. .

|

U.S. NUCLEAR REGULATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMENT

REGION IV.

Report" fio. 99900214/81-01 Program No. 51300

Company: Anderson Greenwood and Company,

5425 South Rice Ave.Houston, Texas 77081

Inspection Conducted: March 23-26, 1981,

Inspector:. / // 7Y [

Wm. O. Kelley, G ntractor pspector - Mecnanical Engineer DateReactive Inspection SectionVendor Inspection Branch

4 /2. 3 /r/Approved. eI. Barnes, Chief DateReactive Inspection SectionVendor Inspection Branch

Summary

Inspection on March 23-26, 1981 (99900214/81-01)

Areas Insoected: Implementation of 10 CFR Part 50, Appendix B and applicablecodes and standards including; previously identified items, design document control;evaluation of supplier performance; review of special welding applications;machining; testing of completed products and audits. A genet; review was alsomade of the vendor's activities.

The inspection involved 27 inspector-hours on site..

Results: In the eight areas inspected, no nonconformances or unresolved itemswere identified.

gog2pE N9 R.

99900214._ .. . - . __ _ _ _ _ _ . . . - - _ . ,

o .

2

DETAILS

A. Persons Contacted

Anderson Greenwood and Company (AGCo).

C. 0. Alstadt - Quality EngineerR. A. Bolter - Buyer

*G. C. Donogan - Quality Assurance Manager.*B. Loftin - Quality Control ManagerC. Nickles - Welding SupervisorJ. Parks - Quality Assurance Specialist

*F. Pizzitola - Vice President Quality AssuranceP. Ritter - Welding and Assembly ManagerP. Smith - BuyerJ. W. Spahr - Product EngineerJ.'A. West - Manager of Engineering

Commercial Union Insurance Comeanies

Benito N. Juarez - Nuclear Shop Inspector

* Denotes those persons who attended the Exit Interview(See paragraph J).

B. General Review of Vendor's Activities

1. There has been no change in the status of the ASME issued Certificatesof Authorization reported in NRC-IE Report Number 99900214/80-1.

2. The authorized inspection agency is Commercial Union InsuranceCompanies. The authorized nuclear inspector is a itinerant inspector.

3. AGCo's contribution to the nuclear industry represents approximatelyfive percent of its total workload.

C. Previously Identified Items

(Closed) Deviation (Report Number 9E900214/80-01, Item A.).Contrary to Criterion II of Appendix B to 10 CFR Part 50 and Section 1.7of the ASME accepted Quality Assurance Mar.ual, there was no evidence thatthe Director, Quality Assurance had prepared and approved an outline orother guidance for conducting or otherwise controlling the training program.

The inspector verified that AGCo had prepared, approved and issued QualityProcedure Directive QPD No. 1-2, Revision 0, " Training Program Outlinefor Those Persons Whose Activities Affect Quality of Nuclear Products,"in accordance with the requirements of the ASME ar.epted Quality AssuranceProgram.

. . _. . -- -- .-. _ _ .

4

. .

3

(Closed) Deviation (Report Number 99900214/80-01, Item B). Contrary toSubsections N8-4367 and NC-4367 of Division 1 to Section III of the ASMECode, there was no evidence that a procedure had been developed to controlvisual inspections, which specified inspection methods, aids, illumination,techniques and acceptance standards.

,

The inspector verified that AGCo had prepared, approved, and issuedQuality Procedure Directive QPD No. 5-7, Revision 0, " Requirementsfor and Mechanics of Performing Visual Inspection of Welds Prior toPerforming Liquid Penetrant or Magnetic Particle Examinations," inaccordance with the requirements of the ASME accepted Qrality AssuranceProgram.

D. Design Document Control

1. Objectives

The objectives of this area of the inspection were to ascertainwhether procedures had been developed and properly implementedto control the review, approval, release and issuance, of designdocuments in a manner consistent with NRC rules and regulations,and the vendor's commitments in the ASME accepted Quality AssuranceProgram.

2. Method of Accomolishment

The objectives of this area of the inspection were accomplished by:

a. Review of the following in the ASME accepted QA Manual, Revision B:

(1) Section 3, " Design Control," and~

(2) Section 4, " Document Control";

to verify that the vendor had established procedures toprescribe a system for design documentation control.

b. Review of the following procedures:

(1) Engineering Design Standard, DIO Issue Date January 22, 1979," Valve Design & Documentation Checklist Preparation," and

(2) Policy Memo 1-79, "A Procedure for Engineering Changes,"

to verify that they had been prepared by the designatedauthority,. approved by management, and reviewed by QA.

c. Review of the documents listed in paragraphs a. and b. to verifythat provisions were made for identification of personnel responsible

_

, .. .

:

4

for preparing, reviewing, approving, and issuing designdocuments; and that the review and approval of significantchanges were performed by the se;ne personnel. Also to ascertainwhether minor changes to design documents, that do not requirereview and approval, are identified.

,

d. Review of Valve Design C1'ecklist for Sales Order Nos. 94.0232through -8, to verify that the distribution lists are currentand that the proper documents are identified, accessible, andare being used.

e. Interviews of personnel to verify that they were knowledgeablein the procedures applicable to design document control.

3. Findings

a Within this area of the inspection, no nonconformances orunresolved items were identified.

b. The inspector verified that procedures had be#4 iveloped andproperly implemented to control the review, approval, releaseand issuance of design documents in a manner consistent with NRCrules and regulations, and the vendor's coraitments in *.heASM2 accepted Quality Assurance Program.

E. Evaluation of Supplier Performance

1. Objectives

The objectives of this area of the inspection were to yeri'y that:'

a. Procedures had been prepared and approved by the vendorto prescribe a system for evaluation of supplier performance,which is consistent with NRC rules and regulations and the.

vendor's commitment: in the ASME accepted Quality AssuranceProgram.

b. Procedures for evaluation of supplier performance were beingproperly and effectively implemented by the vendor.

2. Method of Accomplishment |

l

The objectives of this area of the inspection were accomplished by:

a. Review of the following documents:

; (1) ASME accepted Quality Assurance Manual, Revision B,Section 16, " Vendor Surveillance," and

1.

(2) QPD No. 3-4, Rev. O, "Subvendor Selection and Evaluation,"

|

||

_ - _ _ _ _ _ . _ _ _ . _ _ _ _ . . _ _ _ _ _ ,_

. . i

5

to verify the vendor had estaolished procedures for effectingevaluation of suppliers, that were consistent with NRC rules andCo'ie requirements.

b. Review of six sets of documents applicable to three suppli.ersto verify that procedures and necessary procurement documentswere available to the persons responsible for performing thequality affected activities, and that the procedures were properlyimplemented.

c. Interviews with personnel to verify tnat they were knowledgeablein the procedures applicable to evaluation of the suppliers' per-formances.

3. Findings

a. Within this area of the inspection, no nonconformances orunresolved items were identified,

b. The NRC inspector verified that procedures had been prepared andapproved by the vendor to prescribe a system for evaluationof supplier performance, which were consistent with NRC rules andregulations and the vendor's commitments in the ASME acceptedQuality Assurance Program.

F. Revi_ew of Soecial Welding Acolications

1. Ob_iectives

The objectives of this area of the inspection were to verify thatspecial welding applications (e.g. cladding, hard surfacing, sealwelding, and weld repair without postweld heat treatment) canformwith the additional requirements established by ASME Code 5. actionsIII and IX, and the vendor's commitments in the ASME accepted QualityAssurance Program.

2. Method of Accomolishment

The objectives of this area of the inspection were accomplished by:

a. Review of the following in the ASME accepted Quality AssuranceManual, Revision B:

(1) Section 5, " Production Control Process," and

(2) Section 10, " Welding," ;

1

1

1

. .- - I

_

. .

6

to verify the vendor had established procedures to prescribea system for the development and qualification of specialwelding specifications, and for qualifying welders and/orwelding machine operators.

'

b. Review of N05-9032-026, Revision A, " Welding Procedure - FrictionProcess", to verify that the special requirements governing specialwelding application procedures and performance qualificationimposed by the ASME Code regarding test sample size, examinationof test sample, and special essential variables are satisfied.

c Interviews with personnel to verify that they were knowledgeablein the procedures applicable to canopy welds.

3. Findings

a. Within this area of the inspection, no nonconformances orunresolved items were identified.

b. The inspector verified that the special welding specificationconforms with the requirements established by ASME Code CaseN-55(1609-1) and the vendor's commitments in the ASME acceptedQuality Assurance Program.

G. Machininq

1. Objectives

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

system of manufacturing which meets NRC rules and regulationsand the vendor's commitments in the ASME accepted QualityAssurance Program.

.

b. The controlled system of manufacturing was effective inasst ring product quality.

2. Method o' Accomolishment.

The objectives of this area of the inspection were accomplishedby:

Review ef the following in the ASME accepted Quality Assurancea.Manua!, Revisica 8:

(1) Section 4, " Document Control,"

.

g: 3c

O. .

7

(2) Section 5, " Production Control Process", and1

(3) _Section 9, " Process Inspection,"

te verify that procedures had been established to prescribea control system of operation.

b. Review of the following procedures:

(1) No. 5-9020-025, Revision 0, " Procedure for UpgradingCommercial Material fer Sclear Applications",

(2) No. 5-9085-003, Revision B, " Work Instruction ProcedureIssuing Partials and Replacemei t. Parts to Assembly WorkOrders", and

(3) No. 5-9085-006, Revision B, " Work Instruction Procedure -Receipt and Issuance of Nuclear Material;"

to verify that they had been prepared by the designated authority,approved by management, reviewed by QA, and are consistentwith NRC rules and regulations, and the vendors commitmentsin the ASME acceptad Quality Assurance Program.

c. Review of the following documents in eight shop orders:

(1) Operation and routing sheets,,

(2) Drawings,

|(3) Receiving Logs, and#

(4) Certified Material Test Reports,

to verify that they provided for: (a) drawing / document controlin the shop; (b) part identification and traceability; (c) in-process and final inspections; (d) identification and segregationof defective items; (e) resolution for nonconforming items; and(f) gages and measuring devices being under a controlledcalibration system.

d. Examination of three representative samples of finished machinedparts, to verify that they were properly identified and machinedto conform to drawing and specification requirements.

e. Examination of the dccuments and drawing contained in the3

shop traveler packet for the following parts:

(1) Bellows Assembly - Owg. D N04-4024-540, Revision E, j1

(2) Valve Parts for Assembly - Dwg, 0 N04-4024-530, Revision E, ji

. .

/I

8<

(3) Completed Valve - Dwg. D N03-6375-640, Revision E,

to verify compliance with applicable documentation requirements.

3. Findings,

a. Within this area of the inspection, no nonconformances orunresolved items were identified.

b. The inspector verified that:

(1) The machining operations were performed under a controlledsystem of manufacturing, which meets NRC rules and regulationsand the vendor's commitments in the ASME accep.ed QualityAssurance Program.

I(2) The controlled system of manufacturing was ef'ective in

assuring product quality.

H. Testing of Comoleted Products

1. Objectives:

The objectives of this area of the inspection were to verify that,

'

products are assembled in accordance with approved procedures anddrawings, all material complied with the specifications, and thefunctional test of the products were performed.

2. Method of Accomplishment

The objectives of this area of the inspection was accom'plished by:

a. Review of hydrostatic and seat leakage tests documentation forShop Orders 94.0186-01 and 94.0180-06 to verify:

| (1) Test procedures and/or instructions were available atthe test station and had been approved by engineering andquality assurance.'

.

(2) The tests had been performed in accordance with the pro-cedures and/or instructions.

4 (3) Changes made to a test procedure had been approved by engine-ering and quality assurance and they had been followed.

: (4) The test data was documented and dispositioned in accordancewith the procedure and/or instructions.

-- _ . . - - - --_ -. - - . . _ - - - - - . -

. .

9

(5) The limits of acceptability of test results had beenestablished and were being used for rejection or acceptanceof the product.

b. Review of test instrumentation used to verify they were as,specified by the procedure and/or instruction and were incalibration.

c. Review of drawing procedures and assembled valves for ShopOrder 94.0186-01 and 94.0180-06 to verify that the valves hadbeen assembled in accordance with approved drawings andprocedures and the material complied with the specifications.

3. Findings

a. Within this area of the inspection, no nonconformances orunresolved items were identified.

I b. The inspector verified that products were assembled in accordancewith approved procedures and drawings, all material complied withthe specifications, and the hydrostatic and seat leakage tests

j of the products were performed.

| I. Audits|

| 1. Objectives1

| The objectives of this area of the inspection were to verify that:i

! a. Procedures had been prepared and approved by the vendor toprescribe a system for auditing, which is consistent with NRCrules and regulation and the vendor's commitments in the ASMEaccepted Quality Assurance Program.

! b. The audit procedures are being properly and effectively iniple-| mented by the vendor,l

2. Method of Accomplishment|

| The objectives of this area of the inspection were accomplished by:

a. Review of the following in the ASME accepted Quality AssuranceManual, Revision B:

|! (1) Section 7, " Procurement,"

(2) Section 16, "Vencor Surveillance," and

(3) Section 17, " Quality Assurance Audit,",

,._

__-

,

. .

10

to verify the vendor had established procedures which prescribea system for audits.

b. Review of the following documents:

(1) QPD No. 3-4 Revision 0, "Subvendor Selection and Eval'uation,"and

(2) "1981 External - Internal Audit Schedule,"

to verify that they had been prepared by the de;ignTtedauthority. approved by responsible management, and reviewedby the qual |ty assurance function.

Review of the documents referenced in paragraphs a. and b., toc.verify that they: (1) identify the organization responsiblefnr auditing; (2) establish the audit personnel qualifications;(3) provide for training and indoctrination of audit personnel;(4) establish the essential elements of the audit system;(5) provide for audit schedules to assure coverage of all elementsof the quality assurance program; and (6) require reporting tothe audited organization and performance of follow up on requiredcorrective actions by the auditing organization.

d. Review of six audit reports to verify that the procedures andthe necessary audit system documents were available to the audit-irt personnel; and that the procedures were being properly andeffectively implemented.

e. Review of Approved Suppliers List..

3. Findings

a. Within this area of this inspection, no nonconformances orunresolved items were identified.

b. The inspector verified that:

(1) Procedures had been prepared and approved by the vendor,which prescribe a system for auditing consistent withNRC rules and regulation and the vendor's commitments inthe ASME accepted Quality Assurance Program.

(2) The audit procedures were ceing properly and effectivelyimplemented by the ver.cor.

J. Exit Interview

At the conclusion of the inspection on March 26, 1981, the inspector metwith the company's management, identified in paragraph A, for the purpose

_ _ . _ _ .

c .-- ,

. .

11-

of informing them as to the results of the inspection. During this meeting,management was informed no nonconformances or unresolved items were identi-fied.

The company's management acknowledged the inspector's statement and-had no additional consents.

.

|

|

|

- .-- . . . - _ , ._- . _ .. . _ - - . -_.