IR 05000329/1980010
| ML19341C770 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/09/1981 |
| From: | Cook R, Clint Jones, Lee E K, Livermore H, Norelius C, Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19341C764 | List: |
| References | |
| 50-329-80-10-01, 50-329-80-10-1, 50-330-80-11, NUDOCS 8103040159 | |
| Download: ML19341C770 (38) | |
Text
{{#Wiki_filter:. " . . . U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-329/80-10; 50-330/80-11 Docket Nos. 50-329; 50-330 Licenses No. CPPR-81; CPPR-82 Licensee: Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 Facility Name: Midland Nuclear Power Plant, Units 1 and 2 Investigation Conducted: March 6 - July 31, 1980 Investigation At: Midland Site, Midland, MI / # // Investigator: ~ C. H. Weil Date Investigative Specialist [[ m bw I // Inspectors: R. J. Cook M Date Resident Inspector, Midland L ' s Y.
lwe f. c) - g/ C. E.(Iones Date Reactor Inspector &A /G / E. W. K. Lee Date / / / Reactor Inspector 42 k& / f [/ ' H. H. Livermore
U Date Reactor Inspector Other Accompanying Personnel: D. W. Hayes (March 17-19, 1980) G. A. Phillip (March 17-19, 1980) /h8/ Reviewed By: - -
C. E. Norelius Date Assistant to the Director 810 30 4 0M'
. . , , /k C / kh Reviewed By: _ R. C. Kno'p % Date u+ ' Chief, Construction Projects Section No. 1 Investigation Summary: Investigation on March 6 - July 31, 1980 (Report No. 50-329/80-10; 50-330/80-11) Areas Investigated: Special, unannounced investigation concerning allegations pe taining to the Zack Company (the heating, ventilating and air conditioning) (HVAC) subcontractor at the Midland Nuclear Power Plant construction site. Allegations concerned material traceability, falsifi-cation of records, procedures, and training of quality control inspectors.
The investigation consisted of interviews, observations, and the review of records and other documents. This investigation involved 540 investigative hours, both on and offsite, by seven NRC individuals.
Results: Investigation was made into twenty-one allegations (dealing with material traceability, violation of procedures, falsification of records, and the training of quality control inspectors) regarding the Zack Company work at the Midland construction site. Twelve of the twenty-one allegations were substantiated, and resulted in noncompliance with Title 10, Code of Federal Regulations, Part 50 (10 CFR 50), Appendix B, Criteria IV (Procurement Document Control), V (Construction, Procedures, and Drawings).
VII (Control of Purchased Material, Equipment, and Services), VIII (Iden-tification and Control of Materials, Parts, and Components), IX (Control of Special Processes), X (Inspection), XV (Nonconforming Materials, Parts, or Components), XVI (Corrective Action), XVII (Quality Assurance Records), and XVIII (Audits). The remaining nine allegations were not substantiated.
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- . . REASON FOR INVESTIGATION On March 6 and 10, 1980, Individual 'A' provided seventeen allegations per-taining to the Zack Company (the HVAC subcontractor) at the Midland Nuclear Power Plant construction site, to Nuclear Regulatory Commission Region III (RIII) personnel. These allegations dealt with material traceability, violations of procedures, falsification of documents, and the training of quality control inspectors. Subsequently, Individual 'A' provided two additional allegations. Da March 10 and 12, 1980, Individual 'B' provided essentially the same information as Individual 'A', concerning the Zack Company work at the Midland Nuclear Power Plant construction site. On April 14, 1980, Individual 'A' provided one additional allegation per-taining to the Zack Company. On April 18, 1980, Individual 'C' advised RIII personnel of problems encountered with the traceability of materials used by the Zack Company at the Midland site. On April 25, 1980, another alleger, Individual 'D', made one additional allegation.
SUMMARY OF FACTS As the result of allegations received concerning the activities of the Zack Company, HVAC subcontractor, at the Midland site, an investigation was initiated. During the initial phases of the investigation, Region III became aware that Consumers Power Company had issued a Management Corrective Action Request (MCAR), dated January 8, 1980, pertaining to the Zack Company.
The MCAR showed Zack had failed to initiate corrective action on a large number of nonconformance reports and audit findings in a timely manner and had failed to address other requirements and commitments of the quality program. The MCAR, among other things, indicated there were 284 open Zack field nonconformance reports, of which 277 required either rework or the implementation of an adequate procedure to complete hardware installation.
In examining the circumstances surrounding the issuance of the MCAR it was determined that during the period May 23 to October 2, 1979, Consumers Power Company had issued seven nonconformance reports, all of which recommended 100% reinspection of work as a corrective action. On October 9, 1979, a meeting was held between Bechtel Power Corporation and Consumers Power Company "to discuss certain immediate concerns regarding the Zack Company . (HVAC subcontractor) Quality Assurance Program." The meeting notes indicated that Consumers Power Company had r.oted "a lack of responsiveness" by Zack.
Commitments regarding corrective action made by Zack to Consumers through Bechtel, indicated "a report on problems, causes and recommendations to be part of a forthcoming formal action plan" to be prepared by November 12, 1979, were not met prior to the date of the MCAR.
The investigation determined, that as of March 19, 1980, corrective action had not been completed on any of the above-mentioned seven Consumers Power Company nonconformance reports. The preliminary findings of the investigation were discussed with Consumers Power Company site management on March 19, 1980, and with Consumers Power corporate management, by tele-phone, on March 20, 1980. During the latter conversation an understanding was reached that a stop work order would be issued to the Zack Company.
This understanding was confirmed by a letter, dated March 21, 1980, from Region III to Consumers Power Company.
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. ' - . ' During this investigation twelve of twenty-one allegations were substantiated.
Ten items of noncompliance with 10 CFR 50, Appendix B, Criteria, were iden-tified regarding the activities of the Zack Company. Numerous examples of a failure to maintain material control and traceability as well as procedural violations were identified.
In addition, one item of noncompliance, relating to 10 CFR Part 50, Appendix B, Criterion XVI, failure by Consumers Power Company to promptly correct failures, deficiencies, deviations, defective materials and equipment and nonconformance regarding the HVAC work, was identified.
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.- __ _ ' . DETAILS
1.
Personnel Contacted Consumers Power Company
- S. H. Howell, Senior Vice President
- J. Cook, Vice President - Midland
- W. Bird, Midland Quality Assurance Manager
- J. Wood, Quality Assurance Group
- H. W. Slager, Materials Section Head-Design Production J. L. Corley, Chief, Quality Assurance - Midland
- D. R. Keating, Quality Assurance Group Supervisor - Midland M. F. DeWitt, Quality Assurance Group - Midland T. C. Cooke, Project Superintendent - Midland B. H. Peck, Construction Supervisor - Midland J. S. Strahl, Construction Control Supervisor - Midland J. S. Kreple, Engineer: PM0 - Midland Bechtel Power Corporation
- J. A. Rutgers, Project Manager
- J. R. Barbee, Supervisor Codes and Standards
- M. Elgaaly, Pr oject Engineering
- L. A. Dreisbach, PQAE E. Smith, LQAE L. Davis, Site Manager T. C. Valenzano, Project Superintendent of Services J. W. Lillywhite, Field Contract Administrator W. L. Braclay, PFQCE M. A. Dietrich, QAE P. Falkenborg, QAE E. F. Price, S/C Zack Company
- C. L. Eichstaedt, Vice President / Operations Manager J. DeZutel, Vice President
- M. E. D' Haem, Quality Control Manager, Midland R. Akers, Quality Control Inspector L. R. Chapman, Quality Control Inspector D. C. Dartey, Quality Control Inspector J. K. Dittenbir, Quality Control Inspector R. L. Ewald, Quality Control Inspector T. B. Franchuk, Quality Control Inspector R. E. Milne, Quality Control Inspector D. R. Sanders, Quality Control Inspector R. McCarley, Project Manager - Midland L. J. Rytlewski, Superintendent - Midland R. F. LaRoche, General Foreman l
R. G. Brown, Fabrication Shop Foreman
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. ' Individuals Individual 'A' Individual 'B' ' Individual 'C' Individual 'D'
- Denotes presence at Management meeting, May 2, 1980.
2.
Introduction The Midland Nuclear Power Plant, Units 1 and 2, are under construc-tion by Consumers Power Company at Midland, Michigan. Bechtel Power Corporation is the architect-engineering firm, as well as the constructor of the plant. The facility will utilize a Pressurized Water Reactor (PWR) supplied by the Babcock and Wilcox Company.
The Zack Company has been designated to provide and install the heating, ventilating and air conditioning (HVAC) systems for the Midland plant.
These systems serve both safety-related and non-safety-related areas cf the plant.
10 CFR Part 50, Appendix B sets forth eighteen Quality Assurance Criteria applicable to nuclear power plant construction activities.
Consumers Power Company and its contractor organizations, among them Bechtel Power Corporation and Zack Company, have prepared Quality Assurance / Quality Control manuals and procedures setting forth the specific requirements applicable to their activities at the Midland site. These documents also specify that certain activities will meet specific industry codes and standards.
The following documents are applicable to the HVAC activities which ' were examined during this investigation and were used as a basis for determining compliance or noncompliance with NRC requirements: Consumers Power Company QA Program Policy Nos. 4, 5, 7, 8, 9, 10, 15, 16, 17, and 18.
Bechtel Specification for Heating, Ventilating and Air Conditioning Seismic Class I equipment and Ductwork Installation for the Consumers Power Company Midland Plant, Units 1 and 2 - Specification Guide No. 7220-M-151 A(Q).
Zack Company Quality Assurance Manual.
Zack Company Procedures Nos. MB-QCP-1, 3, 6, 7, 8, 20, and 21.
ASME Material Specification Designations A36, A527-1 and A575.
ASML Section IX.
i ' American Welding Society, AWS D1.1.1977.
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' . . (Specific instances of noncompliance are identified in this report by a reference in parenthesis to the appropriate Appendix B criterion.
The applicable procedure or standard is not in all instances identified).
3.
Receipt of Allegations On March 6, 1980, Individual 'A' contacted RIII personnel.
Indivi-dual 'A' stated be was quite concerned with the quality control (QC) program of the Zack Company, the HVAC subcontractor, at the Midland Nuclear Power Station construction site.
Individual 'A' advised he was concerned with the Zack QC sectien's activities in terms of material , traceability, procedural violations, the training of the QC inspectors, and the falsification of records.
Individual 'A' provided a written statement (Exhibit I) in which he set forth his specific concerns.
Subsequently, Individual 'B' provided essentially the same information as Individual 'A' to RIII personnel.
In addition to his written statement, Individual 'A' provided infor-mation concerning the lack of independence of an audit of the Zack, Midland, QC function by the Zack Company, as well as providing three additional allegations, as follows: a.
Parts fabricated at the Midland fabrication shop were made from the verbal description and instructions of the fabrication shop foreman. Blueprints or written instructions were not used to fabricate the duct parts; b.
Duct parts fabricated at the Midland fabrication shop were not traceable. The work was not documented, and when it was docu-mented, travelers had not been annotated with either the correct coil or angle numbers (if the coil or angle number was noted at all). Traveler number F942/940 was marked to show angle iron control number 71, 697, and 662-3 had been used, when the correct number should be 887. Traveler ticket number 944/942 was marked to show angle control numbers 41, 697, and 662-3 had been used, when the correct number should be 887 (on the 2 inch by 2 inch by 1/4 inch angle iron) and 944 (on the 3 1/2 inch by 3 1/2 inch by 1/4 inch angle iron).
Both traveler numbers, F942/940 and F944/942 were marked as quality control inspected on August 24, 1978; c.
Two welders were using the same identification stamp, CU7.
4.
Review of Management Corrective Action Report During the preliminary stages of the investigation, the existence of a Consumers Power Company Management Corrective Action Report (MCAR) daaling with the performance of the Zack Company at the Midland Nuclear Power Plant construction site became known to RIII. MCAR number MD-1 was issued by Consumers Power Company on January 8, 1980. The MCAR-7- ___
. i . . showed the Zack Corporation had failed to initiate corrective action on a large number of Nonconformance Reports (NCRs) and audit findings in a timely manner and to address other requirements and commitments of the Quality Assurance (QA) Program. The MCAR also indicated there were 284, open, Zack field NCRs of which 277 required either rework or the impler.A:tation of adequate procedures to complete hardware instal-lation.
These were in addition to the NCRs generated by Consumers Power.
During the period May 23 - October 2, 1979, Consumers Power Company issued seven NCRs, all of which indicated 100% reinspection of Zack's work as the recommended corrective action. On October 8, 1979, a meeting was held between Bechtel Power Corporation and Consumers Power Company, "to discuss certain immediate concerns regarding the Zack Company (HVAC subcontractor) Quality Assurance Program." According to the meeting notes, Consumers Power Company notcJ "a lack of responsiveness" by Zack Company, and inquired as to the steps being taken to correct the nonconformances and to reverse quality deviation trends.
Bechtel Power advised the Zack Company had been informed that "no future fee payments will be made until these items are answered and Zack's timeliness improves." Bechtel also stated, the Zack QA manager had written that all outstanding findings and QC FM's will be answered by October 12, 1979. Fee payments to Zack were resumed in February 1980. None of the seven Consumers' NCRs referred to above had been closed out as of March 19, 1980.
During the October 8, 1979 meeting, Bechtel Power also indicated the president of the Zack Company had outlined a thirteen point, tentative action plan to improve the Zack QA program.
Consumers Power Company also requested "Bechtel QA to expedite Bechtel Engineering for answers to questions on Zack welding procedures."
On October 9, 1979, the Zack president prepared a memorandum, which was sent to Bechtel the same date, stating an individual was assigned "to implement a system for controlling NCRs at Midland, with priority given to old NCRs."
In a memorandum, dated November 28, 1979, a copy of which was furnished to Consumers Power Corporate QA, the Consumers site QA stated that during discussions with Bechtel Subcontracts on November 19, 1979, it was indicated the Zack Company had been granted an extension to November 22 for submittal of the final report relative to corrective actions. The memorandum also stated, "Zack has been requested to show cause by Decembo 15, 1979 as to why they should be allowed to continue l construction cased on: (a) Their ability to manage the quality program, end (b) their ability to satisfactorily implement the contract."
The notes of a meeting held on December 13, 1979 indicated the indi-vidual, who was assigned by the Zack president to control NCRs, stated he did not have a clear cut procedure for closing NCRs. The notes l l.
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. . also indicated that the, then, Zack site QC manager said he was not prepared at that time to discuss in process inspections, but that these inspections were limited due to lack of manpower. He said he hai one fully qualified inspector on the day shift and one on the night shift.
At about the end of December or the beginning of January, Zack assigned a new QC manager to the Midland site and increased the number of QC inspectors.
By letter dated January 30, 1980, Bechtel Power Company responded to MCAR number MD-1 and provided Zack's response, dated January 16, 1980.
The following information was obtained regarding the current status of some of the specific items in MCAR number MD-1: a.
NCR M-01-4-0-057, dated May 23,1971 The recommended corrective action was 100% reinspection of Zack welds due to first inspection misses on hangers and supports.
Consumers Power advised they had identified unacceptable welds which had been previously accepted by Zack. Several vertical welds and all overhead welds were unacceptable.
It was estimated 30% of the welds inspected were unacceptable.
Bechtel personnel advised there were 39 deficiencies identified, which were related to Consumers' NCRs and that a progress report from Zack, dated March 17, 1980, showed all but five of these had been resolved. However, Zack personnel advised the 100% reinspec-tion of welds made prior to May 23, 1979, the date of the Consumer NCR, would entail thousands of welds and only an estimated 1% had been reinspected.
b.
NCR M-01-4-9-074 dated July 24, 1979 The recommended corrective action was 100% reinspection of all drop-in type anchor bolts. Consumers Power Compan;' advised the use of this type of bolt was discontinued in July 1979, and that corrective action was deferred pending a prercribed fix by Bechtel Engineering. Bechtel Subcontracts stated they did not know when this would be forthcoming. Zack personnel stated they were in the process of locating these bolts by means of a walkdown. They indicated they were two-thirds of the way through the Auxiliary Building and planned to complete the task of identifying those ,
installed by the end of May 1980.
c.
NCRs M-01-4-9-104 dated September 27, 1979 and M-01-4-9-106 dated October 2, 1979 The recommended corrective action called for 100% reinspection of HVAC air handling equipment to verify proper installation requirements.
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. ' . Re: 104; Zack personnel advised about 22 of 120 items had been ' reinspected and they hoped to closeout this item by the end of May 1980. No problems had been found so far during the reinspection.
Re: 106; Zack advised this item was closed out by issuing some , new Zack NCRs which were still open.
d.
NCRs M-01-4-9-083 dated August 14, 1979; M-01-4-9-086 dated August 21, 1979; M-01-4-9-087 dated August 22, 1979 The recommended corrective action was 100% reinspection / rework of all welding performed without required preheat.
Zack personnel advised that not all of the welds involved had been identified. They estimated 90-100 hangers, having two to six welds each, were involved. They said that about one month prior to this investigation a letter had been sent to Bechtel describing the action proposed to correct the problem.
Bechtel personnel stated they did not know when a response would be given to Zack.
None of the above-listed Consumers Power Company NCRs, generated during the period May 23 - October 2, 1979, had been closed out as of March 19, 1980 (Criterion XVI).
The status of the MCAR was discussed with Consumers Power Company site management on March 19, 1980 and by telephone with Corporate management on March 20, 1980. An understanding reached during the latter conver-sations was confirmed by letter dated March 21, 1980, from Region III to Consumers Power Company, a copy of which is attached to this report as Exhibit II. On March 20, 1980, Bechtel Power Corporation issued a stop work order to the Zack Company.
5.
Allegations ' Based on interviews with Individuals 'A' and 'B' on March 6, 10 and 12, 1980, nineteen allegations were received. These allegations, and the information obtained regarding them during the investigation, are > set forth below.
Allegation No. 1 - Travelers (the documents accompanying the Zack products) indicating the materials and procedures are pre-signed as i being accepted by the QC section at the Midland job site. The items are fabricated at the Midland job site, but the pre-signed traveler indicates the materials were fabricated by the Zack Company in Chicago.
The primary way of determining where an item was fabricated was by paint. The items fabricated at the Midland job site are not painted, as the Midland job site does not have the facilities to paint. All items fabricated at the Chicago shop are painted, as the Chicago shop does have the facilities to apply paint.
(The items fabricated by Zack were required to have a traveler showing the materials and pro-cedures applicable to the item. Travelers were pre-signed to show acceptance by the QC section at the Midland site).
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. ' , Items have been fabricated at the 74ek Company shop in Chicago and bave been sent to the Midland jot,tte with the necessary travelers.
Once at the Midland job site, the fabricated items have been scrapped, for one reason or another, and replacements have been fabricated at j the Midland job site. The travelers from the Chicago shop were not annotated to show the item from Chicago had been scrapped. The replacements made at the Midland job site were made using the Chicago travelers, and new travelers were not made for the replacement item fabricated at the Midland job site.
Finding - It was noted a number of travelers had been initialed by QC inspectors on the left hand side of the proper sign-off space on the traveler. The various QC inspectors interviewed stated the initials on the left side of the traveler indicated the QC inspector had verified that the sketch on the traveler was correct, and the initials did not mean the item had been either completed or accepted by the QC inspector.
It was also established that field fabricated and/or repaired items were painted by means of aerosol spray in the field fabrication shop after items had been inspected and accepted by the QC inspectors.
Paint, or the lack of it, did not provide a basis for determining whether an item was fabricated in Chicago or at the Midland site.
Allegation No. 2 - Travelers were being " signed off" as Quality Assurance received at the Midland job site, yet the items described by the travelers were not completed. Examples of this practice were: (1) Traveler number V03-42B-F10171, flanges and vanes were not installed.
(2) Traveler number V03-SH2-F9437, vanes nct installed and one end of the duct was still raw material and not finished.
(3) Traveler number V26-SH2B-46.1-P1515, welds were loose, not gas tight as required.
(4) Traveler number V04-SH2-277A-F10676, vanes were neither welded nor screwed-in as required.
(5) Traveler V10-42B-10171, vanes were neither welded nor screwed-in as required.
(6) Traveler number V10-42B.1-F10172, flanges were not installed.
(7) Traveler number V26SH2B-47.1-1516, joints were loose and not gas tight.
(8) Traveler number V3SH2-2C-F10397 was in the process of being installed at the 599' elevation in the auxiliary building, when it was discovered to have defective vanes (undersized), defective welds on flange to duct joint, and improper weld spacing on the vane rail. However, the piece was noted to have been inspected completely.
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. ~ . (9) Traveler number V2-SH1-1-2A-F8403 was signed as being received i from Chicago, yet was found being fabricated on site using the same traveler.
Finding - The following information was obtained concerning the above-listed travelers.
(1) Traveler number V03-42B-F10171. Zack personnel stated a traveler i ~ did not exist with this number.
(2) Traveler number V03-SH2-2-F9437. Zack personnel advised the original item was fabricated to meet the Seismic Class 2 requirements instead of Class 1.
The item was subsequently scrapped.
A replacement piece, partially completed, was found in the field - fabrication shop.
It was established that: (a) A Nonconformance Report (NCR) had not been prepared when the original item was found to be nonconforming (Criterion XV).
' i I (b) A new traveler was not initiated for the replacement piece (Criterion V).
! (c) Turning vanes used in the replacemeat piece were not traceable ' ! (Criterion VIII).
(3) Traveler number V26-SH2B-46.1-P1515.
Zack personnel stated the loose flange was to facilitate field installation and the piece ! was to be field tested for gas tightness after installation in accordance with Bechtel Specification 7220-M-151A(Q), Revision 7.
However, it was established that: (a) The welder identification was not recorded on the traveler (Criterion V).
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(b) The coil control number was recorded on the traveler as 383, but the control number was not visible on the item (Criterion VIII).
(c) Two control numbers, 929 and 727-2, were marked on the angle iron used on the item, but control number 727-2 was not l l recorded on the traveler (Criterion VIII).
! (d) The traveler indicated Welding Procedure Number QCP-22 was to be used. This procedure is a shielded metal are welding process. However, the weld appeared to have been welded l with a gas metal arc welding process (Criterion IX).
(e) The traveler number was not placed on all of the sub-components (Criterion VIII).
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. s (4) Traveler number V04-SH2-277A-F10676. This item was determined to be a non-safety-related item.
(5) Traveler number V10-42B-10171. Vanes were welded in the duct.
However, it was established that: (a) Turning vanes used in the duct were not traceable (Criterion VIII).
(b) The welder identification was not recorded on traveler (Criterion V).
(c) The traveler indicated Welding Procedure Number QCP-22 was to be used. This procedure is a shielded metal arc welding process, but the weld appeared to have been welded with a gas metal arc welding process (Criterion IX).
(6) Traveler number V10-42B.1-F10172. Flanges were installed.
However, it was established that: (a) Turning vanes used in the duct were not traceable (Criterion VIII).
(b) The welder identification was not recorded on the traveler (Criterion V).
(c) The traveler indicated Welding Procedure Number QCP-22 was to be used. This procedure is a shielded metal arc welding process, but the weld appeared to have been welded with a gas metal are welding process (Criterion IX).
(7) Traveler number V26-SH2B-47.1-P1516.
Zack personnel advised that the loose flange was to facilitate field installation. Also, the piece would be field tested for gas tightness after installation in accordance with Specification 7220-M-151A(Q), Revision 7.
' However, it was established that: (a) The welder identification was not recorded on the traveler (Criterion V).
(b) The coil control number was recorded on the traveler as 383, but the control number was not visible on the item. Also the traveler number was not shown on all sub-components (Criterion VIII).
(c) The traveler indicated Welding Procedure Number QCP-22 was to be used. This procedure is a shielded metal are welding process, but the weld appeared to have been welded with a gas metal arc welding process (Criterion IX).
(d) Certain flange-to-duct welds had undercut exceeding the 1/32" allowed by the Bechtel specification (Criterion X).
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. (8) Traveler number V3-SH2-2C-F10397. This item was scrapped. A new
item was being fabricated in the field fabrication shop under a new traveler number V3-SH2-2D-F12685.
It was established that: (a) The traveler indicated Welding Procedure Number QCP-22 or QCP-34 was to be used. The procedures are shielded metal , arc welding process, but the welds appeared to have been
welded with a gas metal arc welding process (Criterion IX).
l (b) Turning vanes used in the duct were not traceable (Criterion VIII).
< (9) Traveler number V2-SH1-1-2A-F8403. This item was found in the field fabrication shop. The foreman stated work had not been performed on this item at the field fabrication site. The traveler indicated Velding Procedure Number QCP-1-P5C5 was to be used. This procedure was qualified for welding on material thickness between 0.0672" and 0.269" and base material conformed . to SA414, Grade A.
The traveler indicated the sheet metal in this duct was 18 gauge (0.0475") and was galvanized carbon steel ' which is ASTM A527 (Criterion IX).
While conducting inquires into the above allegations, RIII personnel ' observed that turning vane stock in lengths of ten feet was stored in a rack in the field fabrication shop. A large amount of the turning vane stock was observed not marked with either material control numbers or color codes, and therefore was not traceable to the applicable material certification. This stock had been used in the fabrication of various items (Criterion VIII).
Allegation No. 3 - Traveler Numbers V22SH1-1-P31(3/864)-F11030 and V26-SH1B-11-F10807. Original fabrication of the hangers required documentation of the materials used. Repairs were made to the hangers and the repair materials and procedures used were not documented.
i Finding - Traveler Number V22SH1-1-P31(3/864)-F-11030. This traveler
was replaced by Traveler Number V26-SH1B-12-F10802. It did not appear that repairs were made to hanger number V26-SH1B-11-F10807. However, ' , l it was established that:
, (a) The angle iron control number was not recorded on the traveler > (Criterion VIII).
(b) The welder identification symbols were not recorded on either traveler (Criterion V).
(c) Angle iron marked V26-SH1B-11-F10807 was installed in hanger number V26-SH1B-12-F10802, and vice versa (Criterion VIII).
(d) Traveler Number V26-SHIB-11-F10807 showed the angle iron was welded to a 4" x 5.4" x 45" channel. The angle iron, as installed, was welded to a 7" deep, and 2-1/4" wide channel (Criterion V).
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r - . . (e) All of the angle irons were not marked with control and/or traveler numbers (Criterion VIII).
Allegation No. 4 - Traveler Number V27-SH3A-29-F4410 was marked Quality Assurance inspected and was considered to have been completed. An unscheduled reinspection of the piece disclosed excessive porosity, missing welds, and heavy gouges in the side of the duct.
Finding - Traveler Number V27-SH-3A-29-F4410 was marked QA inspected on June 5, 1979. On June 22, 1979, a Hold Report, Number 53, was pre-pared for "not painted per requirements of 7220-M151-A, Section 15.0."
On August 8, 1979, Nonconformance Report, Number 491, was prepared, citing the above reason. On October 10, 1979, Nonconformance Report, Number 677, was prepared, citing " Flex connection is damaged. Welds have excessive porosity, also one longitudinal wc1d has ("." Zack personnel advised this item had been returned to Chicago for repair.
Allegation No. 5 - Repairs are being made at the Midland job site and travelers are not prepared to record the repairs made.
Items prepared elsewhere (Zack, Chicago) are repaired at the Midland job site using procedures and materials different from the materials and procedures used during the original fabrication.
Finding - It was notea the following four ducts were the only d-ats presently being repaired at the Midland field fabrication shop. The repairs were to the spacing of the flange-to-duct weld: Duct Drawing Traveler Nonconformance Number Number Number Report Number
V34 SH1 F9395 B114 .
V34 SH1 F9396 B113
V34 SH1 F1306 BillA
V34 SHI F1306 B111B It was established that: (a) Although the traveler for the specific item was not annotated to document the repairs; Nonconformance Reports were initiated in accordance with Zack Procedure Number QCP-9, revision 1, to , ' indicate the repairs. The procedures and materials used during the repair of the four available duct pieces were identical to those used during the original fabrication.
(b) The identity of the welder performing the weld repair was not documented (Criterion V).
(c) Welding Procedure Number QCP-1 (P5CS) was used to fabricate ducts No. V34-SH1-1-F9395, No. V34-SH1-5-F9396, No. V34-SH1-2-P1306, No. V34-SH1-3-P1-306, and No. V34-SH1-4-P1306. The sheet metal of the ducts is ASTM A527 with a thickness of 18 gauge (0.0475"). The Zack Company Welding Procedure Number MB-QCP-1 (P-5CS), - 15 - _ _
. . . , Revision 2, requires that "(2) welding of material in the thickness range of 1/16 (0.06?5) inch to 3/16 (0.1875) inch."
The procedure was actually qualified to weld in the thickness range of 0.0672 inch to 0.269 inch (Criterion IX).
(d) The travelers for ducts No. V34-SH1-F9395, No. V34-SH1-5-F9396, No. V34-SH1-4-F1306 and No. V34-SH1-3-1306 s+.ated the welding procedure to be used was Number QCP-1-P5CS. This procedure requires the use of carbon dioxide as the shielded gas.
Indivi-duals stated that carbon dioxide was not available at the Midland site, and therefore this procedure was not followed in performing these welds (Criterion IX).
Allegation No. 6 - The Midland job site does not have established Quality Assurance " Hold Points" such as no follow-up on shipped loose flanges, etc.
Finding - Neither the applicable code nor the Quality Assurance Program required the establishment of mandatory QA " Hold Points." A " Hold Area" was in existence in the laydown area.
Allegation No. 7 - The Zack Company at the Midland job site does not use any welding pre-heat techniques. Welding pre-heating has never been documented at the Midland job site. The Zack Company does not have either gas or electric heaters at the Midland job site to be used for welding pre-heating.
Finding - The problem of pre-heating was identified by Consumers in August 1979 and was documented by Consumers Power Company in three nonconformance reports, as well as in a Management Corrective Action Request, MO-1, dated January 8, 1980. It was determined that welding which required pre-heat was being monitored by QC inspectors on a random surveillance basis and these surveillance activities were documented. This was confirmed through a review of two Zach special inspection reports, dated March 10 and 14, 1980.
Allegation No. 8 - Steel coils, Numbers 341 and 381, were recently received at the Midland job site without the written material certi-fication accompanying them.
Finding - It was established that: (a) Material certification for steel coils Numbers 341 and 381 was available at the Midland job site. Steel coil Number 341 was purchased under P"rchase Order Number C642. Steel coil Number 381 was purchased under Purchase Order Number C743.
(b) The Zack quality assurance group had not reviewed Purchase Order Number C743. Such review was required by the Zack QA Manual, Amendment 1 to Section 5, Rev. O, Paragraph 3.
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. . ' . - . . ASTM Material Specification Designation A527-71, Paragraph 3.2 sets forth specific information required in orders for material made to this specification. Purchase Order Number C743 did not include information on the " coating type and designation," or, " chemical treatment," as required by material specification ASTM A527. Purchase Order Number C542 did not include infor-mation on whether the material should be " oiled or not oiled" or the applicable year of the specification, as required by ASTM A527 (Criterion IV).
Allegation No. 9 - Air monitors purchased by the Zack Company for installation at the Midland Nuclear Power Station were made without specifying or approving the welding procedure to be used. The air monitors, made without an approved welding procedure, have been released for installation at the Midland Nuclear Power Station.
Finding - It was established that nineteen air monitors manufactured by Air Monitor Corporation were received on site. Four have been installed in nca-safety-related systems, and installation in the field did not require welding. However, Air Monitor Corporation started manufacturing the units without prior acceptance of a welding procedure, by the buyer, as required in Bechtel Specification Number 7220-M-151A(Q), Revision 7 (Criterion IX).
Allegation No.10 - Parts fabricated in t ae weld shop (fab shop) are not made from blueprints. Welders get oral instructions from the foreman on how to fabricate the part.
Finding - It was established the traveler contains sufficient information-to allow workman to fabricate parts; furthermore, the size and length of welds are included in plate details located in the fab shop and are available for reference, if needed.
Allegation No. 11 - Duct parts in the fabrication shop have no trace-ability, work is usually not documented, and when it is documented, the travelers have neither the coil nor angle number.
Finding - Numerous cases of material traceability and control problems are identified in various paragraphs of this report.
Allegation 12 - Duct hangers are being installed without the travelers for the parts being annotated to reflect the correct angle iron control numbers (i.e., Traveler Numbers F942, F940 and F944 were annotated with one set of numbers, yet the duct hangers were marked with a second set of numbers).
Finding - Traveler Number F960 for Hanger No. V19-9(3/C898) F949.
! Angle iron control numbers 697 and 662-3 were recorded on the traveler; however, the identification number was not marked on the angle iron (Criterion VIII).
f.
$ , - 17 - - -. _ - - _ -
r . Traveler Number F942 for Hanger No. V19-11(6/C898) F942. Angle iron control numbers 711, 697, and 662-3 were recorded on the traveler; however, only control number 887 was marked on two pieces of the angle iron and an identification number was not marked on the other angle iron (Criterion VIII).
Traveler number F944 for Hanger No. V19-13(7/C898) F944. Angle iron control numbers 711, 697 and o62-3 were recorded on the traveler; however, only control number 877 was marked on one piece of the angle iron and an identification number was not marked on the other angle iron (Criterion VIII).
Allegation No. 13 - The Zack Company does not have any established, written procedures to document the repair work done at the Midland job site.
Finding - Section 16 of the Zack Company Quality Assurance Manual states, "This section contains the methods used for identification, control and resolution of nonconforming conditions found in equipment (Zack or Owren (sic) furnished) materials, fabrications, storage and/ or installation.... responsibility shall also include taking those steps necessary to prevent recurrence."
A selected review of Nonconformance Reports and Hold Reports disclosed each report documented the basis for the hold or nonconformance and details of the resolution, some of which involved repairs.
Allegation No. 14 - Quality Control Inspectors do not receive indepth training in Quality Control / Quality Assurance procedures prior to being placed into their positions as Quality Control inspectors.
Finding - Ibe Zack Company was committed to comply with the requirements of the American National Standard (ANSI N45.2.6-1973) Qualifications, inspection, Examination, and Testing Personnel for the Construction Phase of Nuclear Power Plants in certifications of their Quality Assurance / Quality Control personnel. The personnel files of each QC inspector including their resume, the required reading list, the training records, test scores and examination reports, medical qualifications (natural or corrected near-distance acquity, color vision) and certificate of qualification were reviewed. The Zack QC inspectors at the Midland site met, or exceeded, the minimum require-ments of ANSI N45.2.6-1973. The Zack QC Manager at Midland exceeded the minimum qualification requirements of the standard to fill his position at a Level III QC inspector.
Three Zack Company QC Inspectors, employed at the Midland site, were requested to demonstrate how they performed their assigned duties.
The QC Inspectors were asked to demonstrate their techniques for nspecting installed equipment and to demonstrate how they determined the materials met specifications and material quality control used in j the manufacture and installation of HVAC systems.
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r i . . One QC Inspector demonstrated proficiency in examining equipment, locating and understanding material specification requirements and the correlation of one detailed drawing to enother. A second QC Inspector demonstrated similar proficiency, Our showed less ability in correlating information by cross referencing control drawings. The third QC Inspector demonstrated acceptable proficiency in the field and demonstrated less proficiency than the other inspectors in correlating cross referenced print information and material control verification.
The three areas examined in the field were the 599 elevation of the auxiliary building, the 568 elevation of the auxiliary building and the service water building.
Allegation No. 15 - Welding rods have been received for use at the Midland job site without the necessary certification papers, and those rods have been used in fabrications and installation without the weld rod certification documents.
Finding - An inventory was made of the Zack Company, Midland, weld rod on March 13, 1980. The inventory disclosed the following welding rods were either being issued or were in storage awaiting issue: Electrode Electrode Manufacturer's Zack P.O.
Manufacturer's Manufacturer Class Diameter Control Number Number Cert. Date Hobart 6011 1/8" 90317A C-4007 Undated Hobart 7018 1/8" 90384Z076 C-12305 1/3/79 Hobart 7018 1/8" 90013A179 C-12313 1/24/79 Lincoln 7018 1/32" 37G C-580/14203 2/10/77 The welding rod issue room was locked and access to it was controlled by the QC inspectors. The welding rods in storage were at the fabri-cation shop in a locked cabinet, and access to it was controlled by the QC inspectors.
During a review of the manufacturer's Typical Certificate of Conformance to Specification for Filler Material, the following observations were made concerning the promptness of certificate review by Zack QA/QC personnel.
Zack Purchase Order C-13241, May 14, 1979, for 1/8" and 1/32", E-6011 electrode.
Clronology: May 16, 1979 Date of the Hobart Certificate of Conformance for 1/8" E6011 weld rod, serial number 90198Z.
May 17, 1979 Zack, Chicago, ships to Zack, Midland, on load #38: a.
100#, 3/32", 6011 weld rod, Ticket Number F-4125.
b.
600#, 1/8", 6011 weld rod, Ticket Number F-4126.
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r
. . May 18, 1979 Load number 38, above, is received at Zack, Midland.
May 29, 1979 Zack, Chicago, performs QA review of the Hobart Certificate of Conf ormance for 1/8", E6011, serial number 90198Z.
' June 6, 1979 Zack, Chicago, ships to Zack, Midland, 600#, 3/32", E-6011 (Ticket number F-6044) on Load #42.
October 17, 1979 Zack, Chicago, performs QA review of the Hobart Certificate of Conformance for 3/32", E-6011, serial number 90155A. Hobart Certificate of Conformance is neither dated nor signed by Hobart.
March 11, 1980 Zack, Midland, QC Inspectors tag five boxes (each box weighing approximately 50 pounds) for HOLD, due to lack of documentation (Certs. not available) for 3/32", E-6011, 90155A.
March 17, 1980 Zack, Midland, receives copy of the Hobart Certificate of Conformance for 3/32", E-6011, serial number 90155A, from Zack, Chicago.
Review of the Zack, Midland, Noncompliance listings disclosed five boxes (250 pounds) of Hobart E-6011 3/32" diameter weld rod received during the period May 17, 1979 - June 6, 1979, were not placed on Hold for " lack of documentation (Mat'l Certs)" until March 11, 1980. This review indicated the weld rod had been issued and utilized prior to receipt of weld rod material certification and this condition was not identified on a timely basis. The remainder of this weld rod, 450 pounds in 9 boxes, was not placed on hold and its use could not be determined (Criterion XVI).
In addition to the above, three other instances were noted in which the lack of weld rod material certifications were not promptly identified. These instances were: Zack Purchase Order C-4007, September 28, 1979, for 1000#, 1/8" and 3/32" diameter electrode.
Chronology: October 26, 1979 Zack, Chicago, performs QA review of Hobart Certi-ficate of Conformance for E-6011 electrode, 1/8", serial number 90317A. The Hobart Certificate of < Conformance was neither signed nor dated.
October 29, 1979 Zack, Chicago, ships to Zack, Midland, 100#, 3/32" 6011, weld rod (Ticket number F-11419) on Load #67.
October 31, 1979 Above load is received at Zack, Midland.
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' . . . , November 7, 1979 Zack, Chicago, ships to Zack, Midland, 500#, 3/32", ' 6011, weld rod (Ticket number F-11575) on Load 71.
November 8, 1979 Hobart Certificate of Conformance late for 3/32", E-6011, serial number 90397A, weld rod.
November 16, 1979 Zack, Midland, performs receipt inspection of the 500# of weld rod shipped on November 7, 1979.
November 19, 1979 Zack, Chicago, performs QA review of Hobart Certi-ficate of Conformance for E-6011 electrode, 3/32", serial number 90397A, dated November 8, 1979.
March 11, 1980 Zack, Midland, QC Inspectors HOLD tag for " Lack of Documentation:" I box, Hobart, E-6011, 3/32" serial number 90397A.
March 17, 1980 Zack, Midland, receives copy of the Hobart Certi-ficate of Conformance for E-6011 electrode, 3/32" diameter, serial number 90397A, from Zack, Chicago.
A review of the tack, Midland, Nonconformance Reports composite listings disclossd only one box (50 pounds) of 1500 pounds of 3/32" diameter, Hobart E-6011, control number 90397A weld rod were placed on " hold" during the period October 31, 1979 - March 11, 1980, for " Lack of Documentation (Mat'l Certs)."
Zack Purchase Order C-4044, December 18, 1979, for.035 and.045 welding wire.
Chronology: December 19, 1979 Zack, Chicago, ships to Zack, Midland, 288# in 8" spools, A675,.035 wire (heat #411J6431), ticket number F-11656, Loai #79.
December 26, 1979 Load #79 is received at the Midland job site.
December 27, 1979 Date of the AIRCO Quality Conformance Report for A675.035" diametrr wire, heat #411J6431, lot
- 91017AIB.
January 3,1980 Zack, Chicago, performs QA review of AIRCO Quality Conformance Report for.035 wire, heat #411J6431, lot #91017A1B.
January 11, 1980 Zack, Chicago, ships to Zack, Midland, 12 spools, A675,.045" diameter, AIRCO wire, ticket number F-11448, load #82.
January 22, 1980 Load #82 is received at the Midland job site.
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. i \\ . - j i l February 14, 1980 Date of the AIRCO Quality Conformance Report for .045" wire, heat #411J6431, type A675.
' February 25, 1980 Zack, Chicago, performs QA review of AIRCG Quality Conformance Report for.045" wire, beat #411J6431.
March 11, 1980 Zack, Midland, QC inspectors place Hold tags on: 18 spools (12 pounds each, 216 pounds), AIRCO, a.
.035" diameter welding wire, heat #411J6431, Control #91017A1B.
b.
Six spools (12 pounds each, 72 pounds), AIRCO, .045" diameter welding wire, heat #411J6431.
March 17, 1980 Zack, Midland, receives copies of the AIRCO Quality Conformance Reports for the.035" and.045" diameter welding wire, from Zack, Chicago.
A review of the Zack, Midland, Nonconformance Reports / Hold composite listings disclosed 18 spools (216 pounds) of the 24 spools (288 pounds) of the.035" diameter wire and 6 spools (72 pounds) of the 12 spools (72 pounds) of the.045" diameter wire were placed on hold during the period December 26, 1979 - March 11, 1980.
The March 13, 1980, inventory of the Zack, Midland, weld rod storage facility (fabrication shop) disclosed the following items had been marked " Hold - Lack of Documentation (Mat'l Certs)."
Electrode Electrode Manufacturer's Heat Number of Manufacturer Class Diameter Control Number Number Containers Atom Arc 7018 1/8" 02-1-G902T CG 421H5281 9 cans Hobard 6011 3/32" 90164Z I box - AIRCO - .045" 70616AIC 421A6821 5, 12 lbs. spools Hobart - .035" 1709393 L83330 30 lbs.
The hold tags for the above were dated March 11, 1980. Review of Zack, Midland, material certificates and receiving records, and inquiries of Zack, Midland, QC inspectors, during the period March 13-27, 1980, did not disclose any documents during the investigation (Material Certifi-cates Travelers) identifiable with the above listed welding electrode.
The Zack Company weld rod issue room was examined on March 13-14, 1980.
During this examination, it was noted the stickers on the door of the warming oven used to identify the material contained in the oven had identifying numbers of 37G for weld electrode stored in the lower por-tion and what appeared to be the numbers "376" for the material in the upper portion. A Zack employee stated the 376 number was really 37G.
The lower portion of the oven contained E-7018-3/32" weld electrode, and the upper portion contained E-7018-1/8" weld electrode. Material certifications for E-7018-3/32" weld rod with control number 37G were located.
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F
. Material certification could not be located for E-7018-1/8" weld elec-trode with a 37G number. Based on the Weld Rod Issue Sheet, it was determined that approximately 60 pieces of E-7018-1/8" weld electrode from control number 37G were consumed in one day. The source of the E-7018, 1/8" diameter, weld electrode issued from the rod issue room could not be determined (Criterion VII).
Allegation No. 16 - The Zack Company uses American Welding Society number 7018 electrode welding rods. The storage of the number 7018 rods is to be in metal containers where the moisture is controlled.
The Zack Company stores 7018 rods in cardboard boxes, and the moisture content is not controlled.
Finding - The March 13, 1980, inventory of the weld rod storage area in the Midland Job Site Fabrication shop disclosed the following AIRCO, 7018, Low Hydrogen weld rod had been marked on March 11, 1980 by Zack, Midlan1, QC inspectors for being, " Improperly Boxed - Should Be in Metal Containers:" Rod Manufacturer's Number of Diameter Control Number Cardboard Boxes 3/32" 911-29C4C
3/32" 911-29C4B
1/8" 9920C4C
1/8" 9920C40
1/8" 910-2C-SA
1/8" Unknown
3/32" Unknown
34 Cardboard Boxes During the course of ;he review of the Manufacturer's Typical Certifi-cate of Conformance to Specification for Filler Material, the following observations were made concerning the promptness of segregation of nonconforming materials: Zack Purchase Order C-14212, 7018, 3/32" diameter, lot #91129C-4B.
Chronology: December 10, 1979 Zack, Chicago loads, "1000# 3/32" E-7018 electrodes, traveler number F-11570.
December 15, 1979 Above described shipment arrives at the Midland site.
March 11, 1979 Zack QC, Midland, tag 5 cardboard boxes (250 pounds) to be returned to Chicago as the rods had not been in metal containers.
March 27, 1980 Zack, Midland, QC Manager, advised the 5 cardboard boxes of weld rod had been returned to Zack, Chicago, on March 11, and the boxes had been returned to the manufacturer.
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Review of the Zack, Midland, Nonconformance Reports disclosed five cardboard boxes (250 pounds) of the 1000 pounds (200 boxes) of the 7018 AIRCO weld rod were not marked until March 11, 1980 as noncon-forming for " Improperly Boxed - Should be in Metal Containters;" although the weld rod was received at Zack, Midland, on December 15, 1979 (Criterion XVI).
On March 27, 1980, the Zack, Midland, QC Manager advised the 34 card-board boxes containing AIRCO 7018 welding electrode had been returned to Zack, Chicago, on March 11, 1980, and the 34 cardboard boxes of 7018 weld rod were subsequently returned to the manufacturer.
Allegation No. 17 - Fire dampers at the Midland Nuclear Power Plant were installed by the Zack Company without using an approved welding procedure and without documenting the welding. The installation of the fire dampers and the subsequent repair of the fire dampers were not documented by the Zack Company.
Findings - Travelers and Quality Control Survey Reports for equipment installation and/or ductwork installation for V22C duct 10, 10A, V22C duct 40, V22B duct 40 and V22Sh 1-1 ducts 15, 29 and 62 were reviewed.
During these reviews, the Zack Co. could not demonstrate which proce-dure had been prescribed, if any, for the welding of the fire dampers associated with the above referenced ductwork. The weld procedure was not referenced on the travelers for the above listea pieces, which were located in the Auxiliary Building at the 614' elevation and were associated with the Battery Rooms.
During the review of welding of fire dampers, the validity and approval status of applicable procedures which may have been used was examined.
One procedure, MB-QCP-33, SMAW Welding of Structural Steel to Sheet Steel and Sheet Steel to Sheet Steil for Galvanized Materials with E-6011 Electrodes, pertained to the welding of the fire dampers. This particular procedure had three revisions. Revision "0" was approved by Bechtel Power Corp. for use on September 6,1979. Revision "1" was disapproved by Bechtel Power Corp. on November 12, 1979 with " work may not proceed" instructions. Revision "2" was approved by Bechtel for use on January 15, 1980. Discussion with Zack Co. personnel revealed that safety related fire dampers may have been installed during the period of November 12, 1979 to January 15, 1980, when QCP-33 was not an approved procedure. However, within the scope of the reviews performed and with the lack of adequate document,ation, this could be neither substantiated or refuted.
As a result of a 10 CFR Part 21 notification by the Ruskin Manufacturing i Company pertaining to NIBD73 fire dampers, Zack Company personnel were attempting to identify those fire dampers which might be affected. The Ruskin Manufacturing Company had supplied a listing of the dampers which may be affected, and which were shipped to the Midland site. These dampers were identified on the listing by serial number and size.
Approximately forty of these dampers had been installed. Zack Company QC personnel appeared to have difficulty in locating and identifying affected safety-related Ruskin dampers. A comparison of the noncon- - 24 - . -. __ __ _
f i
i formance tags issued on Ruskin dampers with the listing supplied by Ruskin identified numerous discrepancies and ambiguities. Further, ' Zack Company personnel could not produce equipment installation records indicating the final inspection of installed, serialized, safety-related Ruskin fire dampers (Criterion XVII).
Allegation No. 18 - A recent audit of the Zack, Midland, QC function was conducted by an individual having prior management responsibilities at Zack, Midland, and the audit had not been conducted by an impartial individual.
Findings - The previous Zack, Midland, Project Manager (Mr. F. D. Thompson) became the Zack Company QA Manager in December, 1979. On March 6 and 7, 1980, Thompson participated in the annual audit of the Zack, Midland, QC function. A review of the " Quality Assurance Job Site Audit Report" for March 6 and 7, 1980, disclosed that Thompson, the present QA Manager, and Mr. Harry Geyer, Project QA Manager, comprised the audit team. Geyer appeared to have QC responsibility in many of the areas examined during the investigation.
Thompson was responsible for auditing areas in which he had immediate prior responsibilities (Criterion XVIII).
Allegation No. 19 - Two welders were using the same identification stamp, CU7.
Findings - A review of welder qualification and welder identification number records showed that two, qualified, welders had been issued an identical welder identification number, CU7.
Both welders had identi-fied their welds using this symbol.
Zack Company personnel stated the second welder re:eiving CU7, as on identifying symbol, welded primarily in the Upper Spreading Room, and these CU7 weld symbols were changed to CU7B using, yellow, Nissen Marker. Welds on hangers number 35 and 36 detailed drawing number V26SH1 carried dual welder identification number of CU7 and CU7B (Criterion IX).
6.
Additional Allegations On April 14, 1980, Individual 'A' contacted Region III, and made an additional allegation. This allegation concerned activities by the Zack Company following the issuance of the stop work order on March 20, 1980.
On April 18, 1980, Region III was advised of problems which were encountered following the stop work order, primarily concerning the traceability of materials. These matters and the information obtained concerning them are set forth below.
Allegation No. 20 - Where traveler sketches did not match the description of the installed hangers; new travelers were being drawn to show the installed hanger. The old travelers are being destroyed.
l Information regarding material certification that was not on the old ' traveler was being placed on the new traveler.
l l l I - 25 - l
.. . -. ' .
. , . Finding - The six Zack QC inspectors at the Midland site were inter-viewed and provided the following information.
Three of the six inspectors were engaged in the reinspection of the installed HVAC hangers required by MCAR, ND-1, January 8,1980 (Para-j graph 4 of this report). During the reinspection they had encountered problems dealing with the agreement of the traveler sketch to the installed piece.
In some instances the installed piece did not resemble
the traveler sketch. In other instances the welding procedure called for on a traveler did not agree with the welding procedure used during fabrication. Also, the certificates of conformance for materials used during fabrication and installation were not recorded on the travelers.
In the instances where the traveler sketch and the actual installed . piece did not agree, or where the welding procedure prescribed on the ' traveler did not agree with the procedure used during fabricatior or installation; the QC inspectors were researching the Bechtel ci'il drawings (the 'C' drawings). In researching the 'C' drawings, they found field changes had been made and the hangers had been installed in accordance with the 'C' drawings and the field changes, but the traveler had not been updated. The installed hangers were marked with a nonconformance tag and a nonconformt.nce report was written.
The recommended method of corrective actirn on the nonconformance reports was to change the traveler drawing. In instances where there was only a minor change to be made to the traveler (i.e., where a longitudinal brace had been added to the hanger and the brace had not been shown on the traveler sketch) the recommended method of corrective action on the nonconformance report was to draw the added brace on the traveler sketch.
In other instances where a major change had to be made (i.e., where the installed hanger did not agree at all .h a traveler sketch, as in the case of a double duct run being suostituted for a single duct run) the recommended corrective action was to draw a new traveler.
None of the three quality control inspectors conducting the reinspection of the HVAC hangers was aware of any of the old travelers being destroyed
after the traveler u24 been superseded by new travelers.
. Where the welding procedure on the installed hanger did not agree with the welding procedure prescribed by the traveler, the quality control inspectors again referred to the 'C' drawings.
In referring to the 'C' drawings they found the velding procedure called for on the traveler ' (e.g., IAP5CS) was in error, as the 'C' drawing would prescribe an entirely different welding procedure (e.g., QCP-22). In the instances where the welding procedure described an the traveler and the procedure described on the 'C' drawing were in conflict, the quality control , inspectors found that the welding procedure actually used during fabri-cation and installation agreed with the welding procedure prescribed by the 'C' drawing.
In these instances the inspectors were placing nonconformance tags on the installed hangers and issuing nonconformance The recommended corrective action on the nonconformance reports.
report was to change the welding procedure on the traveler to reflect the correct welding procedure used.
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' . . . Where the identified problems could not be rectified by referring to the 'C' drawing, the quality control inspectors were issuing noaconformance tags and preparing nonconformance reports in order to identify the problems.
None of the nonconformance reports for these problems had been closed out at the time of the investigation.
Each of the quality control inspectors was reviewing the traveler for material certification numbers. In the instances where the material certification numbers were not on the traveler, but were marked on the installed piece, the quality control inspectors would issue a hold tag.
The inspectors would then research the material certifications and attempt to determine if quality material had been used during fabrication and installation.
In the instances where the material certification was available to the quality control inspectors, they would record it on the traveler and then close out the hold tog by using that information.
In the other Instances where the mater:e1 certifications were not available for their review the quality control inspectors would issue a nonconformante tag for the piece in question and prepare a nonconformance report. Af ter issuing the nonconformance report, the quality control inspectors would att:mpt to iden*.ify the material through the Zack quality assurance section in Chicago. Where the quality assurance section could determine the material used during fabrication and installation, the quality control inspectors at Midland would then recommend in their nonconformance reports that the material certification information be incorporated into the traveler. Where the material used during fabrication and installation could not be determined at all, the quality control inspectors would recommend in their noncon-formance reports that the item in question be scrapped.
During the course of the interviews of the quality control inspectors, Individual 'C' provided written statements (Exhibits III and IV).
Individual 'C' stated he had encountered two instances where material traceability had become a problem.
In one instance angle iron marked with control No. 752-1 was used to fabricate bargers. While reviewing the materi-1 certifications for the 752-1 angle iron, Individual 'C' could not locate the material certification, and later determined that material certification did not exist at all for ingle iron control No. 752-1.
Individual 'C' did determine the angle iron should have been control No. 758-1 under traveler No. F-4106.
Individual 'C' stated the problem with these two control numbers was caused during the preparation of that traveler and that the 8 of the number 758-1 was not readily distinguishable and at first glance appeared to be a 2.
Individual 'C' stated he brought this problen to the attention , of the Zack, Midland Quality Control Manager, and the Quality Control Manager told Individual 'C' to change the numbers on the angle iron from 752-1 to 758-1.
Subsequent interview of the Quality Control Manager and Individual 'C' disclosed the Quality Control Manager had advised Individual 'C' to change th number frcs 752 to 758 on both the traveler and on the material, ndividual 'C' advised that he had prepared a hold report to describe :his problem and that the hold report had not been closed out at t.e time of the investigation.
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( . - . . Individual 'C' also stated that he had encountered a problem with channel ircn with control number 801-2.
During his review of material certifications, Individual 'C' could not find the material certifi-cation for channel iron 801-2 in the size of 3 inch by 5 pound. The available material certification under control No. 801-2 was for 4 inch by 5.4 pound channel iron. This channel iron was also shipped under traveler number F-4106. In referring to traveler F-4106, Individual 'C' found that the 3 inch by 5 pound channel iron did not have a control number written on the traveler at all. Individual 'C' was instructed by the Quality Control Manager at Midland to contact the Zack, Chicago, Quality Assurance Section to obtain additional information pertaining to this channel iron. Individual 'C' was informed by memo from the Quality Assurance Section that the correct control number for the channel iron sh uld be C-666.
Individual 'C' prepared a hold report and placed the channel _ron on hold until the certifications for the material were received.
Interview of the QC inspector in charge of document control disclosed that in the instances where new travelers were being prepared to document discrepancies between old travelers and the actual installed hangers, the old travelers were not being destroyed. The old travelers and the documents relating to them were retained in the individual file for each hanger. This file also included the new traveler that was prepared to resolve the discrepancy and the related inspection reports pertaining to that hanger. A selective review of hangers and hanger files confirmed that original tra elers were being retained in the hanger files in those instances whtve a new hanger or a new traveler had to be prepared to resolve the discrepancy between the actu:1 installed hanger and the old traveler.
Allegation No. 21 - Individual 'D' stated examples of bad welds made by the Zack Company during HVAC installation could be found in the control room. These bad welds had been accepted by the quality control inspectors during the initial inspection, and this area had not Leen placed on the Zack reinspection list.
Finding - Random observations in the Midland control room disclosed numerous improper welds in the HVAC installation. Many of these welds showed excessive porosity and slag inclusion. One hanger, No. V26-SH-3, having defective welds was selected for further review. A review of the Zack files did not reveal an in-process inspection report for hanger No. V25-SH-3.
Also, the review disclosed. =t this hanger had not been scheduled for reinspection by the Zack Company. However, Consumers Power Company had made note of poor in-process hanger inspections by the Zack Company on Consumers Noncompliance Report M-01-4-9-079, as well as being a parc of the Management Corrective Action Request (MCAR) No. MD-1, dated January 8, 1980. Both the Consumers Power Company's Nonconformance Report and the Management Corrective Action Request required the total reinspection of all installed HVAC hangers, including those installed in the control room. Both the Consumers Power Company Nonconformance Report and the Management Corrective Action Request are still open and work remains pending on both.
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7.
Other Matters Marking of Galvanized Carbon Sheet Steel Finding - While in the Zack, Midland, fabrication shop sheet steel was observed to be marked in a dual manner. Each 4' x 12' steel sheet bore duplicate identification numbers. The sheets were marked with the coil number in yellow. Nissen marker, as well as having the coil number and the Zack Company Purchase Order Number marked with a black felt-tip marker (Eberhard Faber Marquette).
While in the vicinity of Battery Room 351, Elevation 614, Auxiliary Building, an installed duct system was found to be m rked in black, "V22-F-21, Aux 614 F5848, 2V?i-0S-B. Similarly, in the Upper Cable Spreader Room two installed duct pieces were marked in black, "2402 V26-SH1, F9110, 28 x 16", and "2402, V26-SH1-33, F9117, 28 x 12.
Inquiry of Zack, Midland, QC inspectors disclosed the duct pieces, described above, were Seismic Class I, nnd the black marker was used as the yellow, Nissen marker had a tendency to smear before d rying.
Inquiry of the Bechtel Power Systems Quality Assurance Representative revealed the black marker was not a currently approved matking material, but a design change was in the process, but not yet approved, of being made to allow the use of the Eberhard Faber Marquette on galvanized carbon steel (Criterion V).
Calibration of Portable Weld Rod Carriers Finding - During a visit to the Zack weld rod storage and issue rooms j on March 13, 1980, four of twelve portable weld rod carriers (caddies) were found to be lacking identification control markings and were void of any calibration stickers. Records indicated two of the units were out of calibration (due November, 1979) and two units had not been recorded at all (Criterion IX).
De-energized Weld Rod Carrier Finding - During an examination of the fabrication shop on March 13, 1980, a de-energized weld electrode warming caddy was acted in a portion of the building where welding operations were performed.
Further examinations of the caddy revealed the caddy was cold to the
touch and it contained a mixture of E-6011 and E-7018 welding electrode.
' A cursory count of the weld electrode contained in the caddy indicated that at least twelve E-7018 and at least eight E-6011 weld electrodes were in the caddy. The caddy did not appear to have an identifying serial number. No Filler Metal Withdrawal Form was available which could account for the weld ele.'. rode in the caddy (Criterion IX).
Gas Metal Arc Welding Finding - During the examination of the Zack Company fabrication shop, on March 13, 1980, a 45* by, nominally, 4' diameter duct was l l - 29 - _
i . being repair welded using a gas metal arc weld process. The duct was identified on Zack traveler number F-9396 and on drawing number V34-SH1-5. Subsequent to this examination, the material certifications were sought for the weld filler material being used, and an examination of the weld filler material spool was requested. RIII personnel were informed the material certifications were not available, and the weld filler material spool (with the remaining wire) had been discarded.
Nonconforming condition were not identified for those duct pieces which were known to have been previously welded with the discarded weld filler material. At a later time during the investigation, a partially used spool of 0.035" diameter, E-703-3, weld filler material was produced by Zack Company personnel and was claimed to be the spool which had been in use at the time of the fabrication of the duct piece, Traveler number F-9396. Zack personnel claimed the spool had been retrieved from the trash. Material certifications were eventueily produced for the spool which was claimed to have been retrieved. This spool was ide tified as 0.035" diameter Hobart HB-25, heat number 183330, control number 1709393. Zack Company personnel indicated that the wire remaining on the spool would be ut ilized (Criterion XV).
Electrode Processing Finding - Electrode processing was observed at change of shift, on March 13 '980.
It was noted, weld rod was returned to the attendant in heated rod caddies by welders of the day shift. Approximately 12 (#7018) electrodes in one rod caddie were cold to the touch. The attendant did not know that processing of this rod was to be entirely different than the heated (this rod should be thrown away) electrodes.
It was clearly apparent from questioning that the attendant was not familiar with the applications of the AWS DI.1, Part B, Section 4.9 requirement that low hydrogen electrodes (7018) must be redried after being allowed to go without heat for greater than four hours.
Since he had no say of knowing how long the rod had been cold, his only action was to bend and throw the rod away, ar only a weld rod storage oven, no. an oven of ufficient temperature range to permit rod reconditioning, was available.
Use of White Nonconformance Tag Finding - The Zack Company lay down area, Jocated adjacent to the fabrication shop was examined on April 23, 1980. During this examina-l tion, it was noted that essentially all Nonconformance Tags applied to l numerous, NIBD 23, Ruskin fire dampers stored in this area were made of l a white paper and appeared to be a Xerox copy of the regularly issued yellow Noncomformance Tags. These tags were applied as a result of 10 CFR Part 21 notification pertaining to installation of negator type
closure springs. The Service Water Building was also examined on l April 23, 197 Zack Company Nonconformance Tags placed on hangers l located in the centermost service water pump bay were made of white l paper which also appeared to be Xerox copies of the required yellow Nonconformance Tags (Criterion XV).
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N.. ' . . . Nonconformance Tag Item Identification Finding - During the investigation, Zack personnel placed Nonformance Tags on, NIBD 23, Ruskin fire dampers as a result of a 10 CFR Part 21 notification. Many of these tags identified the damper only by the damper size and a drawing number which would identify the duct layout schematic and hanger location. Some tags identified an elevation.
Other tags specified only a damper size. There are several safety-related and non-safety-related Ruskin dampers of identical size used in the heating, ventilating and air conditioning systems. An identifying item number and piece mark number was not entered on any of the approximately 60 Nonconformance Tags reviewed pertaining to the Ruskin damper Part 21 nonconformance (Criterion XV).
Permanent Weld Identification and Documentation Finding - Zack Company was requested to produce the permanent documen-tation associated with the welding for hangers numbered 33, 34, 36, 37, 38, and 21A located in the Upper Spreading Room and detailed on drawing number V-26SHl. No permanent documentation could be produced which would identify a given weld with a welder's symbol, type electrode, date and inspector's initials (Criterion V).
linding - During the investigation, several duct hangers were examined which are located in the Upper Spreading Room. The hangers examined are detailed on drawing number V26SH1 and are hangers numbered 33, 34, 36, 37, 38 and 21A. Each of these hangers has at least one weld which has not been marked with a welder identification number and one hanger has four multiple weld areas which do not have welding identification numbers (Criterion IX).
Other Observations The following observations were made by RIII personnel during the course of this investigation: An installed hanger, No. V9-SH1-7, did not resemble the sketch of the hanger on the traveler, No. V19-7(1/C893). The original hanger (in the configuration as shown on the traveler) was fabricated by the Zack facility in Chicago.
The hanger (in the configuration as installed) was fabricated and installed without a new traveler being prepared.
(Criterion V) The physical dimensions of the angel iron of an installed hanger, No. VI-3(7/C886) F916, were different f-,m the dimensions listed on the traveler for that hanger. The height of the hanger prescribed by the traveler for that hanger was 43 3/4", but the actual height of the installed hanger was appro.:imately 37".
The installed angle brace was a 2" x 2" angle, instead of the 3 1/2" x 3 1/2" x 1/4" angle required by the traveler.
(Criterion V) A procedure for the final inspection of items field fabricated at the Midland site did not exist.
(Criterion X) - 31 - '
T' . . . A hanger, V19-Sh 1-7, did rot have either the traveler number or the material control number identified on all of the sub-components. This hanger was fabricated with an angle iron marked with the identification for hanger number VI-3(9/C880)-F916).
(Criterion Vi1I) A hanger, No. V1-3(7/C886)-F916 did not have either the traveler number or material control number marked, or otherwise identified, on all of the ' sub-components.
(Criterion VIII) The Zack Company was storing numerous sections of angle iron in the Poseyville, MI, "Laydown Area".
The sections of angle iron were not marked with material control numbers or any other identification markings to insure material traceability was maintained.
(Criterion VIII) Sections of angle iron used to fabricate a duct, No. V26-Sh2B-46.1-P1515 had material control number 727-2 written on them. A review of the material certification for angle iron control number indicated the material was ASTM A575. It was determined the Zack Company did not have a qualified welding procedure to weld on ASTM A575 material in accordance with AWS D1.1.1977 Code (Criterion IX).
8.
Management Meeting Subsequent to this investigation, a meeting was held with the Consumers Power Company, Bechtel Power Corporation and Zack Company personnel identified in Paragraph 1 of this report, at the Region III office on May 2, 1980. The purpose of this meeting was to discuss Region III's concerns regarding the implementation of the Consumers Power Company's quality assurance program at the Midland Nuclear Power Plant, Units 1 and 2, as pertaining to the Zack Corporation and the Region III Immediate Action Letter dated March 21, 1980.
In addition to discussing Region III's concerns and the need for prompt Consumers Power Company management attention / involvement to resolve these concerns, enforcemer options available to the NRC were discussed.
Attachments:
A.
Exhibit I, Copy of Typed Transcript of Statement by Individual 'A' B.
Exhibit II, Copy of Immediate Action Letter dated March 21, 1980 C.
Exhibit III & IV, Copy of Typed Transcript of Statements by Individual 'C' - 32 -
_ -. - . - . , . Bay City, Michigan (LOCATION) March 12, 1980 (DATE) I, (Individual "A"), t areby make the following statement to CHARLES H. WEIL, who has identified himself to me as an Investigator of the United States Nuclear Regulatory Commission.
I make this statement freely with no threats or promises of reward having been made to me.
Mr. Weil has assisted me in the preparation and typing of this statement.
I have been employed by the Zack Company (the heating, ventilation ano air conditioning subcontractor at the Midland Nuclear Power Station construction site) for the last seven months. For the last two months, I have worked as a Quality Control Inspector for the Zack Company.
During the course of my employment the following items have come to my attention: Travellers (the documents a
REGION III, Glen Ellyn, Illinois Exhibit I-3- - -. , ___
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. < . , ' Midland, Michigan April 18, 1980 (Date) I, (Individual 'C'), hereby make the following statement to CHARLES H. WEIL, who has identified himself to me as an Investigator of the United States Nuclear Regulatory Commission.
I make this statement freely with no threats or promises of reward having been made to me.
I am presently employed by the Zack Company at the Midland Nuclear Power Plant Construction Site, Midland, Michigan. My position with the Zack Company is Quality Control Insps tor, Level I.
I have been employed by the Zack Company since January, 1980.
The Zack Cc pany is responsible for the installation of the heating, ventilation, and air conditioning systems at the Midland Plant. The Zack Company is presently doing a complete reinspection of installed ductwork hangers at the Midland Plant.
In my position as a Quality Control Inspector it is my responsibility to inspect completed ductwork for completeness, quality, and fabrication and installation in accordance with the prescribed codes.
During the reinspection, I have found two areas that have caused me to be concerned: 1.
The installed ductwork being reinspected is being placed on " hold" or being marked as "non-conforming" at a high rate. Most of the problems seem to be in the area of accountability on paper.
In many instances the weld procedure described on the traveler, the traveler is the written instructions on how a piece of hangers is to be fabricated and installed, does not agree with the weld procedure used during installation or fabrication.
I have found the problem to be that the weld procedures placed on the traveler during traveler preparation were in error and not the weld procedure actually used during instal-lation of the hanger or during its fabr..ation.
I have found that for the most part the weld procedure used during installation or fabrication agrees with the weld procedure specified in the detail drawings (blueprints).
2.
During the reinspections I have found several instances where incorrect material control numbers, the number assigned to identify material from its purchase through fabrication to final installation were incorrect.
I found that the control numbers entered on the traveler and placed on the material were not traceable through records to any materials received at the Midland Site.
Two examples of this being: A.
1\\" X 1\\" X t" angle from arriviug on the site was marked with control number 752-1.
During the reinspection of the installed hangers, I attempted to trace the material certifications for control number 752-1.
I found that material certification for control numbe: l?.-1 did not exist. However, I did find material certificatich xe r control number 758-1 under traveler number F-4106.
Exhibit III
. - . I believe the problem was caused by whomever prepared the traveler, . as the 758-1 was hard to distinguish from the number 752, and therefore the numbers were transposed from an 8 to a 2 on all materials for that control number.
I called this problem to the attention of my supervisor, MIKE D'HAME. The Quality Control Manager for Zack at the Midland Site. D'HA!E told me to change all of the numbers of the travelers for the angel iron from 752 to 758, and then to go to the laydown and change the control numbers on the materials from 752 to 758.
B.
During the reinspection I found 3" X 5# channel iron to be marked with the control number 801-2. When I went to find the material cergificationsforcontrolnumber801-2,Ifounditwasfor4"X 5.4 channel iron. I informed D'HAME of this problem, and he told I tele-me to call HARRY GEYER at the "ack Company in Chicago.
phoned GEYER and described the problem to him. GEYER sent me a note, stating, "Ron Milne, Cert for 3 X 5# channel which was shipped on Traveler # F4106." I referred to traveler F-4106.
I found four pieces of 3" X 5" channel iron was shipped under that travelgr and the traveler did not have a control number for the Immediately above the entry on the travel for p 3" X 5 chganel.channelironwasthecontrolnumber801-2 fog 4"X5.4 the 3" X 5 The material certification for the 3" X 5 channel channel iron.
iron sent to me with the note by GEYER was from the Calumet Steel Company, Chicago Heights, IL. This certification showed the Zack control number of C-666 with an order date of April 3,1978. The date on traveler number F-4106 was May 9, 1979 and the material was receipt inspected at the Midland Site on may 10, 1979.
I informed D'HAME of these discrepancies. D'HAME told me to change the control numbers on the channel iron from 801-2 to C-666, and D'HAME also to also change the control numbers on the travelerc.
told me to destroy the note from GEYER.
I intend to use GEYER's note to cross-reference the material certifications on the trave'ers and on the non-conformance reports.
I cannot understand Both of these examples involve nuclear safety systems.
how the changing of the control numbers on either the traveler or on the material would insure total material traceability.
Mr. Weil har assisted me in the preparation and typing of this statement.
I have made any I have read the foregoing statement consisting of 2 pages.
I have signed necessary corrections and I have initialed those corrections.
i my name in the margin of each page. This statement is the truth to the best of my knowledge and belief.
l (Individual "C") i I WITNESS: Charles H. Weil
Exhibit III ( -2-l l l
. x.x.
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. . Midland, MI 4/25/80 (Date) I, (Individual "C"), hereby make the following statement to Charles H. Weil, who has identified himself to me as an investigator of the United States Nuclear Regulatory Commission.
I make this statement freely with no threats or promises of reward having been made to me.
With refrence to my statement taken 4/18/80 the 2nd & 3rd last sentences of paragraph 2B of my statement are in error.
D'Hame never told me to change the numbers from 801-2 to RM 666, and he never told me to destroy the note from Geyer.
I assumed from Geyer's note I was to change the numbers, but I never did change those numbers. No one in RM supervision at the site told me to destroy the note from Geyer. The remainder of my statement of 4/18/80 is true & correct as written.
I have read the forgoing statement consisting of 2 pages.
I have made all necessary corrections and I have initialed those corrections.
I have signed my name in the margin of each page. This statement is the truth to the best of my knowledge and belief.
/S/ (INDIVIDUAL 'C') g WITNESS: /S/ Charles H. Weil Exhibit IV }}