ML20249C684
| ML20249C684 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/1998 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20249C680 | List: |
| References | |
| REF-QA-99901335 99901335-98-01, 99901335-98-1, NUDOCS 9807010027 | |
| Download: ML20249C684 (15) | |
Text
t 1
U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Spent Fuel Project Office inspection Report Docket:
999-1335 Report:
999-1335/98-01 Vendor:
Columbiana Boiler Compans/
i Columbiana, Ohio l
l Date:
May 11-14,1998 Inspection Team:
T. Matula, Team Leader, SFPO S. McDuffie, SFPO G. Roberts, INEEL Approved by:
Susan F. Shankman, Deputy Director
~
Licensing and Inspection Directorate i
Spent Fuel Project Office, NMSS 9307010027 990625 PDR GA999 EMV*****
i..
,9990.1335 _
y L
Inspection Report Docket 999-1335 EXECUTIVE
SUMMARY
NRC Inspection Report No. 999-1335/98-01 On May 11-14,1998, the U.S. Nuclear Regulatory Commission (NRC) performed an announced inspection of Columbiana Boiler Company (CBC) at its facility in Columbiana, Ohio.
The team inspected CBC's activities associated with the fabrication of Uranium Hexafluoride (UF,) cylinders, Models 308 and 48Y. The purpose of the inspection was to determine if -
CBC's fabrication activities were performed in accordance with the requirements of 10 CFR Parts 21 and 71; Certificates of Compliance (COCs) 6553, 9196, and 9234; and American National Standards Institute (ANSI) N14.1-1990, " Uranium Hexafluoride - Packaging for Transport." The team assessed CBC's management and fabricat;on contris. The results of the inspection are summarized in Table 1.
i Management Controls
=
The team determined that CBC's management controls were generally acceptable.
i However, several areas of CBC's management control system were not in compliance
- with 10 CFR part 71, Subpart H. The team identified one violation and 'hree nonconformances in this area. The lack of 10 CFR Part 21 postings and training documentation led to a violation regarding Part 21 which is considered to have high f
safety significance. Specific nonconformances, having Icw safety significance, include i
inadequate Quality Systems Manager (QSM) independence from cost and schedule j
considerations, failure to adequately control nonconforming material, failure to document j
nonce npliancas, and failure to conduct internal and extemal audits. The team made observations regarding the absence of a procedure for classification of components, an inadequate corrective action procedure, missing document approval signatures, and I
having a centralized location for fabrication drawings and procedures rather than having them at wc* stations.
4
- Eabfication Controls The team determined that CBC's fabrication controls were generall;' acceptable. The team identified two nonconformances having low safety significance regarding the control of torque used in the assembly of cylinders, as well as tool and equipment calibration. The tasm made an observation regarding material she4 life control.
Overall Conclusions The team conduded that CBC's management controls and fabrication controls were generally acceptable and that the UF, cylinders fabricated by CBC will meet their intended safety function. However, the team identified one violation having high safety significance and five nonconformances having low safety significance. The team was informed that CBC had hired a new Quality Assurance (QA) Manager in March 1998 f
2' i
l'
-(
.t.
I inspection Report Docket 999-1335 who completely updated CBC's QA program to comply with the requirements of 10 CFR Part 71.- The team noted that CBC is currently in the process of implement!ng new QA procedures which, when fully implemented, will address the issues identifed during this inspection. The implementation of the updated QA program will be inspected in a future inspection.
1 Table 1 Summary ofinspection Findings Ti$squif Ment][
h Subject of Violation or L. Number
- Type of Finding s
,< Report.
diMo'tig
- j!R
' Nonconspliance',, ', Wof,.l : 'W.':,, * * ; A ' : Section '
410 CFRF < '-
T:i
~ ' "
% 19
' M * ' :
' Findings' M ' F D 6 7Secti$ri%
~
?" i. : 't^#v I? ' E M' ' a 4 ' '^c /?
21.6 Posting requirements 1(1)
Violation 2.3.2
.(999-1335/98-01-02) 71.103 Quality assurance 1 (1)
Nonconformance 2.2.2 organization (999-1335/98-01-01) 71.105 Quality assurance program 1 (1)
Observation 2.2.2 71.113 Document control 1 (2)
Observation 2.4.2 71.117 l identification and control of 1 (1)
Observation 3.2.2 materials, parts, and j
components
'71.123 Test control 1 (1)
Nonconformance 3.3.2 (999-1335/98-01-05) 71.125 Control of measuring and test 1 (4)
Ncnconformance 3.5.2 equipment (999-1335/98-01-06) 71.131 Nonconforming materials, 1 (3)
Nonconformance 2.3.2 parts, or components (S99-1335/98-01-03) 71.133 Corrective action 1 (1)
Observation 2.3.2 71.137 Audits 1 (1)
Nonconformance 2.5.2 (999-1335/98-01-04)
- Numbers in parentheses indicate the number of supporting noncompliance as examples.
3 l
i Inspection Roport Docket 999-1335 LIST OF ACRONYMS USED ANSI American National Standards Institute CBC Columbiana Boiler Company CFR Code of Federal Regulations COC Certificate of Compliance INEEL Idaho National Engineering and Environmental Laboratory NMSS Office of Nuclear Material Safety and Safeguards NCR Nonconformar.ce Report NDE Nondestructive Evaluation NRC Nuclear Regulatory Commission QA Quality Assurance QSM Quality Systems Manager SFPO Spent Fue! Project Office UF.
Uranium Hexafluoride WI Work Instruction WSIF Work Station Inspection Form INSPECTION PROCEDURE USED 86001, " Design, Fabrication, Testing, and Maintenance of Transportation Packaging" l
l
)
i 4
t-Inspection Report Docket 999-1335 PERSONS CONTACTED The team held an entrance meeting with CBC on May 11,1998, to present the scope and objectives of the NRC inspection. On May 14,1998, the team held an exit meeting with CBC to present the preliminary findings of the inspection. The individuals present at the entrance and exit meetings are listed in Table 2.
Table 2 Persons Contacted 4
NamN '
, ' '..Ydie' ',' : ? " E:~~,',n
$mg? wl % L L YEhk E5 1'
~:s
~.
~
g
,m J.Bossone CBC, Quality Control Manager X
X X
T. Dougherty CBC, President (via telephone)
X A. Eckert CBC, Executive Vice-President of X
X
{
Manufacturing (exit via telephone) j R. Fabrizio CBC, General Manager of X
X X
Manufacturing Operations J. Jones CBC, Quality Systems Manager X
X X
T. Matula NRC, inspection Team Leader X
X X
S. McDuffie NRC, inspector X
X X
J. Reed CBC, Quality Control Assistant X
X G. Roberts NRC/INEEL, inspector X
X X
T. Rummel CBC, Vice-President X
X X.
1 l-l F'
5 L--_ _ _ __
i-i inspection Ps, cort Docket fr99-1335 l
REPORT DETAILS i
1.
Inspection Scope The team inspected CBC's management and fabrication controls regarding the fabrication of UF cylinders, Models 30B and 48Y. The purpose of the inspection was to determine if CBC's fabrication activities were performed in accordance with the requirement:s of 10 CFR Parts 21 and 71; COCs 6553,9196, and 9234; and ANSI N14.1. ANSI N14.1 requires that fabrication activities meet applicable requirements of 10 CFR Part 71, Subpart H, " Quality Assurance." The team inspected documentation, interviewed personnel, and observed activities.
2.
Management Controls 2.1 General To determine the effectiveness of the management controls, the team reviewed CBC's practices and procedures, as well as their implementation and related documentation.
The team focused on program implementation, nonconforrnance controls, documentation controls, and audit programs.
2.2 Quality Assurance Policies 2.2.1 fig 9mt The team reviewed CBC's QA authorities, responsibilities, and independence; organizational charts; graded approach to QA based on importance to safety; and commercial parts dedication program.
2.2.2 Observations and Findings The team identified a nonconformance (999-1335/98-01-01) regarding 10 CFR 71.103,
" Quality assurance organization." This section states: "The persons and organizations performing quality assurance functions shall report to a management level that assures that the required authoity and organizational freedom, including sufficient independence from cost and schedule, when opposed to safety considerations, are provided." This nonconformance has low safety significance, as the team observed no evidence that QA organizational freedom had previcusly been compromised, but the potential for future conflict of interest did exist. The team identified the following noncompliance in which
' CBC's QA organization was inadequate:
The team found that the QSM does not have sufficient independence from cost and schedule. Specifically, CBC's organization chart showed that the QSM reports only to the Executive Vice-President of Commercial Operatio is; this 6
l Inspection Report Docket 999-1335 Vice-President is responsible for controlling costs and meeting fabrication schedules.
The team had pn observation regarding 10 CFR 71.105, " Quality assurance program."
This section states: "The licensee, through its quality assurance program, shall provide control over activities affecting the quality of the identified materials and components to an extent consistent with their importance to safety."
CBC did not have a program in place for classifying components important to safety. CBC had recently revised Procedure OP-3.9, " Procurement of materials, parts, services and welding material," Revision 1, March 26,1998, which states that components may be classified at two levels of importance to safety, Categories A and B. In addition, CBC had recently revised Procedure OP-3.8,
" Vendor Selection and Approval," Revision 1, March 26,1998, to state that a commercial grade products dedication process will be in place. However, Procedures OP-3.8 and OP-3.9 do not describe the processes for classifying components or for implementing the commercial grade dedication process. CBC initiated Nonconformance Report (NCR) 12 to address the lack of component classification and commercial grade dedication procedures.
' 2.3 Nonconformance Controls 2.3.1 Sg291 The team reviewed CBC's nonconformance control program to assess the effectiveness of measures established to control materials, parts, or components that do not conform to requirements. The inspection of nonconformance controls focused on how CBC identified, segregated, tracked, and controlled nonconforming items.
The inspectors also reviewed 10 CFR Part 21 training, implementing procedures, intemal postings, supplier notifications, reporting processes, and program controls in accordance with the provisions of 10 CFR Part 21, " Reporting of Defects and Noncompliance."
2.3.2 Observations and Findinas The team identified a violation (999-1335/98-01-02) regarding 10 CFR 21.6, " Posting requirements." This section states: "Each... entity subject to the regulations in this part shall post current copies of-(i) The regulations of this part; (ii) Section 206 of the Energy Reorganization Act of 1974; and (iii) procedures adopted pursuant to the regulations in this part. These documents must be posted in a conspicuous position...
where the activities subject to this part are conducted. if posting of the regulations 'n this part or the procedures adopted pursuant to the regulations in this part is not practicable, the licensee or firm subject to the regulations in this part may, in addition to posting Section 206, post a notice which describes the regulation / procedures, including 7
I i
i
--._.-_-----____-_--.-__---_--------,---..-------_2-
]
. Inspection Report Docket 999-1335 the name of the individual to whom reports may be made, and states where they may be examined." This violation has high safety significance since establishing an effective system for reporting defects and noncompliance is critical to assuring public health and safety. The team identified the following instances in which CBC's 10 CFR Part 21 postings and training were inadequate:
CBC did not post all the documents required by 10 CFR Part 21. Specifically, CBC had three locations where Part 21 postings were required; the main office building, and fabrication Plants 1 and 3. CBC did not post any of the required Part 21 documents in the main office building and the Part 21 postings in fabrication Plants 1 and 3 were incomplete. The Part 21 postings in fabrication Plants 1 and 3 consisied of Procedure OP-9.6, "10 CFR 21 Deviations,"
Revision 0, February 2,1998, that contained only a portion of Section 206.
The team observed that CBC did not train its emphyees in the requirements of 10 CFR Part 21. Specifically, the Quality Control Manager stated that Part 21 training was provided to fabrication Plant 3 employees in February 1998; however,' CBC could not provide any documentation of training performed regarding the requirements of Part 21. The team interviewed three CBC employees in fabrication Plant 3 regarding their knowledge of the requirements of Part 21. These individuals were not aware of the Part 21 requirements. CBC initiated NCR 14, stating that all employees will be trained on 10 CFR Part 21 requirements by June 1,1998. On June 12,196d, CBC provided written.
confirmation that all employees had received Part 21 training.
The team identified a nonconformance (999-1335/98-01-03) regarding 10 CFR 71.131,
" Nonconforming materials, parts, or components." This section states: "The licensee shall establish measures to control materials, parts, or components that do not conform to the licensee's requirements to prevent their inadvertent use or installation. These
. measures must include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations. Nonconforming items must be reviewed and accepted, rejected, repaired, or reworked in accordance
- with documented procedures." This nonconformance has low safety significance. The
' team identified the following omcompliances in which CBC's control of nonconforming materials, parts, and components was inadequate:
A.
CBC did not control nonconforming material in its fabrication area. Specifically, Procedure OP-2.2, "Columbiana inspection," Revision 1, March 26,1998, states:
" Material that is unacceptable... must be rejected and information submitted to the welding supervisor for disposition." The team found two pallets of nonconforming weld wire and weld rod in the fabrication area that were not identified in CBC's nonconformance reporting system. This material was not properly controlled, dispositioned, nor secured to prevent its inadvertent use.
i k
CBC took immediate corrective action by initiating NCR 10 to facilitate appropriate disposition of this material.
L 8
j l
l t
_(
Inspection Repod Docket 999-1335 B.
CBC's QA staff did not review and approve an NCR. Specifically, CBC QA staff initiated an NCR during receipt inspection of 50 valve end couplings for Mode,I 48Y cylinders; one of the valve end couplings did not display a required heat number. The nonconforming valve end coupling was discarded, as directed by QA staff, but this disposition and final QA review / approval was not recorded on the NCR as required by OP-9.1, " Nonconforming items and Corrective Action," Revision 0, February 2,1998. CBC took immediate corrective action by completing the NCR and adding the appropriate close-out signatures to it.
C.
CBC's nonconformance control program did not document or control deficiencies or deviations identified during fabrication. Specifically, Procedure OP-9.1, states:
' Corrections made during the course of normal fabrication operations need not be repoded provided such corrections are accomplished prior to QA acceptance." The team noted that a Modei 48Y cylinder, X-ray 2116-2-2, was rejected by QA because of an unacceptable longitudinal seam weld. CBC did not document this deficiency in its nonconformance control program. CBC staff informed the team that the CBC nonconformance program does not document in-process deficiencies such as this, but rather they are tracked informally by QC until corrected. However, with no formal records of such deficiencies, CBC is unable to trend or identify any recurring fabrication problems and take corrective action. The CBC QSM stated that this information should be captured and that Procedure OP-9.1 will be revised to require documentation of deficiencies and deviations identified during in-process inspections.
'The team had an observation regarding 10 CFR 71.133, " Corrective action." This section states, "The licensee shall establish measures to assure that conditions adverse to quality... are promptly identified and corrected. In the case of a significant ' condition adverse to quality, the measures must assure that the cause of the condition is determined and corrective action taken to precluda repetition."
The team observed that Procedure OP-91, " Nonconforming items and Corrective Action," Revision 0, February 2,1998, contains only one paragraph addressing corrective action. The procedure does not adequately discuss the process for documenting significant conditions adverse to quality, the root cause(s) for the conditions, and the corrective action taken. The QSM stated that a comprehensive corrective action process needs to be developed, and that a stand-alone procedure on corrective action was being developed and would be in place befo're the end of July 1998.
2.4 Documentation Controls
--2.4.1 Staga Tiae team reviewed CBC's program for controlling quality-related documentation such as instructions, procedures, and drawings. The team examined the documents for l..
[
inspection Report Docket 999-1335 I
adequacy, approval signatures, and availability. The team also reviewed CBC's procedure development program.
2.4.2 Observations and Findinas The team had two observations regarding 10 CFR 71.113, ' Document control." This I
section states: "The licensee shall establish measures to control the issuance of documents.... These measures must assure that documents, including changes, are reviewed for adequacy, approved for release by authorized personnel, and distributed and used at the location where the prescribed activity is performed."
A.
CBC did not document any management approval on its fabrication instructions.
Specifically, Procedure OP-3.2, Revision 0, February 2,1998, states that CBC Work Instructions (Wis) shall be approved by the QSM and the relevant department manager. CBC issued 38 Wls for fabricating, testing, c!eaning, and shipping Model 30B and 48Y cylinders. The team found no approval signatures on any of the 38 Wis. CBC dccumented fabrication steps on 22 individual Work Station Inspection Forms (WSIFs). The WSIFs contain acceptance criteria such as weld preparation angles, piece measurements, and weld acceptance criteria.
The team found no approval signatures on any of the 22 WSIFs. CBC took immediate corrective action by initiating NCR 11, which addressed the requirement for approval signatures on procedures, Wis, and WSIFs.
B.
CBC does not have fabrication drawings and procedures at work stations.
l Specifically, CBC staff informed the team that on May 11,1998, all fabrication drawings and procedures for the Model 30B and 48Y cylinders we.re l
consolidated into a central locaticn in the fabrication area. Prior to this date, the drawings and procedures ware located at individual work stations. Fabrication and QC inspection personnel are required to go to the central location whenwar they needed to refer to written instructions or procedures during fabrication or inspection activities. CBC management stated that they will closely monitor the new placement of drawings and procedures to ensure that it is effective, and revert to the old placement if it is not.
2.5 -
Audit Proarams 2.5.1 Scopa The team reviewed CBC's audit program to determine whether audit plans, procedures, l
. and records were available. The inspection of the audit program focused on determining whether: (1) CBC scheduled and performed intemal QA audits and vendor audits in accordance with approved procedures or checklists, (2) qualified, independent, r
personnel performed the audits, (3) CBC managers reviewed audit results, and (4) CBC took appropriate follow up actions in those areas found deficient.
10 i
o H
Inspection Report Docket 999-1335 2.5.2 Observations and Findinas The team identified a nonconformance (999-1335/98-01-04) regarding 10 CFR 71.137,
" Audits." This section states: "The licensee shall carry out a comprehensive system of planned and periodic audits, to verify compliance with all aspects of the quality
- assurance program, and to determine the effectiveness of the program." This nonconformance has low safety significance. The team identified the following noncompliance in which CBC's audits are inadequate:
CBC had not performed any intemal or extemal (vendor) audits. CBC had identified this program deficiency prior to the inspection, and recently created and revised Procedure OP-10.0, " Auditing," Revision 1, March 26,1998, to address intemal and extemal audits. CBC had not yet implemented this procedure at the time of the inspection, but discussicas with CBC staff indicated a commitment to the new audit program. Furthermore, CBC took immediate corrective action by initiating NCR 12, which addresses extemal audits.
2.6 Conclusions on Manaaement Controls The team determined that CBC's management controls were generally acceptable.
However, several areas of CBC's management control system were not in compliance with 10 CFR part 71, Subpart H. The team identified one violation and three 4
nonconformances in this area. The lack of 10 CFR Part 21 postings and training documentation led to a violation regarding Part 21 which is considered to have high safety significance. Specific nonconformances, having low safety significance, include inadequate QSM independence from cost and schedule considerations, failure to adequately control nonconforming material, failure to document noncompliance, and failure to conduct intemal and extemr.1 audits. The team made observations regarding the absence of a procedure for classificatic9 of components, an inadequate corrective
, action procedure, missing document approval signatures, and having a centralized location for fabrication drawings and procedures rather than having them at work stations.
3.
Fabrication Controla l
3.1 General The team reviewed CBC's fabrication controls to verify that all phases of the fabrication process were properly implemented, controlled, and verifiable. The team focused on
' material procuremerit, fabrication and assembly, test and inspection, and tools and equipment.
11
Inspection Report Docket 999-1335 3.2 Material Procurement 3.2.1 Sggt The team verified that materials were controlled, verifiable, and traceable from the time of purchase through the life of the packaging by reviewing procurement documents, the receipt inspection program, material traceability and documentation, drawings and procedures, and the shelflife of safety-related components.
3.2.2 Observations and Findinas The team had an observation regarding 10 CFR 71.117, " identification and control of materials, parts, and components." This section states, "The licensee shall establish measures for the identification and control of materials, parts, and components...
These identification and control measures must be designed to prevent the use of incorrect or defective materials, parts, and components."
CBC does not have a procedure to monitor and control shelf life of specific parts or components. Specifically, CBC uses paint in the fabrication of UF. cyl5ders that is subject to shelf life control. The team observed that the paint was not identified regarding shelf life expiration and that CBC did not have a documented sheif life control procedure.
3.3 Fabrication and Assembiv 3.3.1 SG20t The team determined whether fabrication procedures were documented, approved, and implemented for each step of the fabrication process. The team also looked at whether appropriate codes, standards, and drawings were identified and implemented. The scope of the inspection of fabrication and assembly included the review of activities conceming fabrication travelers, fabrication, assembly, special processes, cleaning, and storage.
3.3.2 Observations and Findinas The team noted that CBC had a document for each cylinder fabricated that listed all of the materials used, along v.ith the associated traceability information, for the cylinder heads, shell, bonnet lugs, plugs, valves, and couplings. The team found that this document was an effective tool for identifying and documenting the material usad in fabricating each cylinder.
l The team found CBC's fabrication procedures to be adequate in that they conts!ned the
. relevant Model 30B and 48Y cylinder fabrication requirements required in ANSI N14.1.
i 12
s-Inspection Report Docket 999-1335 The team identified a nonconformance (999-1335/98-01-05) regarding 10 CFR 71.123,
" Test control." This section states: "The licensee shall establish a test program....
The test procedures must include provisions for assuring that all prerequisites for the given test are met." This nonconformance has low safety significance. The team identified the following noncompliance in which CBC's test control is inadequate:
ANSI N14.1, Paragraph 6.15.8, " Testing," states that not more than 55 foot-pounds torque shall be used to seat the valves. The application of excessive torque will damage the valves and is cause for rejection. However, in Procedures OP-4.1 and OP-4.2, the fabrication procedures for the Model 30B and 48Y cylinders, the team found no guidance to prevent excessive torquing when seating the valve.
3.4 Test and insoection 3.4.1 S.cona The team ensured that tests and inspections were controlled, verifiable, and traceable.
The team reviewed procedures and inspection records, observed work practices, interviewed personnel to determine compliance with the CBC test and inspection program, and verified that the procedures controlling testing and inspection were documented,- approved, and implemented. The team also reviewed inspection requirements, acceptance criteria, test conditions, test documentation, nondestructive examination (NDE) controls, and QA hold points.
3.4.2 Observations and Findinos The team found that CBC's test procedures and inspection records were controlled and traceable. The team determined that the hydrostatic pressure and air leak test procedures were detailed and comprehensive. In addition, all NDE qualifications of the QA staff were documented and current.
3.5 Tools and Eauicment 3.5.1 S.QQge The team ensured that procedures for the control of tools and equipment were documented, approved, and implemented. The team evak.ated the use of tools and equipment to determine whether the proper ranges and sensitivities were maintained, the necessary physical controls were in place, and the equipment calibrations were traceable to national standards for calibration. The team also examined selected calibration records and procedures for tools and gauges, as well as the traceability of specific tool use.
13 I
L__
Inspection Report Docket 999-1335 3.5.2 Observations and Findinos The team identified a nonconformance (999-1335/98-01-06) regarding 10 CFR 71.125,
" Control of measuring and test equipment." This section states: "The licensee shall establish measures to assure that tools, gauges, instruments, and other measuring and testing devices used in acLities affecting quality are properly controlled, calibrated, and adjusted at specific times to maintain accuracy within necessary limits." This nonconformance has low safety significance. The team identified the following noncompliance in which CBC's control of measuring and test equipment was inadequate:
A.
CBC did not calibrate its micrometers used for inspection and acceptance ovdi their entire range of measurement. Specifically, QA used 1-inch micrometers, over their entire measurement range, to inspect and accept components. Each day, QA staff used calibrated 0.5-inch and 1-inch measuring blocks to check these 1-inch micrometers for accuracy at these two points only. However, these two points of measurement do not verify the accuracy of the micrometers over their entire range.
B.
CBC did not identify its calibrated measuring and test equipment. Specifically, CBC could not provide any logs listing all of its calibrated measuring and test equipment nor any records indicating the calibration due dates for each piece of equipment. In addition, CBC did not place calibration stickers on any ofits measuring and test equipment except for pressure gauges and welding machines. Calibration stickers enable any worker to determine at a glance whether a specific tool ha valid calibration.
C.
ANSI N14.1, Paragraph 6.1.2, states: "The manufacturer shali measure the actual water capacity of each cylinder, and shall certify to the purchaser the wat2r weight in pounds at a temperature of 60 *F." Therefore, an accurate water temperature reading is important regard:ng this certification. CBC did not calibrate the Weksler instruments mercury thermometer used to measure water temperature during the cylinder water volume tests.
D.
CBC has no method or procedure in place to identify and evaluate previously accepted components if the measuring and test equipment, used to accept the component, is found to be defective or out of calibration.
3.6 Conclusions on Fabrication Controls The team determined that CBC's fabrication controls were generally acceptable. The team identified two nonconformances having low stfety significance regarding the control of torque used in the assembly of cylinders, as well as tool and equipment calibration. The team made an observation regarding material shelflife control.
14 i
r.
Y inspection Report Docket 999-1335 4.
Overall Conclusions 4.1 Management Controls The team determined that CBC's management controls were generally acceptable.
However, several areas of CBC's management control system were not in compliance with 10 CFR part 71, Subpart H. The team identified one violation and three nonconformances in this area. The lack of 10 CFR Part 21 postings and training documentation led to a violation regarding Part 21 which is considered to have high safety significance. Specific nonconformances, having low safety significance, include inadequate QSM independence from cost and schedule considerations, failure to adequatel' control nonconforming material, failure to document noncompliance, and y
fsilure to conduct intemal and extemal audits. The team made observations regarding -
the absence of a procedure for classification of components, an inadequate corrective action procedure, missing document approval signatures, and having a centralized location for fabrication drawings and procedures rather than having them at work
- stations.
i 4.2 Fabrication Controls The team determined that CBC's fabrication controls were generally acceptable. The team identified two nonconformances having low safety significance regarding the control of torque used in the assembly of cylinders, as well as tool and equipment calibration. The team made an observation regarding material shelf life control.
4.3 Overall Conclusions The team concluded that CBC's management controls and fabrication controls were generally acceptable and that the UF, cylinders fabricated by CBC will meet their intended safety function. However, the team identified one violation havirig high safety significance and five nonconformances having low safety significance. The team was Informed that CBC had hired a new QA Manager in March 1998 who completely j
updated CBC's QA program to comply with the requirements of 10 CFR Part 71. The team noted that CBC is currently in the process of implementing new QA procedures which, when fully implemented, will address the issues identified during this inspection.
The implementation of the updated QA program will be inspected in a future inspection.
A 5.
Exit IWeeting On May 14,1998, at the conclusion of the inspection, the team held an exit meeting with CBC staff and management to present the preliminary inspection findings. CBC's management acknowledged the inspection findings presented by the team. Additional information on 10 CFR Part 21 training was transmitted to the NRC by telephone on June 12,1998.
15