.

.

ENGIN EERS AND M ANUFACTURERS OF-CENTRIFUG AL PUMPS * HYDRAULIC TURBINES * VALVE 5 . NUCLE AR COMPONENTS,

-

M A OlVISf 0N OF GUY F. ATKINSON COMPANY e

m.,n, c. 6.. m ...u...... , _ ............ a- .=a

Xai#s Ogius a,J &ac6:<j - 28oo N. W. FRONT AVENUE = PoRTLANo. OREGON 9721o

*

February 2,1979

U. S. Nuclear Regulatory Commission "

Region IV -

611 Ryan Plaza Drive, Suite 100Arlington, Texas 76011

Attention: Mr. Karl V. Seyfrit, Director

Reference: NRC Letter, Seyfrit to Tharp, dated 19 Dec. 1978

Ge ntleme n:

Enclosed are our responses to the NRC findings for the audit performed byyour office on November 13 - lo,1978.

I share your concern about lack of complete implementation of committedcorrective actions. It is a reflection on BWC which none of us can or willt91e rate. To resolve this mat,ter, our Internal Auditor will be performingspecific corrective action implementation audits on our commitments. Thesewill be documented on our internal audit form, a copy of which I receive.

We trust that these actions, as well at the specific actions contained in theenclosed response, will meet with the approval of your office. If we canbe of any further assistance, please do not hesitate to contact us.

Very truly yours,

BINGHAM - WILLAMETTE COMPANY~

'Wm. E. TharpPresident and General Manager

WET /ba 2228 011

7906160001E nc ts.

,,.... . . ~ , , . . , . . . . . , ~ , . . . . . . . . . . _.......m., ,. _.U.~... R e _ , , ~ 1.T e, ~ , , ~ c. , A ~ n

.

..

.

!

li

FINDING A - CONTROL OF MEASURING AND TEST EQUIPMENT'

DESCRIPTION OF FINDING,

Contrary to a prev;ous corrective action commitment, review and revisionof calibration procedures was not completed by May 31, 1978. Further,

! calibration of a boom welder was performed to the wrong calibration| procedure and to the wrong amperage values.i

CORRECTIVE ACTION

The boom welder in question was recalibrated to the correct proceduralrequirements on November 17, 1978. In addition, procedure D92.20 wasdevelona' 'aring calibration instructions for boom welders and issuedon Decenoer I,1978.

;STEPS TAKEN TO PREVENT RECURRENCE

BWC will perform a fonnalized internal audit to verify that the correctiveaction has been implemented.

'

IDATE CORRECTIVE ACTION & PREVENTATIVE MEASURES WILL BE r.0MPLETE

February 15, 1979 .

2228 012

il '

4

!

l'

I |rl'

1,

I

'

- - .,,

.

IFINDING B - INSTRUCTIONS PROCEDURES AND DRAWINGS;

i,

DESCRIPTION OF FINDINGr

! Contrary to a previous corrective action statement, Operation 15 had noti been signed off on a work order. Additional examples of bypassed work' order operation sign offs were observed.

a

! CORRECTIVE ACTION

Operation 15 was not signed off due to verbal miscommunication. The subjectwork order was subsequently superseded by a new work order in an effort to" clean-up" the confusion.

At the time of the finding all items to be used in the fabrication had nucbeen conpleted, thus Operation 15 <erification and recording of heatnumbers could not be completed and closed out. Verification has been madethat the operation in question has been completed and signed off.

STEPS TAKEN TO PREVENT RECURRENCE

The work order format is currently being revised to highlight sign offrequirements at each operation by providing one specific space at eachoperation for this purpose only.

DATE CORRECTIVE ACTION AND PREVENTATIVE MEASURES WILL BE COMPLETE

April 15,1979

1

2228 013,

I<

i

t

i

I '

,

|<

st

i

..

.__

,. . _ . . _ _ . _

.

FINDING C - INSTRUCTIONS, PROCEDURES AND DRAWINCS

IDENTIFICATION AND CONTROL OF MATERIAL

'

DESCRIPTION OF FINDING

Contrary to a previous corrective action commitment, three assembly workorders were observed which did not include verification of part heat numbersafter fit / tack and/or weld operations.

;

CORRECT VE ACTION

The three work orders have been upgraded to include verification of partFeat numbers after fit / tack and/or weld operations.

STEPS TAKEN T0 PREVENT RECURRENCE

1) Weekly Training Sessionsa) Currently three have been held.b) Four additional training sessions will be held and completed byFebruary 1,1979.

..

2) Department supervisor will review all "ASME CODE WELDING WORK ORDERS"from 1/2/79 to 2/28/79 for proper verification operations. Additionaltraining sessions will be held if required to provide the properdepartmental understanding of the ASME Code and BWC commitments toproduce parts in accordance with the Code.

DATE CORRECTIVE ACTION AND PREVENTATIVE MEASURES WILL BE C0fPLETEFebruary 28, 1979

2228, 014

.

,- _ -

.

FINDING D - CONTROL OF SPECIAL PROCESSES

DESChIPTION OF FINDING

Welding Procedure WPS ASP 3-16 was selected for use on two (2) work orderswhich included a subsequent solution anneal for which ASP 3-16 was notqualified.

.a

CORRECTIVE ACTION

WPS ASP 3-16 is being qualified for the post weld heat treatment of solutionannealing. This will be completed by February 23, 1979.

STEPS TAKEfl TO PREVENT RECURRENCE

A work order review procedure will be initiated which will outline the elementsof Quality Assurance review of the work order. This will include assurancethat use of a weld procedure is not coupled with a PWHT which violates theweld procedure PWHT requirements.

DATE CORRECTIVE ACTION & PREVENTATIVE MEASURES WILL BE C0t@LETE

March 23,1979

2228 015

. .

.~

-

.

FINDING E - INSTRUCTIONS, PROCEDURES AND DRAWINGS

DESCRIPTION OF FINDING

Contrary to the requirements of Procedure H31.27 vendors fc r purchaseordars 1-39668 and 1-52000 did not atpear on the Approved Vendors List.

CORRECTIVE ACTION

The material purchased on P.O. 1-39668 has been tested and qualifiedthrough BWC's internal quality assur ?r_ system.

BWC is revising H31227 to more clearly define the limits of the subcontractedservices which will be controlled through quality assurance survey andapproval.

STEPS TAKEN TO PREVENT RECURRENCE _

Quality Assurance will issue a memo to the Plata Shop stock room foremento indicate ASME III application on weld material requisitions when thatapplication is anticipated.

BWC is revising H31.27 to more clearly def.~ne the limits of the subcontractedservices which will be controlled through quality assurance survey andapproval .

Based upon recent ASME Code interpretations and a telephone survey ofcommon industry practices, calibration services will be controlled throughpurchase order instructions. In the future, calibration labs will not berequired to appear on the Approved Vendors List, since these services arenot specifically controlled by existing quality assurance standards.

DATE C0f9ECTIVE ACTION AND PREVENTATIVE MEASURES WILL BE COMPLETEFebruary 15, 1979

2228 016

.

.

-.

...

.

FINDING F - INSTRUCTIONS, PROCEDURES AND DRAWINGS

DESCRIPTION OF FINDING

Contrary to the requirements of Section 4 of the Q A. Manual, purchaseorders 1-48647 and 1-52000 had not been fonvarded to Quality Assurancefor review and approval .

CORRECTIVE ACTION

Material purchased on P.O. 1-48647 is being tested and qualified withinBWC's Q. A. Program.

BWC is revising H31.27 to more clearly define the limits of the subcontractedservices which will be controlled through quality assurance survey andapproval .

STEPS TAKEN TO PREVENT RECURRENCE

Quality Assurance will issue a memo to the Plate Shop stock room foremen toindicate ASME III application on weld material requisitions when thatapplication is anticipated.

'

BWC is revising H31.27 to more clearly define the limits of the subcontractedservices which will be controlled through quality assurance survey andapproval .

Based upon recent ASME Coce interpretations and a telephone survey of commonindustry practices, calibration services will be controlled through purchaseorder instructions. In the future, calibration labs will not be required toappear en the Approved Vendors List, since these services are not specificallycor. trolled by existing quality assurance standards.

DATE CORRECTIVE ACTION AND PPIVENTATIVE MEASURES WILL BE COMPLETE

2728 017

'

.

*.

.

FINDING G - NONCONFORMING MATERIAL, PARTS AND COMPONENTS

DESCRIPTION OF FINDING

Contrary to Section 15 of the Q.A. Manual, a body ring, platform and hatchcover did not have inspection report stickers attached to them even thoughopen inspection reports existed.

a

CORRECTIVE ACTION

IR's 24432, 32513 and 24435 were closed out cn 10/23/78,12/19/78 and10/25/78, respecti vely. Therefore it is not possible to imp.ement applicationof s ti ckers .

STEPS TAKEN TO PREVENT RECURRENCE

The violation has been discussed with the Chief Inspector and a memostressing the need for attaching an inspection report sth ker to nonconforaingitems was issued to all inspections on January 26, 1979.

DATE CORRECTIVE ACTION AND PREVENTATIVE MEASURES WILL BE COMPLETE

Complete.

2228 018.

.