part 50, Appendix B and 10 CFR Part 21 were referenced in the P0s and/or specifications.
The huclear Energy Services (hES) specification for the Vermont Yankee pro.iect referenced the 1900 Edition of Sections 11, 111 i
(Subsection NF), V and IX of the ASME Code, whereas the 1977 Editicn 1
of the same Sections were listed as applicable documents in the l
Store and hebster (S&W) 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 qualified te AhSI h45.2.6.
l Weld filler metal was to be in accordance with Subsection NF of Section 11! and specificetien AWS AS.9.
In general, the material l
specifications included ASTM A240, A276, and AS64.
Cleaning
5
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6 ORSP G CN; U.S. TOOL AND DIE l
ALLISON PARK, PEhhSYLVANIA 1
REPOE7 INSPECTION l
NO.:
99901082/67-01 RESULT 3:
jPAGE 6 of }5 ll requirements were noted as Class B of ANSI N45.2.1; and handling, pacLeging, ard shipping were to sneet the Level C requirements of AhS1 h45.2.?. Record retention was in accordar,ce with ANSI N45.2.9 l
and typical documents shipped to the customer included: certified l
material test reports for stainless steel and weld material ' heat I
treatment certifications-(17-4 PH material), NCE reports, inspection reports, nonconformance reports, repair and rework repcris, and a certificate of confomance from UST&D.
3.
Plent Tour I
The intpectors 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 noted in the south shop.
Items witnessed in the north i
-r shop included machining, installation of poison material (i.e.,
bcraflex 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 harmer had a painted handle. UST&C personnel infortned the inspector that 1
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 decurented instruction / procedure to centrol the use of painted and unpainted tools.
honconfo'rma nce 87-01-08 was identified in this area.
4.
Production Work Routinc & Inspection Plan (PWE1P)
A PWRIP, which is similar to a " shop traveler," is generated by the Project kanager for each nuclear job. The PWRIP is laid out as an E-size drawing and identifies, for both the north and south shops, each production operation, CC inspection /in-process exar.inations, and customer witness points and mandatory hold points.
Several notes pertaining to the requirements of the customer's specification, inspections including documentation, and hold.pcints j
are also included.
Item No. 7 of the PWRIP states that "documen-
.i' tation is not always required" for in-process examinations. This does not agree with Section 14.2 of the QAPM which states, in part, "Ir.spection reports will document all inspections and testin delineated on the Production Kerk Routing & Inspection Plan.g The l
l 7
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U.S. TOOL Atc DIE ALLISON PAPr., FEhhS)LVAh]A REPO E INSPECTION h0.:
999C10E2/E7-01 RESULTS:
PAGE 7 of 15 PWFIP, includin5 changes, is approved by the Engineering and QA l
departments.
The PWRIP cane into effect upon the generation of the i
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 PkkIP existed for the nine nuclear projects since 1002.
1 During the inspection of shop activities, U5760 Drawing 8601-0, 1
1 F.evision 1,
- Production Work Routing and Inspection Plan," for 1
the LaSalle project was reviewed. After the individual cell is f
teck-welded and jetline welded together, an in-process examination anc weld inspection were to be performed.
These two activities are outlined in Proceoures 10.3 and 10.5 respectively.
When dccumentatier, or inspection reports were requested for the in-process examinations ard 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.
Upcn further review of the procedure, it was noted that in-process examinations were defined as periodic random sampling type checks to determine that the shop is providing material which complies with the US160 QA/QC program requirements. The shop QC. personnel were unable te define, quantitatively or with a percentage, the number of periodic render sampling type checks to be perfomed by the inspector.
Procedure 10.3 is inadequate in that it does not give sufficient instructions te the QC inspector as to what qutntity a random sample f t and oues net ensure a censistent number of in-process exaniinations among the different inspectors.
honconformance 87-01-09 was identified in this area.
In addition, Procedure 10.3 does not require documentation of the in-process exan inations, however, each part may be physically marked af ter an in-process examination has been performed. The option of merking components to indicate completion of an in-process examination is used by the south shop QC inspector. However, the mark used is a check mark made en the component surface with a marking pen. Several similar marks are also made on the co'nponent 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
m6rkings.
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U.S. TOOL AND DIE ALLIS0h FARK, PENNSYLVANIA
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INSPECTION REPORT PAGE 8 of 15 H0.:
- 7901082/S7-01 RESULTS:
Nonconformance E7-01-10 was identified in this area.
l S.
Welding and Weldine Machines Welding being performed on spent fuel storage racks for the LaSalle and Vermont Yankee projects was observed, Three welders were performing production work at the time c the inspection. The following items were reviewed during the insper. tion: presence of Welding Procedure Specifications (WPS) at the work area, preheat 2
and interpass temperature control, compatibility of WPSs to production work and compliance with WPS essential and nonesser.tial 4
variables.
Welding machines were ioentified with a unique. identification l
nutter for verification of amperage and voltage requirements.
Automatic welding equipment had attached documentation to alert the welding operators of amperage and voltage ranges and tolerances for the thickness of the material being used.
In addition, each marvel welding machine contained a ccr. trolled record showing each welder who used the machine, date of use, and WPS used. This record l
is used as a summary of weld perfortr.ances for welder qualification l
records.
i No iters cf nonconferr.ance or unresolved items were identified i
]
in this area.
l l
C.
Weld Inspection l
Final inspection of the completed spent fuel storage racks is l
outlined in Procedure 10.4, Revision 1, and includes a verification cf the physical dimensions of the completed rack to the approved shop drawing dimensions.
During the inspection of completed fuel storage racks for the LaSalle prcject, sisual and dimensional checks of fillet welds on fuel rack pedestal mcunting pads were performed by the NRC inspector. Drawing 6601-30, Revision.4, was used for the inspection. During the inspection, two fillet welds on the mounting ped were found to be l
less than the one-quarter inch weld specified on the drawing. The rack was identified as UST&D rack number 11 (Commonwealth Edison-rack number 2FC16C). A review of the final ir.spection checklist revealeo that these welds had been inspected and fcund acceptatic by l
the UST&D QC inspector.
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U.S. TOOL AfC CIE ALL150h PAPK, PEhNSYLVANI A INSPECTION REPCR; PAGE 9 of 15 N0;:
999020E2/E7-01 RESULTS:
1 Pricr to the exit meeting, the welds were repaired. The new welds l
were examined by UST&C QC perscnnel and.found acce;talle. The NRC inspector verified that the welds were acceptable per the drawing.
honconformance 87-01-04 was identified in this area.
7.
Welder Qualifications and Training The welder qualifications to applicable Welding (Procedure Specifi-cations (hPS), Procedure Qualification Records PCR) and design specification requirements were reviewed.
Each wilder record included his unique welder identification number, the WPS to which he was quelified and the supporting PQRs. Training records for four welders were reviewed. The records documented which trair.ing sessicn the welders attended and the date (see Section 16 of this repert).
The UST&D QA program requirs: that all personnel qualified to WPS-53 for automatic spet/ fusion we' ding be trained tc the applicable WFS, have practical experience and perform two test samples' prior to prcduction welding. The records of e'ight welckrs qualified to WP5 53 were reviewed and found in compliance with the require-j l
nents mentioned above.
The review of welder qualifications and trainir.g resulted in no items of nonconformance or unresolved items; however, training was minimal in that welders are trained only to the WPSs and there is no evidence that welders are trhined to new revisior.s of KPSs.
i L.
Weld Filler faterial Control A review of weld filler material control was perfonwrd using UST&O Procedure 9.2, Revision 4.
The areas which were examined included:
i weld filler material storage areas, storage of filler mate.-ial, f
marking of material (straight and spools), assigrment of material.
inventory control (MIC) numbers and issuar.ce/ return records These
~
items were inspected et the weld filler material issuance stations 61 both the north and south shops'. The review of weld filler material centrol indicated that Procedure 9.2 was being implemented.
No items of nonconformance or unresolved items were identified in this area, i
s
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U.S. TOOL AND CIE ALLIS0h PARK, PEi*SYLVANIA INSPECTION REFCRT PAGE 10 of 15 NO.:
M 901002 /67-01 F.E SULTS:
nondestructive Examination (NDE) Personnel Qualifications l
9.
The hCE qualification records were reviewed using DST &D Procedure Certifications and qualificaticr.s of the USTAD 2.5, Revision 1.
Level 111 NDE consultant, the QC Manager and two QC inspectors were Prior training hours; general, practical, and specific reviewed.
tests, including the amount of questions per discipline and test results; ar,d a verification of annual eye examinations received by Records of training and indoctrination the personnel were reviewed.
of personnel to the NDE procedures and program were also reviewed, The review of documentation for NDE personnel qualifications e
resulted in no iteras of nonconformance or unresolved items; however,
- documented evidence cf training of NDE personnel was mir.imal.
n Control of Measurinc and Test Equipment (MTLE) 10.
The hRC inspector reviewed applicable sections of the QAPM, one procedure anc calibration records to determine whether N5TE was properly identified, controlled and calibrated at specified intervals.
Inspection areas in the north and south fabrication shops were inspected to review the calibration status of gages and treasuring instruments found in these areas.
With the exception of four ID box mandrels, the inspccted equipmer.t contained a vib o-etcheo S/N. The four mandrels were for the t
Xewaunee, LaSalle and Vermorit Yankee projects and were located in the south shop. A Cardex system, which is. maintained by the QC Each card Manager, is used to record calibration infomation.
l identifies the type of equipment including S/N, calibration date, calibration frequency, the standard used, and the icentity of the individual perfoming the calibration.
Equipment examined at the south shop included a vernier caliper, two rticrometers, one thickness gege, one width gage, one tong test anmeter, and four ID bex mandrels.
At the north shop, one tong test ammeter, three micrometers, one dial thickness gage, ont vernier caliper, one bcre gage, one radius gage set, one inside inicrometer set, one optical cortparator, one box mandrel (LaSalle prcject) and' I
three r.icremeter standards were examined.
In addition, the calibration status of the eight welding machines in the north shop
. he information contained on the calibration stickers T
was checked.
on the items was in agreement with the applicable card.
J
OFG4 '2A1:CM U.S. '00L AND DIE ALLISCb PAU., PENNSYLVANIA 1
PEPOR~
IhSPECTICh NC.:
99901062/E7-01 RESULTS:
PAGE 11 of 15 The twc AC-DC tong test ameters (S/N AX-42975 and -58261) are sent tc Colurtia Electric Manufacturing (CEh) for calibration every two Test reports fror. CEM indiceted that the equipment was years.
calibrated in February 1900 with standards traceable to the Kational Bureau of Standards (NBS). A Certificate of Calibration from De All Pittsburgh indicated that a master gage block set (S/N C-4) was 1
calibrated in October 1504 with standards traceable to NBS.
It was I
noted that a document did not exist to identify the specific i
equipr.ent covered by the calibration program including the calibration frequency of such equipment.
honcetformance 87-01-05 was identified in this area.
11.
Procurement Occument Control Fnrty-three P0s to 15 material manufacturers / suppliers, four P0s to a r.achining verdor, three P0s to two vendors for calibration services, and one P0 to a plating vudor were reviewed to assure that applicable technical and QA program requirements were included or referenced in the P0s. With the exception of one order, all the P0s were initialed and dated by a QA individual. The P0 in question was No. 66-60610, dated June 6, 1986, to KALCO Corporation for felt tir r,arkers and nuclear grade cloth tape. Nineteen P0s did not invoke the requirements of 10 CFR Part 21 upon vendors - eight P0s l
to four narufacturers/ suppliers of weld wire, three PCs to two l
I calibration service vendors, one PO tc a machining vendor, one PO to a suplier of festeners, and six P0s to manufacturers / suppliers of I stainless steel.
In addition, the requirement that a vador have a QA program which was approved by UST&D us not included in nineteen l
i
- PCs te vendors - four P0s to Cromie Machine and Tool, one PC to Colurbia Electric Manufacturing, two P0s to Do All Pittsburgh, one PO to Capitol Pipe & Steel Products, one P0 to Comercial Fasteners, three F0s to West Penn Laco, one P0 to Allegheny Ludlum, one PC to Techalley, two P0s to Sandvik, one PO to Weldstar, one PO to Alloy-
{
Oxygen Weld Supply and one PO to Metal Goods.
It was also noteo l
e thtt for PO 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 "celta ferrite detertrination" statement.
l Violation 87-01-01 and Nonconformances 07-01-06 and 87-01-07 were identified in this area.
- 12. Documentation Packages (DP)
A DP did not exist for the Yemont Yankee and Kewaunee projects as finished racks were not yet completed for these projects. The
e i
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U.S. TOOL ANC DIE ALL150h PARK, PENNSYLVAh1A s
INSPECTION I
REPORT PAGE 12 of 15 h0 :
99901082/E7-01 RESULTS:
inspector reviewed three DPs for Rack M120-24'for Wolf 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 l
products; a CMTR from Sandvik, who is a certificate holder, for ER 308 L weld wire; and a certificate of confomance (C of C) from Comercial fasteners for fasteners. Several foms for box identifi-i cetion/ inspection, bottom plate identification / inspection, lead-in guide assembly to rack, and visual weld inspection reports were includec. A Bechtel Supplier Deviation Disposition Request and a UST&D henconformance Report and Verticality Test Report were also 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 e
conformed to Bechtel specification 10466-C-175.
y The DFs for the two LaSalle racks consisted of the follering:
Documentation Checklist, Shop Bill of Katerial (SEM), CMTRs, UST&D C of C, Weld Examination Records, Final Inspection Checklists (FIC).
Devietion/ Variance Requests, Qualified Welders List, and a C of C The SBM listed the material inventory control I'
for the boraflex.
(MIC) number as well as the material specification and supplier fer each iter. (e.g., bcx half, bottom plate, pedestal body, etc.).
The FIC verified thet the following activitits were accomplished or a finished rack: diniensional verification, Mit No. verification, visual weld inspection, cleaning, marking, boraflex verification, and the mandrel insertion test, ho iter.s of nonconformance or unresolved items were identified in this area.
13.
Vendor Evaluations The NRC inspector reviewed the evaluations UST&D perfomed en its vendors and how approved vendors remain on the Approved Vendors List. This process is outlineo in Procedure 7.2, ' Evaluation of Vendors," Revision 1, dated March 12, 1987.
Eleven vendor evaluation packages were reviewed. The packages contained the original survey or audit checklist of the vendor and The reevaluations consisted of a
~
reevaluations of the vendor.
Vendor Evaluation Questionnaire and a historical que.lity performance data review.
i OkG W 2AT10N:
U.S. TOOL AhD DIE l
ALLIS0h PARK, PENNSYLVAh!A i
REFCR-INSPECTJON NO.: - 999010E2/87-01 RESULYS:
FAGT. 13 of 15 l
During the review,'it was noted that Do All Pittsburgh and Co'1ucia hanufa:turing Electric, who supoly calibration services, have net been evaluated by UST&D, nor has a historical e,vality perfomance data record been raintained en either ver. dor. Also during the review.. it was noted that Indus'. rial Service Center had been audited by UST&D Ma rch 12-15, 1966, while PO B6-60143 to Industrial Service
]
Center had been placed Februaty 14, 1986. This evaluation was not j
l performed within the.specified 14 days of issuance of the P0 as required by Secticn 2.1 of Procedure 7.2.
l Nonconfomances E7-01-11 and 67-01-13 were identified in this area, t,
la.
10 CfR Part 21 During the inspection, the NRC inspectors examined areas for the pesting of 10 CFR Part 21 at both fabrication shops.
It was noted that 10 CFR Part 21, USTit Frocedure 16.2 and Public Law 96-295 Act of June 30, 1960, Section 223 were posted, but Section 206 of the Energy Reorgar.ization Act of 1974 was not posted at the south shop.
Section 21.6 of 10 CFR Part 21 and UST&D Procedure 16.2, " Reportable Defects and Nonconpliances (Nuclear Projects) 10 CFR 21," Revision 2, dated March 12, 1987, require Section 206 to be posted. Prior to-l the exit meeting, Section 206 and other applicable documents were posted at both shops.
Violation 67-01-02 was identified in this area.
l l
II.
Trcinino The NRC inspector reviewed UST&D Procedure 2.3, " Training," Revision 3, dated March 23, 1966. The procedure requires all UST&D personnel l
performing quality related activites to be trained as applicable to l
their activity. The procedure also requires that training records l
be maintained.
The NRC inspector reviewed 13 employee training records and training session records. The employee training records identify what
~
trair.ing the employee has received while the training session i
records identify who attended the training, the date and an outline l
l of the subjects which were covered during the training.
~
l During this review it was noted that two machinists employed in the shop had training record files, but had not received any training.
Also noted were the facts that a training record, with no documented.
training, was present for a retired employee; several training 4p MMMWy
hRGA!.: 2 A11Ch:
U.S. TOOL AND DIE ALLISON PARK, PENNSYLVAt:l A l
1hSPECTION REFCRT FAGE 14 of 10 NO.:
999C1082/67-01 RESULTS:
records were incomplete in that hire dates and training session subjects were nissing; and two employees were trained outside the 45 In addition, UST&D only trains its day limit for new employees.
personnel to the quality control procedure which the employee will The be using without an overall QA/QC program training session.
personnel are not trained to new revisions of the procedures nor is j
l there any type of refresher training given to current employees after the initial training course and after they have been employed l
fer a lengthy amount of time.
Nonconformance E7-01-12 was identified in this area, s.
le 16.
Audfts The NRC inspectors reviewed four internal audits. The Internal Froject Managenent Audit, dated May 29, 1986, the Production Audit, l y dated August 23, 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 (summary of results),
and was performed by a qualified auditor. The audits which were reviewed were perfomed and documented in accordance with Procedure 18.1, " Audits, Revision S, dated March 12, 1987.
No items of nonconfomance or unresolved items were identified in this area.
F.
PERSONS CONTACTED:
P. Brinks, QC Manager, South Shop F. CeSimons, Foreman, horth Shop W. Dickson, Director of Manufacturing E. Jablonsky, QC Inspector, North Shop L. Karenboyer, Welder
- R. Linder, Manager of Engineering l
- E. March, Vice Chaiman of the Board, Chief Executive Officer E. Reinhart, QC Mar,ager, North Shop J. Rhoden, Project h6 nager F. Rhodes, Vice President, Manufacturing R. Rudisill, Welder
- M. Rodgers, President
)
P. Stewart, Machinist
- B. Wachter, Vice President, Engineering and Research l
K. Weber, Assistant Project Manager
'F. Witsch, CA Manager
- Attenced Exit Meeting
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U.S. TOOL AND DIE ALL150h PARL, PEhh5YLVANIA I
I INSPECTION
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REF0k1 PAGE 15 of 15 LO.:
999010E:/87-01 RESULTS:.
[
TABLE 1 l
Humber of Date l
Utility /AE_
Project M
R,acks/ Positions Completed l
SLLFFS Wolf Creek PWR-MDR 12/1328 1982 l
1 Karsas Gas &
hen-Poison Electric /Eechtel Ie SEUFFS Callewt>
PWR-MDP.
12/1328 1902
~
I Unicr: Electric /
Non-Poison f*
Bechte' i
Long Is16nc Shorehan SWR-Non 15/1700 1983 Lichting/Stene Poison 8/756 W6ter Flux 2/144
& Webster Trap Control Rods Public Services Seabrook New Fuel 3/90 1983 l
Corpeny Storage Racks hiagara Mohawk hir,e Mile II BWR-MDR Stere L Webster Poison 17/2530 1984 10/1519 Ro:hester Gas &
Ginna Modified 6/420 1984 Electric PWR Checker-board to Poison Racks Comenwealtt LaSalle 11 BWR Poison 20/4073 In Progress EP sor
~
Wisconsin Public Service Corp.
Kewaunee PWR Poison 4/360 In Progress Nuclear Energy Ve rrr.ont Services Yankee BWR Poison 10/2820 In Progress 1
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ENCLOSURE 2 a'.
p TELEPHONE (412)487 7030 fa?
U. S. TOOL & DIE, INC.
TOOL 4 S1 4030 AOUTE 8 e ALUSON PARK. PENNSYLVANIA 15101 j
i I
June 9, 1987 J
United States Nuclear Regulatory Commission Vendor Inspection Branch Division of Reactor Inspection & Safeguards Office of Nuclear Reactor Regu1Ation Washington, DC 20555 Attn:
Mr. Ellis W. Herschoff, Acting Chief Re:
Docket #9901082/87-01
, 6-i Gentlemen:
In respon'e te the inspection report referenced above and submitted s
to U.S. Tool & Die, Incorporated on May 12, 1987, we subrdt the following:
l APPENDIX A
~
VIOLATION i1 ~
... a review of documentation packages for spent fuel storage racks fabricated under ASME Code Section III, Subsce. Lion NF revealed thes while 10 CFR Part 21 vas imposed on U.S. Tool &
Die, Incorporated (UST&D) by their customers, UST&D did not specify that 10 CTR Part 21 requirements would apply on Purchse Orders..."
UST&D COMMN T a)
The applicability of,the reporting requirements of 10CTR21 l
has been placed on USTED by its various Clients who I
recognize these requirements do not pertain to material purchased as a commercial product (as defined in 10CFR21)
Only af ter receipt of cessercie.1 products at UST&D and-dvdication to the specific bat;ic component by UST&D are -
the isporting requirements 'in effect.
(14tters from the various Client's and the Atomic Industrial Perum's Committee l
Position Paper expanding on this position were presented to the NRC inspectors during the inspection).
Based on these documents the imposition of 10CFR21 is not applicable to t.he following Purchase Orders: 686-60802,
-81208, and 487-70132 to West Penn Laco; 487-70115 to Weld Star; 486-61112, -70103, and #87-70118 to Alloy-Oxygen Weld Supply; 486-61218 to Metal Goods; and 186-60921, E'p%
487-70130, and -70208 to Williams & Company.
-8706150193 870609 i'>p.
q t g PDR-GA999 EPfWSTD
( f.
6 E
99901082 PDR
.g.
e b)
Per project specifications,10CTR21 was not applicable to:
4 P.O.882-1051 to Com:cercial Tasteners;- 482-1032 to A11tgheny 7,udluc; 486-60620 to Industri&1 Service Center and therefore.
not imposed on the vendors.
l J
on both the original and revision el of P.O.483-1387 to c)
Sandvik, the applicability of 10CTR21 is noted on f,Page 2 of 2.
i d)
P.O.186-60208 to Columbia Electric and (84-1701 atsd #84-1679 to Do All Pittsburgh were for service to commercial type.
tools.
P.O.886-61228 to Cromie Machine and Tool was for subcontracting machining of UST&D supplied material.
10CTR21 should have been noted on this Purchase Ordere 1
CORRICTIVE ACTION for Item (d)
A revision to the Purchase Orders $ 86-60208 to Columbia e
Electric; 184-1701 and 484-1679 to De hil Pittsbukgh; I
and #86-61228 to Cromie Machine & Tool will be iscued i
and include the reporting requirements of 10CTR21.
l g
A review of 10CTR21 and UST&D's procurement procedures will be made with all personnel processing purchase i
orders to prevent recurrence.
This Corrective Action will be completed by June 30, 1987.
Internal audit activities will prevent recurrence.
v.:OLATION #2 -
UST&D failed to past 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 inspecticn as confircad by Item 14 (page 13) of the NRC Inspection Report.
CORRICTIVE ACTION Corrective Action has been completed.
Internal audit activities will prevent Tecurrer.ce.
l 1
s -
t APPENDIX B NONCONFORMANCE il in-process examinations were not being performed.at the South Shop per the " Production Work Routing and Inspe6 tion Plan," Drawing 8601-0, Revision 1, for kne< spent fuell, racks being manuf actured for the LaSalle project. (87-01o03g "
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 l
at the South Shop.
Cocplete 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 4xamination and Production Work Routing & Inspection Plan procedures.
This review will be complete by Juna 30, 1987.
NOSCONFORMASCE 4 2 two undersize welds vers identified ~by the NRC inspectors on a fuel rack which had been inspected and found acceptable by UST&D Qtality Control. (87-01-04)"
UST&D COMMINT Upon discovery, a weld pass was added to the undersite 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.
CCRRICTIVE ACTION A review of the use of weld gauges. and weld acceptance criteria will be sede with Quality Control personnel by June 30, 1907 to Esevent recurrence.
j l
l i
l
1,
NON00NFOR.VR;CE f3 a review of measuring and test equipment (H&TE) and calibration records revealed the following:
1 a)
Documented evidence was not available to verify tyat the calibration interval for M&TE was established in procedures.
b)
The four inner diameter (ID) box mandrels for the LKewannee,
Vermont Yankee, and LaSalle projects in the South 'f abrication shop were not identified with a permanent unique S/N applied by vibro-etching or with a durable label.
c)
A calibration interval was not established in the "Cardex" system for the modified ;tD box mandrel for the LaSalle project in the North fabrication shop. (87-01-05)*
UST&D COMMENT 1
Corrective Action has been or will be taken as follows:
l r
a)
As delineated in UST&D'c calibration procedure, the eclibration intervals are established in the "Cardex" system but vill be I
incorporated into an Appendix to Procedure 12. 1 This addition to the procedur# 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 I
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 bor. gauges has been established.
This modified box gauge for the LaSalle 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.
h t
eem o
M 4 A A
5-
?
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...*-
UST&D COMMENT a)
P.O.486-60746, ~60813,'-60814 and -61228 to Cromih 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.
p.
c)
P.O.682-1051 to Commercial Fasteners and P.O.482-1032 to Allegheny Ludium was for material for a DOE project.
The project specifications did not require imposition of the 10CTR50 Appendix B requirements.
i di P.O.186-60802, -81208, and 487-70132 to West Penn Laco, P.O.iB2-1311 and 83-1387 to Sandvik, P.O.187-70115 to Weld Star and P.O.f85-51023 to Techalloy does not include furnishing material to their Quality Assurance / Quality Contic' Program.
However, a review of tne Material Test Reports for the material ordered shows the material has been j
furnished by ASME Certificate Holders and in accordance with their appropriate Quality Assurance / Quality control Program.
e)
P.O.486-70103 to Alloy Oxygen does impose furnishing material in accordance with their Quality Assurance / Quality Control l
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 l
1 of conformance for calibration of said tools traceable to the National Bureau of Standards.
l I
CORRECTIVE ACTION
{
Revised P.O.tB6-60802, and 687-70132 to West Penn Laco;
- 82-1311 and 483-1387 to Sandvik; 687-70115 to Weld Start.
and 485-51023 to Techalley 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.
l j
l r
NOSCONTORMANCE i5 J
a review of purchase orders indicated that P.O.487-70118 to A11cy oxygen Welding Supply for stainless steel weld filler t
metal did not contain a delta-ferrite determination statement',
I and P.O.486-60610 to WALCO Corporation for markers and tape was i
not signed / initiated and dated by Quality Assurance personnel.
l l
l (87-01-07)"
I i
UST&D COMMENT The weld wire ordered from Alloy-Oxygen Welding Supply is of a co= position that by its nature f ar exceeds the delta-ferrite 4
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.
CORRICTIVE ACTION Revised purchase orders will be issued with the proper requirements and signatures.
g.
i
'these actions will be covered in the training session for purchasing personnel to be conducted by June 30, 1987 to prevent recurrence, NOSCO'NFORMANCE 16
"... it was noted that a documented procedure / instruction did not exist to control tools (e.g., wire brushes, grinding wheels, hammers, etc.) that were designated for use only on stainless steel material.
(87-01-08)"
UST&D COMMENT The vast majority of work done at UST&D is with stainless steel, however, some carbon steel work has been done.
It has been UST&D's standard operating procedure over the years to paint tools used on carbon steel.
This procedure has never been put into writing.
CORRECTIVE ACTION Instructions will be written to the Production Department to, 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.
9 NONOOhTOPP.ANCE f7
... Procedure 10.3 does not provide the Quality Control Inspector appropriate guidance indicating the required random sample qucntities or percentages needed to ensure a representative sample during in-process examinations.
(87-01-09)"
f UST&D COHHENT 6
As part of the in-process inspection, material trafenbility i s L
maintained on a 1004 basis; all cells are gaged to assure i
proper dimensions are maintainedi and as a minimum,. machined parts with critical dimensions are "first piece" inspected, and spot checked on a 10% random sampling basis.
If any discrepancy is revealed by this inspection, a minimum of 10 previously fabricated pieces ate checked.
Any discrepancy found in these 10 pieces will require a 100% inspection Of all.
pieces.
CORRECTIVE ACTION 4-4 Procedure 10.3 will be revised to include the above I
quantitative acceptance criteria and training will be -
s conducted with Quality Control personnel by June 30, L 987 to review this change.
NONCOUF0FFJJ1CE 9 8 l
l
... marking procedures used by the South shop Quality Control inspector for in-process examination.do not clearly identify l
items or components which have satisfactorily passed the required-examinations or who exaiined the part.
(87-01-10)"
UST&D COMHENT w
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 l
be generated.
This training will occur by June 30, 1987.
1 i
e 48' 4
- e g
l 1
]
ad
~ '
N:4:CONTOPP.ANCE # 9
"... vendor evaluations had not been performed on Do All Pittsburgh and Columbia Electric Manufacturing who provide calibration services for UST&D.
(87-01-11)"
UST&D COMMENT t
l t
l These pieces of equipment were purchased under thelcuality Assurance / Quality Control Program of the prior own rship of UST&D.
n 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 3 manufacturer of measuring / test equipment can be considered pre-qualified to calibrate their equipment.-
]
Certification has been provided by these manufacturers that i
the calibration methods and equipaent used is traceable to the National Bureau of Standards.
.s.
CORRECTIVI: ACTION j
A re-evaluation will be conducted on these two vendors i
by August 15, 1987.
NONCONFOPF.ANCE 810
"... trair.ing records did not exist for two UST&D shop employees.
(87-01-12)"
UST&D CO.$0ENT The two machinists have been employed by UST&D for over 15 and i
20 years and training had not been documented.
CORRECTIVE ACTION Corrective Action vill include training of employees to their activities and documentation will be completed by June 30, 1987.,
j l
I l
. I" AUG 2 41983 t*
13ingham-Willamette Company ATTN:
Mr. J. L. Wood l
i Quality Assurance Supervisor P. O. Box 1024T Portland, OR 97210 I
Gentlemen:
SUBJECT:
QA PROGRAM REQUIREMENTS FOR SUPPLIERS OF CALIBRATION SERVICES The Wood /Potapevs letter dated July 25, 1983, requested the Commission's concurrence with Eingham-Willamette Company's (BWC) position (ref. Rove /Barnes letter dated January 11, 1982) on the audit requirements of suppliers of calibration services.
The Division of Quality Assurance, Safeguards, and Inspection Programs (QASIP) l in the Office of Inspection and Enforcement was contacted to obtain an of ficial l
NRC position on the above subject.
The following information states the NRC position received from QASIP, and the ' osition addresses the following three p
types of suppliers of calibr.ation services:
1.
Suppliers who offer calibration services for measuring and test equipment not manufactured by them.
2, Supplitrs 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 N41.2 is required of thase three types cf suppliers, our position is as follows:
The suppliers noted in types 1 and 2 above are required to have a qualith assurance 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 standaed, ANSI N45.2, should be applied consistent with tha activities undertaken in the generation of the service and product; e.g., design, procurement, manufacturing, testing, etc.
-In the ene 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 H45.2 since it is a nationally l
l recognized iaboratory with proven abilities and disciplines.
s gg[dh
s l
-l
,,e
,J-l Bingham Willamette Company
- l With regard for the need of preaward evaluation and postaward audits for these three types of suppliers, our positiere is as follows:
A preaward evaluation and postaward audits are required for the types 1 and 2 suppliers.
It s.hould be noted that the results of pre-award evaluations that have beeft performed on the same supplier by another purchaser working to a QA program that satisfies Appendix B to 10 CFR Part 50 may be shared among purchasers; e.g., utilization of the CASE register.
l A preaward evaluation and postaward audits are not required for work l
performed at the National Bureau of Standards.
Please accept my apology for the delay in respondiog to BWC's 1982 letter.
If you have any questions on the above comments, please contact Jim Conway (817) 860-8236 or Ian Barnes (817) 860-9176.
Sincerely,
-o,isin i siened b/l C. J. H AkU Uldis Potapovs, Chief j
Vendor Program Branch j
a e
a 4
l O
l l
-A
%g, CST &D COMMENT i
ContGr This purchase order was issusd to Industrial Sorv ced until Industrin1 6
e with a provision that no material be shippeThe first shipment of Service Center was audited by UST&D.materiil ordered b ived by UST&D on April 8, 1986.
CORRECTIVE ACTION r(ment A training session will be conducted with procuto review purchas ng y i
tivities.
30, 1987 personnel by June ctive Action U.S. Tool & Die, Incorporated feels that the above corre o
overed by this l
will satisfy the Violations and Nonconformances unc NRC inspection.
Sincerely, U.S. TOOL &
IE, INC.
l' le-Michael Rodgers President
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4 ENCLOSURE 3 fo ca cg'c UNITED STATES
/[*7, ( [,j NUCLE AR REGUL ATORY COMMISSION w ASHINGTON. D C. 20555
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l July 28, 1987 l
Docket he. "1990.1082/87-01 L,.S. Toc 1 and Die, Incorporated ATTli: Mr. Micnael J. Rodgers President 4030 Route 6 Allison Park, Pennsylvania '5101 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 l
Inspection Report flo. 99901052/87-01, dated May 12, 1987. Your response and I
corrective action for Notice of Violation 87-01-02, and Items cf Nonconforme.nce 87-01-04, 87-01-05, 87-01-07, 87-01-08, 87-01-09, 87-01-10, and 87-01-12 appear i
to be adequate and ne additional information is requested. The following items, however, require additional information to determine the adequacy of the UST&D response and corrective action.
Part a) of the response to Notice of Violation 87-01-01 states that after receipt of commercial grade material at UST&D and dedication to the specific basic cceponent by UST4D, the reporting requirements of 10 CFR 21 are in effect. This is in accordance with 10 CFR 21.3(c-1). Please provide a description of.UST&D's 1
- dedication' process that is used to upgrade commercial grade products for use as basic components 3:id a sample of the documentation implementing the dedica-tion. process for' P0s 36-60802, -81208, -61112, -70103, -61218. -60921, 87-70132,-
-70115, -70118, -70130, and -70208. For part b) of that response, please provide x pertinent sections si the project specifications which address the applicability of 10 CFR 21 to,Pps 82-10!1 -1032, and 86-6020. Part c) states that 10 CFR 21.
is impostd.on (gei2 of PO 83-1387 to Sandvik. Please provide a copy of Ph 65-1367.
'm It hould be'noted that the NRC has not taken a position en the Atomic Industrial
' Forum's Committee Position Paper, "Recomended Practices for Procurement of Replacement / Spare Parts for Nuclear Power Plants." Also, in addition to imposing 10 CFR 21 on UST&h 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 VC.
.ae response to Item of Honconf ormance 87-01-03 states that.in-process examinations not perfQued at the South Shop were performed at the North Shop prior to installa-I tion of toq M ils into the final rack assembly.
Please provide assuunce that the types of in-process exams performed at the North Shop met the requirements of " Production Work Routing and. Inspection Plan," Drawing 8601-D, and Procedure 14.1, i e
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.'.: h L.S. Tool and Die, Incorporated July 28, 1987 The response to Item of Nonconfomance 87-01-00 is incomplete in that PO E2-1068 to Capitol Pipe and Steel and PO 86-81208 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 i
and + hat controls are implemented to ensure the UST&D QA/QC program is being
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followed at Cromie Machine.
Part e) of the response states that "Q" on P0s to l
Alloy Oxygen implies imposition of their QA/QC program on that P0. Please provide assurance that the-individual issuing the P0 acknowledges what special j
nutations are required on certain P0s which impose QA/QC prograrrs. 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 j
Electric Manufacturing and Do All Pittsburgh and these types of manufacturers i
have QA/QC programs in place.
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The respense 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 s
they manufacture is enclosed for your information.
1 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 avoit is performed" clause is added to the P0 as needed.
l If you have any questions concerning these requests for additional infomation, j
l please contact Ms. Claudia Abbate at (301) 492-4776 or Mr. James Stone at i
(301)492-9661.
l Sincerely, l
l Ellis W. Merse f, Acting Chief i
Vendor Inspecti Branch l
Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation
Enclosure:
As stated
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1 Commonwesith Edison Company l
ATTN: Mr. Cordell Reed j
Vice President Post Office Box 767 Chicago, Illinois 60690 l
Wisconsin Public Service Corporation l
ATTN: Mr. D. C. Hintz i
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 l
RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Bechtel Energy Corporation ATTN: Mr. Robert Baremore Project Supplier, Quality Supervisor j
5400 Westheimer Ct P. O. Box 2166 Houston, Texas 77252-2166 ic:
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