ML20246D525

Licensee Contractor and Vendor Inspection Status Report. Quarterly Report,October-December 1988.(White Book)

ML20246D525
Person / Time
Issue date:	04/30/1989
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-0040, NUREG-0040-V12-N04, NUREG-40, NUREG-40-V12-N4, NUDOCS 8905100254
Download: ML20246D525 (58)

Text

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NUREG-0040 Vol.12, No. 4 LICENSEE CONTRACTOR AND VENDOR INSPECTION STATUS REPORT QUARTERLY REPORT October 1988 - December 1988 UNITED STATES NUCLEAR REGULATORY COMMISSION i

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Available from Superintendent of Documents U.S. Government Printing Office Post Office Box 37082 Washington, D.C. 20013 7082 A year's subscription consists of 4 issues for this publication, Single copies of this publication are available from National Technical Information Service, Springfield, VA 22161 i

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NUREG-0040 Vol.12, No. 4 l LICENSEE CONTRACTOR AND VENDOR INSPECTION STATUS REPORT QUARTERI.Y REPORT October 1988 December 1988 l

Manuscript Completed: March 1989 Date Published: April 1989 Division of Reactor inspection and Safeguards l Office of Nuclear Reactor Regulation l U.S. Nuclear Regulatory Commission l Washington, DC 20555

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't TABLE OF CONTENTS PAGE 4 I

3. Preface ........................................................ v l

2. R e p o r t i n g F o r ma t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii 1

3. Index .......................................................... ix {

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4. Inspection Reports ............................................. 1 2

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1 List of Selected Bulletins and Information Notices Concerning Adequacy of Vendor Audits and Quality of Vendor Products ............................................. 45 1

6. Table of Vendor Inspection Reports l Related to Reactor Plants ...................................... 47 l

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PREFACE l

l A fundamental premise of the Nuclear Regulatory Commission's (NRC) nuclear i

facility licensing and inspection program is that licensees are responsible for the proper construction and safe operation of their nuclear power plants.

The total government-industry system for the inspection of nuclear facilities -

has been designed to provide for multiple levels of inspection and verification.

Licensees, contractors, and vendors each participate in a quality verification process in accordance with requirements prescribed by, or consistent with, NRC rules and regulations. The NRC inspects to determine whether its requirements are being met by a licensee and his contractors, while the great bulk of the inspection activity is performed by the industry within the framework of ongoing quality verification programs.

In implementing this multilayered approach, a licensee is responsible for developing a detailed quality assurance (QA) plan. This plan includes the QA l programs of the licensee's contractors and vendors. The NRC reviews the _{

licensee's and contractor's QA plans to determine that implementation of the i proposed QA program would be satisfactory and responsive to NRC regulations. j

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In the case of the principal licensee contractors, such as nuclear steam  :)

supply system designers and architect engineering firms, the NRC encourages submittal of a description of corporate-wide QA programs for review and acceptance by the NRC. Once accepted by NRC, a corporate QA program of a licensee's contractor will be acceptable for all license applications that incorporate the program by reference in a Safety Analysis Report (SAR). In such cases, a contractors's QA program will not be reviewed by the NRC as part of the licensing review process, provided that the incorporation in the SAR is  !

without change or modification. However, new or revised regulations, Regulatory Guides, or Standard Peview Plans affecting QA program controls may be applied by the NRC to previously accepted QA programs.

When design and construction activities were high, firms designing nuclear steam supply systems, architect engineering firms designing nuclear power

• plants, and certain selected major equipment vendors were inspected on a  ;

regular basis by NRC to ascertain through direct observation of selected- l activities whether these design firms and vendors were satisfactorily )

implementing the accepted QA program. However, with the substantial decline ,

of new plant design activities, the . inspection of QA program implementation i has been deemphasized. Instead, the NRC vendor inspection focus has been shifted to vendor activities associated with nuclear plant operation, maintenance, and modifications. Inspection emphasis in now placed on the ,

quality of the vendor products including hardware fabrication, licensee-  !

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vendor interfaces, environmental qualification of equipment, and equipment problems found during operation and corrective action. If nonconformances i with NRC requirements and regulations are found, the inspected organization  !

is requested to take appropriate corrective action and to institute preventive j measures to preclude recurrence. If generic implications are identified, NRC j assures that affected licensees are expeditiously informed.

In addition to the above, the Vendor Program Branch has begun inspections at licensee facilities covering the areas of procurement of replacement parts i I

for use in safety-related systems and licensee / vendor interface programs as requested in Generic Letter 83-28. This edition of the Whit + Book contains copies of the inspection reports of inspections completed to date. Subsequent issues will 'contain those reports that are issued in the quarterly report period covered by that White Book.

In the past, NRC issued confirming letters to the principal contractors to indicate that NRC inspections have confirmed satisfactory implementation of the accepted QA programs. Licensees and applicants could, at their option, use the letters to fulfill their obligation under 10 CFR 50 Appendix B, Criterion VII, that requires them to perform initial source evaluation audits and subsequent periodic audits to verify QA program implementation. However, '

based on the above described change in nuclear plant design and construction j activities, NRC will no longer issue confirming letters to principal contractors since future NRC vendor program inspections will focus on selected areas rather than addressing the implementation of their respective QA programs. Therefore, confinning letters that have already exceeded their three year effective period will not be renewed. Confirming letters issued less than three years ago will remain in effect until the stated effective period expires. Therefore, as the confirming letters expire, licensees and applicants will no longer be allowed to take credit for the NRC acceptance of the implementation of a principal contractor's QA program. Licensees continue to be responsible for the conduct of initial source evaluation audits and subsequent periodic audits to verify QA program implementation.

The White Book will continue to be published and will contain copies of all vendor inspections issued during the calendar quarter specified. The vendor inspection reports list the nuclear facilities to which the results are applicable thereby informing licensees and vendors of potential problems. . In dddition, the affected NRC Regional Offices are notified of any significant problem areas that may require special attention. The White Book also con-tains a list of selected Bulletins and Information Notices involving vendor issues.

The White Book contains information normally used to establish a " qualified suppliers" list; however, the information contained in this document is not adequate nor is it intended to stand by itself as a basis for qualification i of suppliers.

Correspondence with contractors and vendors relative to the inspection data l i

contained in the White Book is placed in the USNRC Public Document Room, located in Washington, D.C.

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1 ORGANIZATION: COMPANY, DIVISION CITY, STATE REPORT INSPECTION IMSPECTION i N0.: Docket / Year / Sequence DATE: ON SITE HOURS: j CORRESPONDENCE ADDRESS: Corporate Name Division ATTN: i Name/ Title Address City, State Zip Code ORGANIZATIONAL CONTACT: Name/ Title i TELEPHONE NUMBER: Telephone Number NUCLEAR INDUSTRY ACTIVITY: Description of type of components, equipment, or services supplied.

ASSIGNED INSPECTOR:

Name/ Vendor Program Branch Section Date i

OTHER INSPECTOR (S): Name/ Vendor Program Branch Section APPROVED BY:

Name/ Chief - Section/ Vendor Program Branch Date INSPECTION BASES AND SCOPE:

A. BASES: Pertain to the inspection criteria that are applicable to the activity being inspected; i.e., 10 CFR Part 21, Appendix'B to 10 CFR Part 50 and Safety Analysis Report or Topical Report comitments.

B. SCOPE: Summarizes the specific areas that were reviewed, and/or identi- I fies plant systems, equipment or s For reactive (identified problem) pecific components inspections, that were the scope inspected.

sumarizes the problem that caused the inspection to be performed.

PLANT SITE APPLICABILITY: List plant name and docket numbers of licensed 1 facilities for the inspection, which equipment, services, or records were examined during j vii A

ORGANIZATION: ORGANIZATION CITY, STATE '

REPORT INSPECTION NO.: RESULTS: PAGE 2 of 2 a

A. VIOLATIONS: Shown here are any inspection results determined to be in violation of Federal Regulations (such as 10 CFR Part 21) that are ,

applicable to the organization being inspected. J B. NONCONF0PEANCES: Shown here are any inspection results determined to be in nonconformance with applicable consnitments to NRC requirements.

In addition to identifying the applicable NRC requirements, the specific industry codes and standards, company QA manual sections, or operating procedures which are used to implement these consnitments may be referenced.

C. UNRESOLVED ITEMS: Shown here are inspection results about which more information is required in order to determine whether they are acceptable items or whether a violation or nonconformance may exist. Such items will be resolved during subsequent inspections.

D. STATUS OF PREVIOUS INSPECTION FINDINGS: This section is used to identify the status of previously identified violations, items of nonconformance,.

and/or unresolved items until they are closed by appropriate action.

For all such items, and if closed, include a brief statement concerning action which closed the item. 'If this section is omitted, all previcus inspection findings have been closed.

E. INSPECTION FINDINGS AND OTHER COMMENTS: This section is used to provide significant information concerning the inspection areas identified under

" Inspection Scope." Included are such items as mitigating circumstances concerning a violation or nonconformance, or statements concerning the limitations or depth of inspection (sample size, type of review performed and special circumstances or concerns identified for possible followup).

For reactive inspections, this section will be used to summarize the disposition or status of the condition of event which caused the  ;

inspection to be performed.  !

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F. PERSONS CONTACTED: Typed, Name, Title  !

• present during exit meeting l SAMPLE PAGE j (EXPLANATION OF FORMAT AND TERMIN0 LOGY) t I

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l INDEX FACILITY REPORT NUMBER PAGE i

Anchor / Darling Industries, Inc. 99901115/88-01 1 Hatfield, Pennsylvania {

Curtiss-Wright Corporation 99901127/88-01 11 Buffalo, New York Fisher Controls International, Inc. 99900105/88-01 21 Marshalltown, Iowa Texas Bolt Company 99900888/88-01 33 Houston, Texas ix

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ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC.

HATFIELD, PENNSYLVANIA REPORT INSPECTION INSPECTION NO.: 99901115/88-01 DATE: August 15-19, 1988 ON-SITE HOURS: 78 1

CORRESPONDENCE ADDRESS: Mr. William A. Benning Division President Anchor / Darling Industries, Inc.

1880 North Penn Road Hatfield, Pennsylvania 19440 l ORGANIZATIONAL CONTACT: Mr. John Killinger, QA Manager )

TELEPHONE NUMBER: (215) 822-1229 j I

NUCLEAR INDUSTRY ACTIVITY: Designer and Manufacturer of dyna / damp mechanical l snubbers used throughout the nuclear power industry. Anchor / Darling Industries also holds a Quality System Certificate issued by the American Society of Mechanical Engineers as a material supplier.

ASSIGNED INSPECTOR:

R. L'.

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Pettis, Jr. , Special Proj%t's Inspection M-6-/8 Date Section (SPIS), Vendor Inspection Branch OTHERINSPECTOR(S): T. Foley, SP APPROVED BY: [e afp l2 4,q U. Potapovs, Chief, SPIS, Vehdor Inspection Branch Date ,

l INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 21 and ASME III, Subsection NCA, Article NCA-3800.

B. SCOPE: The inspection was performed to review Anchor / Darling Industries Quality Assurance Program in relation to the design, manufacture, and assembly of component standard supports (snubbers) supplied to the nuclear industry.

PLANT SITE APPLICABILITY: Multiple plant sites.

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ORGANIZATION: fNCHOR/ DARLING INDUSTRIES, INC.

HATFIELD, PEilNSYLVANIA REPORT INSPECTION N0.: 99901115/88-01 RESULTS: PAGE 2 of 10 A. VIOLATIONS:

Contrary to Section 21.31 of 10 CFR Part 21, Anchor / Darling Industries (A/DI) purchase orders to vendors for safety-related components and

ervices, up through early 1988, failed to specify the provisions of 10 CFR Part 21. Several purchase orders reviewed during the 1988 time frame did invoke Part 21, but only on a limited basis (88-01-01).

This is a Severity Level IV violation (Supplemant VII).

B. NONCONFORMANCES:

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1. Contrary to Section 3.4 of the A/DI Quality Assurance Manual (QAM) and related implementing procedure EN-QR-1, dated April 1988, Registered Professional Engineer Mr. William Benning's tri-annual certification was performed on July 29, 1986, over two years after the required date of May 5, 1984 (88-01-02).

2. Contrary to Section 1.3.1 of the A/D1 QAM, the A/DI QA Manager i reported directly to the newly appointed Facilities Manager who also had production responsibility during the period June 30, 1988 to August 18, 1988, thus creating a situation whereby the QA Manager lacked sufficient independence from production activities (88-01-03).

3. Contrary to Sections 7.3 and 9.3 of the A/DI QAM, approximately 68 Material Rejection Notices (MRNs) covering potentially defective material during the period 1981 to present, remain "0 PEN" and the affected material cannot be located (88-01-04). '

4. Contrary Section 3.5.3.3.2 of the A/DI QAM, Engineering deleted

" passivation" from two process sheet (Part Nos. 32163 and 30120) '

without an engineering evaluation substantiating the removal (88-01-05).

5. Contrary to Section 4.4.1 of the A/DI QAM, A/DI did not supply failed snubber test results to Duke Power Company, as required in the purchase order (88-01-06).

C. UNRESOLVED ITEMS:

None  !

1 D. STATUS OF PREVIOUS INSPECTION FINDINGS:  !

Not Applicable i

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ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC. /

HATFIELD, PENNSYLVANIA '

REPORT INSPECTION l NO.: 99901115/88-01 RESULTS: PAGE 3 cf 10 l

E. OTHER FINDINGS OR COMMENTS:

BACKGROUND:

Anchor / Darling Industries ( A/DI) is a Material Supplier as defined in ASME III, Subsection NCA, Article NCA 3800, and authorized by ASME under Quality Systems Certificate No. 442 dated July 31, 1987 to perform testing, examination, and treatments per Subsections NCA or  !

NF, which were not performed by the Material Manufacturer.

A/DI, a manufacturer of component standard supports used throughout the nuclear power industry, specializes in the design and manufacture of mechanical shock arrestors commonly referred to as " snubbers" produced under the provisions of NF-1214 which states that mass produced catalog items (component standard supports) fabricated without welding shall be considered material.

l A/DI's trade name for their snubber is the oyna/ damp model which is a velocity sensitive device which retracts or extends from the housing when a force is applied to the snubber rod. The rack gear which is fixed inside the rod causes rotation of a step-up gear that is I connected to the verge wheel. During normal thermal transients the '

rack is free to displace with relatively small resistance. Under dynamic conditions, oscillation of the verge limits movement of the geared rack to a velocity proportional to the applied load. Since the snubber is always engaged, instant snubbing action assures positive displacement control of the connected component. All snubbers produced by A/DI conform to the provisions ASME III Subsection NF and are qualified for use in Class 1 nuclear applications.

1. Review of Nonconforming Material A/D1 processes all nonconforming material through QA procedure QA-NC-1 " Nonconforming Material and MRS Disposition." This  !

procedure requires the Receiving and Work-in-Process Inspector to: (1) identify nonconforming material and initiate a Material Rejection Notice (MRN); (2) Maintain a Material hold Status Report for the MRN's, and (3) maintain a record of venoor deficiencies and keep QA advised. The procedure also requires the inspector to place a " Hold" label on the nonconforming material and segregate in a designated hold area 'for review and disposition. The MRN is distributed to the Quality Assurance Engineer for Material Review Board dispositioning. A review of the receipt inspector's MRN log indicated that approximately 2500 3

ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC.

HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901115/88-01 RESULTS: PAGE 4 of 10 i MRN's had been issued since the program's inception in June 1981. l Approximately 100 currently remained "0 PEN" which covered a two 1 year period. During the inspection, only two items were noted as I being segregated, awaiting dispositioning, while an additional l four items were noted as being properly dispositionea. A/ dis i explanation for the open MRN's indicated that a previous A/DI's product line, " Actuator Valves," was sold to another vendor and the nonconforming material associated with actuator valve parts were scrapped and were not formally dispositioned. A more detailed review of each item reflected 68 MRNs which were not i dispositioned for which there was no explanation. These MRNs (

consisted of several hundred parts and varied in the significance  !

of the discrepancies. The following table provides examples of the scope, magnitude and severity of the discrepancies identified:

N0. PARTS DATE MRN N0. DISCREPANCY / DESCRIPTION AFFECTED 1/81 896 Rack Assembly Skewed Teeth 221 1/83 1433 Verge Wheel Out of Specification 72 2/83 1457 Load Bearing Item Cannot 78 Be Inspected 3/83 1478 Bar Stock Failed Physical 1 Tests 6/83 1523 Load Bearing Rear Housing 4 Cracked 6/83 1535 Load Bearing Ball Screw 63 Out of Specification l 7/83 1575 Front Housing Cracks 5 10/83 1603 Snubbers Binding in the Field 2 10/84 1906 24" Clamp Body Cracked 1 12/84 1946 Pipe Clamps Out of Specification 26 1

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ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC. l HATFIELD, PENNSYLVANIA 1 ;

REPORT INSPECTION NO.:

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99901115/88-01 RESULTS: PAGE 5 of 10 N0. PARTS DATE MRN NO. DISCREPANCY / DESCRIPTION AFFECTED No date 2356 Failed Drag Test 13 No date 2367 No Trace Code Stamp 10 12/87 2450 Undercut Treads 22 4/88 2518 Incomplete Plating 99 A review of the records of vendor deficiencies indicated inconsistencies between the MRN log and the record. Numerous  !

entries were obliterated by " white out" or scratched out, while '

entries made in the index were missing from the log. Many vendor deficiencies were noted as being dispositioned but without corrective action (i.e., item returned to vendor). )

A/DI management acknowledged these findings and stated that a review of the logs would be conducted and discrepancies ,

corrected. Nonconformance (88-01-04) was identified during {

this part of the inspection.

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2. Engineering Control

a. During a review of A/DI process sheet specifications for load bearing members, it was noted that several process sheets originally required passivation, but the process was subsequently annotated as not required and initialed. This occurred on several component process sheets, but not on all i the sheets reviewed. Some process sheets attached to components stored on the shelves still required the items to {i be passivoted. A/DI Standard EN-SF-1 " Passivation Process for Stainless Steel" requires that all 300 series, 400 series and 17-4-PH stainless steel parts used in the manufacture of component supports be passivated. Passivation is the process where components are pickled in a hydrochloric acid reagent to remove free ferrite from machined surfaces which may have been transferred or imbedded during the machining operations performed during the fabrication of parts.

A/DI Standard EN-DC-2, " Distribution and Control of Engineering Documents," dated March 6,1987, requires that 5

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ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC.

HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901115/88-01 RESULTS: PAGE 6 of 10 all changes to process sheets be controlled by an Engineering Change Memorandum (ECM). A/DI was asked to provide the ECM that supports the basis for deleting passivation from stainless steel components. The A/DI Engineering Manager stated that the process was discontinued in May 1988, and since then, approximately 300 process .

sheets have beer processed without passivation. The process l was terminated after an informal test which the company believes to conclude that passivation may be more of a degradation to the structural integrity of a component than a benefit, due to hydrogen embrittlement from the {

hydrochloric acid bath. The inspector noted that the deletion of passivation was performed without a documented engineering basis and not in accordance with A/DI Standard EN-DC-2. A/DI is currently in the process of documenting the engineering basis for the removal of passivation.

Nonconformance(88-01-05) was identified during this part of the inspection.

b. A review of ECM No. 1458, dated June 17, 1988, stated that

" Engineering cannot support these changes by calculation and ore only making the changes because they were directed to do ,

so by management." A/DI was requested to explain this ,

comment and provide an engineering evaluation substantiating '

the change. The Division President explained that the tolerance changes to the Thrust Race and Roller Thrust Race from .218 .001 to .212 .213 and from .311 .313 to

.3065 .3075, respectively, resulted from field experience noted during the disassembly of the 1,600 and 55,000 pound rated load snubbers. However, no documented basis existed to support the change. During the inspection the A/DI Division President initiated documentation supporting the change and attached it to the subject ECM.

3. Exempt Materials Interpretation - Article NF-2000 A/ dis QA Manual specifies that only load bearing parts of the snubber are subject to the quality requirements of Section III Division 1 of the ASME Code. Subsection NF-2121 of Section III,

" Permitted Material Specification," specifies that gaskets, seals, bushings, springs, compression spring end plates, bearings, retaining rings, washers, wear shoes, hydraulic fluids, etc.,

are exempt from the require,ments of Article NF-2000, " Material,"

and as such, do not require a Material Manufacturer's Certificate of Compliance as stated in NF-2130. The A/DI QA Program does not address ports that have a safety function and are outside the scope 6

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ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC. )

HATFIELD, PENNSYLVANIA 1 l

REPORT INSPECTION N0.: 99901115/88-01 RESULTS: PAGE 7 of 10 of the ASME Code. It was noted by the inspectors that several parts in the direct load path of the A/DI mechanical snubber are considered to be exempt from QA requirements. These include the ball nut, ball bushing, thrust race, ball bearing, and the i load member on the AD-125 model snubber. These components are purchased by A/DI as commercial grade items and appear not to ,

have the benefit of a dedication program or other QA receipt  !

inspection controls applied to them to ascertain the critical

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characteristics of the components. Raw material is purchased l by A/DI from vendors certified under the ASME Quality Systems Certificate program as Material Manufacturer's or Material Suppliers.

In one instance, the inspectors noted that the spherical ball bushing used at the ends of the snubber assembly is purchased strictly " commercial grade" from vendors not on A/DI's approved vendors list. Since this " bushing" is considered by A/DI and ASME as exempt from the provisions of ASME III, Article NF-2000, A/DI's interpretation is that no QA need be applied. The i inspector pointed out that commercially procured parts which lie in the direct load path of the snubber, although exempt ]

from complying with the manufacturer's Certificate of I Compliance requirements, must comply with the quality provisions of 10 CFR 50, Appendix B. Such parts can either be purchased from approved vendors audited by A/DI which demonstrate an Appendix B quality program, or purchased as commercial grade and upgraded by A/DI in accordance with prescribed dedication procedures. This is necessary since A/DI assembles snubbers meeting ASME III, Subsection NF requirements, which can ultimately be used in Nuclear Class 1 dppl1 Cations.

4. 10 CFR Part 21 The inspectors reviewed numerous A/DI purchase orders to subtier material manufacturer's, suppliers, and vendors of subcontracted services to determine that the requirements of 10 CFR 21.31 were met. This review indicated that A/DI policy was not to pass on these requirements since A/DI controls the identification and traceability of all primary load bearing parts used in their component standard supports, unless exempt under the provisions of hF-2121. A/DI's position is that in the event a snubber part f ailed as a result of a material deficiency, A/DI would notify all customers who had purchased component standard supports manufactured 7

i ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC.

HATFIELD, PENNSYLVANIA REPORT INSPECTION N0.: 99901115/88-01 RESULTS: PAGE 8 of 10 from that heat of material. This philosophy appears to have been in practice since 1981 with few exceptions noted in several 1988 purchase orders which invoked the requirements j of 10 CFR 21.31. This change in position appears to have come over the last year due to conversations with A/DI's parent  !

company - Anchor / Darling Valve. These discussions apparently  !

highlighted to A/DI the importance and correct interpretation uf 10 CFR 21.31 which requires that each procurement document for a basic component issued after January 6,1978 specify, when applicable, that the provisions of 10 CFR Part 21 apply.

A/DI procedure to report defects and noncompliance, QA-NC-3, dated September 1985, was reviewed by the inspectors and noted to be adequate. Violation (88-01-01) was identified during this part of the inspection.

5. Professional Engineer Certification A review of the qualifications of Registered Professional Engineer, Mr. William Benning, Division President, identified initial certification on May 5,1981. Subsequent certification was performed by Mr. E. Heimark, Manager of Engineering, on July 29, 1986. This lat.ter certification violated A/DI Standard 1 EN-QR-1, dated April 1983, and also the requirements of I ANSI /ASME N626.3-1979 which require that the qualifications of I all Registered Professional Engineers engaged in ASME Code certification activities be reviewed every three years for conformance to these standards. Mr. Benning is a registered mechanical engineer in California and a professional engineer 3 in Pennsylvania and is scheduled for decertification by July 1989.

It was noted that during the period Mr. Benning was not certified (May 5, 1984 through July 29,1986), Load Capacity Data Sheets for A/DI Models 400, 700, 1500, and 5,000 were certified by him on August 9, 1985. Honconformance (88-01-02) was identified during this part of the inspection.

6. Organization - Authority and Responsibility The A/DI QA Manual states in Section 1.3.1, Revision 5, dated June 24, 1987, that the QA Manager reports to the General Manager.

In addition, ASME III, Subsection NCA Article NCA-3864.1(b)(2) j states that the person responsible for defining and measuring the  ;

overall effectiveness of the Quality System Program (QA Manager) l shall be sufficiently independent from the pressures of production. i During the inspection, it was noted that on January 15, 1988, Mr. W. Benning, A/DI Division President and General Manager, promoted Mr. Robert Z. Brown to the position of Facilities Manager 8

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ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC.

HATFIELD, PENNSYLVANIA REPORT INSPECTION NO.: 99901115/88-01 RESULTS: PAGE 9 of 10 for the Hatfield facility. In this position, Mr. Brown reported directly to Mr. Benning and was responsible for managing the materials, manufacturing, engineering, and quality assurance functions.

On February 24, 1988, Mr. Thomas Brown resigned as Quality Assurance (QA) Manager. The position was temporarily filled by Mr. G. W. Knieser, the A/DI QA Manager of the Williamsport, Pennsylvania facility. Effective May 3,1988, Mr. J. H. Killinger was appointed QA Manager for the Hatfield facility. On June 30, 1988, Mr. Thomas McCully resigned as A/DI Manager of Manufacturing.

During this time, Mr. Benning was not in full time residence of the Hatfield facility due to convalescence over prior surgery. Since production activity was at a low level, the decision to wait until volume increased to have a replacement Manufacturing Manager was made by Mr. Benning, thereby adding production responsibility to Mr. Brown's duties. As a result, the separation between manufacturing and QA did not exist auring ~ the period June 30 through August 16, 1988. This fact was brought to Mr. Benning's attention during the inspection (August 17,1988) and resulted in an A/DI memo dnnouncing that effective August 19, 1988, Mr. John Killinger will report directly to Mr. Benning, A/DI General Manager.

Products shipped and tested from June 30 through August 18, 1988 from A/DI for use in domestic nuclear applications consisted of various structural attachments, shims, lugs, one 1,500 pound model snubber, and an order to test five 1,500 pound snubbers. Orders initiated from the Duke Power Company, Virginia Electric Power Company, Arkansas Power and Light, and the MK - Ferguson Company.

Nonconformance (88-01-03) was identified during this part of the inspection.

7. Duke Power Company Snubber Test Mill - Power Supply Company (MPSC) purchase order No. R25861-73, dated May 3,1988, was placed on A/DI to functional test five dyna / damp snubbers, Model Nos. AD-150L and AD-151L for the McGuire Nuclear Station. The purchase order required that A/DI provide documentation of all test results in accordance with current in-house procedures and did not invoke any special nuclear requirements (i.e., safety-related). A review of the test documentation revealea that three out of the five snubbers tested by A/DI failed in-house test procedure EN-TT-S1 which specifies-test requirements to determine operability, lost motion, drag, and velocity. All parameters tested are recorded on A/DI 9

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ORGANIZATION: ANCHOR / DARLING INDUSTRIES, INC.

HATFIELD, PENNSYLVANIA J REPORT INSPECTION NO.: 99901115/88-01 RESULTS: PAGE 10 of 10 l

" Test and Final Inspection Record" form. The test results l reviewed by the NRC inspector identified two snubbers, Serial Nos. 477 and 480, exceeding velocity extension and retraction limits, while Serial No. 476 exceeded drag extension and retraction limits. A/DI stated the three units were disassembled, cleaned, inspected, reassembled, and were retested satisfactorily. A/DI stated that all tests were observed by a l Duke Power representative and as a result, failed test data was not submitted in the final report. It is NRC's position that Duke Power Company should have received all test results, especially failed results, since In-Service Inspection testing programs for snubbers rely on this information to determine the sample size necessary for testing. Nonconformance (88-01-06) was identified during this part of the inspection.

As a result of this finding, A/DI submitted a retest / repair report  !

to McGuire on August 24, 1988 identifying all snubber test results.

A/DI's understanding was that Duke Power purchased these units originally as trial specimens, and that they were never installed in a safety-related application at McGuire.

F. A/DI PERSONNEL CONTACTED W. Benning, Division President R. Brown, Materials Manager R. Fandetti, Product Manager E. Heimark, Manager of Engineering J. Killinger, Manager of Quality Assurance J. Getka, Inspection Supervisor l

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i ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK REPORT INSPECTION INSPECTION NO.: 99901127/88-01 DATE: November 14-18, 1988 ON-SITE HOURS: 32 CORRESPONDENCE ADDRESS: Mr. Donald H. Osborn, General Manager Curtiss-Wright Corporation 60 Grider Street Buffalo, New York 14215 ORGANIZATIONAL CONTACT: Mr. Gerald Weart TELEPHONE NUMBER: (716) 894-7770 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of extruded steel pipe for commercial, military, and nuclear application. Nuclear activity is less than 10 percent of current business.

ASSIGNED INSPECTOR: d', % Es d $<- h /

R. L. Cilimberg, Progf<am Development and Reactive D4te/M/

Inspection Section (PDRIS)

OTHER INSPECTOR (S): D. J. Lynn, Consultant W. Glinski, Consultant APPROVED BY: I /4/

E. T. Baker, Chief, PDRIS, Vendor Inspection Branch ae INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 21 and 10 CFR Part 50, Appendix B.

B. SCOPE:

This inspection was made to follow-up a request from NRC Region II that the Vendor Inspection Branch determine if Curtiss-Wright has furnished nonconforming material to Vogtle or other facilities. Thi's inspection reviewed specifically the ultrasonic inspection and solution annealing of austenitic stainless steel.

PLANT SITE APPLICABILITY: Vogtle 1/2 (50-424/425).

11

1 i

i ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK j

REPORT INSPECTION NO.: 99901127/88-01 RESULTS: PAGE 2 of 9 A. VIOLATIONS:

None B. NONCONFORMANCES:

1. Contrary to Criterion XII of Appendix 8 to 10 CFR Part 50 and the  ;

Curtiss-Wright (CW) Quality Control Manual (QCM), Revision L, '

dated May 30, 1986, a temperature recorder, serial number N4690777-01, was calibrated on November 7, 1987, which was after the required due date of October 7, 1987. (88-01-01) ,

1

2. Contrary to Criterion IX of Appendix B to 10 CFR Part 50 and the CW process specification MPD 1169, " Color Code and Control of Grinding Abrasives," Revision 1, dated December 13, 1973, grinding wheels were found in the final surface preparation are,a which were not color coded. (88-01-02)

C. UNRESOLVED ITEMS:

None D. STATUS OF PREVIOUS INSPECTION FINDINGS:

Not applicable E. INSPECTION FINDINGS AND OTHER COMMENTS:

1. The NRC staff informed CW management representatives of the scope of the inspection during the entrance meeting on November 14, 1988, and summarized the inspection findings and observations during the exit meeting on November 18, 1988.

2. Stainless Steel Pipe at Vogtle Units 1 and 2 The NRC Region II office advised the Vendor Inspection Branch of a problem with 10-inch, Schedule 140 piping, Heat 13-351, Type 316 (ASME SA376,Section III, Class 1) supplied by CW through Guyon Alloys through Bechtel to Georgia Power. This piping was

' installed between the accumulator tanks and cold legs at Vogtle Units 1 and 2. The problem was identified as anomalous acoustic properties of the installed piping and a sample of the piping was described as exhibiting a highly banded microstructure. The 12

ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK REPORT INSPECTION NO.: 99901127/88-01 RESULTS: PAGE 3 of 9 banded microstructure suggested to a Georgia Power consultant that CW may not have fully annealed the material and may not have performed ultrasonic testing (UT) in accordance with ASME SA655.

The document review discussed in Section 3, solution annealing discussion in Section 4, and the UT discussion in Section 5 indi-cate that piping supplied to Guyon Alloys by CW was fully annealed and met the UT requirements of SA655.

3. Document Review CW documents indicated that heat 13-351 represented material that was ordered from CW by Guyon Alloys, Inc. on purchase order (PO)

A-25583-N, dated April 30, 1979. The Guyon P0 ordered 10-inch NPS Schedule 140 (10 3/4-inch x 1.000-inch AW) seamless stainless steel pipe per ASME SA312/SA376, type 316, with 0.04 percent minimum carbon for nuclear Class 1 service. The pipe was to be 100 percent ultrasonically tested to a 5 percent notch standard in two directions per paragraph NB-2550 of ASME Section III, 1977 Edition through Summer 1978 Addenda. The pipe was to be solution annealed and water quenched. The P0 required that material test reports (MTRs) indicate heat treatment temperature, holding time, and a statement that material was cooled by water quenching to below 800 F in less than three minutes. The P0 required that MTRs indicate that the material was manufactured under a QA program that meets the requirements of ASME Section III, NCA-3800, and that 10 CFR Part 21 applies to this procurement.

CW P0 1861, dated May 10, 1979, was issued to Electralloy Corpora-tion for type 316 stainless steel extrusion billets. P0 1861 imposed 10 CFR Part 21 and process specification MPD-1509, "Austenitic Alloy Steel Cast Extrusion 8illets-AOD," Revision B, dated June 30, 1978. Electralloy MTR, dated July 18, 1979, certi-fied a ladle analysis for requirements for SA-312.

heat 8-118 which meets the chemistry CW used heat 8-118 to extrude tube / pipe heat 1081-26-2 on September 26, 1979. Pipe 1081-26-2 was solution annealed on October 9,1979 to produce heat treat lot number 13-351. A CW Certified Material Test Report (CMTR), dated December 5, 1979, was issued for heat treat lot number 13-351 which was signed by the supervisor of metallurgy and notarized by Patricia Bronzino. This CMTR certified that the pipe met the requirements for ASME SA312 and ASME Section III, Class 1, 1977 Edition through Summer 1978 Addenda and was manufactured under a 13

ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK REPORT INSPECTION NO.: 99901127/88-01 RESULTS: PAGE 4 of 9 QA program meeting the requirements of NCA-3800. Parts were hydrostatically tested at 2791 psi for a minimum of five seconds with no defects noted. UT was performed to a 5 percent notch in accordance with NB-2550 of the above mentioned ASME Code and accepted. Pipe was annealed at 1950 F plus or minus 25 F for 1/2 hour minimum at temperature and water quenched to below 800 F in less than three minutes.

4. Solution Annealing Stainless Steel The inspectors reviewed CW MPO 973G, " Heat Treatment for Austenitic Stainless Steel (300 series)," Revision 6, dated April 4, 1978 for compliance with SA-312 and SA-376 of the ASME Code.

Heat treatment charts and records were determined to meet the requirements of MPD 973, Revision 6 for four separate furnace cycles. Review of the furnace operator's log book for the seven furnace loads (including heat 13-351) processed between October 9 - 10, 1979 indicates that pipe 1081-26-2 was heat treated in accordance with the requirements of SA376 and SA312.

5. Ultrasonic Testing 5.1 Document Review The inspectors reviewed a CW UT inspection record indicating that pipe 1081-2C-2 was inspected on October 22, 1979 and found acceptable. UT was performed in accordance with QCI 09-97, " Ultrasonic Inspection Procedure for Extruded Pipe,"

Rcvision 3, dated October 11, 1979. The UT equipment used was a KB USIP-11 with a KB 2-103, 2.25 MHz, immersion transducer. The CW inspector was W. Hayward, Level II. The NRC inspectors determined that QCI 09-97, Revision 3 complied with ASME NB-2550 and ASME SA-655. The inspectors noted that only two circumferential scans are required by the ASME sections imposed by Guyon P0 A-25583-N, and these were the only scans performed by CW. The CW UT report did not mention any anomalous UT properties and listed the test results as "ok."

5.2 Review of UT facilities, equipment, and current inspection procedures.

14

_ _ _ . _ . . . s

ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK REPORT INSPECTION

~NO.. 99901127/88-01 RESULTS: PAGE 5 of 9 I

5.2.1 Equipment (a) Immersion Tank equipped with rotating rolls suitable for handling pipe sizes of concern (42 inches wide by 46 feet long).

(b) Bridge and carriage capable of manipulating one search tube and transducer and capable of traver-sing the length of pipe being tested.

(c) UT Instrument: KBI USIP-11, SN3470, certified on May 18, 1988, due on May 18, 1989.

Transducer: Technisonic PNF-0208-GP, 2.25 MHz,

.75 inch diameter.

(d) Calibration Standards Reviewed:

Standard 1882-1: 304SS, 10.781-inch OD, 1.123-inch wall.

Spot' checked thickness by contact UT. Observed notch layout, appeared satisfactory.

Standard 1835-1-2: 316SS, 10.781 inch 00, 1.00-inch wall This is the calibration standard which is applicable for pipe 1081-26-2 and the CW QA manager stated this standard would have been used in 1979.

The NRC inspectors used a tape measure to verify the OD at 10.75 inches, wall at 1 inch, and the length at 12 inches. The 00 notch is 1-1/2 inches long extending 3 inches from the serial number end to 4-1/2 inches from the serial number end. The ID notch is 1-1/8 inch long, extending 1 inch from the serial number end to 2-1/8 inchs from the serial number end. The notches are 120 apart. The width and depth of the notches were not physically measured but appear to be within requirements.

15

\

l ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK REPORT INSPECTION i

NO.: 99901127/88-01 RESULTS:

I PAGE 6 of 9 5.2.2 Calibration Procedure (a) CW Level II inspector, Mr. W. Hayward, demonstrated the calibration procedure and indicated that the demonstration was similar to the inspection that he performed on pipe 1081-26-2 in 1979.

(b) Mr. Hayward performed a calibration in accordance with QCI 09-97, Revision 3, using calibration standard 1835-1-2 as follows:

(1) Verified the normality of the transducer.

(2) Offset the transducer circumferential1y by 1-5/8 inches.

(3) Calibrated on the OD notch setting the indication at 50 percent of screen height and 70 percent of sweep length and marked the location on the screen with a grease pencil.

(4) Calibrated on the ID notch. The indication appeared at 80 percent of screen height and 40 percent of sweep length. The location was marked on the screen with a grease pencil to establish the distance amplitude correction (DAC) line.

(5) Indications were scanned dynamically and the traversing speed adjusted to locate each indication at least twice during the scan.

(6) The rotational speed which is not readily adjusted by the operator was one revolution per 12 seconds which is approximately 2.8 inches per second.

(7) Mr. Hayward stated that equipment is avail-able to permit doing two circumferential scans simultaneously with two transducers and two instruments. However, Hayward stated that pipe 1081-26-2 was traversed twice using the same instrument to achieve two circum-ferenti'al scans.

16

ORGANIZATION: CURTISS-WRIGHT CORPORATION

. BUFFALO, NEW YORK REPORT INSPECTION N0.. 99901127/88-01 RESULTS:

PAGE 7 of 9 (8) Mr. Hayward was cooperative, knowledgeable, and followed QCI 09-97, Revision 3 using good UT practice in the performance of this demonstration.

(9) Mr. Hayward stated that management is very supportive of QA activities and has never imposed production pressure on him that might adversely affect UT.

(c) Additional Evaluation Calibration standard 1835-1-2 was ultrasonically tested to determine if any anomalous acoustic properties were present that would affect the UT velocity and therefore the angle of refraction.

No anomalies were located and the velocity was determined to be 231,000 inches per second using a Panametrics Digital Thickness Unit. The velocity is approximate because the wall thick-ness was not measured and was assumed to be one inch as stamped on the material. The inspectors determined the minimum possible offset to be 0.875 inches and the maximum possible offset to be 2.000 inches by choosing offsets that produced acceptable indications from the ID and OD notches.

The offsets were determined to permit calculation of the actual entry angle should that information be needed in the future.

5. 3 Conclusion The documentation of the UT of pipe 1081-26-2 indicates that the material shipped to Guyon met the UT requirements of P0 A-25583-N. Observation of current UT practice at CW did not raise any doubts concerning the qualification of the person who performed the UT on pipe 1081-26-2.

6. Instrument Calibration The inspectors reviewed calibration stickers on UT instrument KB-USIP-11, micrometer Q-382, and a temperature recorder with serial number N469077701.

The dates on the calibration stickers 17

ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK REPORT INSPECTION NO.: 99901127/88-01 RESULTS: PAGE 8 of 9 indicated that the recorder was one month past the calibration due date before it was calibrated. (See Nonconformance 88-01-01)

7. Pipe Fabrication The inspectors observed fabrication activity in the CW extrusion process. Work was being performed in accordance with written procedures except in the final. surface preparation area.

Grinding wheels were located in this area which were not color coded. MPD 1169, Revision 1 requires that grinding wheels be color coded to ensure that a wheel-is not used to grind more than one type material. (See Nonconformance 88-01-02)

8. Customer Complaints Section 6 of CW QCM, Revision L, requires that the QC Manager investigates sales and customer complaints and oversees required follow-up corrective action. A log of Process Discrepancy Sales Reports (PDSRs) was reviewed to determine if any customer com-plaints had been filed concerning inadequate heat treatment. No i

heat treat problems had been reported on the 335 PDSRs written since CW initiated operations. A review of PDSRs 304, 312, 170, 171, 172, 148, and 153 determined that oversight of follow-up of corrective action was documented and signed by the QC Manager.

9. Internal Audits The inspectors reviewed internal audit reports for 1988 to determine conformance with the CW QA program. It was determined that the audits were performed in accordance with the requirements of Section 6 of the CW QCM, Revision L.

10. Customer Audits The inspectors reviewed two reports for audits that Bechtel performed at CW during 1987 and 1988, one report for a 1987 audit by Guyon Alloys, and three reports for 1986-1988 audits performed by McJunkin Corporation. The 1987 Bechtel report found that CW lost the internal audit reports for 1986 which poses a question as to whether the audits were performed. No other audit findings by CW customers were reported for the 1986-1988 period.

18

ORGANIZATION: CURTISS-WRIGHT CORPORATION BUFFALO, NEW YORK REPORT INSPECTION NO.: 99901127/88-01 RESULTS:

PAGE 9 of 9

11. 10 CFR Part 21 The inspectors determined that CW implements the posting requirements and procurement document applicability of 10 CFR Part 21. QCI 01-15, " Procedure for Reporting of Defects and Noncompliance Under the Provision of 10 CFR 21," Revision 2, dated October 9,1986, is the CW procedure which responds to section 21.21 of 10 CFR Part 21. No violations were identified in this area of the inspection.

F. PERSONS CONTACTED:

W. Galus W. Hayward

• D. Osborn

• G. Weart

• Attended Exit Meeting 19

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLT0WN, IOWA REPORT INSPECTION INSPECTION NO.: 99900105/88-01 DATE: September 12-17, 1988 OH-SITE HOURS: 78 CORRESPONDENCE ADDRESS: Mr. T. D. Buzbee, Plant Manager 3 Fisher Controls International, Inc.

205 South Center Street Post Office Box 190 Marshalltown, Iowa 50158 1

ORGANIZATIONAL CONTACT: Mr. Denny Cahill, QA Manager ]

TELEFh0NE liUMBER: (515)754-2428 NUCLEAR INDUSTRY ACTIVITY: Manufacturers of ASME Class 1, 2, and 3 valves, process control electrical and pneumatic monitoring devices and safety-related valve-actuator assemblies in both sliding stem and rotary shaft applications.

ASSIGNED INSPECTOR: [i./[u/L /< 99

/m . 'U.

d Perfdsino, Reactive Inspection Section at OTHER INSPECTOR ( ): T. Tinkel, Sondlysts, Inc. 1 Z. Lan, International Atomic Energy Agency Fellow, National Nuclear Safety Agency of Peoples Republic of Chind on temporary assignment to NRC Vendor Inspection Branch l APPROVED BY: // 22 a//o/y LE. T. Bakert Chief, Reactive insoection Section 'Date J

/

INSPECTION BASES AND SCOPE:

A. BASES: Appendix B to 10 CFR Part 50, ANSI N45.2, and 10 CFR Part 21.

B. SCOPE: To review the circumstances surrounding the Duke Power Company problem concerning Fisher valve air operator sizing.

PLANT SITE APPLICABILITY: All plants.

21

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLTOWN, IOWA REPORT INSPECTION NO.. 99900105/88-01 RESULTS: PAGE 2 of 12 A. VIOLATIONS:

None.

B. NONCONFORMANCES:

Contrary to Criterion XII, " Control of Measuring and Test Equipment,"

of Appendix B to 10 CFR Part 50, the following items were noted in the measuring and test equipment (M&TE) area-

1. Three out of 19 M&TE items inspected were out of calibration according to the M&TE calibration history record cards (88-01-01);

2. One M&TE calibration history record could not be found by Fisher for a flow-rate test device, No. CRB-104 (88-01-02);

3. Fisher Calibration Procedure 2H3 does not specify an acceptance /

rejection criteria for calibrating torque wrenches (88-01-03);

and

4. The Fisher program for controlling its M&TE tools and instruments does not require visual " calibration due date" labels to be affixed to all types of individual M&TE items nor does the program ensure that only calibrated equipment is available for use in the shop.

Therefore, one cannot determine whether or not a specific M&TE item is within calibration before use without first researching its calibration history card, which is not required by Fisher's procedures. (88-01-04)

C. UNRESOLVED /0 PEN ITEMS:

1. (0 pen Issue) Fisher Valve Actuator Sizing (88-01-05)

The Fisher Controls International staff (Fisher) contacted the NRC on June 8, 1988 to discuss actuator sizing calculational methods regarding rotary shaft ano sliding stem friction forces and licensee replacement of originally supplied stem packing materials with different types of stem packing. The purpose of the call was to discuss whether or not the issues appeared to be generic to other manufacturers and the significance. The discus-sions centered around the calculational methods regarding seating /

unseating forces on sliding stem and Fisher model 9200 rotary shaft valves, and added friction resulting from using graphite stem packing as opposed to the original teflon packing.

22

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLT0WN, IOWA

$ REPORT INSPECTION NO.: 99900105/88-01 RESULTS: PAGE 3 of 12 The discussions resulted in an NRC staff concern that some installed automatic valves may be equipped with actuators that cannot provide sufficient thrust to perform all required design functions under all required design conditions. As an example of the potential for undersized actuators, the Duke Power Company (Duke) in conjuction with Fisher determined that several of its actuators at the McGuire Facility were too small to meet their original design operating requirements. It was recommended by Fisher that two actuators be replaced with larger units and that several other actuators have spring tension adjustments. Subse-quent Duke analyses determined that the McGuire operating design parameters would allow them to perform spring tension adjustments and spring replacements until the matter is completely resolved.

Discussion:

As a result of the NRC staff technical review that was performed with the assistance of Fisher engineering personnel, the technical information provided by Duke and Fisher was confirmed and some safety-related operational concerns were identified. The principal concern is that some Fisher automatic valve actuators installed in various nuclear power plants may be equipped with valve actuators that would be too small to perform their valve seating or unseating function during plant transients.

Fisher identified the potential valve problems and started an engineering review to identify all of the circumstances surrounding the potential problem. The Fisher reviews identified three separate aspects that affect two of its valve lines (i.e., sliding stem type and rotary shaft wafer style).

Problems Associated With Rotary Shaft Fisher Model 9200 N Stamp

~

Valves (Butterfly).

The typical applications of rotary shaft type valves are for con-tainment isolation and throttling or on/off flow control of compo-nent cooling or auxiliary systems. Manufactured sizes range any-where between 4 to 96 inches diameter. As a result of product improvement testing and experience, Fisher modified its mathematical equation for sizing actuators on its 9200 N stamp series butterfly valves on three different occasions.

23

~ ~

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLT0WN, IOWA REPORT INSPECTION NO.: 99900105/88-01 RESULTS: PAGE 4 of 12 These particular valves employ rotary shafts rather than sliding stems. According to Fisher, regardless of the type of packing involved, packing friction torque is small compared to system differential pressure torque and disk seating / unseating torque. As a result stem packing friction is not a concern when sizing operators for these valves.

However, some of these valves may be equipped with undersized actuators for a different reason. Butterfly valves ordered prior to March 1,1982, were equipped with actuators sized using a relationship that, under some circumstances, underestimated the magnitude of the friction torque required to seat / unseat the butterfly disk in the elastomer seat used in this valve series.

Butterfly valves ordered after March 1,1982, are not subject to concern because they were equipped with actuators sized using the current Fisher method that more accurately predicts valve seat / disk frictional torque.

Problems Associated With Sliding Stem Type Automatic Valves.

The typical applications of sliding stem type valves are for safety and nonsafety-related use in sizes ranging between one and eight inches diameter. The problem identified with this type valve concerns valve stem packing friction forces which were not accounted for in the original actuator torque sizing calculations.

Prior to approximately January 1,1977, Fisher sizea all actuators for automatic valves without providing any allowances for friction due to valve stem packing materials. The practice of sizing the actuators without regard to packing friction did not pose any significant problem for volves supplied with Fisher's standard (single configuration) PTFE (teflon) packing because the friction forces associated with this packing are relatively small. However, in the mid 1970's, due to the nuclear power industry concerns about the use of teflon in harsh environments, Fisher started to supply its automatic control valves with other (non-teflon) packing materials.

Graphite packing materials were used and can cause approximately 10 times more valve stem friction force than its teflon counterparts.

The concern is that the higher friction forces in some cases cannot be compensated for by other margin factors included in the original 24

l ORGANIZATION: FISHER CONTROLS IflTERNATIONAL, INC.  !

MARSHALLTOWN, IOWA REPORT INSPECTION NO.: 99900105/88-01 RESULTS: PAGE 5 of 12 sizing calculations. Where this occurs, the installed actuator will not be able to develop sufficient force or torque to meet all the original design functions of the valve.

In April 1976, Fisher started to explicitly consider packing j

friction forces in the actuator sizing calculations. Consequently, j automatic valves with sliding stems delivered by Fisher after i January 1977 are considered to have been properly sized.

1 Second, the Fisher field service representatives have noted that some nuclear plant customers have been installing replacement packing materials in Fisher valves that are different from the originally supplied teflon packing material. Fisher is concerned that some of the replacement packing materials may result in packing triction forces that exceed those assumed for the original  ;

valve actuator sizing. If this occurs, the installed actuators may not be able to provide sufficient torque to meet their original design functional requirements. There are two specific valve stem packing change-outs of concern:

One is installing non-teflon packing (graphite) in o valve that was originally suppliea with teflon packing.

The other is installing ribbon-type graphite packing in a valve that was originally supplied with formed, laminated, graphite packing. The ribbon-type usually results in higher friction forces than the pre-formed Wdsher shape graphite inserts. According to Fisher test results ano experience, graphite ribbon packing will usually exceed the friction forces of formed graphite.

2. (0 pen Issue) QC Receipt Inspection (88-01-06)

The inspectors identified pctential problems in the methods in which Fisher is controlling its receipt inspection areas. This concern appears to be in addition to the concern identified during the previous NRC inspection (reference item 99900105/86-01-03) which is discussed in D.3 below. This issue will be classified as an open item pending further discussion anc review by the NRC inspectors.

Inspector observations indicate that the Fisher QC inspection dCtivitics are not assuring that incoming parts, materials, and 25

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

HARSHALLTOWN, IOWA REPORT INSPECTION NO.: 99900105/88-01 RESULTS: PAGE 6 of 12 components are in accordance with the purchase order technical specifications. Additionally, Fisher may not be meeting the intent of the ANSI and Appendix B to 10 CFR Part 50 requirements in the areas of " Inspection," " Control of Materials Parts and Components,"

and " Instructions, Procedures, and Drawings." As an example it was noticed that the Fisher inspectors did not appear to have instruc-tions that would specifically require certain dimensional or func-tional component characteristics to be verified. Discussions with the Fisher inspectors indicated that the selection of the dimen-sional and functional characteristics of a given component that were to be verified, if any, were left up to the discretion of the individual inspector. This practice, if its typical, is not acceptable because the receipt activities for commercial grade components (CGC) forms part of the bases for CGC's to be used in nuclear safety-related systems (these issues are also discussed in item D.3 below).

It is noted that these issues were not reviewed by the inspectors in enough detail to determine whether or not a nonconformance is applicable. Therefore, the issue will remain as an OPEN item.

D. PREVIOUS INSPECTION FINDINGS:

1. (Closed) Violation 86-01-01:

Contrary to 10 CFR Part 21, ".. . Fisher does not have a procedure to provide for evaluating deviations in parts, components, or products which are intended for nuclear use and are processed under the standard Quality Assurance Manual."

The inspector's review determined that Fisher has established appropriate instructions and has incorporated them in its QA manual. Additionally, Fisher has adopted a customer notification program, Fisher Anomaly Notification Program (FAN), to identify items that may require an NRC licensee to perform an evaluation pursuant to 10 CFR Part 21.

2. (Closed) Violation 86-01-02:

Contrary to 10 CFR Part 21, " Fisher f ailed to assure that procurement documents for two safety-related Limitorque motor operators specified that the provisions of 10 CFR Part 21 were applicable."

26

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLTOWN, IOWA REPORT INSPECTION NO.: 99900105/88-01 RESULTS: PAGE 7 of 12 The Fisher review of this issue revealed that the Limitorque Corporation self imposed the provisions of 10 CFR Part 21 on itself for this purchase order as well as all safety-related orders that it receives, Additionally, Fisher developed and implemented a computer program for its procurement activities called its " process code system." This system ensures that all applicable requirements, including Part 21, are verified and printed on each purchase order.

3. (0 pen) Nonconformance 86-01-03:

Contrary to Criterion V of Appendix B to 10 CFR Part 50, " Fisher failed to establish procedures and instructions for quantitative or qualitative acceptance criteria for finished parts receiving inspection activities."

Fisher provided its response to the 1986 NRC inspection report in a letter dateo December 17, 1986. The Fisher response stated that it would improve one aspect of its existing receipt inspection program even though it already provides adequate information to the inspectors to inspect finished parts. Fisher committed to develop and implement an " inspection history form" that would include:

(1) Date received; (2) Quantity received; (3) Quantity inspected; (4) Quantity rejected; (5) Vendor; and (6) Comments. The Fisher letter indicated that the remainder of its QC receipt inspection process is adequately implemented by controls such as:

Fisher Inspector job description with includes his/her duties and responsibilities.

Purchase order verified receipt cards (indicates quantity received, P0 number, part number, bin location where sent by warehouse receipt personnel, material code number, vendor code number, etc.)

Material reference list - (cross reference between a material code number and the type of material [i.e.,

graphite laminate - grafoil AXX-801U2]).

Material specification drawing - (delineates actual material specifications and physical characteristics).

Inspection sample plan information.

Fisher drawings for piece-part physical characteristics.

(

27

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLTOWN, IOWA REPORT INSPECTION NO.: 99900105/88-01 RESULTS: PAGE 8 of 12 The NRC inspector observed several receipt inspectors in the performance of their quality activities. The NRC inspector also querried the Fisher inspectors regarding documented quantitative and qualitative acceptance criteria and the documented scope and depth of their inspection activities. It was revealed that neither the " inspected" nor the " quantity rejected" attributes have been established and documented on the Fisher " inspection history forms."

Additionally, there are no instructions, procedures, or policies that require the QA inspectors to verify any specific minimum or maximum inspection points for physical or chemical characteristics for incoming parts (as discusseo in C.2). The decision of what characteristics are to be inspected, if any, is left to the judgement of the individual inspectors in most cases. For example, while observing receipt inspection on an indicator assembly (P/N 39A1126X012, Series 4196), it was noted that no verification of dimensional characteristics was performed. Ths inspection appeared to be limited to a visual inspection for finish and damage. Another observation of receipt inspection of actuator coil springs (such as P/N 6371) revealed that the dimensional and functional attributes selected for reverification from a particular drawing are dependent upon the individual inspector.

Therefore, this finding will be left as an OPEN item due to incomplete implementation of the Fisher commitment in regard to its inspection history forms. The inspector also concluded that Fisher management is not adequately controlling nor documenting its receipt inspection activities; however, further review of this area will be performed during a future inspection.

4. (Closed) Nonconformance 86-01-04:

Contrary to the NRC regulations, " Fisher failed to notify its customers that the output torque available from its size-two cast iron cjear sector for type 1073-1076 manual valve actuators was derated to 8000 inch-pounds maximum torque in oroer to prevent their inadvertent use or installation."

Fisher subsequently notified the applicable customers with a

" Fisher Anomaly Notification" letter of the problem so that the licensees could evaluate the torque downrating to their specific desigr. applications. Additionally, as discussed in 0.1 above, the Fisher FAN program will ncw provide a vehicle for Fisher to transmit any future technical concerns or improvements to the NRC licensees.

28

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLT0WN, IOWA l l

REPORT INSPECTION NO.: 99900105/88-01 RESULTS: PAGE 9 of 12 E. OTHER FINDINGS AND COMMENTS:

1. Measuring and Test Equipment:

The inspector performed a two part review of the implementation i and control of the Fisher measuring and test equipment (M&TE) system. The first part consisted of a walk-through inspection of

the Fisher Governor Road (GR) machine shop fabrication facility and its Center Street (CS) fabrication assembly facility to inspect M&TE items that were either in actual use or that were available for use. The second part of the inspection consisted of the review of the calibration history record documents for the chosen M&TE items and a cursory procedure review.

Nineteen individual M&TE items were observed and documented by the inspector and three out of the 19 were found to be out of calibration. (See Nonconfromance 88-01-01) One of the 19 was found to not have a calibration history record document on file.

(See Nonconformance 88-01-02)

It was noted that each M&TE item was identified with its own unique identification (ID) number to allow traceability back to the work history cards. However, it was also noted that the ID number was the only M&TE-related marking on many of the tools and instruments. The ANSI and Appendix B requirements require that the M&TE items used in activities affecting quality be controlled, calibrated, and adjusted at specified periods.

It could not be determined whether Fisher is adequately control-ling inadvertent use of tools and instruments that may be out of calibration. For example, there were no " calibration due date" labels or other similar control, to identify that a M&TE item is within calibration prior, during, or after its use. Therefore, based on the above, the nonconformance in section B concerning the failure of the current system to adequately control calibra-tion was identified. (See Nonconfnrmance 88-01-04)

The M&TE items inspected were as follows:

Serial No.

M&TE Calibration Due Date Coments CRB 210 November 1988 Pressure - meter (with the final tester) 29

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLTOWN, IOWA l REPORT INSPECTION NO : 99900105/88-01 RESULTS: PAGE 10 of 12

{

i

_ Serial No, M&TE Calibration Due Date Coments CRB 104 Unknown Flow meter (with Failed to find the record final integrate for flow meter calibration.

tester)

SY 1459 Annual-March 1988 Spring compression . Calibration due date exceeded.

rate load cell tester No Serial No. July 27, 1988 Spring travel Calibration due date exceeded.

rate indicator F 7073 February 3, 1988/ Thread plugs.

February 1989

\

F 7680 October 22, 1987/ Smooth plugs October 22, 1988 9106-4 May 4, 1988/

Torque wrench No original calibration November 1988 measuring data, percentage only. (See Nonconformance i 88-01-03) 222 Checked before & Pressure gauge af ter every use C-13068 April 24,1987/

Pressure meter April 24, 1989 master TC-1-082 September 19,i'988 Outside micrometer i

30

l

/

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLTOWN, IOWA REPORT INSPECTION N0.: 99900105/88-01 RESULTS: PAGE 11 of 12 l

Serial No.

M&TE Calibration Due Date Conments FC 3083 Janua ry 19, 1988 Micrometer FC 11263 April 15,1988 Intrimikes FC 8378 March 24, 1988 Mics FC 8322 March 24, 1988 Mics l

F 1786 April 21, 1988 Thread ring gauge F3724 October 13, 1988 Smooth plug gauge l F 3197 January 14, 1988 Thread plug gauge i

l 15316 August 5, 1988/ Certified by Magnaflux.

Black light intensity meter February 5, 1989 l 72148 August 12, 1988 Certified by ISI.

Magnetic particle testing machine 31 1

ORGANIZATION: FISHER CONTROLS INTERNATIONAL, INC.

MARSHALLTOWN, ICWA REPORT INSPECTION NO.: 99900105/88-01 RESULTS:

PAGE 12 of 12 F. PERSONNEL CONTACTED:

Denny Cahill, QA Director Ron Duimstra, QA Department Manager Bob Knusten, Quality Analyst Dennis R. Hulin, QA Engineer Bud Innis, Floor Inspector Jeff Klatt, QA Inspector Kent Runrielhart, Application Engineering Chuck Colwell, Project Planning Floyd Jury, Engineering, Nuclear Quality Analysis Fred Luthe, Engineering, New Product Design - Valves John Dresser, Engineering Mark Adams, Applications Engineering Larry Schwienebart, Receipt Inspector Gerald Miller, Receipt Inspector Larry Metz, Quality Document Analyst Jim Harsha, Rough Stock Inspector 32

i ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT- INSPECTION INSPECTION 4

NO.: 99900888/88-01 DATE: Seotember 26-30, 1988 ON-SITE HOURS: 96 CORRESPONDENCE ADDRESS: Mr. W. E. Windt, Vice President Nuclear Division P.O. Box 1211 Houston, Texas 77251-1211 ORGANIZATIONAL CONTACT: Mr E. J. Charanza, QA/QC Manager TELEPHONE NUMBER: (713) 869-7111 l NUCLEAR INDUSTRY ACTIVITY: Fasteners.

1 i

i ASSIGNED INSPECTOR: [5T D c/> x.- .,[e x /F[7/f?

James T. Conway, Progranf Development and Reactive Ddte Inspection Section (PDRIS)

OTHER INSPECTORS: L. Parker, PDRIS I

G. Cwalina, PDRIS I i k. g sultant)

APPROVED BY: ' g/ E d' "

Edward T. Baker, Chief, PDRIS, Vendor Inspection Branch e lhSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21.

B. SCOPE: The inspection was conducted to perform a programmatic evaluation of the implementation of Texas Bolt's (TB) QA program as it relates to the fabrication of fasteners for nuclear facilities.

l PLANT SITE APPLICABILITY: Palo Verde, South Texas Plant, Duke Power Company, Tennessee Valley Authority, Carolina Power and Light, and possibly other plants.

33

ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT IflSPECTION NO.: 99900888/60-01 RESULTS: PAGE 2 of 12 A. VIOLATION:

Contrary to Section 21.31 of 10 CFR Part 21, a review of purchase orders (P0) to vendors revealed that while 10 CFR Part 21 was imposed upon TB by several nuclear customers including Anchor / Darling, ITT Grinnel, Bechtel Construction, United Engineers and Constructors, Bechtel Power Corporation, Anderson-Greenwood, Energy Steel and Supply, Hardware Speciality, Duke Power, Houston Light & Power, William Powell, Carolina Power and Light (CP&L), Nova Machine, DuBose Steel, Tennessee Valley Authority, HUB, Capitol Pipe & Steel Products, and Oravo. TB did not impose 10 CFR Part 21 requirements on P0s 1093 (August 10,1988) to Southwest Plating; 39696 (March 17, 1988) to Army Materials Research l Center; and 40026 (May 18, 1988), 38148 (May 4, 1987), and 38853 (September 18,1987) to Gulf Coast Calibration. (88-01-01)

B. NONCONFORMANCES:

1. Contrary to Subsection NCA-3867.4(a) of Section III of the ASME Code, TB did not include the chemical product analysis performed by TB on CMTRs dated November 13, 1986; December 22, 1986, and I December 23, 1986 to Carolina Power and Light. (88-01-02)

2. Contrary to Criterion IX of Appendix B to 10 CFR Part 50 and Section 7.6.1 of the Quality System Manual (QSM), there was no documented evidence that TB reviewed the personnel qualifications or approved and maintained the procedures of Southwest Plating who did cadmium plating on nuclear fasteners. (88-01-03)

3. Contrary to Criterion IV of Appendix B to 10 CFR Part 50 and Section 5 of ANSI N45.2, the requirement for a vendor to have an approved QA program was not stated on P0s 1093 (August 10,1988) to Southwest Plating; 39696 (March 17,1988) to Army Materials Research Center; 40422P (August 4, 1988) to Industrial Inspection; and 40026 (May 18, 1988), 38148 (May 4, 1987), and 38853 (September 18, 1987) to Gulf Coast Calibration. (88-01-04)

4. Contrary to Criterion VII of Appendix B to 10 CFR Part 50 and Section 7.1 of the QSM, TB did not approve International Nickel of Huntington, West Virginia who supplied material for safety-relatea fasteners on TB P0s 3724S (April 19, 1977) and 3815S (May 17, 1978). (88-01-05)

5. Contrary to Criterion XVI of Appendix B to 10 CFR Part 50 ano Section 16.1 of the QSM, procedure TB-QAP-1, " Texas Bolt Company Auoit Procedure," dated September 1, 1977 does not require that 34

ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS' '

REPORT INSPECTION N0.: 99900888/88-01 RESULTS: PAGE 3 of 12 identified program deficiencies be documented. (88-01-06)

6. Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50, Subsection NCA-3869.1 of Section III of the ASME Code, and Section 19 of ANSI N45.2, a review of internal audit records revealed the following: (88-01-07)

(a) Audits of the Quality System department, dated February 6, 1987 and August 5, 1987, were performed by the Quality System Manager and the Vice President, Nuclear Division, respectively. Both individuals had direct responsibility for the area being audited.

(b) The audit of the Quality Systems department, dated February 6,1987, was reviewed by the Production Supervisor who did not have responsibility for the area being audited.

(c) The audit of the Quality Systems department, dated August 5,1987, was reviewed by an employee in the department not having managerial responsibility.

(d) Audits of the Purchasing department performed in August 1986 and prior were reviewed by the QA/QC Manager who did not have responsibility for the area being audited.

(e) The audit of the Quality Systems department of August 1985 jaentified a deficient item and specified needed corrective action. Documentation does not exist to show that a follow-up audit was performed to assure that the corrective I action was satisfactorily completed.

l (f) Audits of the Quality System department in February and August 1988, were performed by the Vice President / General  !

Manager, but he was not specified as a qualified auditor i until September 23, 1988. 1 1

(g) Although the Vice President / General Manager was approved by l the Vice President, Nuclear Division, documentation did not l

exist to show that he meets the requirements specified in procedure TB-QAP-1.

7. Contrary to Criterion II of Appendix B to 10 CFR Part 50 and Section 2 of ANSI N45.2, a review of documents and interviews with personnel revealed that: (88-10-08) 35

ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION H0.: 99900888/88-01 RESULTS: PAGE 4 of 12 (a) Two individuals involved in final visual inspection and packing of nuclear components had not received training in the QSM:

(b) With the exception of the Vice President / General Manager, personnel in the purchasing and manufacturing departments did not receive training in the requirements of the QSM.

(c) The following personnel have not signed a document inoicating they have read and understood the QSM:

- the President, who is a certified auditor,

- Production supervisors or other personnel involved in manufacturing nuclear components,

- Sales personnel involved in procuring nuclear services.

8. Contrary to criterien VI of Appendix B 10 CFR Part 50, Subsection NCA-3866.2 of Section III of ASME Code, and Section 7 of ANSI N45.2, uncontrolled procedures were located in the following work l

I areas for some quality related activities. (88-01-09)

a. Procedures found at the hot-dip galanizing and sheroidizing

)

work stations were not under control of the document control '

system. Further, there was no indication that these proce-cures had received a technical and quality review,

b. An uncontrolled copy of revision 6 to TB-MT-#1, " Magnetic Particle Inspection Procedure," was found in the magnetic particle inspection room.

c. Outdated revisions of TB-HT-#1, " Heat Treat Procedures," were found at the heat treat supervisor's work station.

d. An uncontrolled copy of Heat Treat Procedure TB-EFB-#1, Rev. O, dated April 1, 1985, was found at the heat treat supervisor's desk. The master Procedure Control Book did not indicate that this copy of the procedure was included in the document control system.

9. Contrary to Tb Procedure TBV-1, two inspectors who had not received the required eye ex6mination were observed performing visual inspection en nuclear satety-related nuts for Nova Machine order 098191 (TB order 221365). (88-01-10) 36

ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION

NO.

99900888/88-01 RESULTS: PAGE 5 of 12 C. UNRESOLVED ITEMS:

As part of the inspection the inspectors discussed recent failures at Palo Verde of fasteners manufactured by Texas Bolt. Texas Bolt had very little information concern $ng the failures, but had requested that samples be returned for testing. This issue is considered unresolved and will be reviewed during a future inspection. (88-01-11)

D. STATUS OF PREVIOUS INSPECTION FINDINGS:

Not addressed during this inspection.

E. OTHER FINDINGS AND COMMENTS:

1. TB TB has been producing threaded fasteners since about 1945. The company currently manufactures bolts, nuts, studs, and special parts by cold and hot forging techniques for both nuclear and non-nuclear applications. Approximately 95 percent of the threading is done by rolling, and the remainder is done by cutting. TB has it own f acilities for heat treating and uses an atmospherically controllea furnace to control decarburization.

One quality assurance program which is documented in the QSM is used by TB for the manufacture of all its products. The policy statement in the QSM signed by the President states that the program complies with the criteria in Subsection 3800 of Section 111 of the ASME Code and ANSI N45.2. TB representatives stated that TB purchases raw material (e.g. , bar stock, coils) only f rom domestic suppliers such as Atlantic Steel, Copperweld, Republic, dnd Crucible. The material is upgraded via chemical analysis ano mechanical testing (tensile, hardness and charpy) in TB's laboratory to satisfy certified material requirements. TB also does magnetic particle examinations in house when required by the material specification or the customer.

2. Failed Fasteners - Palo Verde Nuclear Generating Station (PVNGS)

On July 25, 1988, Arizona Nuclear Power Project (ANPP) submitted a report in aCCordance with 10 CFR Part 21 concerning fasteners which had failed on March 21, 1987, March 19, 1988, and on June 2, 1988. Information stated that the fasteners are 1/2-inch x 1 1/4-inch ASME Section III, SA-193, Grade B6 bolts used to retain gaskets on Posi Seal (PS) valves. The valves were 37

ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION NO.: 99900888/88-01 RESULTS: PAGE 6 of 12 supplied to PVNGS by Combustion Engineering (CE), and the bolts were supplied to PS by TB. The suspect bolting has been isolated to a single lot of 200 bolts. Twenty-four of the bolts were installed on the PS valves supplied to PVNGS by CE and the other 176 bolts are in stock at PS. PS will test some bolts and will send a sample of bolts to TB for analysis. A PVNGS site modifica-tion had been issued to replace the SA-193 grade B6 gasket retainer (

bolts with SA-564 type 630 bolts. This reactive item is not generic.

All of the fasteners in question have been located and those that are safety-related have been replaced.

TB's Vice President, Nuclear Division stated that approximately three months prior to this inspection he had been contacted by an ANPP buyer concerning the above fasteners. The buyer was i

I asked to check the bolt head markings, but at the time of this inspection, TB had not received a response from the buyer. The QA/QC Manager at TB stated that on August 3,1988 he had been contacted by Mr. Milton of ANPP about hardness tests that had been performed on the bolts in question. The QA/QC Manager subsequently {

talked to B. Berry of PS on August 4,1988 about the testing. The Rockwell hardness values that were obtained appeared to be inconsistent, and the QA/QC Manager requested bolt samples for subsequent testing at TB, On the afternoon of September 27, 1988, the Vice President, Nuclear Division called Mr. Gehr (ANPP) for further information concerning this problem. Mr. Gehr put the Vice President in contact with Mr. Milton who was going to send TB the test information if he could get approval to do so from his management. By the end of the inspection, the test data had not a rri ved. In conclusion, TB had little but verbal knowledge of the problem. No bolts or documented test data have been sent to iB for their evaluation. (See Unresolved Item 88-01-11.)

3. Control of Purchased Material and Services The inspector reviewed Section 7.0, " Control of Purchase Materials and Services," of the QSM and various records to assure that material and services were purchased from qualified vendors.

Twenty-seven external audits covered a time period from April 1984 to September 1988. With no exceptions, they were ali performed using a checklist and the Vice President, Nuclear Division, was the lead auditor. The active Approved Vendors List (AVL) containea five material manufacturers, one material supplier, and seven service 38

ORGANIZATION: TEXAS BOLT COMPANY I

HOUSTON, TEXAS REPORT INSPECTION

( N0.: 99900888/88-01 RESULTS: PAGE 7 of 12 vendors. The most recent audit for the active vendors was l l September 1988 for Crucible, Republic, Carpenter, Bethlehem, J l and Atlantic Steel Companies, S.C.C - August 1988; Southwest l Plating - April 1988; Gulf Coast Calibration - May 1988; Advanced i inspection Products - April 1988; Technology and Calibration j August 1988; James Nash - July 1988; Industrial Inspection l May 1988; and Honeywell - April 1986. Review of two TB P0s  !

(No. 372455, dated April 19, 1977 and 38155S, dated May 17,1978) l revealed that material for nuclear fastaners had been supplied by 1 International Nickel - Huntington Alloy. TB stated that they l qualified Huntington Alloy by testing and chemical analysis of the stock material. (See Nonconformance 88-10-05.)

The auaitor qualification records for the Vice President, Nuclear Division and the QA/QC Manager, appear to meet the requirements of ANSI 45.2.23. In conjunction with this review, " Texas Bolt Company Audit Procedure" TB-QAP-1, dated September 1, 1977, was reviewed in part. (See Honconformance 88-01-06)

4. Documentation Packages (DP)

Approximately 80 DPs covering the sale of ASME Section III, Class 1, 2, and 3 fasteners to 18 customers were reviewed. Each package contained the customer P0 and specifications and TB's sales order, invoice, quotation, travelers, and certified material test reports (CMTR). They were selected to determine if the technical and quality requirements of the purchaser's P0 were met. The nuclear customers included Anchor / Darling, ITT Grinnel, Bechtel Construction, United Engineers and Constructors, Bechtel Power Corporation, Anderson-Greenwood, Energy Steel and Supply, Hardware Speciality, Duke Power, Houston Light & Power, William Powell, Carolina Power and Light (CP&L), Nova Machine, DuBose Steel, Tennessee Valley Authority, HUB, Capitol Pipe & Steel Products, and Dravo.

It was noted in two orders to CP&L that TB did not report the chemicul product analysis on the CMTRs. The chemical analysis-reported for 1/2-inch x 21/2-inch studs (Heat No, M7099B) and 1 inch heavy hex nuts (Heat No. M6280B) on CMTR dated December 23, 1986 was the analysis performed by Huntington Alloys, the manufacturer, and not the check analysis done by TB on test reports 866799 (December 15, 1986) and 870013 (December 22,1986).

39

ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT lhSPECTION NO.: 99900888/88-01 RESULTS: PAGE 8 of 12 The chemical analysis reported on CMTR, datea December 22, 1986 for 1/2 inch movel cap screws (Heat No. M72518) and nuts, (Heat No.

M3708B) was the ladle analysis from the manufacturer ano not the check analysis periormea by TB on test reports 866750 and 866751.

(See Nonconformance 88-01-02.)

5. Customer Audits of TB The inspector reviewed eight sets of audit documentation by purchasers of TB fasteners. Each customer approved the TB quality program and its implementation. None of the audits found any deficiencies with the TB quality program. The documentation reviewed was from Process Fasteners Corporation (October 1, 1986), Bechtel Power Corporation, (May 18-20,1988),

Duke Power Company (April 21-22,1988), Pacific Gas and Electric Company (January 22, 1988 and June 7-8,1988), Hardware Speciality Company, (January 8, 1986), and William Powell (August 6, 1986).

6. Calibration of Measuring and Test Equipment (M&TE)

The inspector reviewed Section 12 " Control of Measuring and Test Equipment" of the QSM, procedures TB-CAL 1B-#1, " Procedure for Calibration of Mikes, Plug Gages, ana Ring Gages," dated July 1, 1981 and TB-CMTE-#1, " Control of Measurement and Test Equipment," dated April 4, 1985, and calibration records to assure M&TE is properly centrolled and calibrated, i

A number of M&TE was inspected for calibration status. A summary follows: seven temperature controls, four temperature recorders, magnaflux unit including black light and ammeter, four ring gages, two plug gages, four micrometers, one vernier, two hardness testers, gage wires, two Tinius Olsen testers (one tensile and one charpy),

one Weston foot candle meter, and one U/V meter. All of the items had been calibrated within the last year.

With a few exceptions, records indicated TB calibrates micrometers, plug gages, and ring gages on a monthly basis, even though the required frequency is six months. TB uses a colored dot system to indicate calibration status.

for calibration at Gulf Coast Calibration.The gage block set was currently out calibration by Gulf Coast in September 1987. The set was previously Specimens for charpy calibration were procured from U. S. Army Materiais Research Center, Watertown, MA. These specimens were returned to Watertown for evaluation f0llowing impact testing by TB.

40

ORGANIZATION: TEXAS BOLT COMPANY h00STON, TEXAS REFORT INSPECTION NO.: 99900888/88-01 RESULTS: PAGE 9 of 12 1 1

Certification documentation from Honeywell for calibration of various temperature instruments on the heat treat furnaces were reviewed. The instruments were calibrated using three Biddle Model 72-311 (S/Ns 81640, 81075, and 77753) units which were all traceable to the National Institute of Standards and Techology (NIST). J. Nash calibrated the Tinuis Olson tensile tester on August 1, 1988 using four load cells traceable-to NIST. The recorder (S/h 77101) for the tensile tester was calibrated by Technology and Calibration on August 19, 1988. The Magnaflux unit (TAQ 524) was calibrated by Industrial Inspection (II) on September 9, 1988. II's procedure.CT-9880 " Magnetic Particle Inspection Equipment" was reviewed. The procedure was not dated and there was no indication that TB had reviewed and approveo a this procedure.

7. 10 CFR Part 21 The inspector reviewed procedure TB-P21 "10 CFR 21 Procedure," ,

dated March 1, 1985, for implementing 10 CFR Part 21 requirements.

Compliance with posting requirements was also evaluated. The required documents were posted in three location, outside the QA/QC office, in the laboratory, and in the lunch room.

A review of TB P0s to vendors of nuclear material and services listed below revealed that TB did not invoke the requirements of 10 CFR Part 21 in the subject P0s. (See Violation 88-01-01.)

Southwest Plating, P0 1093 Army Materials Research Center, PO 39696 Gulf Coast Calibration, P0s 40026, 38148, and 38853

8. Document Control The inspector reviewed a number of procedures used by TB to perform special processes. It was noted that procedures found at the work stations for hot-dip galvanizing and spheroidizing were not included in the document control system nor had they received a technical and quality review by TB. An uncontrolled copy of revision 6 to TB-MT-#1, " Magnetic Particle Inspection Procedure,"

was found in the magnetic particle inspection room. Outdated revisions TB-HT-#1, " Heat Treat Procedures," were found at the heat treat supervisor's work station.

41

ORGANIZATION: TEXAS BOLT COMPANY HOUSTCN, TEXAS REPORT INSPECTION N0.: 99900888/88-01 RESULTS: PAGE 10 of 12 An uncontrolled copy of Heat Treat Procedure TB-EFB-#1, dated April 1,1985, was found at the heat treat supervisor's desk. The master Procedure Control Book did not indicate that this copy of the procedure was included in the document control system.

Based on discussions with the QA/QC Manager, it was determined that TD had not explicitly reviewed and approved procedures used by Southwest Plating for cadmium plating of safety-related bolts on P0 No. 1093 dated August 10, 1988. (See Nonconformance 88-01-09.)

9. Manufacturing Facility The NRC inspector toured TB's manufacturing facility at various times in the company of TB's personnel. Areas and activities witnessed included storage of incoining material, receipt inspection, heat treating, hot and cold forming, roll threading, machining, magnetic particle (MT) examination, destructive testing, metallography, final inspection, and packaging.

Two TB inspectors were observed performing visual inspection of Section 111 SA 194 nuts. The nuts were part of Nova Machine order 098191 (TB order 221365). Discussion with the inspectors and the QA/QC Manager identified that the inspectors had not received the eye exam required by TB visual inspections procedure TBV-#1. (See Nonconformance 88-01-10.) The QA/QC Manager proceeded to have the eyes of the two inspectors examined the following day. Both inspectors passed the eye examination.

10. Nondestructive Examination (NDE)

The inspector reviewed TB's written practice (TB-NDT-P#1) for NDE, one MT examination procedure, one visual examination procedure, and the qualification records for seven TB exjpniners (three-Level 111 6nd four-Level II). The records consisted of documentation relating to training courses, eye exams, certifications, ASNI certification and exam (h45.2.6), and general, specific, and practical examinations. The records were consistent with the requirements of SNT-TC-1A.

11 performed liquid penetrant examination of safety-related nuts (P0 40422P dated August 5, 1988) for Hardware Specialty Company.

The inspector reviewed proc,edure TB-WW-1182, " Penetrant Procedure for Texas Bolt," which was approved by the QC manager of TB in 42

)

1 l

1 q

ORGANIZATION: TEXAS BOLT COMPANY j HOUSTON, TEXAS J REPORT INSPECTION N0.: 99900888/88-01 RESULTS: PAGE 11 of 12 February 1982. The qualification records for five NDE personnel from 11 were also reviewed and found acceptable.

11. , Internal Audits The inspector reviewed semi-annual internal audit reports dating I from February 1985 to August 1988. These audits covered the areas of " Purchasing," " Production," and " Quality System." As noted in previous NRC Inspection Report No. 99900888/84-01, the audit checklists are very general and limited in scope. The inspector examined two audits which identified deficiencies and specified nEeded Corrective actions. The inspector noted that one of the corrective action items was properly followed up with its completion being documented on the audit. form as required.

Section III of ASME Code, ANSI /ASME N45.2-1977, and TB's QSM and procedures all require audits to be performed by personnel who are independent of the area being audited with audit reports being reviewed by management with responsibility in the area.

The inspector identified several instances where these requirements were not met. TB also requires all auditors to meet requirements specified in company procedures. The inspector found that the Vice President / General Manager was approved by memorandum signed by Vice President, Nuclear with no evidence of his having met all the TB company requirements. Further, the Vice President / General Manager had performed two internal audits prior to his approval as an auditor. (See Nonconformance 88-01-07.)

12. Training i

The NRC inspector reviewed training records to determine if personnel involved in the purchasing, manufacturing, testing and packaging of nuclear material had been indoctrinated into the requirements of the QSM. TB documents this indoctrination by having each individual initial a statement stating that they have read and understood the requirements of the manual. The inspector found that the statement was initialed by the Vice President / General Manager; Vice President, Nuclear; Quality Assurance Manager; and seven employees involvea in testing and inspection. However, the company President, who is listed as a certified auditor had not initialed the statement. Furthermore, no one involved in purchasing, sales or manufacturing, other.than 43

ORGANIZATION: TEXAS BOLT COMPANY h0VSTON, TEXAS REPORT INSPECTION NO.: 99900888/88-01 RESULTS: PAGE 12 of 12 the VP General Manager, had been indoctrinated. Discussions with the VP, General Manager indicated that quality requirements are discussed with manuf acturing foremen in the course of routine meetings but no formal training is performed. In addition, the inspector interviewed two individuals performing final visual inspection and packaging who had not been indoctrinated into the QSM. (See honconfonnance 88-01-08.)

F. PERSONNEL CONTACTED:

• W. E. Windt, VP, Nuclear Division

• A. R. Tomchesson, VP, General Manager

• E. J. Charanzo, QA/QC Manager S. Choranza, Level III Examiner K. Parker, Clerk R. Wilson, Heat Treat Supervisor I. Martinez, Purchasing Agent

• Attended Exit Meeting l i

l i

1 i

44

Selected Bulletins and Information Notices Concerning Adequacy of Vendor Audits and-Quality of Vendor Products Issued October-December 1988

1. Bulletin No. 88-10: Nonconforming Molded Case Circuit Breakers

2. Information Notice No. 88-46 and Licensee Report of Defective Supplement 2: Refurbished Circuit Breakers

3. Information Notice No. 88-95: Inadequate Procurement Requirements Imposed By Licensees On Vendors

4. Information Notice 88-97: Potentially Substandard Valve Replacement Parts

)

45

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46

VENDOR INSPECTIONS RELATED TO REACTOR Pl. ANTS PLANT NAMES Vogtle Palo South Duke TVA CP&L VENDOR 1&2 Verde Texas Power Anchor Darling Applies to all plants Curtis Wright X Fisher Controls Applies to all plants Texas Bolt X X X X X X I

and others 47

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Stl IN$7 RUCTIONS ON Tot REvtN54 l 2 TIT Lt AND Sue T IT Lt a LgAvesLANn Licensee Contractor and Vendor Inspection Status Report, j Quarterly Report - October 1988 - December 1988 4 D ATE R(PORT COMPstTED 4

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l l Same as 7. above Quarterly D PERioO COvtRED flactus've cipread October 1988 - December 1988 i2 SUPPLEM[NT AR Y hof t$

,3 AGS T R ACT (200eorse r tem This periodical covers the results of inspections performed by the NRC's Vendor l Inspection Branch that have been distributed to the inspected organization during the period from October 1988 through December 1988.

6 AvalL A9tLIT Y i4 DocuMtNT AN ALYS16 - a R E vwoRD5/DESCRIPf oms STATEMENT Vendor inspection Unlimited 16 SECURITY CL ASSiFICAtiOh

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