ML24071A248
| ML24071A248 | |
| Person / Time | |
|---|---|
| Site: | 99901263 |
| Issue date: | 03/14/2024 |
| From: | Kerri Kavanagh NRC/NRR/DRO/IQVB |
| To: | John Robbins Consolidated Power Supply (CPS) |
| References | |
| EPID I-2024-201-0000 IR 2024201 | |
| Download: ML24071A248 (24) | |
Text
Mr. Joe Robbins Quality Assurance Manager Consolidated Power Supply 3556 Mary Taylor Rd Birmingham, AL 35235
SUBJECT:
NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF CONSOLIDATED POWER SUPPLY NO. 99901263/2024-201, AND NOTICE OF NONCONFORMANCE
Dear Mr. Robbins:
On January 29 through February 2, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Consolidated Power Supplys (hereafter referred to as CPS) facility in Birmingham, AL. The purpose of the limited scope inspection was to assess CPSs compliance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR)
Part 21, Reporting of Defects and Noncompliance, and selected portions of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.
This technically focused inspection specifically evaluated CPSs implementation of quality activities associated with the manufacture and supply of ASME Class 1, 2, 3, and non-code safety related bars, plates, and tubes used in U.S. nuclear power plants. In addition, the NRC inspection team evaluated CPSs closure of corrective actions for the inspection findings documented in inspection report No. 99901263/2010-201, dated January 3, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML103470235). The enclosed report presents the results of this inspection. This NRC inspection report does not constitute NRCs endorsement of CPSs overall quality assurance (QA) or 10 CFR Part 21 programs.
During this inspection, the NRC inspection team found that the implementation of your QA program failed to meet certain regulatory requirements imposed on you by your customers or NRC licensees. Specifically, the NRC inspection team determined that CPS was not fully implementing its QA program in the area of Commercial-Grade Dedication. The specific finding and references to the pertinent requirements are identified in the enclosures to this letter. In response to the enclosed Notice of Nonconformance (NON), CPS should document the results of the extent of condition review for the finding and determine if there are any effects on other safety-related components.
Please provide a written statement or explanation within 30 days from the date of this letter in accordance with the instructions specified in the enclosed NON. We will consider extending the response time if you show good cause for us to do so.
March 14, 2024
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs Rules of Practice, the NRC will make available electronically for public inspection a copy of this letter, its enclosure, and your response through the NRC Public Document Room or from the NRCs ADAMS, which is accessible at http://www.nrc.gov/reading-rm/adams.html.
To the extent possible, your response should not include any personal privacy, proprietary, or Safeguards Information (SGI) so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request that such material be withheld from public disclosure, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim (e.g., explain why the disclosure of information would create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If SGI is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.
Sincerely, Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.:
99901263 EPID No.:
I-2024-201-0000
Enclosures:
- 1. Notice of Nonconformance
- 2. Inspection Report No. 99901263/2024-201 and Attachment Signed by Kavanagh, Kerri on 03/14/24
ML24071A248 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NRR/DRO/IQVB NAME DPark BAlekos AKeim FVega DATE 03/12/2024 03/12/2024 03/12/2024 03/12/2024 OFFICE NMSS/DFM/IOB NRR/DRO/IRAB NRR/DRO/IQVB NAME JTapp BHughes KKavanagh DATE 03/13/2024 03/13/2024 03/14/2024 NOTICE OF NONCONFORMANCE Consolidated Power Supply Docket No. 99901263 3556 Mary Taylor Rd Report No. 2024-201 Birmingham, AL 35235 Based on the results of a U.S. Nuclear Regulatory Commission (NRC) inspection conducted at the Consolidated Power Supplys (hereafter referred to as CPS) facility in Birmingham, AL, from January 29 through February 2, 2024, CPS did not conduct certain activities in accordance with NRC requirements that were contractually imposed upon CPS by its customers or NRC licensees:
A. Criterion III, Design Control, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, states, in part, that Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions for the structures, systems and components.
Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B to 10 CFR Part 50, states, in part, that measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery.
Section 4.2.1 of CPS Standard Procedure, SP-701, Dedication of Commercial-Grade Items, states, in part, Consolidated Power Supply cannot determine end use or safety significance of items and cannot perform the necessary evaluations for determining which individual characteristics must be verified in order to provide assurance that the dedicated item will perform its intended safety function. As a result, all chemical, mechanical, metallographic, and dimensional tests and inspections required by the material specification and customer order (and/or manufacturer's published literature if applicable) shall be considered as Critical Characteristics requiring verification during CPS dedication.
Contrary to the above, as of February 2, 2024, CPS failed to ensure the selection and review for the suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems, and components (SSC). Further, CPS failed to ensure provisions for examination of products upon delivery. Specifically, as part of the commercial-grade dedication for bar stock, channel strut, and beam materials; CPS failed to verify that certain dimensional critical characteristics such as camber, sweep, flatness, waviness, out of square, end out of square, and length of the item, conformed to the requirements in American Society for Testing and Materials (ASTM) A6, Standard Specification for General Requirements for Rolled Structural Steel Bars, Plates, Shapes, and Sheet Piling. CPS did not perform a physical measurement to verify compliance with the applicable tolerances and only performed a visual inspection to verify these critical characteristics. Adequate verification of all the critical characteristics provides reasonable assurance that the components the materials will be used for will perform their intended safety function.
This issue has been identified as Nonconformance 99901263/2024-201-01.
2 Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Chief, Quality Assurance and Vendor Inspection Branch, Division of Reactor Oversight, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a Reply to a Notice of Nonconformance and should include for each noncompliance: (1) the reason for the noncompliance or, if contested, the basis for disputing the noncompliance; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further noncompliances; and (4) the date when the corrective actions will be completed.
Where good cause is shown, the NRC will consider extending the response time.
Because your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System, which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or Safeguards Information (SGI) so that the NRC can make it available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request that such material be withheld, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If Safeguards Information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.
Dated this 14th day of March 2024.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:
99901263 Report No.:
99901263/2024-201 Vendor:
Consolidated Power Supply 3556 Mary Taylor Rd Birmingham, AL 35235 Vendor
Contact:
Mr. Joe Robbins Quality Assurance Manager Email: Joe.Robbins@consolidatedpower.com Office: (205) 228-8205 Nuclear Industry Activity:
Consolidated Power Supply (hereafter referred to as CPS) is a manufacturer and supplier of ASME Class 1, 2, 3, and non-code safety related bars, plates, and tubes used in NRC regulated facilities.
Inspection Dates:
January 29 - February 2, 2024 Inspectors:
Dong Park NRR/DRO/IQVB, Team Leader Bobby Alekos NRR/DRO/IQVB (Trainee)
Andrea Keim NRR/DRO/IQVB Frankie Vega NRR/DRO/IQVB Jeremy Tapp NMSS/DFM/IOB Approved by:
Kerri A. Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation
2 EXECUTIVE
SUMMARY
Consolidated Power Supply 99901263/2024-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a limited scope routine vendor inspection at the Consolidated Power Supplys (hereafter referred to as CPS) facility in Birmingham, AL, to verify that it had implemented an adequate quality assurance (QA) program that complies with the requirements of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, and 10 CFR Part 21, Reporting of Defects and Noncompliance. The NRC inspection team conducted this inspection on-site from January 29 - February 2, 2024. This was the third NRC inspection of CPSs facility in Birmingham, AL.
This technically focused inspection specifically evaluated CPSs implementation of quality activities associated with the CPSs manufacturing and supply of ASME Class 1, 2, 3, and non-code safety related bars, plates, and tubes used in NRC regulated facilities. In addition, the NRC inspection team evaluated CPSs closure of the inspection findings documented in inspection report (IR) No. 99901263/2010-201, dated January 3, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML103470235).
The following regulations served as the bases for the NRC inspection:
Appendix B to 10 CFR Part 50 10 CFR Part 21 During this inspection, the NRC inspection team implemented inspection procedures (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023; IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023; and IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 10, 2023.
Specific activities observed by the NRC inspection team included:
Liquid penetrant testing (PT) performed on several ASME Class 1 NB 1/2 3000# socket weld (SW) carbon steel (CS) 90 deg elbows.
Metal cutting and machining activities performed on an ASTM A36 CS 3/8 thick flat bar.
Tensile strength testing and chemical testing performed on an ASTM A36 CS 3/8 thick flat bar.
With the exception of the nonconformance described below, the NRC inspection team concluded that CPSs QA policies and procedures comply with the applicable requirements of Appendix B to 10 CFR Part 50 and 10 CFR Part 21, and that CPSs personnel are implementing these policies and procedures effectively. The results of this inspection are summarized below.
3 Design Control and Commercial-Grade Dedication (CGD)
The NRC inspection team issued nonconformance 99901263/2024-201-01 in association with CSPs failure to implement the regulatory requirements of Criterion III, Design Control, and Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B to 10 CFR Part 50. Specifically, as part of the CGD for bar stock, channel strut, and beam materials; CPS failed to verify that certain dimensional critical characteristics such as camber, sweep, flatness, waviness, out of square, end out of square, and length of the item, conformed to the requirements in American Society for Testing and Materials (ASTM) A6, Standard Specification for General Requirements for Rolled Structural Steel Bars, Plates, Shapes, and Sheet Piling.
CPS did not perform a physical measurement to verify compliance with the applicable tolerances and only performed a visual inspection to verify these critical characteristics.
Adequate verification of all the critical characteristics provides reasonable assurance that the components the materials will be used for will perform their intended safety function.
Nonconforming Materials, Parts, or Components and Corrective Action The NRC inspection team reviewed the corrective actions that CPS took to address nonconformance 99901263/2010-201-01, 99901263/2010- 201-02, and 99901263/2010-201-03 documented in IR No. 99901263/2010-201, dated January 3, 2011. The NRC inspection team reviewed the documentation that provided objective evidence for the corrective actions that were completed and verified that the corrective actions were adequately implemented.
Based on this review, the NRC inspection team closed nonconformance 99901263/2010-201-01, 99901263/2010- 201-02, and 99901263/2010-201-03.
Other Inspection Areas The NRC inspection team determined that CPS established its programs for 10 CFR Part 21, nonconforming material, parts, or components, corrective action, procurement document control and oversight of contracted activities, measuring and test equipment, material traceability, manufacturing control, and test control in accordance with the applicable regulatory requirements of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed and activities observed, the NRC inspection team also determined that CPS is implementing its policies and procedures associated with these programs. No findings of significance were identified in these areas.
4 REPORT DETAILS 1.
Design Control and Commercial-Grade Dedication a.
Inspection Scope The U.S. Nuclear Regulatory Commission (NRC) inspection team reviewed Consolidated Power Supplys (hereafter referred to as CPS) policies and implementing procedures that govern the implementation of its design control and commercial-grade dedication (CGD) program to verify compliance with the regulatory requirements of Criterion III, Design Control, and Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. The NRC inspection team also reviewed CPSs program for the utilization of unqualified source material to verify compliance with the requirements of Subparagraph NCA-4255.5, Utilization of Unqualified Source Material, of Section III, Rules for Construction of Nuclear Facility Components, of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel (B&PV) Code.
With respect to CPSs process for the utilization of unqualified source material, the NRC inspection team reviewed a sample of material certificate of conformances, receiving documents, and the supporting laboratory test reports for a 1 x 12 ASME SA479, Type 316 stainless steel round bar. The NRC inspection team confirmed that test reports included the required chemical analysis and mechanical properties testing in accordance with the material specification that was performed on each piece of material in accordance with the requirements of NCA-4255.5. The NRC inspection team also verified that the test results were consistent and from the same heat number.
The NRC inspection team reviewed a sample of CGD documents associated with the CGD of the following items and services: (1) bar stock, (2) beam, (3) channel strut, and (4) calibration services. The documents reviewed included: (1) CGD plans; (2) purchase orders (PO); (3) inspection reports; (4) commercial-grade surveys and (5) testing certificates.
The NRC inspection team evaluated CPSs process for the selection of critical characteristics and acceptance criteria, identification of verification methods, and justification of the sampling methodologies, as applicable, to verify effective implementation of CPSs CGD process. In addition, the NRC inspection team verified that commercial-grade surveys contained the objective evidence necessary to demonstrate the commercial vendors adequately controls the critical characteristics during the fabrication process or service activities.
The NRC inspection team also reviewed CPSs measures for using the International Laboratory Accreditation Cooperation (ILAC) accreditation process in lieu of performing commercial-grade surveys for the procurement of calibration and testing services as part of the CGD process. CPS implements this process as described in the Nuclear Energy Institute document No.14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial-Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, dated September 2020, which was recognized for use by the NRC
5 in a safety evaluation (SE) dated November 23, 2020 (Agencywide Documents Access Management System Accession (ADAMS) No. ML20322A019).
The NRC inspection team also discussed the design control, and CGD programs with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings During the review of a sample of CGD documents for a bar stock associated with CPS PO Z65-46010, channel strut associated with CPS PO D65-31698, beam associated with CPS PO Z65-31147, and wide flange beam associated with PO Z65-20413, the NRC inspection team noted that CPS identified all dimensional requirements from the applicable material standard as critical characteristics. The acceptance method for the verification of dimensional requirements, including camber, sweep, flatness, waviness, out of square, end out of square, and length was by tests and inspections per the applicable material standard that includes dimensional tolerances based on actual dimensions.
Section 4.2.1 of CPS Standard Procedure, SP-701, Dedication of Commercial-Grade Items, states, in part, Consolidated Power Supply cannot determine end use or safety significance of items and cannot perform the necessary evaluations for determining which individual characteristics must be verified in order to provide assurance that the dedicated item will perform its intended safety function. As a result, all chemical, mechanical, metallographic, and dimensional tests and inspections required by the material specification and customer order (and/or manufacturer's published literature if applicable) shall be considered as Critical Characteristics requiring verification during CPS dedication.
Section 4.7.1 of SP-701 states, in part, All CGI's intended for dedication shall be subjected to a standard Receiving Inspection in accordance with the latest revision of CPS Procedure SP-401." The NRC inspection team also noted that step 6.3.8 of SP-401, Receiving Inspection, Revision 13, dated December 2023, states, in part,
[p]erform dimensional inspection of the items and verify the results conform to specified requirements. Record the lowest and highest readings observed (LOW / HIGH) for each attribute of each line item on Form 401. However, the NRC inspection team identified that CPS was only performing a visual inspection rather than a physical measurement to verify the above critical characteristics were acceptable and documenting the result as OK on the receipt inspection record.
Specifically, as part of the CGD for bar stock, channel strut, and beam materials; CPS failed to verify that certain dimensional critical characteristics such as camber, sweep, flatness, waviness, out of square, end out of square, and length of the item, conformed to the requirements in American Society for Testing and Materials (ASTM) A6, Standard Specification for General Requirements for Rolled Structural Steel Bars, Plates, Shapes, and Sheet Piling. CPS did not perform a physical measurement to verify compliance with the applicable tolerances and only performed a visual inspection to verify these critical characteristics. Adequate verification of all the critical characteristics provides reasonable assurance that the components the materials will be used for will perform their intended safety function.
6 The NRC inspection team identified this issue as Nonconformance 99901263/2024-201-01 for CPSs failure to ensure the selection and review for the suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSC and provisions for examination of products upon delivery. CPS initiated Corrective Action Reports (CAR) No. I24-3 to address this issue.
c.
Conclusion The NRC inspection team issued Nonconformance 99901263/2024-201-01 for CPSs failure to implement the regulatory requirements of Criterion III and Criterion VII of Appendix B to 10 CFR Part 50. Nonconformance 99901263/2024-201-01 cites CPS for failing ensure the selection and review for the suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the SSC and provisions for examination of products upon delivery. With the exception of Nonconformance 99901263/2024-201-01, the NRC inspection team concluded that CPS is implementing its CGD program in accordance with the regulatory requirements of Criterion III and Criterion VII of Appendix B to 10 CFR Part 50. No other findings of significance were identified.
2.
10 CFR Part 21 Program a.
Inspection Scope The NRC inspection team reviewed CPSs policies and implementing procedures that govern the implementation of its 10 CFR Part 21, Reporting of Defects and Noncompliance, program to verify compliance with the regulatory requirements. In addition, the NRC inspection team evaluated the 10 CFR Part 21 postings and a sample of CPSs POs for compliance with the requirements of 10 CFR 21.21, Notification of Failure to Comply or Existence of a Defect and its Evaluation, and 10 CFR 21.31, Procurement Documents. The NRC inspection team also verified that CPSs nonconformance and corrective action procedures provide a link to the 10 CFR Part 21 program.
The NRC inspection team also discussed the 10 CFR Part 21 program with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CPS is implementing its 10 CFR Part 21 program in accordance with the regulatory requirements of 10 CFR Part 21. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CPS is implementing its policies and procedures associated with the 10 CFR Part 21 program. No findings of significance were identified.
7 3.
Procurement Document Control and Supplier Oversight a.
Inspection Scope The NRC inspection team reviewed CPSs policies and implementing procedures that govern the implementation of its supplier oversight program to verify compliance with the requirements of Criterion IV, Procurement Document Control, and Criterion VII of Appendix B to 10 CFR Part 50. The NRC inspection team reviewed a sample of POs, CPSs Approved Vendors List (AVL), supplier audit reports, and annual evaluations.
For a sample of POs reviewed, the NRC inspection team verified that the POs included, as appropriate, the applicable technical and quality requirements. For the sample of audits reviewed, the NRC inspection team verified the audit reports included an audit plan, any findings identified, adequate documented objective evidence of compliance with the applicable requirements, and a review by CPSs responsible management. The NRC inspection team verified that the audits were performed by qualified auditors.
Furthermore, the NRC inspection team reviewed the training and qualification records of lead auditors and auditors and confirmed that auditing personnel had completed all the required training and had maintained the applicable qualification in accordance with CPSs procedures.
The NRC inspection team also discussed the procurement document control and supplier oversight program with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CPS is implementing its procurement document control and supplier oversight program in accordance with the regulatory requirements of Criterion IV and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CPS is implementing its policies and procedures associated with the supplier oversight program. No findings of significance were identified.
4.
Material Traceability a.
Inspection Scope The NRC inspection team reviewed CPSs policies and implementing procedures that govern the implementation of its material traceability program to verify compliance with the regulatory requirements of Criterion VIII, Identification and Control of Materials, Parts, and Components, of Appendix B to 10 CFR Part 50.
The NRC inspection team performed a walk-down of the following areas at CPSs manufacturing facility: receipt and final inspection, fabrication and storage, testing, and nonconforming material storage. The NRC inspection team also observed
8 implementation of the material traceability program by CPSs employees during in-process fabrication activities including metal cutting, machining, testing, storage and inventory control. The NRC inspection team verified that all materials inspected were adequately marked with appropriate lot, batch and/or heat numbers using the markings and labeling conventions in accordance with written procedures. The NRC inspection team confirmed that materials were adequately identified with CPSs unique identification code, which is traceable to the POs and vendor certification reports. The NRC inspection team verified that CPSs personnel appropriately maintained the material identification and traceability markings during various stages of fabrication and testing.
The NRC inspection team also discussed the material identification and control program with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CPS is implementing its material traceability program in accordance with the regulatory requirements of Criterion VIII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CPS is adequately implementing its policies and procedures associated with the material traceability program. No findings of significance were identified.
5.
Control of Special Processes
- a. Inspection Scope The NRC inspection team reviewed CPSs policies and implementing procedures that govern the implementation of its control of special processes program to verify compliance with the regulatory requirements of Criterion IX, Control of Special Processes, of Appendix B to 10 CFR Part 50 and with the applicable requirements of Section III and Section V, Nondestructive Examination, of the ASME B&PV Code, and the American Society for Nondestructive Testing (ASNT) SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing.
During the week of the inspection, nondestructive examination (NDE) activities were performed by CPS. Specifically, liquid penetrant testing (PT) was performed on several ASME Class 1 NB 1/2 3000# socket weld (SW) carbon steel (CS) 90 Deg elbows destined for a U.S. nuclear power plant. The NRC inspection team witnessed the application and removal of the liquid penetrant, the drying of the treated surface, the application of dry developer, the surface examination and acceptance of the parts. The NRC inspection team confirmed that the examination was performed in accordance with the applicable CPSs procedures and met the applicable requirements of Section V of the ASME B&PV Code. The NRC inspection team verified that the NDE inspector used calibrated equipment that was within the applicable inspection range. In addition, the NRC inspection team reviewed the Level II inspector qualifications and training records
9 and confirmed that the inspector had completed the required training and had maintained his qualifications in accordance with the applicable CPSs procedures. The NRC inspection team confirmed that the NDE personnel were qualified in accordance with the requirements of ASNT SNT-TC-1A.
Also, during the week of the inspection, the NRC inspection team witnessed metal cutting and machining activities associated with a carbon steel flat bar. These activities were performed as part of the dedication process which required a test specimen from such material for a tensile strength test. The inspection team verified that cutting and machining activities were performed in accordance with CPSs procedures and samples were machined and prepared for testing in accordance with CPSs procedures and met applicable ASTM requirements.
The NRC inspection team also reviewed the training and qualification records of the inspection and test personnel performing the activities described above and confirmed that they had completed the required training and had maintained their qualifications in accordance with the applicable CPSs procedures.
The NRC inspection team also discussed the control of special processes program with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.
- b. Observations and Findings The NRC inspection team observed one minor issue while exercising a test specimen from 1/2 x 12 flat bar. It was observed that the Lab Technician removed the specimen in the transverse direction when the longitudinal direction was required. This condition was identified prior to the machining of the actual specimen and prior to any testing. The NRC inspection team assessed that this issue was of minor safety significance as the issue was identified by a CPS observer, in-process. Also, based on discussions with the QA manager, Laboratory Supervisor and Laboratory Technician, this issue appears to be isolated, and is not recurring, nor is it indicative of a programmatic issue. CPS opened CAR I24-2 to document this issue.
c. Conclusion
The NRC inspection team concluded that CPS is implementing its control of special processes program in accordance with the regulatory requirements of Criterion IX of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CPS is implementing its policies and procedures associated with the control of special processes program. No findings of significance were identified.
6.
Test Control
- a. Inspection Scope The NRC inspection team reviewed CPSs policies and implementing procedures that govern the implementation of its test control program to verify compliance with the requirements of Criterion XI, Test Control, of Appendix B to 10 CFR Part 50.
10 The NRC inspection team witnessed tensile strength testing and chemical testing associated with an ASTM A36 carbon steel flat bar. The NRC inspection team witnessed CPSs processes for receiving and preparing the testing sample, setting up testing equipment and performing the tensile strength and chemical testing and recording test results. The NRC inspection team discussed the process with the test and laboratory technician and confirmed that these activities were performed following CPSs procedures.
The NRC inspection team verified that CPSs test procedures adequately included the applicable technical, quality, and regulatory requirements. The NRC inspection team also reviewed the training and qualification records of the test and laboratory technicians performing the test and confirmed that testing personnel had completed all the required training and had maintained the applicable qualification and certification in accordance with CPSs policies and procedures. The NRC inspection team also confirmed that the following testing elements were satisfied, verified, and recorded, as appropriate: (1) test parameters and initial conditions, (2) test acceptance criteria, (3) test prerequisites, (4) test instrument range, accuracy, and uncertainty appropriate for the test; (5) current calibration, and (6) any deviations documented and evaluated. The NRC inspection team also reviewed the test records for the completed tensile and chemical tests and confirmed that all the test requirements had been met.
The NRC inspection team discussed the test control program with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.
- b. Observations and Findings No findings of significance were identified.
c. Conclusion
The NRC inspection team concluded that CPS is implementing its test control program in accordance with the regulatory requirements of Criterion XI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CPS is adequately implementing its policies and procedures associated with the test control program. No findings of significance were identified.
7.
Control of Measuring and Test Equipment (M&TE) a.
Inspection Scope The NRC inspection team reviewed CPSs policies and implementing procedures that govern the implementation of its M&TE program to verify compliance with the requirements of Criterion XII, Control of Measuring and Test Equipment, of Appendix B to 10 CFR Part 50.
For a sample of M&TE, the NRC inspection team determined that the M&TE had the appropriate calibration stickers and current calibration dates, including the calibration due date. The NRC inspection team also verified that the M&TE had been calibrated,
11 adjusted, and maintained at prescribed intervals prior to use. In addition, the calibration records reviewed by the NRC inspection team indicated the as-found or as-left conditions, accuracy required, calibration results, calibration dates, and the due date for recalibration. Furthermore, the NRC inspection team verified that the selected M&TE was calibrated using procedures traceable to known industry standards. The NRC inspection team confirmed that when M&TE equipment is found to be out of calibration, CPS proceeds to identify items that have been accepted using this equipment since the last valid calibration date and performs an extent of condition review.
The NRC inspection team also discussed M&TE program with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.
b.
Observations and Findings No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CPS is implementing its M&TE program in accordance with the regulatory requirements of Criterion XII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CPS is adequately implementing its policies and procedures associated with the Control of M&TE program. No findings of significance were identified.
8.
Nonconforming Materials, Parts, or Components and Corrective Action a.
Inspection Scope The NRC inspection team reviewed CPSs policies and implementing procedures that govern the control of nonconformances to verify compliance with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50.
The NRC inspection team verified that CPSs processes and procedures provide for the identification, documentation, segregation, evaluation, and disposition of nonconforming items. Nonconformances could be dispositioned as Repair, Scrap, Use-As-Is, or Return to Vendor.
The NRC inspection team reviewed a sample of Nonconforming Reports (NCRs) and verified that CPS: (1) dispositioned the NCRs in accordance with the applicable procedures; (2) documented an appropriate technical justification for the selected disposition; and (3) took adequate corrective action regarding the nonconforming items, as applicable.
The NRC inspection team also reviewed a sample of CARs and verified that the CARs contained: (1) adequate documentation and description of conditions adverse to quality; (2) an appropriate analysis of the cause of these conditions and the corrective actions taken to prevent recurrence; (3) direction for review and approval by the responsible authority to verify timely and effective implementation of the corrective actions.
12 The NRC inspection team reviewed CPSs corrective actions in response to the inspection findings identified in the NRCs Inspection Report (IR) No. 99901263/2010-201, dated January 3, 2011 (ADAMS Accession No. ML103470235).
The NRC inspection team also discussed the nonconforming materials, parts, or components and corrective action programs with CPSs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.
b.
Observations and Findings 1.
Corrective Action Associated with Nonconformance 99901263/2010-201-01 Following the November 2010 inspection of CPS, the NRC issued Nonconformance 99901263/2010-201-01 for CPSs failure to adequately prescribe its CGD process by appropriate procedures. Specifically, CPS failed to properly identify certain dimensional verifications on as-shipped items in dedication plans. In addition, CPS failed to document the identification of critical characteristics when dedication was performed in conjunction with ASME Code material upgrades.
In its response to the NRC, dated January 28, 2011, (ADAMS Accession No. ML1100330053) CPS opened CAR I10-20 to address procedure changes to SP-716 "Utilization of Unqualified Source Material" and SP-701 "Dedication of Commercial-Grade Items". The NRC inspection team reviewed the documentation that provided the objective evidence for the completion of the corrective actions. Based on its review, the NRC inspection team closed Nonconformance 99901263/2010-201-01.
2.
Corrective Action Associated with Nonconformance 99901263/2010-201-02 The NRC also issued Nonconformance 99901263/2010-201-02 for CPSs failure to prescribe appropriate quantitative or qualitative acceptance criteria for determining that the calibration of the optical emission spectrometer had been appropriately accomplished for each element. Specifically, CPS failed to perform the required sample testing to calculate the acceptance criterion for each constituent and to include the calculated acceptance criteria in instructions, procedures, or drawings.
In its response to the NRC, dated January 28, 2011, (ADAMS Accession No. ML1100330053) CPS stated that all laboratory personnel have been trained to the requirements of the revised procedure, SP202, Revision 35. This training was performed on 12/13/2010 and 1/6/2011. In accordance with SP202, Revision 35, Form 202K, "Spectrometer Acceptance Criteria Reference Sheet" will be utilized to document the established acceptance criteria for each method and check standard/verifier utilized. A completed Form 202K will be maintained with the Certificate of Analysis for each check standard/verifier utilized for QC checks. CPS opened CAR I10-22 to address this nonconformance. The NRC inspection team reviewed the documentation that provided the objective evidence for the completion of the corrective actions. Based on its review, the NRC inspection team closed Nonconformance 99901263/2010-201-02.
3.
Corrective Action Associated with Nonconformance 99901263/2010-201-03
13 The NRC also issued Nonconformance 99901263/2010-201-03 for CPSs failure to identify deviations as part of its corrective action process. Specifically, multiple examples of CPS Nonconformance reports failed to identify deviations despite describing nonconformances that departed from the technical requirements in the purchasers procurement documents.
In its response to the NRC, dated January 28, 2011, (ADAMS Accession No. ML1100330053) CPS stated that Procedure SP-601 "Identification, Evaluation, and Reporting of Defects and Failure to Comply" was revised to accomplish the following:
- 1. Reinstate the requirements of Section 21.21 (a) including evaluation and reporting timelines, report format/contents, and the communications requirements of section 21.5; and add the requirement for documenting the basis when it is concluded that a nonconforming condition does not constitute a Deviation or failure to comply as defined in 10 CFR Part 21.
CPS opened CAR I10-21 to address this nonconformance. The NRC inspection team reviewed the documentation that provided the objective evidence for the completion of the corrective actions. Based on its review, the NRC inspection team closed Nonconformance 99901263/2010-201-03.
No findings of significance were identified.
c.
Conclusion The NRC inspection team concluded that CPS is implementing its nonconforming materials, parts, or components and corrective action programs in accordance with the regulatory requirements of Criterion XV and Criterion XVI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that CPS is implementing its policies and procedures associated with the control of nonconforming materials, parts, or components and corrective action. No findings of significance were identified.
9.
Entrance and Exit Meetings On January 29, 2024, the NRC inspection team discussed the scope of the inspection during an entrance meeting with Mr. Joe Robbins, and other members of CPSs management and technical staff. On February 2, 2024, the NRC inspection team presented the inspection results and observations during an exit meeting with Mr. Robbins and other members of CPSs management and technical staff. The attachment to this report lists the attendees of the entrance and exit meetings, as well as those individuals whom the NRC inspection team interviewed.
14 ATTACHMENT 1.
ENTRANCE/EXIT MEETING ATTENDEES Name Title Affiliation Entrance Exit Interviewed Bill Henke Director Consolidated Power Supply (CPS)
X X
CJ Zeitvogel General Manager CPS X
X Joe Robbins Quality Assurance Manager CPS X
X X
Tom Gullo Lab Supervisor CPS X
X X
Randy Burns Lab Technician CPS X
Bryan Parnell Assistant Quality Assurance Manager CPS X
X X
Adam Chizmar Quality Assurance Manager -
Fabrication CPS X
X Erik Rasky Project Engineer CPS X
Nadya Heppenstall Project Engineer CPS X
Jeff Diurba General Manager -
Fabrication CPS X
X Russell Felts Director, Division of Reactor Oversight Nuclear Regulatory Commission (NRC)
X Kerri A. Kavanagh Branch Chief, Quality Assurance and Vendor Inspection Branch NRC X
Dong Park Inspection Team Leader NRC X
X Bobby Alekos Inspector NRC X
X Andrea Keim Inspector NRC X
X
15 Name Title Affiliation Entrance Exit Interviewed Frankie Vega Inspector NRC X
X Jeremy Tapp Inspector NRC X
X
- Remote 2.
INSPECTION PROCEDURES USED Inspection Procedure (IP) 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 10, 2023 IP 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023 IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023 3.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description 99901263/2010-201-01 CLOSED NON Criterion V 99901263/2010-201-02 CLOSED NON Criterion V 99901263/2010-201-03 CLOSED NON Criterion XVI 99901263/2024-201-01 OPEN NON Criterion III and VII 4.
DOCUMENTS REVIEWED Policies and Procedures Quality Assurance Manual for Nuclear Materials, 1st Edition, Revision 3, dated December 1, 2023 Standard Procedure and Forms Index, Revision 12/29/2023 List of materials supplied to Part 72 customers for spent fuel storage applications since 2021 SP-201, Control of Measuring and Test Equipment, Revision 12, dated December 2023 SP-202, "Calibration and Maintenance of Measuring and Test Equipment," Revision 47, dated December 2023 SP-301, Handling and Storage of Items, Revision 8, December 2023 SP-401, Receiving Inspection, Revision 13, December 2023 SP-403, Final Inspection, Revision 10, issued March 2007 SP-405, Nonconformances, Revision 17, dated December 2023 SP-406, Identification and Control of Cut Codes, Revision 9, February 9, 2023 SP-409, Evaluation for Suspect/Counterfeit Items and Certification, Revision 3, dated March 2023
16 SP-501, Qualification and Certification of Lead Audit Personnel, Revision 6, issued December 2023 SP-503, Qualification and Certification of Inspection Personnel, Revision 4, issued July 2000 SP-504 Qualification of CPS Inspection and Test Personnel in accordance with NQA-1 Appendix 2A-1 and ANSI N45.2.6, dated December 2023 SP-601, Identification, Evaluation, and Reporting of Defects and Failure to Comply, Revision 11, dated May 2021 SP-701, Dedication of Commercial-Grade Items, Revision 14, dated September 2011 SP-703, Chemical Testing, Revision 19, dated December 2022 SP-704, Hydrostatic Testing, Revision 7, dated April 2007 SP-705, Bend Test Procedure, Revision 5, dated June 2006 SP-706, Tensile Testing, Revision 12, dated September 2023 SP-716, Utilization of Unqualified Source Material, Revision 11, dated December 2023 SP-738 Pre-Test configuration and dimensional verification of machined tensile test specimens, Rev 0, dated June 2023 SP-739 Operation of the HAAS VF3 CNC mill to prepare ASTM A370/E8 Standard Sheet-Type Specimens having a 1/2 wide reduced section, Rev 0, dated June 2023 SP-802, Vendor Survey/Audits, Revision 14, issued September 2023 SP-804, Source Surveillance/Verification Activities, Revision 5 issued September 2011 SP-805, Performance Assessments, Revision 5, issued December 2023 SP-806, Acceptance of Recognized Accreditation for Suppliers of Subcontracted Calibration, Revision 9, issued December 2023 SP-807, Commercial-Grade Surveys, Revision 3, issued September 2023 SP-808, Annual Vendor Evaluations, Revision 3, issued December 2023 SP-901, NDE Personnel Qualification and Certification Written Practice, Revision 13 February 2023 SP-915, Liquid Penetrant Examination of Bars, Tubular Products, Forgings, and Fittings for ASME Sect III Applications, Revision 22 December 2021 Purchase orders (POs) and sales orders CPS Sales order # 6530902 CPS Sales order 6530895, reducer, stainless steel, F304, ASME SA182, Size 1, female socket weld CPS sales order 6530897, sockolet: 4X2, 3000#, forged, 316 or 316L, ASME SA 182, socket weld CPS Sales order 6540082 CPS Sales order 6511310 PO # 02453325, dated March 6, 2023 PO C1010271, dated January 17, 2024 PO 10339825, dated January 20, 2024, (bar, flat, 1/2, ASTM A-36 carbon steel)
PO 10339825, dated November 22, 2022 (bar, flat, 1/4, 12 ASTM A-46 carbon steel)
PO Z65-46010
17 PO Z65-16048 PO X-174428, Calibration Services, pressure gages, dated October 13, 2023 PO X-17438, 17025 Calibration Services Tinius Olsen, dated December 27, 2023 Testing records and inspection reports Liquid penetrant inspection report associated with purchase order C1010271 - 1/2 3000lb SWCS 90 Deg Elbow, dated January 31, 2024 Receiving inspection report for Z65-21753, dated January 19, 2023 Certification of Hydrostatic Test, Item # 600342, 3/4 S/80 CF SMLS Pipe, August 29, 2018 Test report certification for order number S6582104 Receiving Inspection Record for PO Z65-46010, dated January 22, 2024 Receiving Inspection Record for PO Z65-16048, dated February 26, 2021 Final Inspection Record for PO Z65-16048, dated March 4, 2021 Liquid Penetrant Inspection Report associated with purchase order Z65-16048 - 1 ASME SA479 Type 316 stainless steel round bar, dated February 26, 2021 Ultrasonic Inspection Record for Longitudinal Wave and Back Reflection Set-Ups associated with purchase order Z65-16048 - 1 ASME SA479 Type 316 stainless steel round bar, dated February 26, 2021 Design and Commercial-Grade Dedication Records Dedication Plan for 1x4x20 bar stock, ASTM A36 steel, dated January 10, 2024 Class A Code Upgrade Dedication Plan for 1x12 round bar to ASME SA479 Type 316 stainless steel, dated February 26, 2021 Dedication Plam for Beam, Carbon Steel, W4X13(20RL) ASTM A6/A36, dated March 3, 2023 Dedication Plan 6x6x3/8 CS Angle (20 ft RL), dated March 4, 2023 Dedication Plan DP-806-1, Commercial Grade Item Dedication Plan - Dedication of Calibration Service Accepted on the Basis of ISO/IEC 17025 Accreditation, Revision 1, dated December 27, 2023 Technical Evaluation TE-8-6-1, Commercial Grade Item Dedication Calibration Services, Revision 1, dated May 25, 2021 Calibration and Test Records Certificate of Calibration #1097.01, dated September 5, 2023 (meter light)
Certificate of Calibration CPS001-21-04-01582-4, dated April 26, 2021 (digital surface thermometer)
Certificate of Calibration CPS001-21-04-01577-2, dated April 19, 2021 (cal blocks)
Certificate of Calibration CPS001-22-08-03778-1, dated September 8, 2022 (ca blocks)
Form 202G, Caliper Calibration Record, dated September 30, 2023 (QA-727 caliper)
Form 202, Calibration Record, dated September 30, 2023 (QA-606)
18 Supplier Oversight Records Approved Vendors List dated January 26, 2024 2024 Survey/Audit Schedule, dated November 9, 2023 CPS-2022 Commercial Grade Survey Newman Flange and Fitting Annual Vendor Evaluation for Newman Flange and Fitting, dated September 29, 2023 CPS-2023 Audit of Western Forge and Flange, dated October 3, 2023 Annual Vendor Evaluation for Western Forge and Flange, dated September 21, 2023 CPS-2022 Audit of Global Quality Assurance, dated March 29, 2022 CPS-2023 Annual Evaluation for Global Quality Assurance, dated March 16, 2023 CPS-2022 Commercial Grade Survey of Triad Metals, dated October 13, 2022 Annual Vendor Evaluation for Triad Metals, dated November 17, 2023 Receiving Inspection Report for PO X-17438, dated January 19, 2024 CPS-2021 Audit of ASME supplier: Swepco Tube, dated February 22, 2021 Annual Vendor Evaluation of Swepco, dated January 5, 2024 CPS-2022 Audit of ASME supplier: Trust Manufacturing, dated September 26, 2023 Annual Vendor Evaluation of Trust Manufacturing, dated August 23, 2023 Nonconformance Records List of Nonconformance Reports (NCRs) from 2021, 2022, and 2023 NCR 21-1, issued January 5, 2021 NCR 21-28, issued April 20, 2021 NCR-21-29, issued April 23, 2021 NCR-22-13, issued March 23, 2022 NCR-23-12, issued February 9, 2023 NCR-23-14, issued February 27, 2023 NCR-23-66, issued November 28, 2023 NCR 23-1, dated January 19, 2023 NCR 24-2, dated January 31, 2024 (material failed PT exam during our inspection)
Corrective Action Records List of Corrective Action Reports (CARs) from 2021, 2022, and 2023 I10-20, issued November 19, 2010 I10-21, issued November 19, 2010 I10-22, issued November 19, 2010 I21-1 issued April 13, 2021 I21-2, issued April 20, 2021 I22-1, issued March 23, 2022 I22-7, issued December 22, 2022 I22-8, issued December 22, 2022 I22-9, issued December 22, 2022
19 I22-10, issued December 22, 2022 I23-3, issued February 10, 2023 Corrective Action Requests Opened During the NRC Inspection I24-1, issued February 1, 2024 I24-2, issued January 31, 2024 I24-3, issued February 1, 2024 Material Certification Reports CPS material certification for PO 02453325, elbow, 90 degrees, 2 ASME SA182 CPS material certification for PO 02453325, dated March 14, 2023, pipe, 304 SS ASTM SA312/SA376, Schedule 80 S, Seamless, 3/4 17-24 CPS material certification for PO 02453325, reducer, stainless steel, F304, ASME SA182, Size 1X3/4, female socket weld CPS material certification report for PO 02453325, sockolet: 4X2, 3000#, forged, 316 or 316L, ASME SA 182, socket weld, dated April 13, 2023 CPS material Certification for PO 02453325, Pipe, 304 SS, ASME SA312/SA376, Schedule 80S, Seamless, 3/4 17-24 RL Certified Material Test Report (CMTR) associated with CPS Purchase order Z65-41021, dated January 31, 2024 CMTR CPS item number 600342, 3/4 S/80 CF SMLS Pipe, dated August 23, 2018 CMTR associated with 10339825 dated January 4, 2023 CMTR associated with CPS Lab # 24-0048 for ASTM A36 steel, dated January 29, 2024 CMTR associated with CPS Lab # 24-0049 for ASTM A36 steel, dated January 29, 2024 CMTR associated with CPS Lab # 24-0050 for ASTM A36 steel, dated January 29, 2024 CMTR associated with CPS Lab # 21-0150 for ASME SA479 Type 316 stainless steel, dated March 3, 2021 CMTR associated with CPS Lab # 21-0151 for ASME SA479 Type 316 stainless steel, dated March 3, 2021 CMTR associated with CPS Lab # 21-0152 for ASME SA479 Type 316 stainless steel, dated March 3, 2021 CMTR associated with CPS Lab # 21-0153 for ASME SA479 Type 316 stainless steel, dated March 3, 2021 Training and Qualification Records NDE Personnel Qualification Record - Gary S. Fields (NDE Level II)
Training and Qualification record - Jeff Hodge (Operations Manager)
Training and Qualification Record - Randy Burns (Laboratory Technician Level II)
Training and Qualification - Thomas E. Gullo (Laboratory Technician Level III)
Training and Qualification - Kelvin Spivey (Inspector, Level II)
Lead Auditor Qualification - Latia Gary Lead Auditor Qualification - R.J. Rehkugler