NUREG-0040 

Vol. 21, No. 4 

Licensee Contractor 

and Vendor Inspection 

Status Report 

Quarterly Report 

October - December 1997 

U.S. Nuclear Regulatory Commission 

Office of Nuclear Reactor Regulation 
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NUREG0040 

Vol. 21, No. 4 

Licensee Contractor 

and Vendor Inspection 

Status Report 

Quarterly Report 

October - December 1997 

Manuscript Completed: March 1998 

Date Published: April 1998 

Division of Reactor Controls and Human Factors 

Ofice of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 
~~~ ~~ 

NUREG-0040, Vol. 21, No. 4 has been 

reproduced from the best available copy. 
ABSTRACT 

This periodical covers the results of inspections performed between October 1997 and 

December 1997 by the NRC's Quality Assurance, Vendor Inspection and Maintenance Branch 

that have been distributed to the inspected organizations. 

... 

111 

CONTENTS 

PAGE 

Abstract ....................................................................................................................... iii 

Introduction ................................................................................................................. vii 

Inspection Reports ...................................................................................................... 1 

Astro Nuclear Dynamics, Inc. (99901324/97-01) ....................... 2 

Bethel Park, PA 

Gould’s Pumps, Incorporated 

Seneca Falls, NY 

(99900732/97-01) ....................... 18 

Nova Machine Products Corporation (99901052/97-01) ....................... 29 

Middleburg Heights, OH 

Select Generic Correspondence on the Adequacy of Vendor .................................... 50 

Audits and the Quality of Vendor Products 

V 

INTRODUCTION 

A fundamental premise of the U. S. Nuclear Regulatory Commission (NRC) licensing and 

inspection program is that licensees are responsible for the proper construction and safe and 

efficient operation of their nuclear power plants. The Federal government and nuclear industry 

have established a system for the inspection of commercial nuclear facilities to provide for 

multiple levels of inspection and verification. Each licensee, contractor, and vendor participates 

in a quality verification process in compliance with requirements prescribed by the NRC's rules 

and regulations (Title 10 of the Code of Federal Regulations). The NRC does inspections to 

oversee the commercial nuclear industry to determine whether its requirements are being met 

by licensees and their contractors, while the major inspection effort is performed by the industry 

within the framework of quality verification programs. 

The licensee is responsible for developing and maintaining a detailed quality assurance (QA) 

plan with implementing procedures pursuant to 10 CFR Part 50. Through a system of planned 

and periodic audits and inspections, the licensee is responsible for ensuring that suppliers, 

contractors and vendors also have suitable and appropriate quality programs that meet NRC 

requirements, guides, codes, and standards. 

The NRC reviews and inspects nuclear steam system suppliers (NSSSs), architect engineering 

(AE) firms, suppliers of products and services, independent testing laboratories performing 

equipment qualification tests, and holders of NRC construction permits and operating licenses 

in vendor-related areas. These inspections are done to ensure that the root causes of reported 

vendor-related problems are determined and appropriate corrective actions are developed. The 

inspections also review vendors to verify conformance with applicable NRC and industry quality 

requirements, to verify oversight of their vendors, and coordination between licensees and 

vendors. 

The NRC does inspections to verify the quality and suitability of vendor products, licenseevendor interface, environmental qualification of equipment, and review of equipment problems 

found during operation and their corrective action. When nonconformances with NRC 

requirements and regulations are found, the inspected organization is required to take 

appropriate corrective action and to institute preventive measures to preclude recurrence. 

When generic implications are found, NRC ensures that affected licensees are informed 

through vendor reporting or by NRC generic correspondence such as information notices and 

bulletins. 

vii 
This quarterly report contains copies of all vendor inspection reports issued during the calendar 

quarter for which it is published. Each vendor inspection report lists the nuclear faciilities 

inspected. This information will also alert affected regional offices to any significant problem 

areas that may require special attention. This report lists selected bulletins, generic letters, and 

information notices, and include copies of other pertinent correspondence involving vendor 

issues. 
INSPECTION REPORTS 
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. #)566oool 

I 

November 19, 1997 

Mr. Paul Heffeman 

Astro Nuclear Dynamics Inc. 

2901 Industrial Blvd. 

Bethel Park, PA 15102 

SUBJECT: NRC INSPECTION REPORT 99901 324/97-01 AND NOTICE OF 

NONCONFORMANCE 

Dear Mr. Heffeman: 

On August 26-29 and October 30, 1997, the U.S. Nuclear Regulatory Commission (NRC) 

performed an inspection at the Astro Nuclear Dynamics Inc. (ANDI) facility. The enclosed 

report presents the findings of that inspection. 

The inspection was conducted to assess specific attributes and implementation of the AND1 

quality assurance (QA) program to ascertain whether it met NRC requirements. The inspector 

assessed ANDl's conformance to customer procurement requirements, commercial1 grade 

dedication activities and compliance with Part 21 of Title 10 of the Code of Federd 

mlations. The inspector also assessed licensee monitoring of the quality of itemis purchased 

from ANDI. 

During the inspection, the inspectors determined that AND1 did not adequately implement its 

quality assurance (QA) program to comply with NRC requirements imposed upon AND1 by its 

customers. Specifically, AND1 did not (1) assure that personnel designated to approve quality 

assurance documents were properly trained and certified, and (2) assure that products 

designated as safety-related were stored in an appropriate environment. 

These issues are cited in the enclosed Notice of Nonconformance (NON), and the 

circumstances surrounding them are described in detail in the enclosed report. You are 

requested to respond to the nonconformance 97-01-02 and should follow the instructions 

specified in the enclosed NON when preparing your response. You are not requested to 

respond to nonconformance 97-01-01 because your corrective actions were found ;acceptable 

during the October 30,1997, part of inspection. 

In a September 2, 1997, letter to the NRC, AND1 stated that it was taking Corrective actions to 

improve its QA program to enhance interface and coordination with its customers, and evaluate 

the adequacy of the AND1 storage facility for protecting safety-related items. AND1 further 

stated that it plans to hire an auditing service to perform an independent annual audit of ANDl's 

QA program and its implementation. 

In addition, the inspector observed that licensee monitoring of ANDl's control of qucility did not 

identify the nonconformances described above. 

2 
Mr. P. Heffeman -2- 

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 the NRC's Public Document Room. 

Sincerely, 

Suzann&d. Black, Chief 

Quality Assurance, Vendor Inspection, 

Division of Reactor Controls and Human Factors 

Office of Nuclear Reactor Regulation 

and Maintenance Branch 

Docket No. 99901324 

Enclosures: 1. Notice of Nonconformance 

2. Inspection Report 99901 324/97-01 

3 
Mr. P. Heffeman -3- 

cc: 

Mr. James Johns 

Supervisor, Quality Services 

Duquesne Light Company 

P.O. Box4 

Shippingport, PA 15077 

Mr. Danny Leigh 

Plant Overview Supervisor 

Texas Utilities Electric Company 

Energy Plaza 

1601 Byran Street, 12th Floor 

Dallas, TX 75201-341 1 

Mr. Fred Stobaugh 

Procurement Engineer 

Texas Utilities Electric Company 

Comanche Peak Steam Electric Station 

P.O. BOX 1002 

Glen Rose, TX 76043 

Mr. Dan Poneman 

Counsel 

Hogan and Hartson 

555, 13 Street, N.W. 

Washington, D.C. 20004 
NOTICE OF NONCONFORMANCE 

Astro Nuclear Dynamics Inc. 

Bethel Park, PA 

Docket No.: 99901 324 

Based on the results of an NRC inspection conducted on August 26-29 and October 30,1997, it 

appears that certain of your activities were not conducted in accordance with NRC 

requirements: 

1. Criterion I1 of Appendix B to 10 CFR Part 50, "Quality Assurance Program," requires, in 

part, that the program shall provide for indoctrination and training of personnel 

performing activities affecting quality as necessary to assure that suitable proficiency is 

achieved and maintained. 

Paragraph 4.1 of Section 1-2, "Personnel Qualifications-Inspection and Test," Astro 

Nuclear Dynamics Inc. (ANDI) Quality Assurance Procedures (QAP), dated June 4, 

1995, requires, in part, that qualification of personnel shall be established on the basis 

of achieved technical training. 

Contrary to these requirements, the president of AND1 was responsible to assure that 

the quality of items sold through ANDl's brokerage program conformed to procurement 

documents, but was not trained for the task. 

During the October 30, 1997, inspection, the inspector noted that AND1 had 

discontinued the use of procedure CP-1 IO, "Control and Administration of Brokered 

items Purchased for Resale." Therefore, all certificates of compliance must now be 

signed by the Quality Assurance Manager. Therefore, no response is required for this 

Noncompliance. 

(Nonconformance 99901 324/97-01-01) 

2. Criterion Xlll of Appendix B to 10 CFR Part 50, "Handling, Storage, and Shipping," 

requires, in part, that measures shall be established to prevent the use of incorrect or 

defective materials, parts, or components. For particular products, special protective 

environments, such as moisture and temperature levels, shall, be provided to prevent 

damage or deterioration. 

Paragraph 8.0 of Section 13-1 , "Handling, Storage, and Shipping," AND1 QAP, dated 

June 14, 1995, requires that storage requirements be evaluated and appropriate 

controls and facilities provided to protect the material or equipment against damage, 

minimize deterioration, and prevent contamination during storage. 

Contrary to these requirements, ANDl's storage facility did not have uniform heating and 

temperature control to protect applicable safety-related items from condensation and 

corrosion. 

Enclosure I 
(Nonconformance 99901 324/97-01-02) 

Please send a written statement or explanation to the U.S. Nuclear Regulatory Commission, 

ATTN: Document Control Desk, Washington, D.C. 20555-0001, with a copy to the Chief, 

Quality Assurance, Vendor Inspection and Maintenance Branch, Division of Reactor Controls 

and Human Factors, Office of Nuclear Reactor Regulation, within 30 days of the datcs 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) the 

reason for the Nonconformance, or if contested, the basis for disputing the Nonconformance, 

(2) the corrective steps that have been taken and the results achieved, (3) the corrective steps 

that will be taken to avoid further noncompliance, and (4) the date when your corrective action 

will be completed. Where good cause is shown, consideration will be given to extending the 

response time. 

Dated at Rockville, Maryland 

this / y.fbay of November 1997 

-2- 

6 
Report No: 

Organization: 

Contact: 

Nuclear Industry 

Activity: 

Dates: 

Inspectors: 

Approved by: 

99901 324/97-01 

Astro Nuclear Dynamics Inc. 

Bethel Park, Pennsylvania 

Paul Heffernan, President 

412/851-5500 

Resale of components, machining of mechanical components, 

and seismic testing 

August 26-29, 1997, and 

October 30, 1997 

Gregory C. Cwalina, Senior Operations Engineer 

Ani1 S. Gautam, Senior Reactor Engineer 

Robert A. Gramm, Chief 

Quality Assurance and Safety Assessment Section 

Quality Assurance, Vendor Inspection 

Division of Reactor Controls and Human Factors 

and Maintenance Branch 

Enclosure 2 
1 INSPECTION SUMMARY 

Astro Nuclear Dynamics, Inc. (ANDI) holds ASME N and NPT certificates to provide 

components to the nuclear industry. ANDl's Engineering Laboratories provide safety-related 

engineering and test services to the nuclear and other industries. In addition, AND1 supplies 

surplus parts, purchased by AND1 and resold (brokered), to the nuclear industry. Brokered 

items can be sold as nonsafety-related, bought and resold as safety-related, or bought as 

commercial grade, dedicated and sold as safety-related. 

During this inspection, the inspectors assessed specific attributes and implementation of the 

AND1 quality assurance (QA) program, specifically as it applies to the supply of safety-related 

brokered and commercial grade dedication items to ascertain whether it conformed ti:, NRC 

requirements. The inspector also assessed licensee monitoring of ANDl's control of quality. 

The inspection bases were as follows: 

0 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 (10 CFR Part 50), 

0 10 CFR Part 21, "Reporting of Defects and Noncompliance," and 

0 ANDl's Nuclear Quality Assurance Procedures Manual, Revision 6, dated July 1, 1996. 

During this inspection, the inspectors noted that ANDl's Part 21 procedure did not contain the 

reporting and timeliness requirements specified in Part 21.21. This has been identified an a 

non-cited violation and is discussed in Section 3.1 of this report. In addition, AND1 did not 

conform to certain NRC requirements imposed upon it by NRC licensees. These 

nonconformances are discussed in Section 3.2. 

The inspectors observed that licensees did not identify the nonconformances noted in this 

report. Licensees' monitoring of ANDl's control of quality is discussed in Section 3.3. 

2 STATUS OF PREVIOUS INSPECTION FINDINGS 

This was the first NRC inspection of ANDI. 

3 INSPECTION FINDINGS AND OTHER COMMENTS 

3.1 10 CFR Part 21 Proaram 

a. Inspection Scope 

The inspector reviewed AND! procedure CP-906, "Identification and Reporting of 

Conditions Potentially Adverse to Nuclear Safety." The requirements of the procedure 

apply to " the identification, review and reporting of nuclear safety-related 

noncompliances, deficiencies and defects" as defined in IO CFR. The AND1 procedure 

-2 - 

8 
specifies 10 CFR Part 21.3 and other regulations, including Parts 50.55, and 50.59 as 

included in the scope. 

b. Observations and Findinas 

The inspector noted that the procedure did not contain the evaluation and reporting 

requirements specified in Part 21.21, nor did it contain the timeliness requirements. The 

inspector noted other concerns to ANDI, such as the responsibility of Procurement to (1) 

forward vendor notifications to the president, (2) discuss reported conditions with the 

employee, (3) assess the condition's significance, and (4) document action and inform 

the employee, responsibilities typically associated with engineering or QA. Further, the 

procedure requires employees to report conditions "adverse, or potentially adverse." The 

inspector pointed out that if that requirement relates to conditions adverse to nuclear 

safety, typical employees would not be able to make that determination and, thus, some 

conditions may go unreported. AND1 agreed to revise the procedure to address the 

requirements of Part 21 and the inspector's other concerns. 

c. Conclusions 

3.2 

a. 

b. 

b. 1 

The inspectors concluded that AND1 failed to include the evaluation and reporting 

timeliness requirements of Part 21 in procedure CP-906. In accordance with the NRC 

Enforcement Policy as promulgated in NUREG-1600, this was considered a minor 

violation of NRC requirements and no Notice of Violation is being issued. 

Quali tv Assurance P rocara m 

Inspection Scope 

The inspector examined the adequacy and implementation of ANDl's QA program and 

10 CFR Part 21 applicability, and assessed ANDl's conformance to customer 

procurement requirements. 

Observations and Findinas 

The inspector observed that ANDl's QA program was based on the requirements anc 

criteria of 10 CFR Part 50, Appendix B. At the time of the October 30, 1997, inspection, 

the QA program staff consisted of the Quality Assurance Manager and two other staff. 

The QA manager reported directly to the president of ANDI, and was authorized to stop 

production of a nonconforming item until the nonconforming conditions were corrected. 

Specific items examined and findings are provided in the following sections. 

Training of Personnel 

During the August 26-29, 1997, part of the inspection, the inspector noted that the 

president of AND1 was responsible for the control and administration of the sale o 

brokerage items. The president's responsibility included assuring that the brokerage 

items met applicable QA, technical, maintenance, and storage requirements. 

-3- 

9 
At that time, the sale of brokered items was accomplished according to AND1 Procedure 

CP-110, "Control and Administration of Brokered Items Purchased for Resale." The 

procedure states that a "commercial" certificate of conformance (CoC) is issued for 

brokered items. It was ANDl's contention that only commercial grade items were 

processed under CP-110, and that all safety-related items were provided under ANDl's 

Appendix B QA program. 

The inspectors review of CP-110 indicated that the procedure was intended for the resale 

of commercial grade items. However, the procedure does allow for additional procedures 

and controls if required by customer contract. The inspectors were concerned that AND1 

may inadvertently allow safety-related items to be processed under CP-I IO. For 

example, the inspectors reviewed several brokerage packages (see Section 3.4) and 

their associated documentation. The inspectors observed that, in at least two instances, 

a CoC was provided, signed by the president, which stated that Appendix B was 

applicable. AND1 was able to provide evidence that the CoCs in question related to 

commercial grade purchases (ANDI processed the orders in accordance with their 

Appendix B program merely to assure an adequate control of quality). Although the 

inspectors did not identify any CoCs for satety-related items processed in accordance 

with CP-110, the inspectors concluded that the potential existed for the use of CP-1 IO to 

process safety-related orders. Therefore, the potential existed for the president to sign 

CoCs for safety-related orders. 

Although the president was responsible for assuring that the quality of brokerage items 

sold conformed to procurement documents in accordance with CP-110, he was not 

trained for the task if those orders were to be safety-related. The inspector concluded 

that ANDl's failure to establish the qualification of personnel, as required by Criterion II, 

"Quality Assurance Program," of Appendix B to 10 CFR Part 50, constitutes 

Nonconformance 99900824/97-01-01. 

In his September 2, 1997, letter to the NRC, the president stated that he planned to 

remove himself and any other untrained personnel from performing activities related to 

implementing the ANDI QA program. During the October 30, 1997, inspection, the 

inspector observed that AND1 had abolished CP-1 IO. All purchase orders are now 

processed through the same AND1 QA program. All CoCs, whether commercial grade or 

safety-related are signed by the QA manager. Therefore, since corrective adion has 

been completed, no response to the nonconformance is necessary. 

b.2 Equipment Handling and Storage 

The inspector observed that AND1 certified items to be protected in Class B storage (e.g., 

items for AND1 job number M-1051). During the August 26-29, 1997, inspection, the 

inspector determined that ANDl's storage facility did not have uniform heating1 and 

temperature control to protect applicable safety-related items from condensation and 

corrosion, as defined in ANWASME N45.2.2-1978, "Packaging, Shipping, Receiving, 

Storage, and Handling of Items for Nuclear Plants." The inspector concluded that ANDl's 

failure to establish special protective environments, such as moisture and temperature 

-4- 

10 
levels, as required by Criterion XIII, "Handling, Storage, and Shipping," of Appendix B to 

10 CFR Part 50 constitutes Nonconformance 99900824/97-01-02. 

In a letter dated September 2, 1997, to the NRC AND1 stated that it plans to "conduct a 

Storage Evaluation Program to determine temperature and environmental conditions of 

the AND1 storage facility in order to comply with the requirements of ANWASME 

N45.2.2-1978 for Level B storage. This evaluation would be performed for a period of 60 

days and will generate data which will be utilized for any corrective actions to be taken, if 

necessary." On October 6, 1997, the president confirmed by telephone that AND1 will 

also evaluate the impact on potentially inadequately controlled components, if necessary, 

that had been certified and shipped as protected in Class B storage. 

During the October 30, 1997, inspection, the inspector noted that the evaluation program 

was ongoing. 

b.3 Control of Materials, Parts, and Equipment 

The inspector observed that AND1 maintained both safety-related and non-safety-related 

raw materials, parts, and equipment in its QA-controlled storage area. Although the 

storage area is locked and controlled by QA, the inspectors were concerned regarding 

the possibility of integrating safety and nonsafety components. In its letter dated 

September 2, 1997, to the NRC, AND1 stated that "in the future, AND1 will ensure proper 

separation and segregation of raw materials, parts and equipment based on its safetyrelated and non-safety status." In addition, AND1 plans to revise procedure CP-112, 

"Identification and Control of Materials and Items," dated September 9, 1997, to require 

physical segregation. No further concerns were identified. 

b.4 Receipt Inspections 

The inspector observed that on the basis of Paragraph 5.5 of Section 7-1, "Procurement 

Control," AND1 QAP, dated July I, 1996, receipt inspections to assure materials met the 

procurement documents were performed by QA personnel. The inspector was 

concerned that an independent assessment was not being conducted by personnel other 

than those who perform the receipt inspection. ANDl's QA manager stated that receipt 

inspections were audited annually by individuals independent of the QA group to fulfill the 

QA requirements. No further concerns were identified. 

c. Conclusions 

In general, ANDl's QA program was in compliance with the requirements of Appendix B 

to 10 CFR Part 50. However, the inspectors identified deficiencies in ANDl's 

implementation of its program. ANDl's program for processing brokerage items had the 

potential for including safety-related items which could be certified by a unqualified 

individual. Further, the storage of potentially environmentally sensitive materials had not 

been adequately evaluated. 
3.3 Commercial Grade Dedication Proaram 

a. Inspection Scope 

The inspectors reviewed AND1 Manufacturing/lnspection Procedure (MIP) No. 95A021, 

“Utilization of Commercial Grade Items Through Commercial Dedication,” Revision 2, 

March 26, 1996. MIP 95A021 specifies the process for developing instructions to 

dedicate commercial grade items, performing dedication activities, and accepting the 

items for use in safety-related applications. 

b. Observations and Findinas 

The inspectors noted that AND1 requires technically knowledgeable individuals to 

establish the technical and quality requirements for the commercial grade dedication. 

Among those duties are the technical evaluation, parts classification, identification of 

safety function and critical characteristics, developing the commercial dedication 

instruction (CDI), including inspection and test guidance and acceptance criteria. QA is 

responsible for independently {lerifying information and actions used to dedicate items. 

ANDl’s procedure is intended to provide reasonable assurance that the commlercial 

grade dedication activities assure that the item received is the item specified aind that the 

item is suitable for its intended safety related application. 

The inspectors reviewed ANDl’s procedure and found the procedure will provide for a 

properly dedicated commercial grade item if implemented lcorrectly. 

In order to assess ANDl’s implementation of the procedure, the inspector reviewed two 

examples of dedicated items, one completed and one currently in process. AND1 job 

number M-1277-1, is for the supply of a 314” orifice to the Carolina Power and Light 

Company (CP&L). In a letter of October 24, 1997, AND1 informed CP&L that ithey were 

unable to purchase a safety-related component and would therefore, dedicate a 

commercial grade orifice. AND1 provided the CDI, a typical CoC (stating the 

methodology AND1 would be using), and a CoC attachment (specifying the part name, 

and drawing number, including part number and revision). The CDI includes a 

description of the part’s safety-related function and a list of critical characteristics to be 

verified. The critical characteristics are identified as being related to either the product 

identification or the items’ physical performance. It also contains a description of the 

verification method. The CDI is sent to the customer for their review and approval before 

the dedication activity begins. CP&L had not yet responded to ANDl’s letter. 

The inspector also reviewed AND1 job M-1314, for the dedication of a customer supplied 

needle valve supplied for the Duquesne Light Company. AND1 completed the dedication 

and provided a CoC to the licensee certifying compliance with the PO with the exception 

of one nonconformance. The nonconformance report was included in the package sent 

to the licensee, as was all other documentation, including the CDI. The shipping 

package also included a note identifying that the item was provided as a commercial 

grade dedication item. 

-6- 

12 
C. 

3.4 

a. 

b. 

Conclusions 

The inspectors were satisfied that AND1 properly implemented their commercial grade 

dedication activity. In addition, the requirement to supply the customer the CDI for 

review and approval was regarded as a strength. 

Sale of Brokered Items 

Inspection Scope 

During the August 26-29, 1997, inspection, the inspectors reviewed ANDl's process for 

providing brokered items. The process was described in AND1 procedure CP-1 IO, 

"Control and Administration of Brokered Items Purchased for Resale.'' During the 

October 30, 1997, inspection, the inspector noted that CP-110 was no longer in effect. 

Observations and Findinas 

The inspectors reviewed approximately 30 files relating to the resale of brokered items. 

In most case, the inspector noted that the item was supplied as a commercial grade item 

in accordance with the customer PO. Procedure CP-110 provides for the resale of 

commercial grade items and notes that a commercial CoC will be issued. AND1 stated 

that all resale items sold as safety-related would be processed in accordance with ANDl's 

Appendix B program and not according to CP-1 IO. The inspectors review, in general, 

supported ANDl's contention, however, the inspectors noted some anomalies and 

discussed those items further with AND1 representatives. 

The inspector observed that on August 19, 1996, American Nutech Company (ANC) 

placed purchase order (PO) #OH962YA65610 wi?h AND1 for various instrumentation 

items, including Westinghouse 7300 instrumentation cards, O-rings, and lock wire. 

Although the PO did not invoke 10 CFR Part 50 Appendix B or 10 CFR Part 21 , certain 

line items included a parenthetical statement that the items were "Class Q" or "Class R." 

The inspector noted that AND1 purchased the _W 7300 cards from a subvendor, SERTEC, 

Inc., who had purchased them from Texas Utilities Electric Company (TUEC) as surplus 

material. AND1 shipped the items as commercial-grade (non-safety-related) to ANC 

along with a certificate of compliance (COC) dated August 30, 1996, certifying that "the 

items are in compliance with the procurement documents and all required tests and 

inspections have been performed." The inspector asked AND1 for documentation that 

described Class Q and Class R requirements. The president stated that he contacted 

ANC several times but could not get an adequate response regarding Class Q and 

Class R requirements. He certified the items met Class Q and Class R requirements 

because the customer "desired" its COC to match the associated purchase order. He 

informed ANC that the items were not safety-related by indicating on the COC that 

10 CFR Part 21 was not applicable. 

The inspector observed that AND1 could not provide documentary evidence of any 

communication between AND1 and ANC regarding whether the Class Q and Class R 

-7- 

13 
items were safety-related or non-safety-related. During the inspection, the inspector 

asked the president to contact ANC to confirm whether Class Q items were safetyrelated. The president contacted ANC and was told by Mr. Peter Choo (president of 

ANC), that he had "always told ANDI that the items were being purchased as nucleargrade." On September 8, 1997, the inspector contacted Mr. Choo to confirm his 

understanding regarding ANDl's supply of the material. The inspector informled Mr. Choo 

that the instrumentation cards and other items supplied to him by AND1 for PO 

#OH962YA65610 were commercial-grade and not qualified to Class Q and Cllass R 

requirements. Mr. Choo indicated that he thought AND1 had supplied him witlh "nucleargrade items" which he believed were equivalent to safety-related items. 

The inspector determined that in July 1996, an AND1 staff member contacted Texas 

Utilities Electric Company (TUEC) for documentation that would certify that the cards 

were safety-related. TUEC refused to provide any documentation because the cards 

were no longer qualified to safety-related requirements. During the inspection, the 

inspector asked the president of AND1 why his staff contacted TUEC for safety-related 

documents if he had believed the items were purchased by ANC as commercial-grade. 

The president was not aware that an AND1 staff member had contacted TUEC:. He 

stated that AND1 had not authorized any staff member to contact TUEC and that the staff 

member in question no longer worked at ANDI. 

The inspector noted that on October 7, 1996, ANC informed AND1 that ANC's customer 

was considering not accepting the instrument cards because "the goods were damaged 

and broken on joint parts and still had tags from their use in a nuclear plant." AND1 

responded to ANC by letter dated October 7, 1996, informing ANC that, according to 

SERTEC, the items were safety-related, were functional, and had been stored in an 

environment that met Class B storage requirements. 

The inspector's review of this issue determined that ANC had purchased commercial 

grade items from ANDI, based upon the following. The PO sent to AND1 did not specify 

Appendix B, Part 21 , or any other nuclear unique requirements. Further, ANC had not 

done any audits or surveys of AND1 and did not indicate by any method that AND1 was 

an approved supplier. Further, the items in question were being provided to a foreign 

nuclear plant, not subject to NRC regulation. 

However, the inspector also concluded that AND1 had no basis for certifying that the 

items shipped to ANC met the PO requirements since AND1 was unaware of Class Q and 

Class R procurement requirements. Since the items purchased were commercial grade, 

no notice of nonconformance will be issued. However, because the inspectors were 

concerned that this issue had the potential to affect safety-related orders, it WiaS identified 

as a weakness. 

On the basis of ANDl's September 2 and September 15, 1997, letters to the NRC, and a 

September 24, 1997, telephone conversation between AND1 and an inspector regarding 

the NRC concerns described above, AND1 stated that it plans to revise its procedure 

CP-106, "Quality Assurance Program," Revision D, dated September 4, 1997, to require 

identifying the safety designation of items sold. AND1 stated that it plans to improve its 

-8- 

14 
QA program to enhance communication and coordination with its customers. During the 

October 30, 1997, inspection, AND1 stated that it would review previous POs and CoCs 

to determine if other instances existed whereby AND1 may have certified meeting PO 

requirements without fully understanding what they were. AND1 further committed to 

inform customers (including ANC) by letter if any further instances are identified. The 

president plans to hire an outside auditing service to perform an independent annual 

audit of ANDl's QA program and its implementation. 

The inspector observed that certain CoCs issued by AND1 for customer purchase orders 

(e.g., CoCs for AND1 job numbers S-1219 and M-0984) identified 10 CFR Part 50 

Appendix B requirements as applicable but 10 CFR Part 21 requirements as not 

applicable. It was not clear from the CoCs whether 10 CFR Part 21 was or was not 

being applied to the sale of safety-related items. AND1 reviewed its documents and 

reported that 10 CFR Part 21 applied to all items it sold as safety-related, and that job 

numbers S-1219 and M-0894 were sold as non-safety-related items. AND1 also indicated 

that it applied IO CFR 50 Appendix B on certain items even though these items were 

sold as non-safety-related items. AND1 reportedly did this to assure that the items 

received an adequate quality review. 

During the October 30, 1997, inspection, AND1 informed the inspectors that CP-110 had 

been abolished. All brokerage items were to be processed using the current QA 

program. Those items sold as commercial grade will be noted on the CoC. AND1 

provided the inspector with a recent example which stated: 

1OCFR21 - This is a non-safety related order. 

Further, the CoCs will no longer state that Appendix B applies for nonsafety-related 

items. The inspector agreed this change would result in a clearer CoC. No further 

concerns were identified. 

c. Conclusions 

CP-110 was designed and utilized for providing commercial grade brokerage items. 

Although no instances were found whereby safety-related materials were supplied under 

CP-110, the inspectors felt the existence of the procedure, as written, could lead to its 

use for safety related items. CoCs provided under CP-110 were not always clear in that 

some stated Appendix B was applicable, despite the order not being safety-related. The 

procedure has been abolished. AND1 certified that customer PO requirements had been 

met, despite not knowing what the PO requirement entailed. That practice was identified 

as a weakness. 

3.5 Review of Licensee Monitorina of AND1 

a. Inspection Scope 

The inspector evaluated licensee monitoring of ANDl's control of quality for safety-related 

items purchased by licensees. 

-9- 

15 
b. Observations and Findinas 

In February 1996, TUEC audited ANDl's QA program with representatives from Houston 

Lighting & Power Company and Virginia Power Company. Part of the scope of the audit 

was to verify whether AND1 had established and effectively implemented a QA program 

in compliance with the requirements of 10 CFR Part 50, Appendix B and other industry 

standards. Among program attributes audited were ANDl's training/certificatioin, design 

control, material controVhandling, storage, and shipping. The audit team identified two 

ANDI deficiencies regarding (1) failure to submit a commercial-grade item dedication plan 

to TUEC for approval in accordance with TUEC's procurement requirements, and (2) 

failure to identify the safety function and critical characteristics of several items; requiring 

commercial-grade item dedication. The audit team also observed that AND1 had no 

provisions for the classification of parts for safety-related components or equipment. The 

audit team did not consider its findings to have an adverse impact on the quality of 

ANDl's completed products. TUEC accepted ANDl's corrective actions for the findings 

described above and closed the findings on May 10, 1996, concluding that ANDl's QA 

program was adequate and that implementation was satisfactory. 

In April 1997, Duquesne Light Company (DLC) inspected the equipment they purchased 

from ANDI. The scope of the inspection included verifying certain attributes of the 

implementation of ANDl's QA program. No deficiencies were found. 

The inspector observed that the licensees did not identify ANDl's inadequate storage 

protection for applicable safety-related items. 

c. Conclusions 

In general, licensees' monitoring of ANDl's quality was in accordance with proper criteria, 

procedures, and checklists. Licensees' monitoring of ANDl's control of quality was not 

satisfactory because it did not identify deficiencies in ANDl's storage of equipment. 

3.6 Entrance and Exit Meetinas 

At the entrance meeting on August 26, 1997, the NRC inspector discussed the scope of 

the inspection, outlined the areas to be inspected, and established interactions with AND1 

management. In the exit meetings on August 29 and October 30, 1997, the inspectors 

discussed their findings and observations. 
4 PARTIAL LIST OF PERSONNEL CONTACTED 

AND1 

Paul Heffernan, President 

Dennis R. Swalin, QA Manager 

Donald Gray, QA Engineer 

Sheryl Damico, QA inspector (Former Employee) 

Tarun Basu, Manager of Testing LaboratoFy 

John Antenucci, Supervisor of Testing Laboratory 

Licensees (contacted bv telephone) 

Danny Leigh, Plant Overview Supervisor, TUEC 

James Johns, Supervisor Quality Services, DLC 

Fred Stobaugh, Procurement Engineer, TUEC 

Dan Poneman, Counsel, Hogan and Hartson 

ITEMS OPENED, CLOSED, AND DISCUSSED 

ODened 

99901 324/97-01-01 Para. 3.1 b NON inadequate training of personnel 

99901 324/97-01-02 Para. 3.lb NON inadequate storage 

-11- 

17 
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 205660001 

December 10, 1997 

Mr. Stephen Sakofsky, Director 

Quality Assurance 

Industrial Products Group 

Gould's Pumps, Incorporated 

240 Fall Street 

Seneca Falls, New York 13148 

SUBJECT: NRC INSPECTION REPORT NO. 99900732/97-01 

Dear Mr. Sakofsky: 

On October 2-3, 1997, the U.S. Nuclear Regulatory Commission (NRC) completed 

an inspection at your Gould's Pumps, Incorporated, Industrial Products Group, 

Engineered Products Division (EPD) facility in Seneca Falls, New Yorl:. The 

enclosed report presents the results of that inspection. 

During this inspection, the NRC inspector found that the implementation of 

your quality assurance program failed to meet certain NRC requirements imposed 

on you by your customers. Specifically, EPD has issued certificates of 

compl i ance for rep1 acement parts without epsuring that a1 1 the materi a1 

critical characteristics have been verified. The inspector determined that 

EPD is not verifying that the chemical composition of castings are in 

compliance with the applicable American Society for Testing and Materials 

(ASTM) standards. Instead, it was found that for approximately 10 years, EPD 

has been verifying only selected chemical elements in corrosion resistant 

castings. Additionally, EPD did not verify that ASTM required heat treatment 

of certain alloys had been performed. 

This nonconformance is cited in the enclosed Notice of Nonconformance (NON), 

and the circumstances surrounding it are described in detail in the enclosed 

report. 

the instructions specified in the enclosed NON when preparing your response. 

You are requested to respond to the nonconformance and should follow 

This nonconformance is significant because it represents a deviation from the 

procurement specifications that were imposed upon EPD by its customers. 

Consequently, those deviations for each 1 icensee application of the ilPD 

supplied components must be evaluated in accordance with 921.21, "Notification 

of failure to comply or existence of a defect and its evaluation," of 10 CFR 

Part 21. 

18 
Mr. S. Sakofsky -2- December 10, 1997 

In accordance with 10 CFR 2.790 of the NRC’s “Rules of Practice,“ a copy of this 

letter and its enclosure will be placed in the NRC’s Public Document 

Room (PDR) . 

Si ncerel y , 

Original signed by: Suzanne C. Black 

Suzanne C. Black, Chief 

Qual i ty Assurance, Vendor Inspection 

Division of Reactor Controls and Human Factors 

Office of Nuclear Reactor Regulation 

and Maintenance Branch 

Docket 99900732/97-01 

Enclosure: 1. Notice of Nonconformance 

2. Inspxtion Report 99900732/97-03 

19 
NOTICE OF NONCONFORMANCE 

Gould's Pumps, Incorporated 

240 Fall Street 

Seneca Falls, New York 13148 

Docket No.: 99900732 

Based on the results of an inspection conducted on October 2 and October 3, 

1997, it appears that certain of your activities were not conducted in 

accordance with NRC requirements. 

Criterion 111, "Design Control ,I' of Appendix B, "Quality Assurance Criteria 

for Nuclear Power Plants and Fuel Reprocessing Plants," of 10 CFR Part 50 

requires in part, that measures shall be established to assure that applicable 

regulatory requirements and the design basis are correctly trans1 ated into 

specifications, drawings, procedures, and instructions, to assure that 

appropriate qual i ty standards are specified and included in design documents 

and that deviations from such standards are controlled. Measures shall also 

be established for the selection and review for suitability of application of 

materials, parts, equipment, and processes that are essential to the 

safety-related functions of the structures, systems and components. 

Commonwealth Edison purchase order (PO) 47D744, dated June 17, 1997, requested 

one 7 3/8 inch pump impeller, Part Number R76793-1203, Material - American 

Society for Testing and Materials (ASTM) type ASTM A-296, Grade CF8M. 

Purchase Order 47D744 stated that the PO was safety-related and the 

requirements of 10 CFR Part 21 and 10 CFR Part 50, Appendix B were applicable. 

ASTM A 296-1977, "Standard Specification for Corrosion-Resistant IronChromium, Iron-Chromium-Nickel , and Nickel-Base Alloy Castings for General 

Application," requires that alloys conform to the chemical composition 

prescribed in Table 2. 

Item (C), page 4 of EPD's QCP-187, states: "Critical Characteristics Chart - 

All critical characteristics will be inspected after the parts are selected 

from stock for use on a Non Code Safety Related order ... Information shown on 

the chart will be verified to be complete and accurate. The Inspection/Test 

Record will be signed and dated by the person performing the verification, 

when complete and acceptable. The Inspection test record will be certified by 

a QA Engineer ...." 

Contrary to the above requirements, the inspector determined: 

a) EPD did not include appropriate quality standards in its QCP-187 

critical characteristic requirement charts regarding the material 

verification category. 

20 
Gould's Pumps, Incorporated -2- 

b) Although Gould's Pumps, Incorporated, July 24, 1997, Certificate of 

Compliance to Commonwealth Edison, PO 47D744, certified that the 

replacement part was in compliance with the original part supplied and 

the customer's PO requirements, EPD did not verify all of the ASTM 

chemical composition elements, and did not verify ASTM heat treatment. 

(Nonconformance 99900732/97-01-01) 

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, Special Inspection Branch, Division of Inspection 

and Support Programs, 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 noncanformance: (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 Rockvi 11 e, Mary1 and 

this /nw day of December 1997. 

Enclosure 1 

21 
INSPECTION REPORT 

ORGANIZATION: 

REPORT NO.: 

ORGANIZATIONAL 

CONTACT : 

NUCLEAR INDUSTRY 

ACT I VI TY : 

U.S. NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION 

DIVISION OF REACTOR CONTROLS AND HUMAN FACTORS 

Gould’s Pumps, Incorporated 

Industrial Products Group 

Engineered Products Division 

240 Fall Street 

Seneca Falls, New York 13148 

99900732/97-01 

Mr. James F. Heid, 

Quality Systems Manager 

Engineered Products Division 

Industrial Products Group 

Gould’s Pumps, Incorporated 

(315) 568-2811 

Provides Gould’s pumps, pump replacement 

parts, pump refurbishment, and field service. 

INSPECTION CONDUCTED: October 2-3, 1997 

INSPECTOR: Joseph J. Petrosino, NRR 

APPROVED BY: Robert A. Gramm, Chief 

Quality Assurance and Safety Assessment Section 

Quality Assurance, Vendor Inspection 

Division of Reactor Controls and Human Factors 

Office of Nuclear Reactor Regulation 

and Maintenance Branch 

Enclosure Z! 

1 

22 
1 INSPECTION SUMHARY 

During this inspection, the NRC inspector reviewed the implementation of 

selected portions of the Gould's Pumps, Incorporated, Industrial Products 

Group, Engineered Products Division (EPD) facility Quality Assurance (QA) 

Program, and reviewed activities associated with "commercial grade items" 

and "dedication," as defined in $21.3 of 10 CFR Part 21." 

The inspection bases were: 

e Appendix B, "Qual i ty Assurance Criteria for Nuclear Power Plants 

and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code 

of Federal Reaulations (10 CFR Part 50) 

e 10 CFR Part 21, "Reporting of Defects and Noncompliance" 

During this inspection, one instance where EPD failed to comply with NRC 

requirements imposed upon them by NRC licensees was identified. 

nonconformance represents a long standing practice that EPD has been 

performing for its safety-related dedicatiun process and is discussed in 

Sections 3.2 and 3.3 of this report. 

This 

2 STATUS OF PREVIOUS INSPECTION FINDINGS 

There were no open findings from the last NRC inspection at Gould's Pumps, 

Incorporated, NRC Report 99900732/80-01. 

3 

3.1 

a. 

b. 

INSPECTION FINDINGS AND OTHER COMMENTS 

10 CFR Part 21 Proqram 

ScoDe 

The inspector reviewed EPD's Quality Assurance Instruction (QA1)-231, 

"Procedure For 10 CFR Part 21," Revision 10, dated September 24, 1997, 

for reporting in accordance with 10 CFR Part 21, and observed the 

required posting of the requirements. 

Observations and Findinqs 

The inspector determined that both QAI-231 and the posting complied with 

the Part 21 requirements. However, the inspector noted that QAI-231 did 

not define terms used in QAI-231 that have specific meaning as defined 

in 521.3 of 10 CFR Part 21 such as, deviation, discovery, defect, 

evaluation and substantial safety hazard. The inspector also noted in 

the narrative of QAI-231 that the term "defect" was used incorrectly in 

a few sections of the procedure. That is, circumstances and conditions 

that should have been characterized as being deviations or potential 

defects were referred to as being defects; therefore, the procedure 

would not be consistent with 10 CFR Part 21. 

2 

23 
C. 

3.2 

a. 

b. 

The inspector also noted that the point at which "discovery11 occurs was 

not clearly specified in the narrative body of QAI-231. 

discussed the above aspects with EPD QA Management and EPD committed to 

reviewing and revising QAI-231 within 120 days of the exit meetiing of 

this inspection. 

The inspector 

Concl usi ons 

The inspector concluded that although some portions of the QA 

instruction adopted by EPD would benefit from additional clarification, 

QAI-231 adequately implemented the relevant provisions of 10 CFR 

Part 21. 

Licensee Purchase Order Packases and Certified Material Test RePo& 

InsPection ScoPe 

The inspector selected several 1 i censee purchase order (PO) f i 1 est and 

Certified Material Test Reports (CMTR's) for review. The POs tha.t were 

chosen were for replacement parts tised at licensee facilities, and the 

CMTRs were selected from foundries that 5uppl ied commercial castinss 

that could be selected for dedication as safety-related components. 

Observations and Findinss 

The EPD personnel stated that very few pump assemblies are currently 

sold to licensee facilities because the Gould's Pumps are designeld for 

long term application with internal part replacements as components wear 

out. The inspector noted that each PO file included a copy of the 

customer's PO that showed the imposed requirements, EPD's certificate's 

of compliance/conformance (CoCs), inspection and test records such as, 

"metallographic inspection resul ts-a1 loy analyzer," dimensional 

verification records, and associated refords such as, manufacturer's 

certified material test reports (CMTRs) and CoCs for the pump 

components. The licensee PO'S typically imposed the requirements of 

10 CFR Part 50, Appendix B, 10 CFR Part 21 and EPD's Quality Control 

Procedure (QCP)-187, "Inspection/Test Plar, for Dedication of Commercial 

Grade Replacement Parts," Revision 9, dated September 19, 1997, for the 

components ordered. 

One PO package that was reviewed by the inspector was for a 316 series 

stainless steel impeller replacement. The customer PO, Commonweallth 

Edison PO 470744, dated June 17, 1997, requested one 7 3/8 inch pump 

impeller, Part Number R76793-1203, material: American Society for 

Testing and Materials (ASTM) type ASTM A-296, Grade CFSM. The ASTM 

A-296 standard requires the manufacturer to heat treat each casting in 

accordance with the requirements in Table 1 and to conform with the 

specific chemical composition prescribed in Table 2 of the standard. 

' Manufacturer's CMTRs are obtained by EPD only w ten the EPD customier 

specifically requires a manufacturer's CMTR to be provided. 

3 

24 
The inspector noted that the "Gould's Pumps, Incorporated," Certificate 

of Compliance (CoC) for Commonwealth Edison PO 47D744, dated July 24, 

1997, stated that the replacement parts supplied were in compliance 

with the original parts supplied on the original pump and the customer's 

purchase order requirements and applicable specifications. 

A review of the PO package records and subsequent discussion with EPD 

staff identified that it used its portable metal analyzer (Texas Nuclear 

Analyzer, Model 9277-XL Metallurgist) to verify the applicable elements 

of the ASTM chemical composition. The alloy analyzer inspection results 

sheet in the PO package indicated that only four chemical elements had 

been verified. EPD staff stated that the four elements verified with 

EPD's portable metal analyzer were Molybdenum (Mo), Nickel (Ni) , Chromium (Cr), and Manganese (Mn) for the CF8M alloy. EPD did not 

verify the chemical composition levels for Carbon (C), Silicon (Si), 

Sulfur (S) or Phosphorus (P). The EPD staff stated that its portable 

metal analyzer is not capable of verifying Carbon, Silicon, Phosphorus, 

or Sulfur for the CF8M material. The inspector was told by EPD that the 

portable metal analyzer is used for all chemical composition analyses 

for the dedication of commercial castings. The inspector also 

determined that EPD did not verify thct the appropriate heat treatment 

was performed. 

Discussions with EPD staff indicated that this EPD practice of 

certifying even though all elements are not verified has been performed 

for approximately 10 years without a documented engineering justification for not verifying all the chemical composition elements. 

The inspector determined that EPD's practice of verifying only a limited 

amount of the elements in alloys such as CF8M can render the EPD 

supplied components indeterminate. For example, with CF8M or CF3, the 

potential of stress corrosion cracking increases proportionate to the 

level of Carbon. Additionally, the solution annealing temperatures for 

certain corrosion resistant alloys are important for optimum tensile 

strength, ductility and corrosion resistance. Therefore, the 

determination of the maximum level of Carbon and the adequacy and 

performance of heat treatment is very important. 

adequately verify the material characteristics is identified as 

Nonconformance 99900732/97-01-01, and is discussed further in 

Section 3.3. 

The failure to 

The inspector also noted several CMTRs from one particular foundry that 

did not appear to have an actual "signature" or the QA Manager. 

Instead, it was noted that each of QA Manager's signatures on the 

reviewed CMTR's had been stamped. Consequently, the identity of the 

person who affixed the stamped signature was indeterminate after the 

fact. 

Subsequent discussions with the Quality Systems manager identified that 

EPD does not typically perform audits or surveillance of commercial 

suppliers, unless certain components have specific critical characteristics that can not be verified at EPD's facility. 

thaL all critical characteristics can be verified on castings such as 

EPD staff stated 

4 

25 
C. 

impellers after manufacturing and receipt at EPD. 

inspector determined that the use of a signature.stamp on the foundry 

CMTR was not a significant issue. 

Therefore, the 

Concl us i ons 

The inspector concluded that the metal 1 urgical qual i ty of the suppl ied 

component regarding Commonwealth Edi son PO 470744 is indeterminate 

because EPD did not verifq important chemical composition levels, did 

not have an engineering justification for not verifying a71 the chemical 

composition elements, and did not assess whether the castings 

manufacturer is adequately performing speci a1 processes, such as heat 

treatment. 

The inspector also concluded that the Commonwealth Edison PO package is 

not an isolated occurrence. The inspector was informed that €I'D has 

made it a practice to certify compliance with purchase order requirements, without verifying requirements such as chemical composition are, 

in fact, met. 

3.3 Quality Assurance and Dedication Prosram 

a. InsDection Scope 

The inspector selectively reviewed the EPD QA Manual (QAM) 1002, Fifth 

Issue, Revision 3, Dated April 11, 1996, and associated procedures and 

work instructions related to "dedication" activities, as defined in 

921.3 of 10 CFR Part 21. 

the requirements of the American Society of Mechanical Engineers (ASME) 

Boiler and Pressure Code, Section I11 - "Nuclear Power Plant 

Components," Division 1; ANSI/ASME N45.2-1977, "Quality Assuranlce 

Program for Nuclear Facilities," and 10 CFR Part 50, Appendix B, 

"Qual i ty Assurance Criteria for Nuclear Power P1 ants and Fuel 

Reprocessing Plants." The QA Manager stated that QAM-1002 program 

requirements were applied to all work performed in accordance with EPD's 

Quality Control Procedure (QCP)-187, "Inspection/Test Plan for 

Dedication of Commercial Grade Replacement Parts," Revision 9, dated 

September 19, 1997. 

EPD's QAM-1002 program was established to meet 

b. Observations and Findinas 

The definition of "dedication" in 10 CFR 21.3 specifies that dedication 

must provide reasonable assurance that a commercial grade item (CGI) to 

be used as a basic component will perform its intended safety function, 

and is deemed equivalent to an item designed and manufactured under a 

10 CFR Part 50, Appendix B, QA program. This assurance must be achieved 

by identifying the critical characteristics of the item md verifying 

their acceptability. 

that QCP-187 specifies critical characteristics for the approximately 40 

CGI's that are not procured as safety-related components by EPD. 

A review of EPD's dedication procedure identified 

Section 5, "Procurement Process, of QCP-187 requ;res that the managers 

of Engineering Systems & Standards and Quality Assurance select the 

criticzl characteristics to be verified. The QA manager establishes 

5 

26 
tests and inspections to be performed in accordance with established 

procedures and issues certificates of conformance with the test records. 

Section 6, "Acceptance Criteria," of QCP-187 requires that parts which 

are in compliance with the critical characteristics shall be accepted. 

A discussion with the Manager of Engineering Systems and Standards 

identified that the critical characteristics have been developed based 

upon the engineering drawings, specifications, and operating design 

parameters of the particular pump. The engineering manager stated that 

this delineation of characteristics was to ensure that all important 

operating performance aspects as well as relevant design and material 

considerations were addressed. 

that the critical characteristics were chosen several years ago using 

industry guidance and engineering judgement. 

critical characteristics was not assessed by the inspector. 

The EPD Qual i ty Systems Manager stated 

The adequacy of those 

The inspector reviewed Chart 17, "Impeller Critical Characteristics 

Chart," of QCP-187 which requires material verification and CMTR, (if 

ordered from the manufacturer), verification using the "portable metal 

analyzer.'' The inspector noted that Chart 17, instead of specifying the 

actual material to be verified in accordance with the type and grade of 

steel, merely stated under the heading "material verification" two 

items: "CMTR" [see footnote 11 and "portable metal analyzer." The 

inspector determined that EPD did not include appropriate quantitative 

or qualitative acceptance criteria in Chart 17, QCP-187 for the critical 

characteristics necessary to verify compliance with the different ASTM 

Standards. 

The inspector noted that EPD's "metallographic inspection results-alloy 

analyzer," form (page 45 of QCP-187 has the following chemical elements 

1 isted for analysislverification: Molybdenum, Nickel, Chromium, 

Manganese, Titanium (Ti), Copper (Cu), Vanadium (V), Ironz (Fe), Zinc 

(Zn), Tin (Sn), Lead (Pb), Aluminum (Al), and Wolfram (W) . The ASTM A 

296 elements that are listed under Table 2, "Chemical Requirements," for 

CF8M are: Carbon, Manganese, Silicon, Phosphorus, Sulfur, Chromium, 

Nickel, and Molybdenum. 

Carbon, Silicon, Phosphorus, and Sulfur are important for reliability 

and acceptable performance of stainless steel material, EPD did not 

identify those elements for material verification on its material 

analysis "metallographic inspection results - alloy analyzer" form. As 

discussed in section 3.2 above, EPD's portable metal analyzer does not 

identify all of those chemical elements found in Table 2 of 

ASTM A 296. 

It was noted by the inspector that although 

As a result of a lack of specificity in chart 17, EPD did not verify the 

ASTM A 296, Table 2 chemical composition elements of Carbon, Silicon, 

Phosphorus, and Sulfur for the CF8M impeller casting during its 

dedication process for Commonwealth Edison PO 470744 (see Section 3.2). 

Although the symbol W was used by EPD to represent Wolfram, W is the 

symbol for Tungsten. Tungsten (W) is extracted from Wolframite, Scheel i te and 

other mi neral s . 

6 

27 
c. Conclusions 

The inspector concluded that EPD does not have an adequate basi!; to 

dedicate commercial castings because of the identified practices and 

methodology employed at its Seneca Falls facility. Since EPD does not 

survey/audi t its commercial casting manufacturers and does not verify 

all of the chemical composition elements (even on a sample basis), its 

level of assurance would be questionable. 

Additionally, the inspector concluded that Nonconformance 

99900732/97-01-01 appears to represent a departure from the technical 

requirements included in a procurement document and needs to be 

evaluated in accordance with the provisions of 10 CFR Part 21 by EPD. 

3.4 Entrance and Exit Meetinqs 

In the entrance meeting on October 2, 1997, the NRC inspector discussed 

the scope of the inspection, outlined the areas to be inspected, and 

established interfaces with the Engineered Products Division and 

Industrial Products Group management. In the exit meeting on October 3, 

1997, the inspxtor discussed his findings and concerns. Additional 

discussions were also conducted subsequent to the exit meeting in 

December 1997. 

3.5 Personnel Contacted 

S. Sakofsky Director, Quality Assurance - IPG 

R. Schussler Manager, Engineering Systems and Standards - IPG 

J. Heid Quality Systems Manager - EPD 

P. Soscia Quality Assurance Engineer - EPD 

S. Mahalik Quality Assurance Auditor - EPD 

4 ITEMS OPENED, CLOSED, AND DISCUSSED 

Nonconformance 

99900732/97-01-01 Nonconformance Dedication Process 

Questionable Certifications 

7 

28 
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

October 28, 1997 . ***** ' 

Mr. James Fitzwilliam, Manager 

Quality Assurance 

Nova Machine Products Corporation 

P.O. Box 30879 

Middleburg Heights, OH 44130 

Subject: NRC INSPECTION REPORT 99901 052/97-01 AND NOTICE OF 

NONCONFORMANCE 

Dear Mr. Fitzwilliam: 

On June 2 though 5, 1997, the U.S. Nuclear Regulatory Commission (NRC) conducted an 

inspection of Nova Machine Products Corporation (Nova). An inspection report was issued on 

July 22, 1997. Subsequently, Nova indicted to the NRC that certain statements made in the 

report may be misleading. Therefore, by letter of September 5, 1997, the NRC informed Nova 

that it was withdrawing the inspection report until the issue of potentially misleading information 

could be resolved. On October 2, 1997, the NRC returned to Nova to complete the inspection 

and to review Nova's corrective actions to the Notice of Nonconformance, issued with the 

original report, as described in Nova's letter of August 18, 1997. 

During the June 1997 inspection, the NRC inspectors found that the implementation of your 

quality assurance program failed to meet certain NRC requirements imposed on Nova by 

customers. Specifically, the inspection identified instances where Nova supplied material under 

its ASME Quality Systems Certificate (QSC) without providing all documentation required by the 

applicable ASME Code, NCA 3800 quality assurance program. Additionally, the inspection 

identified one instance where Nova failed to perform all testing required by Paragraph NCA3855.5 of the ASME Code, when upgrading unqualified source material. This material was 

subsequently supplied and certified under Nova's QSC. 

This nonconformance is cited in the enclosed Notice of Nonconformance (NON), and the 

circumstances surrounding it are described in detail in the enclosed report. You responded to 

the nonconformance by letter of August 18, 1997. During the October 1997 inspection, the 

NRC determined that your corrective actions were appropriate and complete. Therefore, no 

further response is required. 

29 
James Fitzwiliiam -2- October 28, 1997 

In accordance with 10 CFR Part 2.790 of the NRC's "Rules of Practice," a copy of this letter and 

its enclosures will be placed in NRC's Public Document Room. 

Sincere iy, 

Original signed by: Richard P. Correia 

for Suzanne C. Black, Chief 

Quality Assurance, Vendor Inspection 

Division of Reactor Controls and Human Factors 

Office of Nuclear Reactor Regulation 

and Maintenance Branch 

Docket No.: 99901 052 

Enclosures: 1. Notice of Nonconformance 

2. Inspection Report 999010521/97-01 
NOTICE OF NONCONFORMANCE 

Nova Machine Products Corporation 

Middleburg Heights, OH 

Docket No.: 99901052 

Based on the resillts of an inspection conducted on .lune 2 through 5, 1997, it appears that 

certain of your activities were not conducted in accordance with NRC requirements. 

A. Criterion V, "Instructions, Procedures and Drawings," of Appendix B to 10 CFR Part 50 

requires, in part, that activities affecting quality shall be prescribed by documented 

instructions, procedures, or drawings and shall be accomplished in accordance with 

these instructions, procedures, or drawings. 

Paragraph NCA-3862.l(b) of Section Ill of the ASME Code states that "When required 

chemical analyses (including mill heat analysis), heat treatment, tests, examinations, or 

repairs are subcontracted, the approved supplier's certification for the operatior 7 

performed shall be furnished as an identified attachment to the Certified Material Test 

Report." 

Paragraph NCA-3855.5, "Utilization of Unqualified Source Material" states, in part, that a 

Material Organization (MO) may use or furnish unqualified source material, provided the 

MO performs or subcontracts a product analysis and all other requirements of the 

material specification on each piece of the material. 

The following examples demonstrate failure to comply with the above requirements and 

constitute Nonconformance 99901 052/97-01-01: 

1. Contrary to the above, Nova Certified Material Test Report (CMTR) for material 

supplied to Centerior Energy (Davis-Besse), under Purchase Order (PO) 

S 078945 D97, certified that this material was supplied in accordance with 

Nova's ASME Quality Systems Certificate (QSC), but did not include a complete 

heat treatment certification, or certification of material internal quality (macroetch 

test) as identified attachments. 

2. Contrary to the above, Nova CMTR for material supplied to Northeast Utilitie; 

(Millstone) under PO 00951296, Release 023, certified that this material was 

supplied in accordance with Nova's QSC, but did not include certification of 

material internal quality in accordance with the test specification referenced in 

the procurement documents. 

-1- 

31 

Enclosure 1 
3. Contrary to the above, Nova certified that upgraded unqualified source material 

supplied to PECO Energy Co. (Limerick Generating Station) under PO 

LS 608180, line item 03, was processed in accordance with their QSC, but did 

not perform the macroetch test, reqiiit-?d by the material specification, on each 

piece of the material. Only one of the four coils of material, procured from an 

unqualified supplier, was macroetched, and the certification for this test was not 

included as an identified attachment to the Nova CMTR. 

Since corrective actions were reviewed and found acceptable, no response is required 

Dated at Rockville, Maryland 

this 2 3 day of Oe-1997 
Report no: 

Organization: 

Contact: 

Nuclear Industry 

Activity: 

Dates: 

Inspectors: 

Approved by: 

US. NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION 

99901 052/97-01 

Nova Machine Products Corporation 

James Fitzwilliam, Quality Assurance Manager 

(216) 267 3200 

Manufacturer of threaded fasteners and supplier of ferrous and 

nonferrous bars, threaded fasteners, fittings, flanges, and other 

products used primarily in nuclear applications. 

June 2 through 5, 1997, and October 2, 1997 

Uldis Potapovs, Senior Reactor Engineer 

Larry L. Campbell, Reactor Engineer 

Gregory C. Cwalina, Senior Operations Engineer 

Donald Naujock, Materials Engineer 

Robert A. Gramm, Chief 

Quality Assurance Section 

Quality Assurance, Vendor Inspection and 

Division of Reactor Controls and Human Factors 

Mainte, lance Branch 

Enclosure 2 
1 INSPECTION SUMMARY 

During the June 2-5, 1997, part of the inspection, the NRC insoectors reviewed the 

implementation of selected portions of Nova Machine Products Corporation’s (Nova) 

quality assurance (QA) program for supplying material under the American Society of 

Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) requirements 

and for prGviding dedicated commercial gradc material in compliance with the 

requirements of 10 CFR 50, Appendix B. The inspectors also reviewed the 

implementation of Nova’s program for reporting of defects under the requirements of 10 

CFR Part 21. This inspection was a part of an NRC pilot program to develop inspection 

procedures for assessing licensee oversight of supplier quality. 

An inspection report was issued to Nova on July 22, 1997. However, by letter of 

August 18, 1997, Nova raised concerns over potentially misleading statements in the 

report. Therefore, the NRC withdrew the initial inspection report pending a review of 

Nova’s concerns That review was completed on October 2, 1997. During lhe October 

1997 inspection, the inspectors further reviewed Nova’s commercial grcje Jedication 

procedures and their adherence to customer and material specification requirements, 

particularly as related to small parts. In addition, the inspectors reviewed Nova’!; 

implementation of corrective actions provided in their August 18, 1997, letter to 1:he 

NRC. 

The inspection bases were: 

e 10 CFR Part 50, Appendix 6, “Quality Assurance Criteria for Nuclear Power 

Plants and Fuel Reprocessing Plants.” 

e 10 CFR Part 21, “Reporting of Defects and Noncompliance.” 

0 ASME Code, Section Ill, Subarticle NCA 3800. 

During this inspection, one nonconformance was identified and is discussed in 

Sections 3.3.b and 3.3.c of this report. 

2 STATUS OF PREVIOUS INSPECTION FINDINGS 

The last NRC inspection of Nova was performed on July 14 through 18, 1986. lhe 

status of findings from that inspection was not reviewed. 

2 

34 
3 INSPECTION FINDINGS AND OTHER COMMENTS 

3.1 Descriotion of Facilities and Activities 

Nova has been accredited by the ASME as a Material Organization (MO), 

manufacturing threaded fasteners and supplying ferrous and nonferrous bars, threaded 

fasteners, fittings, flanges, and other product :,. According to Nova management, 

approximately 60-70% of their sales volume consists of safety related material supplied 

to nuclear utilities. Of that amount, approximately 50% is sold under their ASME Quality 

Systems Certificate (QSC) as complying with the requirements of Subarticle NCA 3800 

of Section Ill of the ASME Code. Manufacturing capability includes cold and hot forming 

and machining. Inspection and test capability includes complete dimensional and visual 

inspection, tensile and hardness testing, and chemical analysis capability for carbon and 

low alloy steels. Nondestructive examination and heat treating are subcontracted to 

approved suppliers. 

3.2 Review of Nova’s 10 C_FR Part 21 Proaram and its Implementation 

The inspectors reviewed 10 CFR Part 21 postings at the manufacturing facility and 

found them to be consistent with the current requirements. The practices for identifying 

and reporting defects and the time frames for evaluation and notification are described 

in Nova procedure NP-09, Revision 7, dated March 3, 1997. This procedure assigns the 

responsibility for documenting the results of deviation evaluations to the QA manager 

and identifies the nonconformance report (NCR) as the record of evaluation. 

The inspectors examined Nova’s nonconformance file and did not identify any instances 

where an evaluation resulted in a reportable condition. The inspectors noted that the 

evaluation typically consisted of a check mark in the appropriate Yes/No box on the 

NCR form with no documented bases for this determination. While it can be argued 

that, in most cases, the bases are readily apparent from other information contained in 

the NCR, this did not always appear to be the case. For example, NCR 97-29 

documented a situation where parts had been rejected and returned to Nova by a 

customer because Nova had failed to perform liquid penetrant testing as required by the 

customer’s purchase order (PO). The NCR identified the cause of the deviation as 

failure to include the liquid penetrant testing requirement in Nova’s PO to their vendor. 

The “Not Reportable” Part 21 box was checked with a notation “LP passed” indicating 

successful testing of the returned parts. The inspectors noted that the evaluation did not 

fully address the root cause of this deviation to determine why the test requirement was 

not included in the PO nor the generic potential of such omissions which could require 

the notification of other customers. 

Evaluation of deviations was identified as a weakness in Nova’s 10 CFR Part 21 

program implementation. Nova management indicated that this issue would be 

addressed by appropriate changes to the implementing procedure. 
3.3 

a. Scope 

The NRC inspectors reviewed the procedural controls and document files for a sample 

of recently filled orders for safety related nxt ,rial supplied under Nova’s ASME QSC to 

evaluate the implementation of the applicable QA program and ASME Code 

requirements. 

b. Observations and Findinas 

Nova operates under one quality program. The Quality Assurance Manual (Edition 4, 

Revision 1) has been written to comply with the applicable requirements of the ASME 

Code, ISO-9001; Canadian Standard 2-299; 10 CFR Part 50, Appendix B; ANSI N45.2 

and other related quality standards. The QA manual is supported by a controlled set of 

implementing procedtxes. 

Approximately 1 CJ document files supporting the certification of recent material sides 

under Nova’s ASME QSC were reviewed to evaluate !he effectiveness of their C!A 

program implementation. Significant observations and findings are summarized below: 

4 Centerior Energy (Davis-Besse) Purchase Order (PO) S 078945 097, dated 

March 13, 1997, for eight 314 inch threaded studs, 13 inches long, in accordance 

with ASME SA-193, Grade 87. 

This material was certified as supplied under Nova’s QSC in full compliartce with 

the applicable PO requirements. Attached to the Nova certification was a 

material test report issued by Chaparral Steel Co. of Midlothian, TX, for 20 tons 

of hot-rolled AIS1 type 4140 steel bars sold to Cardinal Fasteners, Bedford 

Heights, OH. Also attached was a heat treatment certification issued to Nova by 

J.W. Rex Co., Lansdale, PA, (a qualified vendor). The Chaparral certification 

referenced their QSC number, indicating that, although the material was not 

provided as ASME Code material, it was processed in accordance with 

Chaparral’s QSC. 

The inspector noted that: 1) there was no indication of Cardinal Fastener:; role in 

supplying this material or how Nova acquired the material, 2) the heat treatment 

certification was incomplete, since only a tempering cycle was described, and 3) 

there was no indicAon that the material internal quality had been verified by 

macroetch as required by ASME SA-1 93. 

During the course of the inspection, Nova staff produced records indicating that, 

although the material had been purchased by Cardinal, it had been drop-shipped 

to Nova, and that three samples of the material had been macroetched by an 

approved laboratory and found acceptable. The records also indicated thiat the 

heat treatment certification that was provided to the customer represented only a 

4 

36 
re-temper cycle and did not describe the complete heat treatment that was 

performed on this material. The re-temper cycle was necessary because the 

initial temper was conducted at a temperature below the specified minimum. 

Records for the original quench and temper cycle were available. 

The inspector noted that, since Nova certified this material as provided in 

accordance with their QSC, sup,ili :r certifications for the complete heat 

treatment and macroetch examination should have been provided to their 

customer as required by ASME Code, Section Ill, NCA-3862.1 

0 Northeast Utilities (Millstone) PO 00951 296, Release 023, dated March 1 1, 1997 

for 40 feet of 3/4 inch threaded rod in 10 foot lengths, in accordance with ASME 

SA-193, Grade B6X 

This materialwas certified as supplied under Nova's QSC in full compliance with 

the applicable PO and specification requirements. Attached tc the Nova 

certification was a Carpenter Technology (qualified vendor) certificate of test for 

Type 410 annealed ground bar. The certificate also referenced ASi'M A-182, 

Grade F6A (chemistry only). The certificate did not reference or indicate 

compliance with requirements of SA-1 93, but contained a statement " Discs 

Macroetched and Approved." There was no reference to the macroetch test 

method or acceptance criteria. Also attached was a certificate from J.W. Rex 

Co. (approved vendor) stating that 18 pieces and one test piece of this material 

were hardened and tempered per SA-193, Grade B6X to a hardness level of 

24-26 Rc. Also attached was a certificate from Herron Test Lab. (approved 

vendor) with tensile and hardness test results for this material. 

The inspector noted that the mill certification did not contain complete 

information to verify compliance with the internal quality requirements specified 

in SA-193 which requires the macroetch to be performed in accordance with 

ASTM E-381 (or other suitable method as agreed upon between purchaser and 

producer), and provides specific acceptance criteria. In accordance with the 

material certification requirements of NCA-3862, the basis for compliance with 

SA-I 93 requirements should have been included in the original mill certification 

or supplementary test report and provided to the purchaser of this material. 

0 PECO Energy Co. (Limerick Generating Station) PO LS 6081 80, line item 03, 

for Twelve 5/8 inch by 3 1/2 inches long threaded rods, in accordance with ASME 

SA-193, Grade B7 

This material was certified as supplied under Nova's QSC in full compliance with 

the applicable PO and material specification requirements. The certificate also 

noted that the material was upgraded per NCA-3855.5. Attached to ?he Nova 

certification was a Certification of Inspection and Test, issued to Nova by Walker 

Wire and Steel Corp. (not on Nova's approved vendor li,st) which identified the 

material as .640 inch diameter 4140 cold heading quality hot rolled rod. Also 

attached to the Nova certification were heat treatment certification from J. W. 

5 

37 
Rex Company (approved vendor) indiczting that the .material had been 

processed per customer requirements to surface hardness of 27-28 Rc:, a test 

report from Herron Testing Laboratories, Inc. (approved vendor) containing the 

resLlIts of product analyses performed Qn four samples of this material, and a 

test report from Herron Testing Laboratories containing the results of tensile 

tests on this material. 

The inspector noted that the information provided with Nova's certification did not 

provide an adequate basis for establishing compliance to the requirements of 

SA-193, since there was no record of verification of the material internal quality 

(macroetch). Furthermore, it could not be determined if the upgrading was 

properly performed, since the supplier's certification did not indicate how many 

separate pieces of material were provided to fill this order. 

During the course of the inspection, Nova staff produced additional records 

indicating rnat Walker Wire purchased the starting material in four coils from 

Charter Steel. The mill certification was on file at Nova. Nova ah producad a 

test report from Herron Laboratories (approved vendor) indicating that me 

sample of this heat of material had been macroetched in accordance wi,th 

ASTM E-381 and met the acceptance criteria specified in SA-193. 

The inspector noted that, in accordance with NCA 3862.1, the macroetch test 

results should have been provided to the purchaser of the material. The 

inspector also noted that, since the coils were purchased as unqualified source 

material and upgraded in accordance with NCA-3855.5, each of the four coils 

should have been tested. 

C. Conclusions 

The document review described above identified three examples where certificaition 

packages provided to Nova customers were incomplete in that they did not include the 

results or certifications of all tests and heat treatments performed by approved suppliers 

as required by paragraph NCA-3862.1 of Sectionilll of the ASME Code. Failure to 

include certifications from approved suppliers as identified attachments to Nova 

cer'.ifications to Centerior Energy (PO S 078945 D97), Northeast Utilities (PO 

00951296), and PECO Energy (PO LS 608180) were identified as Nonconformance 

99901 052/97-01-01. 

During the October 1997 inspection, the inspectors reviewed Nova's corrective (actions. 

The inspectors determined that Nova provided the applicable certifications to PECO 

Energy by letter of August 13, 1997, and to Centerior Energy and Northeast Utilities by 

letters of August 28, 1997. In addition, Nova revised the certification checklist 

referenced in Procedure NP-15 to address the Code requirement to provide all heat treat 

data required by the marerial specification and to include the macroetch test results, as 

applicable. The inspectors confirmed the revision had been made and reviewed records 

indicating that appropriate personnel had been trained in the revision. 
3.4 Qua I ifi ca t ion of Mate ria I Vendors 

The Nova QA manual has established several categories of vendors, based on their 

scope of supply. The methods of vendor qualification or approval for each of these 

categories are described in Section 6.5 of the manual. Non-accredited vendors of 

ASME Code material are qualified by Nova survey, performed on a three year 

frequency. The surveys are performed by au-itors qualified in accordance with 

Section 14 of the Nova QA manual and procedure NP-IO, "Qualification of Auditors," 

using approved checklists. 

A sampling review of audits of ASME Code material suppliers qualified by Nova, 

including the completed checklists, showed that these documents did not address the 

upgrading of unqualified source material. According to the Nova QA manager, material 

purchased from Nova-qualified manufacturers is generally limited to basic mill products 

which are not upgraded, therefore, upgrading of stock material was not included in the 

scope of the audit checklists. The inspectors, however, identified at least one vendor 

(Flowline Division of Markowitz Enterprises) that Nova had qualified to a scope triat 

included the upgrading of unqualified source material. A review of the vendor's QA 

manual, on file at Nova, indicated that the manual contained adequate controls for the 

upgrading process. 

Failure to include controls for upgrading of unqualified source material in the vendor 

survey checklist was identified as a program weakness. 

3.5 Commercial Grade Item Dedication Proaram 

a. InsDection ScoDe 

The NRC inspectors reviewed the program and procedural controls applicable -to 

Nova's Commercial grade item (CGI) dedication activities including the selection of 

critical characteristics and the use of sampling plans for nondestructive and destructive 

examinations and tests. The inspectors also observed in-process dedication activities 

and reviewed document files for a sample of recently filled and in-process material 

orders to evaluate the implementation of the applicable QA program requirements. 

b. Observations and findinas 

b. 1 Dedication Methodology 

The requirements for CGI dedication are prescribed in Nova's Quality Assurance 

Manual, Edition 4, Revision 1, and Procedure No. NP-12, "Supplemental Testing," 

Revision 10, dated March 3, 1997. 

Nova selects critical characteristics for CGls based on the requirements specified by the 

applicable American Society for Testing and Materials (ASTM) material specification and 

any other testing requirements specified by the customer. Critical characteristics, in 
5.2 

general, include dimemions, workmanship, and when required by the applicable 

material specification, chemistry and mechanical properties and other specified tests. 

Subsequent to the June 1997 inspection, Nova provided clarification to the NRC on the 

verification of mechanical and chemical critical characteristics as provided for in 

Section 1 of Attachments 5.O(A), 5.O(B), and 5 O(C) of Procedure NP-12. Section 1 

states, “Fhchanical and chemical attributes 1 .‘hen size allows (as defined by tlie 

applicable material specification), test and correlate to the requirements dictated by the 

customer or applicable material specification.” Nova informed the inspectors that 

Section 1 of the attachments to Procedure NP-12 requires that all testing and analyses 

required by the applicable ASTM material specification be performed, however, Nova 

further explained that some material specifications exempt products from certain tests 

and analyses based on the product size. 

Use of Sampling Plans for CGI Dedication 

Sampling plans used t,j Nova for CGI dedication are based, in part, on a comtmation of 

the provisions contained in: a) EPRl NP-72 i 8, “Guideline for the Utilization of Sampling 

Plans for Commer5;I-Grade Item Acceptance (N.G.-19),“ dated June 1992, b) ASTM 

A-490 (33). “Standard Specification for Heat-Treated Steel Structural Bolts, 150 ksi 

Minimum Tensile Strength;” and c) the degree of confidence that the lot being sampled 

contains homogenous items. 

Nova informed the NRC inspectors that they chose the sample size provided in the 

shipping lot sampling plan contained in ASTM A-490 (93) because this plan is one of the 

most severe sampling plans for chemical and mechanical destructive testing in the 

ASTM standards. The NRC inspectors expressed a concern to Nova that the Shipping 

Lot Size sample plan provided in ASTM A-490 is for the manufacttirer of a comtmercial 

product line. Also, the NRC inspectors identified that the quality controls identified in 

ASTM A-490 do not appear to meet the quality requirements of Appendix B to 10 CFR 

Part 50 and that such a sample size could include more than one production lot or heat 

of material. Nova informed the inspectors that it selected this sampling plan biased 

upon the quantity provided in the ”Shipping Lot Size” table. 

The NRC inspectors also expressed a concern that the qualitative methods for 

determining when a homoger~ous lot exists and that the basis for such decisions, as 

described in Procedure No. NP-12, were not very prescriptive and placed much reliance 

on judgement. Other concerns expressed by the NRC inspectors are addressed in 

Section 3.5.c.l of this inspection report. 

Procedure NP-12 lists a number of sampling plan selection factors and provides four 

categories of sampling plans based on these factors. These sampling categories are 

included in Attachment 5.0 to Procedure NP-12 and are discussed below: 
b.2(a) SamDlina Plan Attachment 5.0 (A) of Procedure No. NP-12 

Nova uses the following sampling plan for its dedicatiov of CGls purchased from a 

commercial vendor where there is no vendor history, the vendor has not been audited, 

the part is not identified to a standard, and the part is not marked (Reference is made to 

the applicable sampling tables contained in EPRl NP-7218. 

Inspection Characteristic Sampling Plan 

Configuration 

Dimensions 

Appearance 

Hardness* 

C hem i ca I * 

Mechanical* 

Tightened (Table 2-1 of EPRl NP-7218) 

Tightened (Table 2-1 of EPRI NP-7218) 

Tightened (Table 2-1 of EPRl NP-7218) 

Tightened (Table 2-1 of EPRl NP-7218) 

See Section 3.5.b.2(e) of this Report 

See Section 3.5.b.2(e) of this Report 

* When required by the material specification 

b.2(b) Samtdina Plan Attachment 5.0 (B) of Procedure No. NP-12 

Nova uses the following sampling plan for its dedication of CGIs purchased from a 

commercial grade vendor that has been used before (but not qualified) and where parts 

are identified and can be traced to a known standard based on the vendor’s nonqualified 

and unaudited markings and documentation: 

Inspection Characteristic Sampling Plan 

Configuration 

Dimensions 

Appearance 

Hardness* 

Chemical* 

Mechanical* 

Normal (Table 2-1 of EPRl NP-7218) 

Normal (Table 2-1 of EPRI NP-7218) 

Normal (Table 2-1 of EPRl NP-7218) 

Normal (Table 2-1 of EPRI NP-7218) 

See Section 3.5.b.2(e) of this Report 

See Section 3.5.b.2(e) of this Report 

* When required by the material specification 

b.2(c) Samdina Plan Attachment 5.0 !Cl Procedure No. NP-12 (Condition A) 

Nova uses the following sampling plan for its dedication of CGls purchased 

from a commercial grade vendor when a commercial audit of the vendor has been 

conducted to verify the items are produced from a single heat/lot of material and 

traceability has been maintained throughout all processing. 
Inspection Characteristic Sampling Plan 

~ Regardless of Nova's activities associated with the vendor supplying CGls or the revilew 

of the vendor's quality program implementation, Nova uses the same sampling plan ior 

verifying the CGl's chemical and mechanical properties. This amount of testing is based 

on the Shipping Lot Size sampiing plan provided in ASTM A-490 (93). 

~ 

Configuration 

Dimension? 

Appearance 

Hardness* 

Chemical* 

Mechanical* 

Normal (Table 2-1 of EPRl NP-7218) 

Nwmal (Table 2-1 of EPRl NP-7218) 

Normal (Table 2-1 of EPRl NP-7218) 

Normal (Table 2-1 of EPRl NP-7218) 

S ?e Section 3.5.b.2(e) of this Report 

See Section 3.5.b.2(e) of this Report 

* When required by the material specification 

b.2(d) SamDlina Plan Attachment 5.0 (C) Procedure No. NP-12 (Condition B) 

Nova uses the following sampling plan for purchases from a commercial grade vendor 

when a commercial audit of the vendor has been conducted to verify that the items itre 

produced from a single heat/lot of material, traceability has been maintained lhroughout 

all processing and other attributes have been reviewed during the audit ,?ti Tound 

acceptable. 

Inspection Characteristic Sampling Plan 

Configuration 

Dimensions 

Appearance 

Hardness* 

Chemical* 

Mechanical* 

Reduced (Table 2-1 of EPRl NP-7218) 

Reduced (Table 2-1 of EPRl NP-7218) 

Reduced (Table 2-1 of EPRl NP-7218) 

Reduced (Table 2-1 of EPRl NP-7218) 

See Section 3.5.b.2(e) of this Report 

See Section 3.5.b.2(e) of this Report 

* When required by the material specification 

b.2(e) Mechanical and Chemical Testina Per Procedure No. NP-12 

10 

42 
Lot Size Sample Size 

1 (1 to sell, 1 to test) 

2 to 25 

26 to 50 

51 to 150 

151 to 12CO 

1201 to 10,000 

10,000 to 35,000 

35,001 to 150,000 

1 

2 

3 

5 

8 

13 

20 

32 

Accept an ce 

(Note 1) 

(Note 2) 

(Note 2) 

(Note 2) 

(Note 2) 

(Note 2) 

(Note 2) 

(Note 2) 

Note 1 : Acceptance Number is 0, test piece must pass. 

Note 2: Acceptance Number is 0, all test pieces must pass. 

The NRC inspectors and Nova discussed the need for a 95 percent confidence that 

there are only 5 percent defective items in a lot (95/5) as discussed in documents 

referenced in NRC Information Notice No. 96-40, "Deficiencies in Material Dediation 

and Procurement Practices and in Audits of Vendors," dated July 25, 1996. The NRC 

inspectors informed Nova that the 95/5 confidence level is applicable for dedicated CGls 

used in high-safety-significant applications, as determined by NRC licensees using 

probabilistic and deterministic methods similar to those described in NRC draft 

regulatory guides DG-1061, "An Approach for Using Probabilistic Risk Assessment in 

Risk-Informed Decisions on Plant-Specific Changes to the Current Licensing Basis," 

dated March 28, 1997, and DG-1064, "An Approach for Plant-Specific, Risk-Informed 

Decision Making: Graded Quality Assurance," dated March 24, 1997. A 95/5 confidence 

level may also apply to items dedicated for unrestricted safety application (end use or 

safety classification not identified) and certifiea as complying with all requirements of 

10 CFR Part 50, Appendix B. 

Nova questioned the NRC regarding the need for all customer orders to be processed in 

accordance with a sampling plan that provides a 9515 confidence level. The inspectors 

informed Nova that, as discussed above, the 9515 confidence level was applicable only 

to those items dedicated to high safety significant (or unrestricted) applications and that 

it was the NRC licensee's responsibility to evaluate and accept the sampling plans used 

by Nova for dedicating CGls supplied for its purchase orders. It was further discussed 

that for dedicated CGls used in low-safety-significant applications, the use of a gradeu 

approach, as discussed in DG-1064, to determine the necessary sampting plan would 

be acceptable. For such applications, a sampling plan having a confidence level less 

than 95/5 confidence level may be appropriate. 

The NRC inspectors informed Nova that, in general, a reduced (less than 95/5) 

sampling plan should be used only after review and acceptance by the customer. Nova 

informed the NRC inspectors that its sampling plans were generally raviewed by its 

customers during their audits and that recently a joint utility audit had been performed 

and there were no findings in the area of Nova sampling plans used for dedicating CGls. 

The NRC inspectors' review of the joint utility audit is summarized in Section 3.6 of this 

report. 
b.3 Review of Recent Sales of Dedicated Material 

The NRC inspectors reviewed several in process and completed CGI dedication 

packages to determine if the critical charaPteristics for the items had been projDerly 

identified and verified. In addition to the identified quality and technical requirements, 

the following POs invoked the requirements of Appendix B to 10 CFR Part 50 and 

10 CFR Part 21. 

0 Item 2 on Nova Sales Order No. 4981 8, was for the supply of 100, ASTM E3 21, 

Alloy 464, slotted flathead No. 4-40 x 3/16 brass screws, in accordance with 

Nebraska Public Power District PO 97-1 872, dated May 6, 1997. This isales 

order was being processed during the NRC inspection. 

To supply these fasteners, Nova issued a commercial PO and purchased a 1/4 

inch diameter X 6 feet long, ASTM 821, Alloy 464, round bar, from Copper & 

Brass Sales in Cleveland, Ohio. Prior to machining each machine screw, Nova 

cut two pieces of material from the round bar and sent them to an approved 

supplier, Herron Testing Laboratories, Inc., located in Cleveland, Ohio, For 

chemical and mechanical testing (tensile, yield, elongation, and reduction in 

area). Because this sales order was being processed during the inspection. the 

results of the configuration, dimensional. and final visual inspection were not 

available to the NRC inspectors. 

The NRC inspectors found the dedication activities specified by Nova for 

dedicating the screws on Sales Order No. 49818 to be satisfactory. 

0 item 2 on Nova Sales Order No. 39933 was for the supply of 10, SAE J429 

(August 83), Grade 8, 5/16-18 UNC 2A X 4 inch, fully threaded hex head 

capscrews, in accordance with PECO Energy Company Blanket PO No. 159325, 

Release No. 348002, dated May 13, 1997. 

This sales order was being processed during the NRC inspection. To supply 

these fasteners, Nova obtained 5/16-18 UNC 2A X 6 inch fasteners of the 

specified material from its stock. These stock fasteners were purchased safetyrelated in 1988, with Appendix B to 10 CFR Part 50 and 10 CFR Part 21 invoked, 

from Lake Erie Screw Corporation in Cleveland, Ohio. Although Lake Erie Sc ew 

Corporation is not presently an approved supplier, at the time of purchase in 

1988, it was on Nova's approved supplier list. Nova informed the NRC that, 

even though the fasteners purchased from Lake Erie Screw Corporation were 

considered basic cutnponents, they were being processed as though they were 

not fully dedicated CGls because they were being altered from 6 inches to 4 

inches long and the PECO Energy Company's PO had invoked several unique 

certification requirements. 

To process the sales order, Nova performed hardness testing on two capscrews, 

proof load tests on two capscrews, and wedge tests on two capscrews. Nova 

did not perform chemical overchecks on the capscrews and justified not 

12 

44 
performing chemical tests on the capscrews because they were purchased from 

an approved supplier. Eight capscrews were subjected to full dimensional and 

configuration checks and all completed capscrmws were subjected to a final 

visual exam in at ion. 

The NRC inspectors found the procurement, inspection, and testing activities 

performed by Nova for the sup+l} of the capscrews on Sales Order No. 39933 to 

be satisfactory. 

0 Item 5 on Sales Order No. 39089 was for the supply of 100 ANSI B18.21.1(83), 

1/4 inch, type 304 stainless steel lock washers (regular helical) in accordance 

with PECO Energy PO 159622, dated April 7, 1997. 

To supply these fasteners, Nova obtained the lockwashers of the specified size 

and material from its stock. The lockwashers in stock were purchased 

commercially from the Mellowes Company in Milwaukee, Wisconsin in 1987. 

Nova dedicated the lockwashers by obtaining 172 from stock 2nd srforming the 

following dedication activities: 

a. A total of 72 pieces were sent to an approved supplier, Herron Testing 

Laboratories. Inc.. located in Cleveland, Ohio. A total of 18 chemical 

tests and 18 hardness tests were performed. 

b. The remaining 100 lockwashers were subjected to dimensional and visual 

inspections (inside and outside diameters and thickness). 

The NRC inspectors found the procurement, inspection, and testing activities 

performed by Nova for the supply of the lockwashers on Sales Order No. 39089 

to be satisfactory. 

On October 2, 1997, the NRC inspectors reviewed an additional nine Nova CGI 

dedication packages, processed during the period March through September 

1997, for the supply of small metallic products selected from the following POs: 

five for Northeast Utilities (POs 02015122,0201 8733,02039272, and 00951296, 

Blanket Releases No. 34, and No. 58), two for the Tennessee Valley Authority 

(PO P95N2G108252, Releases 1 183024 and 1 184926), one for Nebraska Public 

Power District (PO 971872), and one for PECO Energy (P0159325, Release 

No. 387049). 

The inspectors found that all required chemistry analysis, mechanical testing, 

and hardness testing was performed when required by the applicable PO and 

material specification. 

The inspectors noted that several of the above orders specified ANSI 818.63, “Slotted 

and Recessed Head Machine Screws”. The inspectors and Nova discussed the intent 

of the provisions contained in Section 2.7, “Material,” of ANSI B18.6.3 which states the 

following: 
2.7.1 Material Screws. Unless otherwise specified,. machine screws 

shall be fabricated from carbon steel and shall have a minimum tensik 

strength of 60,000 psi. 

2.7.2 Machine Screws, where so specified, may also be made from 

higher strength steels, corrosion resistant steel, brass, monel, aluminum 

alloys or other materials, as agreed u/:on between the manufacturer and 

the purchaser. 

Nova informed the inspectors that it interprets the above as meaning that only carbon 

steel must satisfy the 60,000 psi minimum tensile strength. Nova considers that screws 

manufactured from stainless steel, brass, or other non-carbon materials are exempt 

from tensile requirements unless specified by the purchaser. Nova considers stainless 

steel as corrosion resistant steel. Nova further informed the inspectors that customer 

POs for non-carbon screws manufactured in accordance with ANSI B18.6.3 typically do 

not specify tensi!s test requirements. 

C. Conclusions 

The NRC inspectors concluded that Nova’s CGi dedication program addresses the 

essential elements of the dedication process and that sufficient guidance for performing 

activities such as inspection and testing are provided. However, the NRC inspectors 

identified the following weaknesses: 

0 The NRC inspectors questioned Nova’s practice of stamping all CMTRs, 

including those received from unqualified suppliers, with a “Nova QA Approved” 

stamp, based only on a comparison of the CMTR reported values to the material 

specification requirements. The inspectors noted that this practice may be 

misleading to the recipients of such CMTRs, since Nova QA approval may be 

reasonably assumed to also include other supplier activities such as material 

melting practice or heat treatment, which may not be directly verifiable for 

unqualified source material. This practice is of concern also because Nova’s 

CGI dedication program does not specifically require that the results of their 

verification tests (chemical and mechanical) be compared to the values; reported 

on the original CMTR to validate this document. Significant composition 

variances, even within the product analysis tolerance limits, between the Nova 

overchecks and CMTR reported values could be an indicator of mixed heats of 

material or incorrect CMTR for the material being dedicated. Significantly 

diverging results could, therefore, also invalidate other pertinent information 

incluaed on the suspect CMTR. 

0 All of the nondestructive sampling plans in the attachments to NP-12 use the 

same destructive testing sampling plan regardless of whether the products were 

purchased as a lot from multiple or a single nonqualified supplier or whlether the 

products were obtained from a supplier that had or had not been subjected to a 

commercial grade survey. 
The NRC inspectors obsewed Nova personnel performing the following activities: a) 

receiving, in process, and final inspections, b) chemical analyses, c) tensile, proof load. 

wedge, and hardness testing, d) order review, and e) shop order processing. Personnel 

performing these activities demonstrated profciency ii accomplishing these activities 

and a high degree of knowledge of the applicable industry codes and standards and 

Nova procedure requirements for the activities. There were no abnormalities observed. 

As a result of their observations and reviews, the NRC inspectors considered the 

following to be additional strengths: 

e Nova's attitude to perform work activities correctly was evident during the 

conduct of the inspection, especially during the discussions between the NRC 

and Nova concerning the selection of appropriate sampling plans used for CGI 

dedication. 

0 The interfaces and communications between the various organizations 

processing a customer's PO were observed to be well established and 

implemented in a professional manner. 

3.6 Nuclear Procuremcilt Issues Committee (NUPIC) Joint Licensee Audit 

The inspectors reviewed information related to a NUPIC joint utility audit, performed at 

Nova on April 23 through 25, 1997. The lead utility for this audit was Nebraska Public 

Power District, Cooper Nuclear Station, with an audit team consisting of a lead auditor 

and a technical specialist from the Nebraska Public Power District and a quality 

assurance engineer from Niagara Mohawk Power. The technical specialist evaluated 

Nova's sampling plan including its use in CGI dedication activities. The technical 

specialist identified no findings, adverse observations, or weaknesses in these areas. 

Nebraska Public Power issued the Nova audit report, including completed audit 

checklists, to the NUPIC members by cover letter dated May 23, 1997. During the NRC 

inspection, the inspectors identified concerns to Nova regarding the NUPIC audit report 

and checklists. As a result of a subsequent internal critique and various comments 

from NUPIC members and by Nova, Nebraska Public Power District issued a revision to 

the audit report, dated June 18, 1997, and distributed this revision to the NUPIC 

members. 

Based on a review of the Nova CGI dedication program and its associated sampling 

plans, the NRC inspectors determined that the original and revised NUPIC joint utility 

audit reports and checklists, dated May 23, 1997, and June 18, 1997, respectively, 

lacked sufficient detail for a NUPIC member to adequately assess NOVA's CGI 

dedication process. 

Specifically, the NUPIC audit report notes that the sampling plans, used in Nova's CGI 

dedication program, meet the provisions of MIL-STD-105E and/or EPRl NP-7218. 

However, the audit reports failed to identify that NOVA's Procedure No. NP-12, 

Revision 10, permitted the use of sampling plans for CGI dedication that did not meet 

47 
either NP-7218 or MIL-STD-105E. As discussed in Sections 3.5.b.2 and 3.5.b.2(e) of 

this inspection report, Nova's destructive testing sampling plan used for CGI dedication 

is based on ASTM A-490(93). 

Additionally, although Nova's practice of stamping CMTRs from approved suppliers is 

addressed, the completed NUPIC audit checklists and audit reports do not address how 

Nova processes CMTRs received from no.-i.qialified suppliers when performing CG' 

dedication. According to Nova's procedures/practice, CMTRs received from 

nonqualified sources are stamped "Nova QA Approved,'' meaning that Nova hias 

reviewed and compared the information on the nonqualified CMTR against applicable 

specification requirements and found it acceptable. Nova then processes the 

associated CGI through its dedication program, defined in Procedure NP-12. Further, 

should the chemical and mechanical overchecks performed by Nova vary from the 

values listed on the CMTR, Procedure NP-12 does not require Nova to take any action 

to investigate such variances. Thus, a customer receiving a CMTR stamped "Nova QA 

Approved" would not be aware that; a) the item associated with the CMTR may have 

been dedicated and the CMTR is from a nonqualified source, b) there is a possibility 

that test results and other the information listed on the CMTR may vary from the actual 

Nova overcheck tW results (Nova does not provide its CGI dedication chemical and 

mechanical test results unless specifically requested by its customers), and. c) there is a 

possibility that information listed on the nonqualified suppliers CMTR has not been 

independently overchecked by Nova. 

In summary, the NRC inspectors noted that the effectiveness and usefulness of joint 

audits are dependent on capturing sufficient information to enable the potential users of 

the audit information to reasonably assess the vendor's program controls and 

implementation for specific activities that are important to the user's procurement needs. 

The Nebraska Public Power District joint audit reports and checklists do not appear to 

contain sufficient detail for NUPIC members to assess Nova's controls for its commercial 

grade item dedication process. For example, as discussed above, the provisioris of 

Procedure No. NP-12 are not adequately described. The "Test and Inspection" section 

contained in the audit report, could be assumed to mean that Nova's destructive testing 

sampling program meets MIL-STD-105E (neither the audit report nor checklist address 

the fact that Nova's destructive testing sampling plan is based on ASTM A-490 inor do 

they address the acceptability of the sample size provided in ASTM A-490 shipping lot 

sampling plan). 

Based on the above discussion, Nova's sampling plan, as described in NP-12 and as 

evaluated by NUPIC members, may not be adequate for items that are intended to be 

used in high-safety-significdnt applications or applications where environmental 

conditions are of particular concern. For such applications, the licensee may desire the 

use of a sampling plan that will provide a higher confidence level than that provided by a 

destructive sampling plan based on ASTM A-490. Also, for these applications, l:he 

licensee may have the need for a CMTR produced under an Appendix B QA Program or 

the actual Nova test results rather than using information delineated on a CMTF! from a 

nonqualified source 
3.7 Entrance and Exit Meetinas 

In the Entrance meetings , on June 2, 1997, and October 2, 1997, the NRC inspectors 

discussed the scope of the inspectiop~ outlined the areas to be inspected, and 

established interfaces with Nova management. In the exit meetings, on June 5, 1997, 

and October 2, 1997, the inspectors discussed their findings and concerns. 

PARTIAL LIST OF PERSONS CONTACTED 

James A. Mraz, President and CEO 

Tim Walker, Executive Vice President 

John Burk, General Manager 

Jim Fitzwilliam, Quality Assurance Manager 

Dave Nenstiel, Laboratory Manager 

Sandy Jacoby, QC Documentation 

Kurt Bartley, Level II Inspector 

Tony Holloway, Level Ill Inspector 

Tim Corrigan, Materials Director 

ITEMS OPENED, CLOSED. AND DISCUSSED 

ODen/Closed 

99901 052/97-01-01 NON Incomplete documentation to support CMTR 

17 

49 
Identifier 

Selected Generic Correspondence on the Adequacy of 

Vendor Audits and the Quality of Vendor Products 

- Title 

Information Notice 97-81 Deficincies in Failure Modes and Effects Analyses for 

Instrumentation and Control Systems 
URC FORM 335 SSION 11. REPORT NURIBER 

2-89) 

lRCM 11 02, 

US. NUCLEAR REGULATORY COMMl~ I (Assigned by NRC. Add Vol., SUPP., Rev., and Addendum Numbers, if any.) 

:201,3202 BIB LlOG RAPHIC AT A 

(See j"st*,,"':n"e A" 

!.TITLE AND SUBTITLE 

Vol . 21, No. 4 

Licensee Contractor and Vendor Inspection 

-Status Report 

Quarter1 y Report October - December 1997 

3. DATE REPORT PUBLISHED 

MONTH I YEAR I April 1998 

4. FIN OR GRANT NUMBER 

Quarterly 

October - 

December 1997 

7. PERIOD COVERED (InclusiveDaresl 

i. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Officeor Region, US. Nuclear Regulatory Commission, andmailing address;if contractor, provide 

name and mailing addred 

Di vision of Reactor Control s and Human Factors 

Office of Nucl ear Reactor Regul ati on 

U. S. Nucl ear Regul atory Commi ssi on 

Washington, D.C. 20555-0001 

I. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, wpe "'Same as above': if contractor, provide NRCDivision, Office or Region. U.S. Nuclear Regulatory Commission, 

and mailing address.1 

Same as 8., above. 

IO. SUPPLEMENTARY NOTES 

I 1. ABSTRACT 1200 words or less1 

This periodical covers the results of inspections performed by the NRC's Quality 

Assurance, Vendor Inspection and Maintenance Branch that have been distributed 

to the inspected organizations during the period from October through December 1997. 

2. KEY W0RDSIDESCR:PTORS (Lisr wodsorphrases that willassist researchers in locatingthereport,I 13. AVAl LABILITY STATEMENT 

Vendor Inspection Unl imi ted 14. SECURITY CLASSIFICATION 

(This Page1 

Uncl assi f i ed 

Uncl assi f i ed 

(This Report1 

15. NUMBER OF PAGES 

16. PRICE 

1 IRC FORM 335 (2-89)