ML20137H187

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QA Program Insp Rept 99901014/85-01 on 850521-22.Violation Noted:Failure to Post Regulations & Procedures,To Establish Individual to Receive Repts & to Adopt Deviation Procedures
ML20137H187
Person / Time
Issue date: 08/08/1985
From: Merschoff E, Miegel N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20137H172 List:
References
REF-QA-99901014 99901014-85-01, 99901014-85-1, NUDOCS 8508280217
Download: ML20137H187 (6)
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Text

ORGAf.ilZATION: Kenneth G. Lilly Fasteners, Inc.

Newark, Delaware REPORT INSPECTION INSPECTION N0.: 99901014/85-01 DATE(S): May 21-22, 1985 ON-SITE HOURS: 19 CORRESPONDENCE ADDRESS: Kenneth G. Lilly Fasteners, Inc.

ATTN: Mr. Gary Lilly President Post Office Box 6005 Newark, Delaware 19711 ORGANIZATIONAL CONTACT: Mr. Richard Rochford, Executive Vice President TELEPHONE NUMBER: (302) 366-7640 PRINCIPAL PRODUCT: Fasteners.

NUCLEAR INDUSTRY ACTIVITY: Less than 1%.

ASSIGNED INSPECTOR: 7/. 4 M I 8/6/8f N. p Miegel uReactive Inspection Section (RIS) Date OTHERINSPECTOR(S): T. F. Burns, BNL APPROVED BY: hA E. W. Merschoff, Chief, RIS 'Date INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 21.

B. SCOPE: To assess the adequacy of control over material traceability at Kenneth G. Lilly Fasteners Inc., for components destined for nuclear power facilities.

PLANT SITE APPLICABILITY: Watts Bar 1 and 2 (50-390, 391).

8508280217 850823 PDR GA999 ENVKGLF 99901014 PDR

ORGANIZATION: Kenneth G. Lilly Fasteners, Inc.

Newark, Delaware REPORT INSPECTION N0.: 99901014/85-01 RESULTS: PAGE 2 of 6 A. VIOLATIONS:

1. Contrary to Section 21.6 of 10 CFR Part 21, Kenneth G. Lilly Fasteners, Inc. (KGL) had not posted: (a) a copy of 10 CFR Part 21, (b) Section 206 of the Energy Reorganization Act of 1974, (c) procedures adopted pursuant to the regulations or (d) a notice describing the regulations and procedures. Further, the name of the individual to whom reports may be made had not been established.

This is a Severity Level V violation (Supplement VII).

2. Contrary to Section 21.21 of 10 CFR Part 21, KGL had not adopted proceduras to provide for: (a) evaluating deviations, (b) causing deviations to be evaluated, or (c) assuring that a director or responsible officer is informed if a basic component fails to comply or contains a defect.

This is a Severity Level V violation (Supplement VII).

B. NONCONFORMANCES None.

C. UNRESOLVED ITEMS None.

D. OTHER FINDINGS AND COMMENTS

1. 10 CFR Part 21 KGL had never developed procedures for reporting defects and noncompliances as required by 10 CFR Part 21. KGL personnel were aware, however, of the existence of 10 CFR Part 21 since it had been invoked on them by Carolina Power and Light (purcha'se order (P.O.) 767496 dated March 26,1982). KGL, in turn, had invoked these requirements on their vendar (P.O.159 dated March 29, 1982). KGL uses, and has always used, the same vendor for all nuclear orders. They instruct potential nuclear customers to audit this facility instead of auditing KGL. KGL personnel believed that they were exempt from the requirements of 10 CFR Part 21 because their policy has been to have all nuclear grade

, material shipped directly from their vendor, who has been

ORGANIZATION: Kenneth G. Lilly Fasteners, Inc.

Newark, Delaware REPORT INSPECTION N0.: 99901014/85-01 RESULTS: PAGE 3 of 6 approved by the customer, directly to the customer. Safety grade material destined for a commercial nuclear power facility never enters the KGL warehouse. A review of the shipping documents associated with the referenced order indicated that the material was shipped directly from the vendor to the customer. This does not, however, relieve KGL from the requirements of 10 CFR Part 21 because they accepted an order issued to them invoking these requirements and in turn passed these requirements on to their customer.

Section 206 of the Energy Reorganization Act of 1974 and 10 CFR Part 21 were also not posted at the facility.

2. QA Programs KGL does not presently have, and has never had, a quality assurance program in place meeting either NCA 3800 or 10 CFR Part 50 Appendix B. There are also no quality assurance or quality control personnel, nor are there any written procedures or instructions that employees can refer to for guidance. All instructions are verbal and daily activities are performed in a manner which has evolved from past experience. The organiza-tional structure and operational practice of the firm has not changed since its inception. At the time of this NRC inspection, KGL did not have plans to institute any type of quality program.

It was for this reason that KGL developed the policy of shipping all nuclear orders directly from the approved supplier to their customer.

3. Record Retention KGL has established a record retention policy of three years.

This policy was adopted as a result of the physical volume of records stored for which there was no apparent need. It was therefore not possible to review any records (i.e., purchase orders, shipping manifests, etc.) or trace any items supplied by KGL prior to 1981-1982, because of the lack of documentation.

4. Watts Bar The Watts Bar Nuclear Plant in Rhea County, Tennessee received unmarked ASTM A 307 bolts from five different suppliers in 1975.

Three of the five suppliers are no longer in business. KGL is one of the two remaining suppliers still operating. This itsoection

ORGANIZATION: Kenneth C. Lilly Fasteners, Inc.

Newark, Delaware REPORT INSPECTION N0.: 99901014/85-01 RESULTS: PAGE 4 of 6 of KGL was conducted to assess the adequacy of control over material traceability due to the problem of unmarked bolts at Watts Bar. It was found that KGL does not presently have and has never had a quality assurance program, nor are there written procedures to govern the daily activities of the firm. Records are retained for a period of three years. It was therefore not possible to trace any orders shipped in 1975. During a tour by the NRC inspectors of the KGL warehouse in Newark, Delaware on May 21,1985 the facility was found to be clean and orderly with all materials packaged or provided with adequate protection from damage and environmental effects. It was confirmed by the KGL executive vice president that it would not be possible to trace a particular item in the warehouse back to its corresponding paperwork (i.e., a KGL purchase order, shipping manifest, certi-fications,etc.) It has been KGL policy to have all nuclear orders shipped directly from the material manufacturer / supplier to their customer, nuclear grade material does not enter the KGL facility.

It could not be verified that adequate material traceability controls had been maintained over the ASTM A 307 bolts supplied to Watts Bar by KGL in 1975.

E. PERSONS CONTACTED

  • Gary K. Lilly, President, Kenneth G. Lilly Fasteners, Inc.

Richard A. Rochford, Executive Vice President, Kenneth G. Lilly Fasteners, Inc.

  • Attending exit meeting F. DOCUMENTS EXAMINED
1. Purchase Order from Carolina Power and Light Company dated 1/20/84.
2. Purchase Order from KGL to fill above order.
3. Purchase order from Carolina Power and Light Company dated 3/24/82 for 4 items. Invokes QA program, 10 CFR Part 21 and NDT requirements.
4. KGL purchase order dated 3/29/82. Invokes same requirements by reference to " attached" QA requirements.

ORGANIZATION: Kenneth G. Lilly Fasteners, Inc.

Newark, Delaware REPORT INSPECTION NO.: 99901014/85-01 RESULTS: PAGE 5 of 6

5. Daniel Construction Company purchase order dated 1/5/82 - 4 items.
6. Daniel Construction Company purchase order dated 8/3/82 - 5 items.
7. Daniel Construction Company purchase order dated 7/2/82 - 1 item.
8. Carolina Power & Light purchase order dated 12/31/81 and 3/24/82

- 4 items - request for quotation which resulted in referenced P.O.

9. Packing list from KGL dated 10/12/82 which indicates items shipped direct from B&G to CP&L.
10. Thirty-two purchase orders - 18 CP&L, 14 Daniel Construction Company - all comercial grade items.
11. Carolina Power & Light purchase order dated 9/29/82 for Brunswick Plant - non-safety-related components.
12. Carolina Power & Light purchase order dated 1/20/84 for Brunswick Plant - non-safety-related components.
13. Certified Material Test Reports and Certification of Compliance dated 9/10/82 for base material and non-destructive tests performed on nuclear material.
14. 16 estimates from KGL to Carolina Power & Light.
15. 4 estimates from KGL to Daniel International (Canada) Ltd.
16. Purchase Order from Daniel International dated 3/30/80; invoices, shipping manifests.
17. Purchase Order from Daniel International dated 4/7/82.
18. Purchase Order from Daniel Construction dated 6/1/82.
19. Purchase Order from Daniel Construction dated 6/4/82.
20. 2 estimates from KGL to Daniel Construction.

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' ORGANIZATION: Kenneth G. Lilly Fasteners, Inc.

Newark, Delaware REPORT INSPECTION NO.: 99901014/85-01 RESULTS: PAGE 6 of 6 1

21. Purchase Order from Daniel Construction for 5 items dated 9/10/82.
22. 2 Purchase Orders from Daniel Construction & KGL C0C dated 8/5/82 and 4/16/82.
23. KGL estimate and shipping manifest for 3 items.
24. Estimate from KGL to Daniel Construction, KGL shipping manifest and C0C dated 5/13/82.
25. Daniel Construction request for quotation dated 4/19/82.
26. TVA " Invitation to Bid".
27. B&G Manufacturing Company Inc. QAM dated 12/7/77.
28. CP&L Purchase Order to KGL dated 3/24/82.

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