ML20202J296

Ack Receipt of 980624 Ltr Which Apprised NRC of Results of Third Party Evaluation of Dedication Process Which Goulds Pumps,Inc Employs to Dedicate Commerical Grade Items for NPP Safety Related Use

ML20202J296
Person / Time
Issue date:	02/04/1999
From:	Correia R NRC (Affiliation Not Assigned)
To:	Sakofsky S GOULDS PUMPS, INC.
References
REF-QA-99900732 99900732-97-01, 99900732-97-1, NUDOCS 9902090093
Download: ML20202J296 (7)

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k UNITED STATES j

g ( NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20666 4 001-L-  %., February 4, 1999 l

. Mr. Stephen Sakofsky, Director

~ Quality A.aurance M Industrial Products Group h Goulds Pumps, incorporated b( 240 Fall Street Seneca Falls, New York 13148 i

SUBJECT:

Goulds Pumps, Incorporated Responses to NRC Inspection Report ,

No. 99900732/97-01 '

Dear Mr. Sakofsky:

Thank you for your June 24,1998, letter which apprised us of the results of a third party evaluation of the dedication procers which Goulds Pumps, incorporated (Goulds) employs to

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dedicate commercial grade items for nuclear power plant safety related use. Your letter also requested the NRC staff to reconsider its inspection Report findings because you believe that it is appropriate for Goulds to continue its current dedication process "as agreed to by [its) ,

. customers."  !

In.your January 8,1998, response letter and " Reply to Notice of Nonconformance 99900732/97-01-01," Goulds committed to have a third party entity evaluate its dedication process. We have reviewed the Thielsch Engineering, Cranston, Rhode Island, Report 7842 (Evaluation Report 7842), in conjunction with the original NRC Inspection Report and your January 8,1998, response. Our review of Evaluation Report 7842 did not identify information f '

about the Goulds program, or its implementation, that would lead us to modify the position stated in our inspection report,

'o Further, as a result of our review of Evaluation Report 7842, the staff continues to have concerns regarding the adequacy of your dedication process. Enclosure 1 is attached for your information, and identifies areas noted during our review of Evaluation Report 7842 where the NRC staff takes exception, or where a disparity exists between information obtained by our staff during and subsequent to the October 2-3,1997, inspection and what was stated in Evaluation Report 7842. ^

Additionally, it is our understanding that you have informed the NUPIC organization that Goulds

. .is no longer supplying products under its ASME Section lli Certificate of Authorization or its

[10 CFR Part 50, Appendix B Quality Assurance Program Nonetheless, Goulds must continue

\ to implement its 10 CFR Part 21 program for any material, pumps, parts or assemblies that were

provided under its 10 CFR Part 50, Appendix B QA program, especially the provisions of 921.21,fNotification of failure to comply or existence of a defect and its evaluation." and $21.51,

' " Maintenance and inspection of records." We also wish to point out that " dedication" activities, as defined in $21,3, of 10 CFR Part 21, must be conducted in accordance with the applicable '

provisions of 10 CFR Part 50, Appendix B.

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s -4 Mr. Stephen Sakofsky In summary, the NRC staff remains concerned that the Goulds dedication process has not been implemented consistently with 10 CFR Part 50, Appendix B and industry guidance such as the Electric Power Research Institute paper, EPRI NP-5652, " Guideline for the Utilization of Commercial Grade items on Nuclear Safety Related Applications (NCIG-07)," (as conditionally accepted by NRC staff).

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC's Public Document Room (PDR). If you or your staff have any questions regarding this matter or your 10 CFR Part 21 responsibilities, we will be pleased to discuss them with you. Please contact Mr. Joseph Petrosino at (301) 415-2979, if you have any questions or need assistance regarding this matter.

Sincerely,

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Richard P. Correia, Acting Chief Quality Assurance, Vendor Inspection and Maintenance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket 99900732/97-01

Enclosures:

1. NRC Staff Discussion

2. NRC Inspection Report 99901323/97-01 i

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b G NRC STAFF COMMENTS ON THIELSCH ENGINEERING REPORT 7842 The following narrative provides examples of where the NRC staff has taken exception to certain parts of Evaluation Report 7842, or where differences exist between Report 7842 and what was stated to NRC staff during its inspection activities. The examples in this enclosure -

are not intended to be inclusive of all disparities and aspects where the NRC staff did not agree with the report.

4 The NRC staff notes that Report 7842 generally provides sound discussion and methodology regarding a dedication program that would satisfy the requirements and guidance contained in 4

10 CFR Part 50, Appendix B,10 CFR Part 21, and industry guidance.

DISCUSSION l

1. Page 3," Requirements of 10 CFR Part 21," bottom paragraph, of Report 7842, states 1 that "Goulds Pumps, as a minimum, would have to determine the critical characteristics l

of that item, and inspect the item to verify that the critical characteristics comply with the j l requirements of the applicable specifications. If necessary, Goulds Pumps would have to supplement the verification of critical characteristics by commercial grade surveys, l

product inspections at the manufacturer's facility, and/or analysis of historical records for  !

. acceptable performance."

The NRC staff notes that the critical characteristics that are necessary to verify for a particular component may vary because the specific plant applications for that component must be considered. As discussed in the NRC inspection report, l licensees procuring components from Goulds may typically specify critical \

characteristics in their Purchase Orders (POs). The POs identified ASTM l material types which Goulds indicated were verified as documented in Goulds l i- certificates of compliance. The requisite chemical composition levels of Carbon,  !

Silicon, Phosphorus or Sulfur were not verified according to Goulds personnel for CGI dedications for the past ten years.

2. Page 4, " Review of Practices Followed by Goulds Pumps in Dedicating Commercial l Grade items," second paragraph, of Report 7842, states "the Manager of Engineering I

Systems and Standards and the Manager of Quality Assurance evaluate the pump or

. pump part in question and identify the critical characteristic of that item. The Manager of Quality Assurance then establishes the inspections and tests necessary to verify these critical characteristics. The tests are then performed and the results documented. A l certificate of Conformance is then issued, and the dedication is complete. Section 5(a) of Goulds Pumps QCP-187 states that these characteristics are those shown on Goulds and/or Manufacturers drawings and order requirements.

As discussed in the subject Inspection report, the inspector identified that contrary to licensee purchase order requirements, Goulds did not typically verify all of the material chemical composition elements. However, the associated l Goulds Pumps cerfificates of compliance stated that the components met all 1

ENCLOSURE i

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i contractual requirements. Therefore, Goulds dedication process was not being implemented as stated above and was not accomplished in accordance with program requirements. l l

3. Page 4, " Review of Practices Followed by Goulds Pumps in Dedicating Commercial l Grade items," fourth paragraph, of Report 7842, states: "This manual describes the l quality assurance system under which commercial grade items are either designed and l manufactured at Goulds Pumps, or purchased by Goulds Pumps . With respect to the purchase of commercial grade items, one provision of QAM-1001 should be noted.

This involves paragraph 8.4 which outlines the policy by Goulds Pumps with respect to

source inspections. It states that source inspection at the subcontractor's facility is specified on the purchase documents when required. Thus, if a nuclear power plant licensee purchasing pump or pump parts from Goulds wished to perform a source inspection, they would have to make that a specific requirement of their purchase cider.. " l l

The NRC staff agrees with the intent of the above statement with some clarification. That is, if a licensee required specific source insoections for their purpose of product acceptance, the NRC would expect that the licensee request ,

would be in the form of a contractual requirement. However, it is important to \

point out that the NRC staff considers a source inspection to be quite different from a commercial grade survey / audit as further discussed below.

With regards to commercialgrade surveys and audits, Section 3.3 of the subject i

inspection Report states that "since [Goulds] does not survey / audit its commercial casting manufacturers and does not verify all ofits chemical composition elements (even on a sample basis), its level of assurance would be questionable." The Goulds Quality Systems Manager stated to the NRC Inspector that: 1) Goulds did not perform commercial grade surveys / audits ofits 1 commercial grade suppliers / manufacturers, 2) Goulds did not request CMTRs (unless contractually requested by a licensee), and 3) Goulds did not verify all chemical elements for CGis being dedicated for safety-related use. Therefore, the staff considered the overall Goulds dedication program as ineffectively established and implemented because of a lack of commercial grade surveys / audits, without the benefit of CMTRs, and without the benefit of sound / complete' historical chemical element data. In conclusion, even if the licensee's PO did not specify that source inspections were to be performed, a dedicating entity is still required to implement confirmatory commercial grade surveys and audits as necossary.

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The NRC staff would not consider Goulds historic data to be sound / complete because Goulds has not verified or recorded its procured cornponent chemistry values for carbon, silicon, phosphorus or sulfur for the past ten years.

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4. Page 6, " Commercial Materials Utilized," second paragraph from the top, of Report 7842, states for applications in nuclear power plants, these materials can be used interchangeably with respect to carbon content.

The NRC staff would note that the licensee's design basis choice of component l material for its particular nuclear power plant application was found to be typically delineated on the applicable purchase orders (directly and indirectly by part number) in accordance with the applicable provisions of 10 CFR Part 50, Appendix B such as, Criterion lit, " Design Control " and Criterion Vil, " Control of Purchased Material, Equipment, and Services." The determination to use different types of austenitic stainless steel components can only be made by the particularlicensee, and a departure from particular PO requirements is not an option of a supplier; instead, it is a deviation to 10 CPR Part 21 requirements.

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5. Page 7 " Commercial Materials Utilized " first paragraph from the top, of Report 7842, states deviations in the analysis of a stainless steel component or even the substitution of a type 316 stainless steel component for a type 304 stainless steel component would not be considered a defect, and would not result in product failures during the types of services involved in nuclear power plants.

I The NRC staff notes that a defect is typically determined by an evaluation of the l circumstance involving c, deviation from the procurement document in conjunction with specific plant application, system interaction, design basis operational parameters, and many other factors.

Therefore, general categorization and conjecture that substitution of a different type of stainless steel component "would not result in product failures during the types of services involved in nuclear power plants," and would not result in a defect may be incorrect. It would be incumbent on the design authority to evaluate the substitution considering the plant specific application of the component.

6. Page 7, " Commercial Materials Utilized," second paragraph from the top, of Report 7842, states deviations that can occur in the composition of austenitic stainless steels are extremely minor and generally are not of concern in the types of applications involving nuclear power plant installations.

There is not adequate information, without the benefit of an evaluation, as defined in f21.3 of 10 CFR Part 21, of a specific occurrence and known application to help substantiate this statement. The NRC staff notes, as discussed herein, that the NRC licensee typically identifies the critical characteristics of theirprocured components (typically by PO requirements) under their 10 CFR Part 50, Appendix B, QA program. Goulds, in tum, is l required to conduct its dedication program in compliance with the contractual l

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1 s a requirements. If deviations are identified in Goulds methods, services, delivered products, or other aspects; Goulds is obligated to evaluate those deviations, if they have the capability, orinform their customers to ensure that a Par 121 evaluation is performed.

7. Page 8, " Commercial Materials Utilized," top paragraph, of Report 7842, states that the different types of nickel alloys can be readily separated with the alloy analyzer.

Although the alloy analyzer would not identify the presence of carbon, sulfur, and phosphorous, these elements in the commercial alloys supplied by all established vendors generally consistentiv (emphasis added] meet the limits for these elements established in the applicable ASTM and ASME Specifications.

The NRC staff notes that Goulds Pumps has not verified carbon, silicon, phosphorus, or sulfur for more than ten years because ofits metal analyzer capability. The value of any historical data base forparticular suppliers incoming components or material would therefore be questionable. Goulds also stated that it did not typically perform commercial grade surveys / audits of its commercialsuppliers. Therefore, the basis for saying that the chemical composition elements supplied by "all* established vendors " generally consistently" meet ASTM /ASME specifications is not clearly identified.

8. Page 10, " Commonwealth Edison Concern," bottom paragraph, of Report 7842, states no stainless steel foundry furnishing materials for installation in nuclear power plants would have produced an impeller that did not meet all of the composition requirements for the CF8M grade.

The NRC staff does not believe that Goulds statement regarding its trust of foundries is supportable in light of: 1) Goulds lack of verification data for certain chemical composition elements, 2) the fact Goulds does not typically request CMTRs, and 3) Goulds lack of periodic survey / audit data which could indicate the effectiveness of suppliers quality program implementation and effectiveness.

For example, an inspection of Westlectric Casting, Incorporated, was documented in NRC Report 99901323/97-01. Westlectric is one of Goulds commercial forging suppliers. In November 1997, the NRC staff found numerous weaknesses, including Westlectric's documentation ofincorrect spectrometer values which resulted in incorrect chemical composition data on its CMTRs.

9. Page 1, Section 4.1 of QCP-187, " Definitions," Revision 9, states that a Commercial Grade Item means an item:

a. Not subject to requirements that are unique to nuclear facilities.

b. Is used in applications other than nuclear facilities.

c. Can be ordered by Manufacturer's published description.

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l The NRC staff notes that this is an incorrect definition. The above definition is for facilities and activities other than nuclear powerplants licensed under 10 CFR

.* fart 50. Please note that @21.3 of Part 21 defines commercial grade items hvhen applied to nuclearpowerplants licensed pursuant to 10 CFR Part 50) as heaning a structure, system or component, orpart thereof that affects its safety function, that was not designed and manufactured as a basic component.

.Qommercial grade items do not include items where the design and lpanufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more

.fltical characteristics of the item cannot be verified).

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e. e p ilt p* 1 UNITED STATES g

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20656-0001

\...../ January 26, 1998 Mr. John R. Heine, President Westlectric Castings, incorporated 2040 Camfield Avenue City of Commerce, Califomia 90040

SUBJECT:

NRC INSPECTION REPORT 99901323/97-01 (NOTICE OF VIOLATION AND NOTICE OF NONCONFORMANCE)

Dear Mr. Heine:

On November 17-19,1997, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Westlectric Castings, incorporated (Westlectric), facility. The enclosed report presents the results of that inspection.

During this inspection, the NRC inspectors noted that Westlectric personnel were knowledgeable and competent in the performance of theirjob functions. However, the NRC Inspectors found that certain of your activities appeared to be in violation of NRC requirements. Specifically, although 10 CFR 21.21, " Notification of failure to comply or existence of a defect and its evaluation," requires that each corporation subject to Part 21 regulations adopt procedures to ensure the evaluation and proper reporting of deviations and failures to comply is performed, Westlectric did not establish an adequate procedure. This violation is cited in the enclosed Notice of Violation (NOV), and the circumstances surrounding the violation are described in detail in the enclosed report. Please note that you are required to respond to this letter and should follow the instructions specified in the enclosed NOV when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ,

ensure compliance with regulatory requirements, in addition, the NRC inspectors found that the implementation of your quality assurance program failed to meet certain NRC requirements imposed on you by your customers. Specifically, the inspectors determined that compliance with 10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," was contractually imposed on Westlectric in approximately 1993 by Pacific Pump (currently Ingersoll-Dresser Pump, Inc. (IDP) and Bryon Jackson Pump Division (BW/IP). Although Westlectric unconditionally accepted the quality assurance (QA) provisions of 10 CFR Part 50, Appendix B, Westlectric did not establish an adequate QA program to specifically identify or address certain of the Appendix B criteria that were applicable to Westlectric activities affecting the quality of the components supplied for safety-related use.

These nonconformances are cited in the enclosed Notice of Nonconforrnance (NON), and the circumstances surrounding them are described in detailin the enclosed report. You are requested to respond to the nonconformances and should follow the instructions specified in the enclosed NON when preparing your response.

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Mr. J.R.. Heine January 26, 1998 Given the extent of the concems identified by the NRC inspectors in the enclosed Inspection Report, the adequacy of the quality oversight functions for the spectrometer operetions is questionable. Therefore, you are also requested to respond regarding the review that Westlectric has implemented to identify: (1) whether your chemical analyses of nuclear component castings has been correctly performed, (2) whether the spectrometer operator training was adsquate, (3) whether the spectrometer correction factor practice was appropriate, (4) whether any shipped casting's chemical analyses are questionable, and (5) whether appropriate (.,Jality Verification activities Md been pelformed to ensure the integrity of the spectrometer operations, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in (ne NRC's Public Document Room (PDR).

Sincerely, t

+ g,y, . 4L i Suzan . Black, Chief i Quality Assurance, Vendor inspection i and Maintenance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket No. 99901323 Enclor arcs: 1. Notice of Violation

2. Notice of Ncnconformance

3. Inspection Report 99901323/97-01 l

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NOTICE OF VIOLATION Westlectric Castings, incorporated Docket No.: 99901323 City of Commerce, Califomia Curing an NRC inspection ecnducted on November 17 through 19,1997, a violatic.. af NRC raquirements was identified, la accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

i 10 CFR 21.21, " Notification of failure to comply or existence of a defect and its evaluation," 1 j requirer, in part, that each corporation subject to the regulations adopt appropriate procedures to ensure the evaluation and proper reporting of deviations and failurns to comply.

Contrary to the above, Quality Assurance (QA) Procedure QA104, "Part 21 - Reporting of Defects and Noncompliance," Revision A, dated January 26,1996 failed to address the evaluation of deviations. (99901323/97-01-01) t This is a Severity Level IV violation (Supplement Vil).

Pursuant to the provisions of 10 CFR 2.201, Westlectric Castings, incorporated, is hereby ,

required to submit a written statement or explanation to the U.S. Nuclear Regulatory 1 Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Chief, Quality Assurance, Vendor Inspect;on, and Maintenance Branch, Division of Reactor Controls and Human Factors, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Violation. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that nave been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include  ;

previous docketed correspondence, if the correspondence adequately addresses the required response. Where good cause is shown, consideration will be given to extending the response l

time.

Dated at Rockville, Maryland this 2d2 day of January 1998 Enclosure 1

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! NOTICE OF NONCONFORMANCE l Westlectric Castings, incorporated Docket No.: 99901323 City of Commerce, Califomia i

Based on the results of an inspection conducted on Nommber 17 through 19,1997, it appears that certain of your activities were not conducted in accordance with NRC requirements.

I A. Criterion I, " Organization," of 10 CFR Part 50, Appendix B, " Quality Assurance Criteria for l Nuclear Power Plants and Fuel Reprocessing Plants," (Appendix B), requires in part, that l the authority and duties of persons and organizations performing activities affecting the l safety-related functions of structures, systems, and components shall be clearfy

[ established and delineated in writing.

Criterion 11, " Quality Assurance Program," of Appendix B, requires that a quality assurance program which complies with the requirements of Appendix B be established.

Westlectric QAM Procedure Section 1.0, " General Policy," states that "all inspectors, including M.T. and P.T. Leve1 H who are under the direct supervision of the Quality

Assurance Assistant are responsible for the proper execution of required N.D.T."

l Contrary to the above, the NRC found that the authority and duties of all Westlectric

, Quality Assurance department personnel were not accurately delineated in the l Westlectric Quality Assurance Manual (QAM), Revision K, dated October 14,1996.

Specifically: (Nonconformance 99901323/97-01-02)

1) Westlectric has not had a QA Assistant :;ince approximately 1991,

2) Until recently the visual inspector worked for and reported to production department personnel.

3) Westlectric has had only one NDE certified inspector (Level 11) since approximately 1990 even though the QAM indicates it has multiple NDE Inspectors.

l 4) The Level ll NDE Inspector also holds the position of " Chief Inspector," the authority i and responsibilities of the Chief Inspector were not delineated in the QAM.

l l 5) The only Westlectric NDE Inspector (the Chief Inspector / Level ll NDE Inspector) reports to the Operations Manager, who is responsible for the activity being inspected.

6) Although both Westlectric visual inspectors report to the QA Manager, they also take NDE and inspection direction from the Chief Inspector / Level 11 NDE Inspector.

B. Criterion V, " Instructions, Procedures, and Drawings," of Appendix B requires that i activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instt uctions, procedures, or j b bb[

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. l drawings shallinclude appropriate quantitative or qualitative acceptance criteria for ,

' determining that important activities have been satisfactorily accomplished. I l

Paragraph 1.4 of Section 3.0, " Quality Control Department Operation and Duties Procedure," of Westlectric's QAM states: the QA Manager will maintain a file in his office ,

of allinspection stamps issued to workers.

Paragraph 1.2 of Section 19.0, " Casting Traceability," of Westlectric's QAM states heat code numbers shall be affixed to pattem with raised aluminum letters or pressed into molding sand with letters attached to a hand!e.

Contrary to the above: (Nonconformance 99901323/97-01-03)

1) two inspection signature stamps, used for the stamping of approval signatures on Westlectric CMTRs and NDE records, in the possession of the Chief Inspector and QA Manager were not identified as being issued on the QA manager's inspection stamp file. As a result, no record existed regarding the signature stamps even though they were used for approving quality records.

2) Although Westlectric's manufacturing process can result in situations where heat numbers are occasionally changed, the QAM and implementing procedures did not specify that grinding out portions of cast heat numbers and replacing them with stamped numbers was an allowable practice. i C. Criterion Xil," Control of Measuring and Test Equipment," of Appendix B requires that measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properiy controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.

Criterion XVil, " Quality Assurance Records," of Appendix B requires that sufficient records be maintained to fumish evidence of activities affecting quality. The records willinclude at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. The records shall also include closely-related data such as qualifications of personnel, procedures, and equipment.

Records shall be identifiable and retrievable.

Westlectric QAM Procedure Section 16.0, " Calibration Procedures," states that 'all calibration shall be performed in accordance with MIL-C-45662 by a qualified outside calibration soarce ar d traceable to NIST Standards."

Contrary to the above, Westlectric staff was unable to provide calibration records for the spectrometer curve-sets, did not have traceability to NIST for its standards, and did not have adequate information regarding the accuracy of the curve-rets. Additionally, Westlectric did not establish specific documented procedures or instructions delineating acceptance and rejection limits on the analysis range for each element affected by one-point standardization. (Nonconformance 99901323/97-01-04)

D. Criterion IX, " Control of Special Processes," of App .. . dix B requires that measures be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using

qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.

, Paragraph 1.5.1 of Procedure 11.0, " Metal Control," of Westlectric's QAM stated the l chemical analysis testing shall be performed by a trained laboratory technician. '

Contrary to the above, Westlectric did not establish adequate procedures or appropnately trained personnel to control its spectrometer chemical analysis' operation.

(Nonconformance 99901323/97-01-05)

Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Chief, Quality Assurance, Vendor inspection and Maintenance Branch, Division of Reactor Controb and Human Factors, 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 nonconformance:

(1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed.

Dated at Rockville, Maryland this Altiay of January 1998

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION 1

Report No: 99901323/97-01  ;

Organization: Westlectric Castings, incorporated 1 2040 Camfield Avenue City of Commerce, Califomia 90040

Contact:

Andrew Arechiga, Quality Assurance Manager  !

(213) 722-8000 i Nuclear Industry Manufacturer of low carbon and stainless Activity: steel sand castings such as impellers, valve bodies and pump replacement parts. I Dates: November 17 - 19,1997 Inspectors: Joseph J. Petrosino, NRR  !

Donald G. Naujock, NRR I Approved by: Robert A. Gramm, Chief Quality Assurance and Safety Assessment Section Quality Assurance, Vendor inspection and Maintenance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation i

I Enclosure 3 )

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,> s o 1 INSPECTION

SUMMARY

During this inspection, the NRC inspectors reviewed the implementation of selected portions of the Westlectric Castings, incorporated, quality assurance (QA) program, and reviewed activities associated with its manufacture and supply of low carbon and stainless steel sand castings to the nuclear industry.

The inspection bases were:

e Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reaulations (Appendix B) e 10 CFR Part 21, " Reporting of Defects and Noncompliance" During this inspection, a violation of NRC requirements was identified and is discussed in Section 3.1 of this report. Additionally, several instances where Westlectric Castings, incorporated (Westlectric), failed to conform to NRC requirements contractually imposed upon them by sub-tier suppliers for NRC licensees were identified. These nonconformances are discussed in Sections 3.2, and 3.4 of this report.

2 STATUS OF PREVIOUS INSPECTION FINDINGS This was the first NRC inspection of the Westlectric facility.

3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 10 CFR Part 21 Proaram

a. Insoection Scone The NRC inspectors reviewed Westlectric's procedure for reporting in accordance with 10 CFR Part 21: QA Procedure QA104, "Part 21 - Reporting of Defects and Noncompliance," Revision A, dated, January 26,1996. The NRC Inspectors also observed and reviewed Westlectric's 10 CFR Part 21 posting.

b. Observations and Findinas The procedure did not address evaluation, notification or associated time constraint requirements of $21.21, " Notification of failure to comply or existence of a defect and its evaluation," of 10 CFR Part 21. Instead, it focused on delineating specific requirements for Westlectric employees regarding intemal processes to identify, document and transmit product deviations to a Westlectric Part 21 Committee member. For example, the

" reporting" section of the procedure had three paragraphs indicating how an employee was required to fill out the Westlectric deviation documentation form.

The NRC Inspectors conducted discussions with the QA Manager to outline the salient points of the Part 21 regulation that are required to be addressed and included in a Part 21 procedure. Failure to have adequate procedures to require that evah ations or reporting of deviations, is performed as required in 10 CFR 21.21(a), cre,stitutes a violation of NRC requirements. The QA Manager committed to revising and issuing the

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L corrected Part 21 procedure within 120 days of the November 19,1997, exit meeting.

i Violation 99901323/97-01-01 was identified in this area. b

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The NRC Inspectors determined that Westlectric's posting documents were in compliance with the Part 21 regulation and that it was conspicuously displayed in multiple locations at Westlectric's facil:ty. However, it was noted that the inadequate Part 21 procedure was integral with the posting. Therefore, the QA Manager stated that he would also revise the posting docurnent to include Westlectric's new Part 21 procedure when it l was revised and issued.

Potential 10 CFR Part 21 lasue As discussed in Section 3.4 below, a Westlectric practice was identified by the NRC Inspectors regarding the method employed for " correcting" the chemical composition

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l' analysis heat results obtained from Westlectric's spectrometer readings. As stated in l

$21.3 of Part 21, a deviation means a departure from the technical requirements included l l

in a procurement document. Since this matter may represent a deviation of the procurement do":uments, as of November 19,1997, Westlectric was reviewing the circumstances to determine ifits customers needed to be informed in accordance with

$21.21(b) of Part 21. l

c. Conclusions The NRC Inspectors concluded that Westlectric's procedure adopted to implement the i

provisions of 10 CFR Part 21 was not adequately established to ensure that evaluations were performed in accordance with $21.21, " Notification of failure to comply or existence of a defect and its evaluation."

3.2 Quality Assurance Proatam i

i a. Insoection Scone l The NRC inspectors reviewed Westlectric's QA Manual (QAM), Revision K, dated

' October 14,1996, and associated procedures and records to assess the Westlectric quality program to determine whether it adequately addressed applicable Appendix B requirements,

b. Observations and Findinas Quality Assurance Manual The NRC Inspectors determined that Appendix B requirements were contractually imposed on Westlectric in approximately 1991 by Pacific Pump (currently ingersoll.

Dresser Pump, Inc. (IDP) and Bryon Jackson Pump Division (BW/IP). It was noted that Westlectric's QA manual (QAM) did not address whether it did or how it would meet the applicable Appandix B criteria necessary to provide adequate confidence that its components supplied for safety-related use would perform satisfactorily in service. That is, the QAM did not adequately address how the applicable requirements of the 18 criteria of Appendix B were to be satisfied by the Westlectric QA program. The introduction of j the QAM stated that the manualis a description of the procedures followed to maintain 4

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quality standards required to produce castings h accordance with Military Specification-Inspection (MIL-l)-45208, " Inspection System Requirements." It also stated that the manual meets the calibration system requirements of Military Specification-Calibration (MIL-C-STD)-45662A, " Calibration System Requirements." The QAM also stated that all measurements related to product conformance are traceable to the National Bureau of Standards (NBS), and that the manual establishes the quality system and procedures i required by the company.

{

The NRC inspectors noted that the QAM contains general instructions and procedures such as casting traceability, pattem maintenance control, corrective action, control of non-conforming castings, calibration procedures, processing te ,t bars and test reports,

, shipping procedures, sand control, heat treat process, and metal control.

Accuraev of QAM Procedures The NRC Inspectors also selectively assessed the Criterion I aspect of requiring that the authority and duties of prsons and organizations performing activities affecting the

' safety-related functions of nuclear power plant components be clearly established and delineated in writing. After reviewing specific requirements of selected procedures, the NRC Inspectors identified several areas where it determined that the procedural steps and requirements were not clearly or accurately established or delineated in writing. For example, the NRC Inspectors found that the QAM general policy section did not accurately reflect the QA personnel and QA department structure that was in existence  ;

for several years. The CAM's general policy section states that all of the Westlectric inspectors, including nore-destructive examination (NDE) level 11 inspectors are under the direct supervision of the "QA Assistant." However, the NRC inspectors determined that i as of November 19,1997:

• Although Westlectric's QAM states that all Westlectric visual and nondestructive examination (NDE) inspectors are under the direct supervision of the "QA Assistant,"

Westlectric has not had a QA Assistant since approximately 1991.

• Until recently the visual inspector worked for and reported to production department personnel. Currently, there are two visualinspectors, e Until recently Westlectric's QA department consisted of only the QA Manager.

Currently, the Westlectric QA department consists of the QA Manager and both visual inspectors, e Westlectric has had only one NDE certified inspector since approximately 1991, and the NDE Inspector does not report to or take direction from the QA Department.

• Although the Level ll Inspector also holds the position of " Chief Inspector," the authority and resp insibility of the Chief Inspector were not delineated in QAM Section 1.0, " Gens al Policy," 3.0, " Quality Control Department Operation and Duties," 8.0, "in-Promss inspection," or 10.0, " Final Inspection."

e Ahhough both Westlectric visual inspectors report to the QA Manager, they also take inspection activity direction from the Chief Inspector / Level ll NDE Inspector. Thus, their independence from production is not assured.

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The NRC Inspectors identified that the Level 11 NDE Inspec'or is also designated as the Cleaning Room Foreman (discussed in weld rod control procedure), and the Cleaning Room Supervisor (discussed in heat treat process). The NRC Inspectors determined that the employee that holds each of these positions reports to, and is under the responsibility of the Operations Manager, and does not report to or take inspection direction from the QA Manager. Discussions with the Westlectric staff and management indicated that this relationship had not been reviewed or approved by the QA organization to determine whether sufficient independence from cost and schedule when opposed to safety considerations existed.

The NRC Inspectors identified that the QAM dascription of the reporting relationship of the visual and NDE inspectors is inconsistent with actual practices. Nonconformance 99901323/97-01-02 has been identified in this area. 1 Insoection Stamos The NRC Inspectors noted during review of PO packages that Westlectric's original l certified material test reports (CMTRs) were not hand signed. It was noted that the i approving official's signature was stamped instead of being signed by the approving i official, the QA Manager. The QA Manager stated that he had a signature stamp for his  !

use (mostly on CMTRs). During a discussion between the NRC Inspectors and QA Manager, the shipping supervisor brought in a stack of CMTRs to sign (stamp), and the QA manager stamped the records and retumed them. The NRC Inspectors noted that the QA manager kept his signature stamp in his desk drawer. When asked whether anyone else was issued signature or inspection stamps, the NRC Inspectors were informed that the Level 11 NDE inspector / Chief Inspector had also been issued a signature stamp for stamping NDE quality records. Subsequently, the NRC inspectors requested the Chief Inspector to retrieve his signature stamp and it was noted that the Chief inspectors signature stamp was stored in a locked cabinet in the Clesning room office.

The Chief inspector stated that the main reason that he had a signature stamp was because many of the Westlectric documents were triplicates. The NRC Inspectors obtained a blank Westlectric CMTR form and noted that the form was made of carbon-copy type paper, which would allow a signed signature to be reproduced on the second and third pages of the triplicate form.

The NRC Inspectors noted that paragraph 1.4 of Section 3.0, " Quality Control Department Operation and Duties Procedure," of Westlectric's QAM requires the QA Manager to maintain a file in his office of all inspection stamps issued to workers, and Criterion V,

" Instructions, Procedures, and Drawings," of Appendix B requires activities affecting quality to be accomplished in accordance with documented procedures. The NRC Inspectors review of this area revealed that the two signature stamps for the QA Manager and Chief Inspector were not indicated as being issued even though they are used for quality record approval. Nonconformance 99901323/97-01-03 was identified in this area.

c. Conclusions The inspectors found that Westlectric's QAM did not accurately describe its QA department personnel and associated duties. Further, the NRC Inspectors concluded that the QA Managers and Level 11 NDE Insoectors signature stamps were not identified as being issued in the QA Managers inspection stamp file.

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3.3 Weldina Control

a. Insoection Scone The NRC Inspectors conducted discussions with Westlectric staff regarding its welding program including welding processes, observed weld rod control and issuance, and reviewed certification and qualification of personnel. The NRC Inspectors noted that Westlectric's welding program control is outlined in a " Welding Control Procedure," that is part of Section 22.0, " Control of Special Processes," of Westlectric's QAM. There were no orders for nuclear applications being processed at the time of the inspections involvir.g weld maps or other special controls. Therefore, the NRC Inspectors were not able to observe orwitness implementation of the welding control process,

b. Observations and Findinas Paragraph 1.1.1 of Section 22.0 of Westlectric's QAM states in part, that the welding program will meet Section IX, " Welding and Brazing Qualifications," of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. The NRC Inspectors reviewed welding procedure specifications (WPS), procedures qualification reports (PQR), and welder qualifications. Westlectric has 20 different WPSs, each with a unique PQR, and currently has 11 welders that are qualified to at least one weld procedure. The NRC Inspectors determined that the welding records are well maintained and records are kept for each welder to indicate when last a specific procedure was used during each 3 month interval. This satisfies the requirements of American Society for Testing and Materials Standard (ASTM) A 488, " Standard Practice for Steel Castings, Welding, Qualification of Procedures and Personnel," which in tum, satisfies the 6 month interval required by subparagraph QW-322.1, " Expiration of Qualifications," of Section IX, ASME Code.

Paragraph 5.1.5 in the weld control procedure stated that major weld repair shall be documented by generating a weld map if required by specification or customer purchase order (PO) requirements. The NRC Inspectors observed examples of weld maps in shop traveler record package 128674, dated February 11,1997, for ingersoll Dresser Pumps (IDP), PO 91797, for an intermediate cover, grade CA6NM, (Heat 976A).

c. Conclusions The NRC inspectors concluded that Westlectric maintained good records of its welder qualification and certification program and also generated and maintained satisfactory .

records to allow traceability of individual welders to the applicable welding specifications I and procedures to maintain certification.

3.4 Soectrometer- Chemical Analvsis

a. Insoection Scone The NRC Inspectors reviewed the current and historical chemical analysis records generated from Westlectric's Thermo Jarrell Ash spectrometer. The purpose was to assess chemical analysis accuracy (by verifving calibration), ensure that the results were

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accurately documented on the applicable certified material test reports (CMTRs), and verify compliance to Westlectric and customer requirements.

b. Observations and Findinas Soectrometer Calibration - First Steo Westlectric performs chemical analysis with a Thermo Jarrell Ash (TJA) 181/81 optical emission spectrometer, Model 12621600, Serial Number 41883. The TJA recommended calibration consisted of two steps. The first step required creating a curve-set' by developing curves for each element that the machine is capable of assessing. Each curve is a plot of light intensities emitted from electrical arcing agt. inst metal standards of different chernical concentrations and the certified chemical concentrations for these standards. Each curve-set is a family of curves for the chemical elements to be analyzed. For example, carbon steelis one unique curve-set, while stainless steelis a different set of curves. The standards are normally purchased from recognized sources including the National Institute of Standards and Technology (NIST).

The NRC Inspectors requested to see the calibration records and traceability back to NIST for Westlectric curve-sets identified as: LOWB (ASTM-A-216), SER3M (ASTM-A-743, CF3M), and SERIES 4M (ASTM-A-743, CA-CNM). The Westlectric staff was unable to provide curve-set calibration records for the spectrometer, and did not have curve-set traceability to NIST. The NRC inspectors and QA Manager phoned the spectrometer service representative and were informed that the curve-sets were retrievable from the computer files along with the identity of the standards.

Spectrometer Standardization - Second Step The second recommended Spectrometer manufacturer's step in calibration is the standardization of the curve-set. The repositioning of the curves in a particular curve-set is called standardization. Standardization of the curve-set is necessary because the spectrometer is sensitive to atmospheric effects, equipment wear, and equipment cleanliness. In order to maintain a high level of accuracy, repeatability, and j reproducibility, the curve-set must be standardized each day before use, and more i frequently if necessary. The NRC Inspectors determined that West!ectric used a one-point technique for standardization. The one-point technique locks a particular alloy's curve-set's chemical composition parameters to the est miated NIST standard. This technique is a fast and effective technique for analyzing specimens with a chemical composition that is similar to that particular standard.

A common weakness in the one-point technique is that the further the test specimen's analysis is from the locked chemical composition value, the larger the potential error in analyses. For the curve sets LOWB, SER3M, and SERIE4M, Westlectric used NIST Standards 1261A,1155, and C-1289 respectively. The NRC Inspectors identified that Westlectric did not establish specific documented acceptance or rejection limits on the analysis range for each element affected by the one-point standardization for each curve-set.

' One curve-set consists of multiple individual or unique curves, l 1

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Since Westlectric did not have comprehensive spectrometer operational procedures, as discussed further in this Section, the spectrometer technicians developed the concept of looking at the standard deviation for each element to determine the acceptability of the calibration. One of the technicians (who is the production melter) informed the NRC j inspectors that low standard deviations were acceptable and high standard deviations i were rejectable. The operator could not place a number on what would be considered the maximum acceptable standard deviation values. The NRC Inspectors consider the lack of written procedures for the acceptance of the standardization calibration and the absence of limits to the chemical range for each element as a deficiency in Westlectric's spectrometer control.

Since the NRC Inspector was not able to obtain evidence of the accuracy of the curve-sets, and since Westlectric was not able to demonstrate traceability of the curve-sets ,

back to NIST standards, the NRC Inspectors were not able to verify that all  !

measurements related to product conformance are traceable to NIST as required.

Additionally, the NRC Inspectors were not able to verify that West!ectric's spectrometer meets the calibration system requirements that Westlectric had stated, that is MIL-C-STD-45662A requirements. The NRC Inspectors determined that Westlectric did not establish adequate measures to controlits spectrometer operation and maintenance.

Nonconformance 99901323/97-01-04 was identified in this area.

As a result of this identified deficiency, a departure from the technical requirements, as defined in $21.3 of 10 CFR Part 21, included in a procurement document may have occurred as discussed within Sections 3.1 and 3.4 of this report.

Goectrometer Procedures The NRC Inspectors found that production personnel that used the spectrometer for its heat verifications used a written procedure for a standardization calibration but it was not controlled within Westlectric's QA program. The procedure was found to be untitled, was not dated, and was not approved or signed by the person (s) who developed the procedure. Additionally, the procedure for a standardization calibration did not set limits on the analysis range for each element affected by the one-point standardization.

Therefore, the NRC Inspectors determined that Westlectric did not assure that the spectrometer was properly controlled, calibrated, and adjusted to maintain its accuracy.

This is another example of No90cnformance 99901323/97-01-04.

Chemistrv Verification Metal Control Procedure, Section 11.0, states that heats shall be comprised of select scrap, iron ore, processed alloys, and remelt-material, it also requires that a minimum of three chemical analysis checks be made on the spectrometer for are fumace heats prior to pouring castings. The three checks for the arc fumace heats are performed at the beginning, middle and end of the process, specifically: (a) melt-down, (b) preliminary, and

(c) final. The preliminary analysis checks all chemical elements to allow calculation of the necessary alloy additions to the heat as well as assuring that a vigorous carbon boil is occurring. The final analysis verifies that all alloy additions were property added and that the analysis meets industry and customer specifications.

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The Westlectric person that assures that each heat is comprised of the correct amounts of materialis the metter. The melter is also responsible for the outcome of each of the three checks by verifying on the spectrometer that each heat, which he is making and

' monitoring, meets the specifications.-

Criterion I, " Organization," of Appendix B, state that the QA functions are those of assuring that an appropriate program is established and effectively executed, and verifying, such as by checking, auditing, and inspection, that activities affecting safety-related items have been correctly performed.

The NRC Inspectors noted that Westlectric's QAM did not specifically allow or disallow its metter from verifying his own work. It merely stated that the chemical analysis testing shall be performed by a trained laboratory technician. The inspectors also noted that Westlectric's in process procedur6 (Faction 8.0), and final inspection procedure (Section 11.0) did not address "inspectior' of heat chemistry, even though the chemical composition is very important to the safety-related component.

Evaluatino Correction of Chemical Comoosition Analyses Effects immediately after standardizing the curve-sets, Westlectric runs the same NIST standard as if it was an ordinary heat specimen. The values from this run are compared to the NIST standard's CMTR values, and the differences for each major element are noted on a daily adjustment work sheet. The operator told the NRC Inspectors that the daily adjustment work sheet is used to change the final chemical analysis of a heat that might otherwise be out of specification. The rationale is that the standardization process is not accurate because the spectrometer does not provide identical results with the values shown on the NIST standard's CMTR (neglecting any tolerances).

Therefore, Westlectric would either add or subtract the daily adjustments to the ar.tual i values from the spectrometer printer. The NRC Inspectors observed that the operator l adjusted the chemical results while making out the " Daily Chemical Analysis Report."2 After the operator performed the corrections to the daily chemical analysis report, it was given tc the QA Manager. The QA Manager then takes the daily chemical analysis report that has been corrected and manually inputs the data into Westlectric's computer network for the documentation and issuance of applicable CMTRs for each heat. The NRC Inspectors observed an example where the shipping department supervisor called up a specific heat on the network and printed the CMTR in the shipping department. The NRC Inspectors were informed by the QA Manager that he is not typically involved in generating the chemical analysis and has limited knowledge regarding the operation of the spectrometer.

During a subsequent telephone conversation with the TJA spectrometer representative, the representative stated to the NRC Inspectors and Westlectric's QA Manager that there is no need to perform any correction or adjustment of the spectrometer values because all necessary adjustments are automatically performed during the standardization process. This was not known by the Westlectric personnel.

2 The daily chemical analysis report was merely.a pre-printed form where the corrected values would be documented and handed to the QA Manager.

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• l As a result of Westlectric's adjustments of its spectrometer results, Westlectric was  !

documenting incorrect spedrometer values and consequently, was issuing CMTRs that  !

were not representative of tne actual chemical composition of the casting.

Section 11.0, " Metal Control," states that the chemical analysis verifies that all alloy additions were properly addeo' and that the analysis meets customer specifications. To determina the effects from Westlectric using this manual adjustment technique, the NRC l inspectors reviewed five heats ? hat were applied on purchase orders identified for nuclear safety-related applications. The five heats were 109B,1258, U195, U354, and 976A.

Table 1 tabulates the chemistry before and after adjustment of the actual spectrometer's chemical analysis and the CMTR chemistry. 1 Tetdo 1  !

Heat Chermcel Ano#yes Betre a AAer Menuel Corre&in/Aouetment (Volues we in Wee 9tt Peroent)

Heat No C Mn Si P S Cr Ni Mo Cu Aeusted?

976A 0 06 0 71 0.52 0 029 0 011 12.27 4.25 0t[ - No 976A 0 03 0 67 0 52 0 028 0011 12 08 4 23 0 63 - Yes

[NIN!!IS h$$hkfhh $7ddhNb [$$iih$Nh $De@ hlk N k s Nkhhhk N$jI$hb fkN<hfk bl4Nd(!h %?}$k[df l 125A 0052 1.23 0 81 0.037 0 021 18 71 10 50 2.92 0.26 No 125A 0 03 1 30 0 84 0 038 0.020 1881 10.25 2.92 - Yes l

ap442W Nks@$#N$$M A@$s @$$$$5 @!MIM$I $$$$ WM@i 1098 0 076 0 67 0 67 0 027 0 022 N$$$P $$$$0  !$$$  ;

12.27 3 70 0.56 - No l 1098 0.03 0 67 0 67 0.027 0OR 12.27 3 70 0.56 ,,,, Yes

3M DA$ $hNix % ij@k $M(ifM %$hkN }h[kkh$$[ j$4j$$$ (IMN! !$jyh $$ s-U195 0.216 0 86 0 50 0 021 0 038 0.34 0 21 0 06 0 05 No j U195 0.21 0.68 0.50 0 020 0.031 R34 0.21 0 06 0 05 Yes Q 5 c'? ' hh NhhhE Thf% $hk*hh MM; h[ %d$h.f i%%k  %% Nhjgh; j U354 0.28 0.92 0 56 2019 0 022 0.18 0.18 0.04 0 (s4 No

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U364 0.28 4 00 0 57 0.023 0 023 0 18 0.18 0.04 0.04 Yes Table 2 tabulates the heat numbers with customer purchase order information. From Table 1, the carbon in heat 109B is 0.076 before adjustment and 0.03 on the CMTR after adjustment. The 0.076 exceeded the inpersoll-Dresser Pump Company purchase order number 074528 specification ASTM-A743 CA6NM which has a 0.06 maximum carbon.

The NRC Inspectors asked Westlectric to standardize the spectrometer and run a recheck of the initial test specimen which came back as 0.05 carbon. Based on the effects that the manual adjustment can have on the final chemical analysis, the NRC inspectcrs informed Westlectric that they were required to review this matter in accordance with $21.21 of 10 CFR Part 21.

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l Tetdo 2 Heat Nwnber enc Customer Purcfwee Order informaton Heat Trewier Customer PO P" Metenal Part No. Og ? Spec. No 976A 120674 10P 91797 1/31/9[ ~ ASTM A 743 M6535 CA6NM 125A 130255 BWAP 21V550517 8/2&/97 ASTM A 361 24296 I 1302$6 CF3M 21997  !

130257 23968 1098 130120 IDP 96895 7/28/97 ASTM A 743 M6535 CA8NM U195 128220 ASTM I U195 126220 BWAP W433033 11/13/96 A 216 72579 Westlectric started to review the circumstances surrounding the matter to determine if it was a deviation, and whether it needed to either evaluate the issue or inform the customer. Subsequent to the inspection, Westlectric informed the NRC staff that it had informed an applicable customer pursuant to (21.21(b) of 10 CFR Part 21, so that it could  ;

cause an evaluation to be performed, and it was still reviewing the remaining issues to determine if additional deviations existed.

The NRC inspectors determined that the adjustment of the spectrometer's chemical analysis results without an established program to control the special process and without a program to assure that appropriately trained personnel operated the spectrometer were indicative of an inadequately controlled special process. Nonconformance 99901323/97-01-05 was identified in this area.

Westlectric QA 11.1.5.1 states that chemical analysis testing shall be performed by a trained lab technician. Westlectric said that their melt shop superintendent has been trained by TJA on the operation of the spectrometer. However, the melt shop super-intendent was unavailable during the inspection. The NRC Inspectors were told that the melt shop superintendent gave on-the-job training to the individuals operating the spectrometer. The NRC Inspectors observed a melter and a recently assigned lab tech operating the spectrometer. The metter 'iold the NRC Inspector that when problems occur he would check the argon pressure, push the spectrometer reset button, adjust the lens (mirror), clean the are chamber, and/or restandardize the spectrometer. If none of these actions clear up the problem, he calls the melt shop superintendent. The lab tech said he calls the metter if he has problems. The NRC inspectors noted that some speci-mens had multiple cracks across the testing surface and sorr.e of the bums ovenapped each other. The NRC Inspectors noted that although either of these conditions can cause incorrect or erroneous readings the Westlectric personnel were not aware of the impact of these conditions. Additionally, the NRC Inspectors determined that neither the melter nor laboratory technician knew how to control movement in the mercury meter during the mirror adjustment prior to standardization. It appeared to the NRC Inspectors that the individuals operating the spectrometer received limited guidance on operating the spectrometer and specimen preparation. Except for the standardization procedure, the spectrometer is operated with no other written guidance. Nonconformance 99901323/97-  ;

01-05 was identified in this area. J Soectrometer Technicians '

i The NRC Inspectors conducted discussions with and observed two production personnel that normally test heat samples taken from the Westlectric arc and induction fumaces during the melting / combining process. Both employees typically operate the spectro-meter; therefore, the NRC Inspector's discussion encompassed the operation, calibration and principles of the spectrometer's chemical analyses. The QA Manager was involved in all of the discussions. The NRC Inspector determined that the two production personnel were regularly assigned to operate the spectrometer and verify the chemical analyses of the heats. One of the employee's title was " melter," and the other was the l production department's " laboratory technician." Both employees work and report to production department management. The metter is a production department employee that is responsible for measuring and putting the correct amount of raw material (alloy additives) into the fumaces to bring the heat within the chemical analysis before the pouring of the specific castings.

The NRC Inspectors were informed by the Westlectric QA Manager that the two Westlectric personnel had received indoctrination on the operation of the spectrometer, but their responses indicated that the training was limited and was not overly comprehen-sive. The NRC Inspectors noted that the Westlectric personnel were not very familiar with the calibration and operating principles of the spectrometer. Although the NRC Inspectors were informed that both employees had received training for the operation of 1 the spectrometer, records to indicate the training was satisfactorily completed were not provided during the inspection. The NRC Inspectors could not verify that both production department employees were appropriately trained for the job activity. Westlectric pro-vided certification records for the employees subsequent to the inspection; however, those records were not specific enough to determine the appropriateness of training.

Although Appendix B requires that special processes are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements, Westlectric did not establish adequate procedures or appropriately trained personnel to control its spectro-meter chemical analyses' operation. This is another example of Nonconformance 99901323/97-01-05.

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c. Conclusions The NRC Inspector was not able to verify that "all measurements related to product conformance regarding its spectrometer are traceable to NIST, and that Westlectric's spectrometer meets the calibration system requirements specified in MIL-C-STD-1 45662A." Westlectric was not able to produce records to indicate that it had been adequately controlling, calibrating and adjusting its spectrometer within documented '

1

• The contents of one fumace batch that is blended to a predetermined chemical composition l is commonly referred to as a " heat." Therefore, each particular fumace batch will be identified with a different heat number.

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parameters, and that its operators were appropriately trained. Given the extent of the concems identified by the NRC Inspectors the adequacy of the quality oversight functions for the spectrometer operation is questionable.

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) 3.5 Traceability of Castinas i1

a. Insoection Scope

! The NRC Inspector reviewed procedure 19.0, " Casting Traceability," to identify the e Westlectric requirements that have been established and to determine whether manufacturing has been in compliance with the requirements.

]. b. Observations and Findinas i Paragraph 1.2 of Procedure 19.0 states that heat / code numbers shall be affixed to 1

pattems with raised aluminum letters or pressed into molding sand with letters attached j

to a handle. The NRC Inspectors observed three 8" x 8" valve body castings from heat U818 which showed that the production department was not in strict compliance with its l procedure. The NRC Inspectors observed that the first three digits of the heat number j cast into the body appeared satisfactory, but the fourth digit was ground off and replaced with a stamped letter. Westlectric stated that the heat number sequence is determined 5

by the molding foreman because he has to insert the heat number into the mold several i days before pouring.

Occasionally, process control modifications such as, smaller quantities for a specific j

heat, or a chemical composition analysis that was incorrect will cause a change in the anticipated production and heat numbers. Instead of making up new molds with the correct heat number, Wet tiectric casts the existing molds, grinds off the wrong portion of the cast heat number, and stamps the correct heat number in its place.

The NRC Inspectors were informed that another exception to the procedure is that on occasion, the cast heat number is illegible and Westlectric will grind off the illegible portion and stamp it. The NRC Inspectors confirmed that even though these practices  !

are commonly performed, they are not delineated in the Westlectric casting traceability i procedure. Although this process is not in conformance with an Appendix B QA program, I the NRC Inspector notes that a nuclear safety related component would be handled somewhat different. That is, a Westlectric shop traveler would be used on nuclear orders and the s'nop traveler, which accompanies the component throughout the manufacturing process, requires that the heat be documented. As a result, if the heat was illegible, the traveler could provide some assurance of the correct heat.

c. Conclusions The NRC Inspectors concluded that although these manufacturing practices may be i necessary to prevent costly rework, they are not in compliance with the documented Westlectric and Appendix B requirements. This practice could be a factor for con-sideration if the component was destined to be " dedicated," in accordance with 10 CFR Part 21, because traceability to a heat may be indeterminate if numbers are modified from original cast numbers. This issue is an additional example of Nonconformance 99901323/97-01-03.

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l 3.6 Nondestructive Examination 4

! a. Insoection Scone l The NRC Inspectors reviewed Westlectric's Procedure's 1.0, " General Policy," and 22.0,

" Control of Special Processes.* Procedure 1.0 outlined Westlectric's QA department

policies and responsibilities and Procedure 22.0 addressed the control of welding, heat

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treat and nondestructive examination (NDE) to assess the adequacy of Westlectric's NDE control.

i b. Observations and Findinas

! Paragraph 1.1.1 of Procedure 22.0 stated that the QA manager is responsible for the i welding program which will meet Section IX of the ASME Boiler and Pressure Vessel i

Code. Paragraph 2.6 of Procedure 1.0 stated that allinspectors, including magnetic particle testing (MT) and dye penetrant testing (FT) Level ll who are under the direct

+

supervision of the QA Assistant are responsible for the proper execution of required NDE.

, They must inspect all castings in accordance with customer requirements and standards j

used in the casting industry.

l As discussed above, the NRC Inspectors determined that Westlectric has three inspectors total, two of whom are only visual inspectors certified to MSS-SP-55, and the

third is characterized as a Level 11 NDE. The two visualinspectors are not trained to i ASME Code. Instead, they use the visual acceptance and rejection criteria illustrated in MSS-SP-55. The NRC Inspector observed examples of rejected material that had been 2

identified by the visualinspectors such as, coup-drag misalignment, interrupted / cold pour, porosity, and holes.

The NRC Inspectors requested Westlectric's NDE personnel certification and qualification 1

records. The NRC Inspectors were only provided with the Chief Inspectors records, which indicated that he was certified as a Level ll MT Inspector, certification dated February 21,1997. The certification stated it was in accordance with SNT-TC-1 A, "American Society for Nondestructive Testing Recommended Practice," but did not list the applicable edition. The Westlectric staff stated that it would review the matter.

The NRC Inspectors were also informed that a Level ill NDE inspector from Sun-Ray Testing intemational, incorporated, Downey, Califomia, developed Westlectric's NDE training program, performed training, maintained the personnel certifications and provided certifications to Westlectric personnel as necessary. The NRC Inspector requested to see the empbyefs written practices covering all phases of certification including training as required by SNT-TC-1 A. At the time of the exit meeting, Westlectric had not made this information available for review. Unresolved item 99901323/97-01-06 was identified in this area.

c. Conclusions Westlectric was unable to provide the procedural controls and documentation associated with NDE personnel certification practices.

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- 3.7 Entrance and Exit Meetinas in the entrance meeting on November 17,1997, the NRC Inspectors discussed the scope of the inspection, outlined the areas to be inspected, and established interfaces with Westlectric management, in the exit meeting on November 19,1997, the NRC Inspectors discussed their findings and concems.

4. PERSONS CONTACTED J.R. Heine President R.L. Ogden Operations Manager A. Arechiga QA Manager G. Kusumi Sales D. O'Sullivan Sales Manager M. Gutierrez Clean Room Foreman / Chief Inspector )-

S. Fericean Shipping Supervisor

- J. Lietzau Inside Sales / Lab Technician ,

R. Young Core / Molding Supervisor l 1

5. ITEMS OPENED, CLOSED, AND DISCUSSED ,

1 99901323/97-01-01 VIO Inadequate Part 21 Procedure 99901323/97-01-02 NON QA Organization and Program 99901323/97-01-03 NON Documented instructions ' l 99901323/97-01-04 NON Control of M&TE and QA Records l

99901323/97-01-05 NON Control of Special Processes 99901323/97-01-06 URI Unresolved item - NDE Program i

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