ML20147B971

QA Program Insp Rept 99900331/78-02 on 780626-30 During Which Items on Noncompliance Were Noted:Machining Under Uncontrolled Conditions

ML20147B971
Person / Time
Issue date:	08/16/1978
From:	Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20147B887	List: ML20147B880 ML20147B903 ML20147B936 ML20147B952 ML20147B971
References
REF-QA-99900331 NUDOCS 7812180102
Download: ML20147B971 (10)

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k VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION  !

0FFICE OF INSPECTION.AND ENFORCEMENT  !

REGION IV  !

Report No. 99900331/78-02 Program No. 44070 Company: Excelco Developments, Inc.

Post Office Box 230 l Silver Creek, New York 14136 '

Inspection Conducted: June 26-30, 1978 Inspector: 'W Mh

_W.' M. McNeill, Condractor Inspection, Vendor 8 - /J-7 f Date Inspection Branch i

j Approved by: 'W- 4Lb / g /r-JP -

Df E. Whitesell, Chibf, Components Sect on I, Date l Vendor Inspection Branch 1 i

Summary i

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Inspection on June 26-30, 1978 (99900331/78-01) j i

Areas Inspected: Implementation of 10 CFR 71 Appendix E, Certificate of i Compliance, Safety Analysis Report, and applicable codes and standards, j including: action on previous inspection findings; machining; procurement; j auditing; and training. The inspection involved thirty (30) inspector- )

hours. I Results: In the four (4) areas inspected, no apparent deviations or unresolved i items were identified in one (1) of these areas. The following seven (7) f deviations and one unresolved item were identified in the remaining areas. j Deviations: Machining - the program did not provide for suitably controlled conditions particulary for control of cutting oils in accordance with NRC J and ASME requirements (Enclosure, Item A.). Machining - inspection reports  !

did not record the gages used in inspection in accordance with NRC and l the QA Manual (Enclosure, Item B.). Machining - weld parameter sheets  ;

documented that welding did not comply with the UPS in particular for  !

current and filler metal in accordance with NRC and ASME requirements i (Enclosure, Item C.). Procurement - subvendors were not required to provide )

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a'QA program consistent with Appendix E in accordance with NRC and QA- .

Manual ~(Enclosure, Item D.)~ Procurement

. documentation' did not demonstrate that purchased materialsf conformed to procurement- documents in accordance

-with NRC and the QA: Manual. 'In particular vendors'used were.not qualified, there was, no' evidence.that' balsa conformed to the-purchase order, and valve and safety heads Purchase Requsitions did r.ot contain all the >

necessary information (Enclosure, Item E.). Procurementf : receiving inspection-for safety heads, fire' valves, etc., was.not prescribed by .

documented instructions in accordance-with NRC and QC procedure requirements (Enclosure, item F.).- Audits -: scheduled audits were not performed nor were-

, there records of:qualificationLfor- unscheduled audit personnel in accordance:  ;

with NRC.and QA Manual requirements- (Enclosure, Item G.). ,

- Dnresolved Item: Ma' chining -'there is a. question as to.what should be the

-inspection requirements on threads; -(Details Section,:C.3.b.).

Other Significant Findings: Nuclear Assurance Corporation has identified  :

to the NRC:that Excelco is its fabricator. Nuclear Assurance Corporation

' has stated in its Certificate of Compliance ~and Safety Analysis Report ,

that Excelco will comply with Appendix E.- Appendix E has been pasted on to Excelco by the Nuclear Assurance Corporation contract as part of the design specification.

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' DETAILS SECTION c

A. Persons' Contacted

• W..D. Abbott, Chief Engineer, Excelco

• L. A. Brooks, President, Excelco' . i D. A.' Jones, Design-Draftsman,'Excelco

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L-G. P.. Mcdonald, Records, Excelco . ,

F. I. McLean, Chief Inspector, Excelco:

• M. M. Pulawski, -QA Manag'er, Excelco J. P. Shaw, Purchasing Agent, Excelco .

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• C, H. McDonnell,' Chief, Nuclear Engineer, United States Testing Co. ,

• C, C. Hoffman, Manager of Cask.0perations, Nuclear Assurance Corporation '

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• Denotes 1those attending the Exit Interview.

B. Action on Previous Inspection Findings (Closed) Deviation (ReportNo.78-01): The mandatory edition and addenda was not in-use. Excelco has been instructed by. Nuclear Assurance

, Corporation to use the mandatory code for fabrication and inspection.

(Closed) Deviation (Report No. 78-01): Shop travelers did not identify the revision. number of documents and were not issued prior to work.

A review of current: travelers established that the revision numbers are identi fied. .

(Closed). Deviation (Report No. 78-01): Welding proceduras were not followed. The welding procedures in question have been revised and approved for use. i (Closed) Deviation (Report No. 78-01): Code requirements on removal of

~ temporary attachments were not followed nor covered in procedures. The requirements have been addressed in a QC procedure and the procedure has been implemented.

C. Machining

1. Objectives ,

The objectives of this area of ~ the inspection were to verify that machining operations.are performed under a controlled.

system of mann'acturing which meets the requirements of'applic-able NRC ASME code and contract requirements. The objectives also'were to verify that the above' system is effective in assuring product quality.

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2. Method of Accomplishment The preceding objectives were accomplished by:

a. Verification- that machining is controlled by review of the travelers for five (5) parts currently being machined. These travelers were for part numbers 1030, 1032, and 1033.

b. Verification that only proper documents are available and being used by review traveler package and the drawing found in the shop.

c. Verified that changes are handled properly by review of several minor changes to the above travelers,

d. Verified that identification and traceability was properly maintained on the above parts by inspection of the parts identification.

e. Verified that some inspections were conducted in accordance with the planning by review of the inspection reports, penetrant inspection reports, and the above travelers.

f. Verified that provisions have been established for nonconformances by. review of the QA Manual, Section 13.

9 Verified that procedures have been established for corrective action by review of the QA Manual, Section 13.

h. Verified that some of the gages are under a gage calibration system by review of the five (5) gages found at the work station.

i. Verified that some measures are implemented to afford protection to the finish of parts by observation of the above parts.

j. Verification that. machining are specified and followed by observation of the machining of the above parts.

k. Verification that finished parts are properly identified and in conformance with the drawing and specification. Except as noted below.

1. Verification that records of parts document compliance with requirements by review of the above travelers, inspection reports, tags and weld parameter sheets.

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l3. Findings-

a. Deviation See Enclosure,; Items.A thru C.

b. Unresolved Items j

The' threading requirements which are established on drawing:

- E10080 are American Standard Association (ASA) B1.5.

Threads were' not inspected-in accordance with ASA Bl.5 in-that the maximum allowable. diameters are not checked-because Excelco does not have-a "not go" type gage. -

ASA .Bl.5 requires- that production type threads be inspected 'i with "go". and "not go" type gages. However there-is,a question'if the designer intended to require the.. threads l to be inspected to these requirements. Nuclear Assurance I Corporation, the designer, will have to .more clearly 1 specify the inspection requirements of these threads. It 1 was also noted that the "go" gage that was used for final i acceptance had not been checked in accordance with ASA .I Bl.5 requirements in that-pitch diameter, out of round, i taper, etc. , were not verified l l

D. Proc.nrement'

1. Objectives j The objectives of this area of tne inspection were to verify l that:

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a. Procedures have been established for pre-contract and ']

periodic evaluation of suppliers and that these procedures are consistent with applicable regulatory, NRC, ASME code and contract requirements.

b. The above procedures are adhered to in the awarding of specific contracts for parts and services which are included '

in the s. cope of this. inspection program.

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c. Procedures have been established for the preparation and review of' procurement documents and that these procedures '

are consistent with applicable regulatory requirements and the manufacturers overall-QA plan.

d. The above. procedures'are adhered to in the procurement of materials, parts or services which are included in the scope of'this program.-

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2. Method of Accomplishment The preceding objectives were accomplished by. I

a. Verification that procedures'are established and implemented on qualification of supplier by review of the QA Manual, Section 3 and the records of six-(6) subvendors. The six ,

include' lead' pouring,;vaIves, heads,' thread parts, and i materials e.g. wood and steel.-

.b. Verification that-the procedures include technical and 1 quality requirements in.-the evaluation by review of the' l checklists used for qualification of the above. suppliers.

c. Verification that method of evaluation was consistent in l some cases with regulatory code and contract requirements-by review of the audits of the above vendors and the ASME Quality _ System certificate.

d. Verification that criteria are established for determining l the method of evaluation by review of QC procedure QC-0206 l dated January-19, 1968.

e. Verification that procedures are issued and implemented on the performance of source evaluation by review of the audit -i reports of the'above six (6) subvendors.

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f. Verification that the auditors used in the above were qualified by review of the training records of the above  ;

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g. Verification that periodic. reevaluation is~ performed by review l of the current and previous audits of each of the above subvendors.

h. Verification .that subvendor status is documented by review of the ' current' Qualified Vendors list.

i. Verification that some procurement documents referenced technical I and quality-requirements by review' of the purchase orders to j

-the above six vendors. '

j. Verification that ' procurement documents are reviewed by review of QA and Engineering sign-off of the above purchase orders.  :

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'k. Verification that changes asL a result of the' bid are.some itime reviewed by. review of the requests for quotes for  !

the above purchase. orders. '

1.- Verification that procurement documents are released and .

distributed properly by comparison.of the P.O. files 'on the 4

above in~ quality control and purchasing.-

m. -Verification that changes to purchase orders are reviewed by ' inspection of .the P.O. changes to- the' above' P.O. 's

n. Verification- that P.O. include control of documentation and  !

hold points by review of purchase: order.on lead pouring. ]

Verification of the receiving inspection planning in some l cases was consistent with the procurement documents.

o. Verification that_ procedures are established for control of  !

subvendor nonconformances. by review of the QA Manual, I Section 13 and QC procedure QC-0206.

p. Verification that procedures are established for subvendor corrective action by review of the QA Manual, Section 13. and

' QC procedure QC-0206.

3. Findings. '

It was established that three-(3) of the six (6) vendors sampled were not given evaluation and selection nor were -

they on the Qualified Vendors. List. There was no documentation i that balsa, some of which has been installed, conformed to the density and Mil-Standard stated in the purchase order.

Purchase Requisitions for fire valves'did'not contain.modifica-tion instructions found on NAC drawing E100E80. The safety

. heads' ordered were not the same part number identified or the.NAC drawing E10080.. Drawing E10080 is part of the design specification and the certificate of ccnformance.

a. Deviations See Enclosure', Items D thru F. '

, b. Unresolved Items None. *

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1 E. . Auditing i 1.- .0bjectives TheLobjectivesLof this; area;of the. inspection were to. verify that procedures-have been prepared and approved by the company to prescribeLa fsystem for auditing'which is consistent with the commitments of the_ QA Program.- The ' objectives were also~.to -

' determine that the audit procedures are being properly. and effectively implemented by-the company. I

2. Method ~of Accomplishment The preceding. objectives were accomplished by:

a. Verification that audit policy is identified by review of the. i QA Manual, Section 12.

b. Verification that responsibilities and authority are documented by review of the.QA Manual.

, c. Verification that auditors are independent of audit subject by review 'of. three (3) unscheduled audits performed .in- cask f abrication.

d. Verification that auditor qualification requirements are established and documented by review of the QA Manual.

e. Verification that auditors are qualified by review of the '

training records of two (2) of the four (4) auditors of the '

above' audi ts. .

f. Verification that the above records are in conformance with the QA Manual.

g. Verification that the audit system provides the authority, manpower, etc., by review of the above audits reports

h. Verification that audit planning is established'by review of the audit checklist used in auditing.

i. Verification that unscheduled are performed by review of thelthree-(3) unscheduled audits. ,

-j. Verification _that check,'ists are available by review of the completed checklist. of the above ' audits.

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k. Verification that procedures address nonconformances by.

review of QA Manual.

1. Verification that audits are reviewed by management by checking the distribution of the above reports.

m. Verification that records are stored properly by review of the above records.

3. Findings There was no schedule established of cask fabrication audits.

It was noted that two (2) of the four (4) auditors who performed three (3) unscheduled audits which covered some cask fabrication had no records of their auditor qualification. These audits were on Receiving Inspection and Manufacturing both dated March 24, 1978.

a. Deviations See Enclosure, Item G.

b. Unresolved Items None.

F. Training

1. Objectives The objectives of this area of the inspection were to verify that procedures have been prepared and approved by the company to prescribe a system for personnel training activities which is consistent with the commitments of the QA Program. The objectives also were to determine that the procedures for training activities are being properly and effectively implemented by the company.

2. Method of Accomplishment The preceding objectives were accomplished by:

a. Verification that the training program is described and covers the proper personnel by review of the QA Manual, Section 15.

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b. Verification that the training detailed in the QA Manual is implemented by review of the training records. -

c. Verification that the inspection personnel is documented by review of the inspection personnel records. i

d. Verification that NDE personnol are trained.in accordance with SNT-TC-1A by review of the NDE personnel record.

3. Findings

a. Deviations .,

None. .

b. Unresolved Items  ;

None, l G. Exit Interview  !

The inspector met with management representatives (denoted in paragraph A) at:the conclusion of the inspection on June 30, 1978. The inspector summarized the scope and findings of the inspection. The management representatives had no comment in response to each item l discussed by the inspector. l I

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