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| ORGANIZATION: POSI-SEAL INTERNATIONALNORTH STONINGTON, CONNECTICUT*

REPORT INSPECTION (NSPECTION |NO.: 99900886/87-01 DATE: 07/06-10/87 )N-SITE HOURS- M

CORRESPONDENCE ADDRESS: Posi-Seal International, Inc.-

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ATTN: Mr. Peter E. Arnold ,

IGeneral ManagerRoute 49 and U.S. 95North Stonington, Connecticut 06359

ORGANIZATIONAL CONTACT: Robert D. Barry, Manager of QualityTELEPHONE NUMBER: (203) 599-1140

NUCLEAR INDUSTRY ACTIVITY: Manufacture butterfly valves.

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ASSIGNED INSPECTOR: 16\ bW% [ Zl-8'l.

'T- 1 J.F . Conway, Program Development and Reactive DateG nspection Section (PDRjlS)

OTHER INSPECTOR (S): C. Abbate. PDRIS

APPROVED BY: w& /hf> D/ 7,

J. Stone / Chief,PDRIS,'VendorInspectionBranch a

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INSPECTION BASES AND SCOPE: )J

A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21. !!I

B. SCOPE: This inspection was made as a result of an allegation pertainingto the removal of hold tags from nuclear valves by a production manager.

PLANT SITE APPLICABILITY: Palo Verde Units 1, 2, 3 (50-528, 529 and 530)..

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8709100415 870909PDR GA999 EPfVPOSIB99900806 PDR;

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ORGANIZATION: POSI-SEAL INTERNATION/.Li' NORTH STONINGTON, CONNECTICUT.

REPORT ' INSPECTIONNO.- 99900RR6/87-01 RESULTS: PAGF 7 nf in

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A. VIOLATIONS: - - . -

Contrary to Section 21.31 of 10 CFR Part 21, a review of documentationpackages (DP) and purchase orders (PO) for butterfly valves fabricatedunder Section III of the ASME Code, revealed that while 10 CFR Part 21was imposed on Posi-Seal International (PSI), PSI did not specify that10 CFR Part 21 requirements would apply on P0s H9657 (September 27, 1983),J0446 (November 4, 1983), and J8593 (January 29, 1985) to ABC0 Weldingand Industrial Supply Company; 12261 (April 1, 1987) to Adironadack SteelCastings; G7646 and 7647 (January 15, 1962), K0988 (June 18, 1965) and11448 (February 19, 1987) to Congdon and Carpenter Company; 13035 (May 26,1987) and 13076 (May 28, 1987) to Empire Steel Castings; K2060 (July 29,1985) to Hy-Temp; 12215 (March 31, 1987) to Jessop Steel; G7459 (January 6

- 1982) to Lebanon Steci Foundry; 13097 (May 29, 1987) to HQS; 12605(April 24, 1987) to Pre::ure Vessel-Nuclear Steels; 11449 (February 19,1987) to Quaker Alloy; ard 12208 (March 30, 1987) to Texas Bolt.

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B. NONCONFORMANCES:

1. Contrary to Criterion IX of Appendix B to 10 CFR Part 50 andSections 12.30 and 12.40 of the Quality Assurance Program Manual. _ _ .

(QAPM), it was noted that three NDE procedures - Nos. 13S-HAR-UT-29,*

23.A.200-1986, and 23.A.031-1986 - used by Magnaflux/MQS Inspectionin February 1984 and June 1987 were not reviewed by PSI.(87-01-02)

2. Contrary to Criterion IX of Appendix B to 10 CFR Part 50, Section12.40C of the QAPM, and Section 9.6.1 of SNT-TC-1A> it was notedthat PSI did not have the qualification records ror fourindividuals from Magnaflux/MQS Inspection who bsa performed NDEin February 1984, February 1986, and June 1987. (87-01-03) -

3. Contrary to subsection NCA-4134.4 of Section III s. the ASME Codeand Criterion IV of Appendix B to 10 CFR Part 50, a review of P0s

I revealed that quality requirements were not passed on to vendors| for the following P0s: 11656 and 11659 (March 2, 1907) to

Airmotive Calibration Corporation; 3689 (April 24, 1979), 3735(June 4, 1979) and 4857 (July 30, 1979) to Cambridge Plating; and3692 (April 27, 1979) to Fountain Plating. (87-01-04)

4. Contrary to subsecticn NCA-4134.5 of Section III of the ASME Codeand Criterion V of Appendix B to 10 CFR Part 50, writteninstructions or procedures did not exist for the use of " hold tags"on nuclear components. (87-01-05)

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ORGANIZATION: POSI-SEAL INTERNATIONALNORTH STONINGTON, CONNECTICUT' *

REPORT ' INSPECTIONNO.- 99900AA6/87-01 RESULTS: PAGF 3 nf 10C. UNRESOLVED ITEMS:

During the inspection, it was noted that 4-24" motor operated butterflyvalves were returned to PSI from the Palo Verde nuclear site. Thevalves were returned in 1985 because of deterioration of the electrolessnickel plating on the valve discs. A meeting was held on June 25, 1985with Combustion Engineering (CE) personnel pertaining to this problem.PSI was unable to furnish documentation of the meeting and the causefor the corrosive attack of the nickel plating. Accordingly, this itemwill remain unresolved until it is discussed with CE and Bechtelduring a future NRC inspection of their facilities.

D. STATUS OF PREVIOUS INSPECTION FINDINGS:

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None. This was the first inspection at this facility.

E. OTHER FINDINGS AND COMMENTS:)

1. Allegation

In April 1987, the Region I office of the NRC was notified of anallegation perteining to the removal of hold tags from nuclear

|y- valves in order to get the valves shipped.|

The use of hold tags and other manufacturing controls werereviewed during the inspection. Section 9.30 of PSI's QAPMstates that travelers are the official status indicators fornuclear components and all other tags, etc. are used for visualaid only. The traveler is the control mechanism for fabrica-tion in that the next operation on the traveler cannot beperformed until the previous operation has been signed off bythe QC inspector. All operations must be signed by QC.

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Hold tags are used on nuclear components as a visuti aid towarn personnel that work is not to be performed on thatcomponent until the hold is released. Hold tags are placed oncomponents which do not meet acceptance criteria. The tagshave two parts. One part is put on the component as a visualaid while the other part is kept by QC until the problem isdispositioned. After dispositioning both parts of the tag aredestroyed.

In addition to the travelers, QC sign-offs, and hold tags, PSIQA personnel perform a final review of the traveler andinspection reports before a computer hold on the component isreleased. This is done in order to assure that al) operationson the traveler have been performed. Until QA completes its

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ORGANIZATION: POSI-SEAL INTERNATIONALNORTH STONINGTON, CONNECTICUT-

REPORT ' INSPECTIONNO.- 99900886/87-01 RESULTS: PAGE 4 nf 10

review and releases the computer hold, a bill of lading or_

shipping papers cannot be printed; and the valve cannot beshipped. -

The inspectors were unable to determine if hold tags wereremoved from nuclear valves or components. However, due to theadditional controls PSI has implemented, a valve could not beshipped unless all holds have been officially released by QA orQC. Subsequently, the allegation could not be substantiated.

2. Nondestructive Examination (NDE)

The NRC inspector reviewed Section 12 of the QAPM, six NDEprocedures, and the qualification records for nine NDE personnel.

- Procedure QCS-001 " Qualification and Certification of Nonde-structive Examination Personnel" documents PSI's qualification /-certification program. A June 1985 letter from PSI's Managerof Quality to Fisher Controls (FC) appointed two individualsfrom FC as Level III examiners for PSI. FC's written practice,procedure No. FMP 2J1 "American Society for NondestructiveTesting Personnel Qualification and Certification" was stampedQA approved and signed by PSI's Manager of Quality.

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It was noted that Magnaflux/MQS Inspection performed ultrasonic'

(UT) radiographic (RT), and liquid penetrant (PT) testing forPSI. MQS personnel E. Toper performed PT and R. Boswellperformed RT in June 1987 on components for Palo Verde (referencejob ho.39620). UT was perfurmed in February 1984 by D. Trott onstems for Beaver Valley (reference job No. 30611). For Clinton(reference job No. 36190), R. Thompson performed RT on discs inFebruary 1986. PSI did not have copies of the qualificationrecords for the four examiners identified above (see Noncon-formance 87-01-03). A review of three procedures from HQS and -used for the NDE testing indicated that PSI did not review andapprove the procedures (see Nonconformance 87-01-02). The

| procedures were No. 135-HAR-UT-29 " Ultrasonic to ASME Section III"dated February 22, 1979; No. 23.A.200-1986 " Penetrant ExaminationFluorescent Dye General Requirements" dated October 27, 1986; andNo. 23.A.031-1986 " Penetrant Examination" dated January 21, 1987.

In general, the type of information found in the record files forthe seven NDE personnel (five - Level II PT and two-Level I PT)from PSI included educational background, resumes, certificatesof training completed, record of qualification, certification

*statements,

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REPORT ' INSPECTION |NO.- 99900886/87-01 RESULTS: PAGE 5 of 10 J

examinations (general, specific, practical) and eye exams. ,

The qualification records appeared to satisfy the regy.irements ofSNT-TC-1A. A review of the NDE procedures at the PT work stationindicated that the current procedures were in the manual.

3. Calibration of Measuring and Test Equipment (M&TE)

The NRC inspector reviewed Section 16 of the QAPM, standardinstructions, calibration schedule cards, and certifications forreference standards used by service vendors to calibrate M&TE.An observation of H&TE at various work stations was also per-formed to assure that M&TE are properly identified, controlledand calibrated at specified intervals. The M&TE selected forreview include the following: a thermometer, two ampmeters,

- two voltmeters, five verniers, 10 micrometers, 15 pressuregages, two gage block sets, and a deadweight tuter.

All the M&TE was in current calibration and a sticker showingthe calibration due date was attached to each item. AirmotiveCalibration Corporation was the vendor that calibrated the twogage block sets and the weights for the deadweight tester. Thepressure gages are calibrated within 24 hours prior to testingand after each test or series of tests not to exceed two weeks._

It was verified that the pressure gages used on testing of5

nuclear valves had been calibrated prior to and after each test(four in 1986 and three in 1987). The ampmeter and voltmeteron the two " Miller syncrowave 500" welding machines werechecked, and all four instruments were in current calibration.

4. Training

Training records for four years were reviewed. The recordsconsisted of a training folder which included a general _

!training matrix, specific training matrices for each departmentof PSI, and training course attendance sheets. The records anttraining were in accordance with Section 18 of the QAPM. The ,

general matrix identified positions in PSI and the sections ofthe QAPM to which employees were to be trained. The specificdepartmental matrices identified individuals and the sectionsof the QAPM to which the individual was trained. Theattendance records identified the section of the QAPM that wasbeing covered by the training, the date, the instructor and theemployees who attended the training. Employees were trained to

. their specific section(s) of the QAPM each time a new revisionI of the manual was issued.

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}REPORT -

INSPECTION

| NO.- 99900886/87-01 RESULTS: PAGE 6 of 10

5. Manufacturing Cortrols_

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During the inspection, manufacturing controls were reviewed by1observing the work being performed in the shop and by a

documentation / procedure review. Areas examined included shoptravelers, material identification and traceability, in-processand final inspection, and inspection personnel qualifications.

In-process and completed travelers for nuclear work werereviewed. The travelers identify the operations to be executed,QA/QC inspections, and maintain material identity and trace-ability. The travelers which were reviewed were complete andin accordance with QAPM Section 8, " Material Control and

- Traceability" and Section 9, " Shop Travelers for Manufacturing,

Assembly and Testing." The inspections had been performed whenrequired by qualified QC personnel. As outlined in QCS-008,

L" Certification of Inspection and Test Personnel," dated

' November 3, 1986, the inspectors were identified on Certifi-cation Record, individual certification records were presentand it was verified that the QC stamps used on the travelerscorresponded to qualified inspectors.

|Y During the review it was noted that hold tags are used on both ,

nuclear and non-nuclear work. A description of how the holdtags were used was given by PSI personnel, but in examining thehold tags it was noted that a hard copy of a hold tag was inthe possession of QC, not the soft copy as stated. Althoughsecticn 14.5.0 of the standard Quality Program describes theuse of hold tags on non-nuclear work, written instruction orprocedure did not exist for the use of hold tags on nuclearwork (see Nonconformance 87-01-05).

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6. Welding

The NRC inspector reviewed Section 10.0 of the QAPM pertainingto welding procedure specifications (WPS), procedure qualifi-cation records (PQR), welding material control and welderqualifications. The Welding Engineer is responsible for pre-paring WPSs and certifying the results of tests / examinations onPQRs. A distribution list for each WPS is maintained by theWelding Engineer who currently is also the Supervisor ofEngineering. In the weld area which consists of two weldingbooths, book No. 6 containing WPSs was reviewed, and eight WPSswere compared with master copies retained by the Welding

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REPORT ' INSPECTION'

PAGE 7 of 10NO . - 99900RR6/87-01 ,JESULTS:,

Engineer to assure that current procedures were at the. workstation. WPSs in book No. 2 (QA Supervisor) and book No.1(Manager of Quality) were also reviewed. The reviewed WPSs inall three books were in agreement with the master copy. Theeight WPSs along with supporting PQRs included the following:No. 1-01-1 " Manual Shielded Metal Arc Welding," Revision 0; No.1-01-1-SR, " Manual Shielded Metal Arc Welding of P-No. 1 CarbonSteel," Revision 0; No.1-04-NUC " Manual Gas Tungsten ArcWelding of P-No. 1 Carbon Steel," Revision 4; No. 1CV 04-1" Manual Gas Tungsten Arc Welding of Impact Tested P-No. 1 Grade1 and 2 Carbon Steel," Revision 2; No. 5F71-04-6 " Manual GasTungsten Arc Hard-Facing Weld Metal Overlay of P-No. 5 BaseMetal," Revision 0; No. 8-01/04-01 " Manual Shielded Metal

- Arc / Gas Tungsten Arc Welding of P-No. 8 Stainless Steel,"Revision 2; No. 8-04-1-SA " Manual Gas Tungsten Arc Welding ofP-No. 8 Stainless Steel," Revision 0; and No. 8CV-03-01" Automatic Submerged Arc Welding of P-No. 8 Group No. 1Stainless Steel." Welding on nuclear valves was not being

' performed during the inspection.

The welder qualification test (WQT) records for four welderswere reviewed. It was noted that the four welders had been!--

| ' qualified to four WPSs (i.e., 1-04-NUC, E01R10, 8-04-1 and ;

E08R10) which were used on past nuclear orders. The certifi-cation of the WQTs indicated that the welds had satisfactorilypassed a guided-bend, tensile, and/or charpy impact tests inaccordance with Section IX of the ASME Code. Testing of )coupons was conducted by Bridgeport Testing or Dirats Testing qLaboratory. l

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In the weld material storage area, low hydrogen covered elect-rodes were stored in a padlocked oven which was operating at -

250*F. A metal cabinet which was also secured with a lock i

contained the stainless steel weld material. The QC Technician jis responsible for storing and issuing welding materials. iControl of material is maintained by heat / lot numbers. The I

welding gases were stored in an area specifically designated )for such storage. |

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The weld history log, which is maintained by the WeldingEngineer, was reviewed for the time period 1983 to the present.The log is updated on a monthly basis and shows the-dates thatone of three welders performed welding to four processes (i.e,GTAU, SMAW, SAW and GMAW). A review of the nuclear weldmaterial list (NWML) in the welding material storage area

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ORGANIZATION: POSI-SEAL INTERNATIONALNORTH STONINGTON, CONNECTICUT. ,

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REPORT -INSPECTION*

NO.: 99900886/87-01 RESULTS: PAGE 8 of 10identified 11 reference Nos. (i.e., nuclear jobs currently inhouse) in which the weld material was purchased on tAree P0s.A review of the NWML in the possession of the Welding Engineeragreed with the reference Nos. and heat Nos. on the listingposted in the weld material storage area.

7. Procurement

The inspectors examined the procurement process at PSI. Thisincluded a review of Section 7 of the QAPM Quality ControlStandard (QCS) 015, " Quality Assurance Approved Vendor List;Vendor Survey, Audit, Evaluation," specifications and P0s fromPSI customers, documentation packages, the PSI Approved VendorList (AVL) and P0s to vendors on the AVL.

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P0s to material suppliers / manufacturers, calibration vendors,NDE vendor, plating vendors and heat treating vendors werereviewed to assure that applicable technical and QA programrequirements were included or referenced in the P0s. Therequirements of 10 CFR Part 21 were imposed on vendors in twocases. These two P0s were for limit switches. The P0s whichdid not invoke the requirements of 10 CFR Part 21 include threeP0s for weld wire - 00593, J0446 and H9657; twelve P0s to

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material suppliers / manufacturers - K0988, G7459, G7646, G7647,| 5

11448, 11449, 12208, 12215, 12261, 12605, 13035, and 13076; oneP0 for heat treating - K2060; and one PO for NDE Services -13097 (see Violation 87-01-01).

Additionally, the requirement that a QA Program be specified inprocurement documents was not included in six P0s to twoplating vendors and one calibration vendor. These P0s include3669, 3692, 3735 and 4851 to plating vendors, and 11658 and11659 for calibration services (see Nonconformance 87-01-04). .

8. Documentation Packages (DP)

Sixteen DPs for Section III, Class 2 and 3 butterfly valves werereviewed. Depending on the customer, the DP consisted of thefollowing documents: QA Records Validation signed by theManager of Quality, Document Index, Assembly Drawing, MaterialTraceability List, Certified Material Test Reports (CilTR),Certificate of Compliance (C of C), weld history (i.e., castingrepair), wall thickness measurement reports, PT and.RT reports,cleaning report, final test reports, and an ASME Code DataReport. The Assembly Drawing details individual parts by

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ORGANIZATION: POSI-SEAL INTERNATIONALl NORTH STONINGTON, CONNECTICUT-

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number and contains general notes (e.g., stamping ard heattreat requirements), QA notes (NDE and welding procedures), andrequired nuclear procedures (body, disc and seat tests;cicaning; painting, and packaging). The CMTRs were for thebody, disc, gasket retainer plate, gasket retainer bolts, weld ;'

material, stems and disc pins. PSI's CMTR certifies that alltests and operations performed by PSI or their subcontractorsfor the body, disc, gasket retaining and retainer bolts,welding filler metal, and leak-off pipe are in compliance withthe requirements of Section II, III and IX of the ASME Code.In addition, the valve stems and disc pins were procured and'

manufactured in accordance with a QA program which meets the-

requirements of Appendix B to 10 CFR Part 50. The CMTR issigned by the Manager of Quality.

The 16 nuclear customers designated by a PSI reference No. and| year include the following: 27813 ('81) Toledo Edison / Davis

Besse, 28988 ('82) UE&C/Seabrooke, 30611 ('83) Westinghouse /8eaver Valley, 32436 ('83) Cleveland Electric Illuminating /Perry, 34838 ('84) Gibbs & Hill /Susquehanna, 35685 ('85)Carolina Power & Light /H. B. Robinson, 35910 ('85) TVA/Sequoyah, 36190 ('85) Illinois Pner/Clinton, 38216 ('86) Duke, _ .

Power / Catawba, 38605 ('86) TVA/ Watts Bar, 39838 ('86) Illinois'

Power /Clinton, 39620 ('86) Bechtel/Palo Verde, 39156 ('86)UE&C/Seabrook, 40599 ('87) Duke Power /McGuire, 40846 ('87) DukePower / Catawba, and 40933 ('87) Illinois Power /Clinton.

9. Audits..

The NRC inspectors reviewed the internal audits for 1986 and.

part of 1987. The 19 criteria outlined in PSI's QAPM were' covered in the audits. Each audit included an audit plan, -

audit checklist, and audit report. Audit findings weredocumented in Corrective Action Reports (CAR), and deficiencieswere corrected in a timely manner. The audits which werereviewed were performed in accordance with the criteriaoutlined in Section 17 of the PSI QAPM.

Ten external audits were reviewed during the inspection. The| auditing of vendors is perforraed using both Section 17 of the

QAPM and Quality Control Standard (QCS) 015, " Quality AssuranceApproved Vendor List; Vendor Survey, Audit, Evaluation," datedOctober 16, 1984. The records which were reviewed included

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I audit checklists and reports and were complete and demonstratedthat PSI is performing vendor audits in accordance with their

*procedures.

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|' ORGANIZATION: POSI-SEAL INTERNATIONAL!* NORTH STONINGTON, CONNECTICUT

REPORT ' INSPECTIONtin . - QQQOORA6/A7-01 REStil TS: PAGE 10 of 10

10. Plant Tour

TheinspectortouredthePSImanufacturingfacilitykvarioustimes during the inspection in the company of PSI officials.Items witnessed included receipt inspection, component storagearea, weld material storage area, machining, assembly, weldingarea, testing, final inspection, PT area, c1 caning, painting,and packaging.

F. PERSONNEL CONTACTED:

*M. Shannon, North American Counsel*K. Gadaree, Accounting Manager

-*R. t. Walter, Director of Operations*R. J. Stitel, Manager Nuclear Sales*S. J. Baker, Materials Manager*D. S. Quirk, Applications Engineer'

*E. W. Good, Manufacturing Manager*D. Mashi, PIP Manager*B. S. Nichols, Quality Assurance Engineer*F. D. Riccioli, Marketing Manager*F. Canastar, Manager Human Resources

y- *J. Corey, Manager Engineering'

*P. E. Arnold, General Manager*J. Azzinaro, Director, Marketing and Sales*E. W. Whitford, Facilities Engineering Supervisor*R. D. Barry, Manager of QualityJ. Jones, Lead Inspector,

E. Banville, Shipping ClerkN. Place, QC TechnicianJ. Rodgers, Welding Engineer

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* Attended exit meeting.

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