IR 05000461/1981018
| ML20010C267 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/12/1981 |
| From: | Danielson D, Key W, Streeter J, Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010C257 | List: |
| References | |
| 50-461-81-18, NUDOCS 8108190299 | |
| Download: ML20010C267 (41) | |
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U.S. NUCLEAR TIGULATORY COMMISSION OFFICE OF IN5fECTION AND ENFORCEMENT
REGION III
Report No. 50-461/81-18
' Docket No. 50-461 License No. CPPR-137 Licensee:
Illinois Power Company 500 South 27tu Street Decatur, IL 62525 Facility Name: Clinton Power' Station, Unit 1 Investigation Conducted: April 1 - June 18, 1981 Investigation At: Chicago and Clinton, IL 8//[//
Investigator:
1) ate C.
H'. Weil- ~ '
Inspector:
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W. J/ Key ~
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Date Reviewed By:
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D. H. Danielson, Chief Date Materials & Processes Section i
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M J.IF. Streeter, Acting Director Date i
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Enforcement and Investigation Staff
Investigation Summary
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Investigation on April 1 - June 18, 1981 (Report No. 50-461/81-18)
Areas Investigated: Unannounced investigation concerning allegations
pertaining to the Zack Company (heating, ventilating and air conditioning
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subcontractor) at the Clinton Power Station, Unit 1.
Nineteen allegations /
concerns were addressed during the course of the investigation. This
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investigation involved 168 investigative hours, both on and offsit._, by two NRC representatives.
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Results: The investigation into the nineteen allegations / areas of concern
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regarding the Zack Company at the Clinton Power Station resulted in three
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items of noncompliance with NRC requirements (10 CFR 50, Appendix B, e
l Criterion V, failure to follow procedures (two items) and 10 CFR 50, i
Append!
B, Criterion XV, failing to control the further use or instal-lation of nonconforming items pending disposition.
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8108190299 810812'
PDR ADOCK 05000461 O
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REASON FOR INVESTIGATION
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During the period April-1_- June 3,'19S1, Individual A provided information
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to Nuclear Regulatory Commission, Region III (RIII) personnel concerning the performance of the Zack Company (the HVAC subcontractor) at the Clinton Power Station.. Individual A stated nineteen allegations / concerns dealing-with the Zack Company's material traceability, adherence to Quality Control procedures, i
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and installation of HVAC systems.
SUMMARY OF FACTS
- An investigation was initiated into the Zack-Company activities at the Clinton Power Station as a result of the information provided by Individual A.
Of the nineteen allegations / concerns, one allegation (No.'8) did not contain sufficient information to pursue. The investigation identified three items of noncompliance with NRC requirements. The items of noncompliance dealt with 10 CFR 50, Appendix B, Criterion V, failure to follow procedures (two items) and 10 CFR 50, Appendix B, Criterion XV, failure to control the further use or installation of nonconforming items pending disposition. Additionally, two ' areas (vertical holes in auxiliary steel clips and seismic, non-safety HVAC hangers within the containment structure) were referred to the NRC Senior Resident Inspector - Clinton for resolution.
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t-DETAILS l.
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Persons Contacted-Illinois Power Company
- G. M. Brashear, t.anager, Clinton Site Activities A. Budnick, Lirector QA E. E. Connon, Director of Compliance
- R. W. Folck, QA Engineer-
- M.-C. Hollon, Supervisor Construction QA D.. Korneman, Supervisor Mechanical Construction
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- J. O. McHood, Vice President-Project Manager
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R. W. Morgenstern, QA Engineer
- J. S. Spencer, Director Design Engineering I
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G. Stinnett, Engineer Baldwin Associates, Inc.
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B. Browne, Subcontract Administrator
G. Chapman, Manager, Technical Services-L. Gelbert, QC Manager R. R. Riedy, Subcontract Administrator J. Robinson, Document Control Supervisor
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Carrillo, Welder R. Casper, Field Superintendent D. Caulkins, QA Manager
C. L. Eichstaedt, Vice President-Nuclear S. K. Jones, General Foreman T. W. Packey, QC Manager
- V. Pemberton, Assistant Project Manager D. Peters, Office Manager
- R. St. Onge, Project Manager M. Washburn, Document Control Supervisor f
Sargent & Lundy Engineeers j
R. Karpinski, Design Engineer
Individuals i
Individual A i
(* Denotes presence at Exit Meeting on June 11, 1981.)
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Introduction The Clinton Power Station, Unit 1, is under construction by the Illinois Power Company (TP) in Dewitt County, Illinois. Baldwin Associates (BA) is the constructor of the plant, and Sargent & Lundy Engineers (S&L) is the architect-engineering firm. The facility will utilize a boiling water reactor (BWR) supplied by the General Electric Corporation.
The Zack Company has been designated to provide and install the heating, ventilating and air conditioning (HVAC) systems for the Clinton plant. The systems serve both safety-related and non-safety-related areas of the plant.
10 CFR Part 50, Appendix B, sets forth eighteen Quality Assurance criteria applicable to nuclear power plant construction activities.
Illinois Power Company and its contractor organizations, among them Baldwin Associates, Sargent and Lundy Engineers, and the Zack Company, have prepared Quality Assurance / Quality Control Manuals and Procedures setting forth the specific requirements applicable to their activities at the Clinton 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 besis for determining compliance or noncompliance with NRC requirement s:
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Clinton Station Quality Assurance Manual Sargent & Lundy Engineer's Specification No. K-2910.
Specification for HVAC Work Clinton Power Station-Unit 1, Illinois Power Company.
Zack Company Quality Assurance Manual and Quality Control Procedures.
ASME Material Specifications A-446, A-525, A-526, and A-527.
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American Welding Society, AWS D1.1.1977.
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Receipt of Allegations During the period April 1-June 3, 1981, Individual A contacted RIII personnel.
Individual A stated he was quite concerned with the performance of the Zack Company, the HVAC subcontractor, at the Clinton Power Station construction site.
Individual A provided nineteen allegations / concerns, detailed in the following paragraphs, regarding Zack Company activities at the site.
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Allegations Allegation No. 1 - Document Control is virtually nonexistent.
Of 119 construction drawings in the possession of the Zack Company at the Clinton Power Station, 63 were outdated.
In many instances, re-visions have been made and were not obtained by the Zack Company.
Findings - During the period May 28-June 2, 1981, the following information was obtained during interviews of John S. Spencer (Director of Design Engineering-IP), John R. Robinson (Document Control Supervisor-BA), Donna Peters (Zack Office Manager), and Marcia Washburn (Document Control Supervisor):
Prior to April 2,1981, design drawings utilized by the Zack Company were provided by BA catellite document control facilities.
It was realized the volume of drawings had become too cumbersome to continue issuing the drawings from the BA satellite facilities. Therefore, on April 2,1981, Zack Company became responsible for their own control of drawings (mylars). On that date, S&L began to make two copies of the mylars, one copy for BA and the second copy for the Zack Company. With control of the mylars transferred to the Zack Company on April 2, the overall control of drawings began to im-prove. However, this did not eliminate the number of Field Change Requests (FCR) or Engineering Change Notice (ECN) outstanding against a particular drawing.
A random review traced the following transmittals and drawings from the Zack Document Control Center to the Field Document Center and to the " stick files" at the individual work sites:
Drawing Transmittal Date Drawing JCR/ECN/NCR F-21011 4/9/81 M14-1051-2 (F)
FCR 8113 F-21016 4/9/81 M14-1132-22 (F)
FCR 7107 & 8149; NCR 4015 F-21056 4/13/81 M14-1108-21 (F)
FCR 7965, 7477, 8402 F-21105 4/21/81 M14-1019-9 (E)
FCR 7796, 8190, 8201, 8558; ECN 238, 344 F-21105 4/21/81 M14-1113-15 (H)
ECN 320 F-21166 4/20/81 M14-1121-11 (B)
FCR 8044 F-21219 4/20/81 M14-1017-5 (H)
FCR 71855, 7486, 7594 6388, 6190
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F-21277 4/30/81 M14-1016-10 (R)
FCR 5974, 6035, 7060, 7675, 7691; ECN 1637 F-21277 4/30/81 M14-1113-1 (N)
FCR 7487, 7060, 7011 7675 F-21277 4/30/81 M14-1121-9 (D)
FCR 7675 F-21280 4/30/81 M14-114-1 (H)
FCR 7186, 7489, 7678, 7673 F-21280 4/30/81 M14-1036-1 (F)
FCR 8093,7489, 7678 F-21283 4/30/81 M14-1060-1 (K)
FCR 8149, 4294 R-1, 6385, 5936, 6193, 7470, 6957, 7013, 7107, 7593, 7635, 8045, 8258 F-21301 4/30/81 M14-1019-9 (G)
FCR 7796, 8190, 8281 8558; ECN 344, 341 F-21302 5/1/81 M14-1110-43 (H)
FCR 6095; NCR 4412, 4393 F-21302 5/1/81 M14-1109-10 (J)
FCR 7818, 7694, 7693 7820, 7819, 7807, 8412 F-21317 5/2/81 M14-1110-54 (J)
FCR 8038 F-21330 5/5/81 M14-1132-29 (B)
NCR 4013 F-21346 5/6/81 M14-1132-32 (C)
FCR 7308; NCR 3030-R1 F-21370 5/9/81 M14-1109-10 (J)
FCR 7818, 7694, 7693; NCR 4393 F-21414 5/13/81 M14-1110-23 (D)
FCR 8559, 8711 F-21435 5/14/81 M14-1017-002 (J)
Drawing F-21435 5/14/81 M14-1017-004 (D)
Draving The review of the drawings and transmittals described above did not identify any outdated drawings.
Allegation No. 2 - S & L Specification "K29" required the painting of the inside of duct welds. Specifically S & L Form 1790-E, page 3 of 11, Paragraph 13, states:
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" FIELD-TOUCH UP FOR GALVANIZING A.
The following shall be touched-up with (1) one coat of zinc-rich paint:
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Areas of galvanized surfaces (of siding, etc., furnished and/or installed by Contractor) which have been marred due to handling, shipping, erection, weathering, etc.
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Field welds made on hot-dipped galvanized surfaces."
The Zack Company continues the installation of duct work at the Clinton plant without the inside of the welds being painted. Also, the welds inside the ducts were not being ground; therefore, the Quality Control inspectors could not inspect for pin holes in the welds.
Findings - On February 20, 1981, Zack Nonconformance Report (NCR)
No.
ZC-CB-390 was prepared. The " description of nonconformance" was listed as " Specification and Procedure referenced state that
' galvanized areas marred due to handling... erection...etc., and Field Welds made on hotdipped galvanized surfaces required touch-up galvanizing.'
Contrary to the above, the internal side of duct work welded to hangers has not been touched-up." On February 23, 1981, the Zack Company wrote the BA Project Manager.
This letter stated in part "a condition exists and has existed since the early stages of our job site installation of sheet metal duct work and hangers.
Welding of the hangers to the ' skin' of the sheet metal duct work causes the G90 galvanized coating on the inside of the ' skin' to be burned away. There is no physical way of coating this ' burn away.'
On the job site meeting held in September 1979 I brought this subject to everyone's attention. No formal answer was received. At the same time the same subject was discussed relative to the ' pin spotting' as performed by the duct installation subcontractor."
On April 3, 1981, S&L Engineering Change Notice (ECN) No. 2130 was initiated. ECN 213 was approved for use on May 29, 1981. This ECN referenced the above Zack Company letter. The ECN authorized the following:
" Revise first sentence in specifications Paragraph 13.38 to read:
"All accessible welds galvanized material shall be coated with a zinc-rich paint in strict accordance with manufacturer's instruction.
" Add the following sentence t, specification Paragraph 313.3a:
" Welds of stiffeners and companion angles to duct work made prior to hanging of duct work shall be considered accessible and shall be touched up on the outside of the duct and on the inside, wherever the galvanizing is disturbed.
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hanging duct work, the Contractor shall weld the hangers to duct work as specified herein and delineated on the design d rawings. The touch-up of these weld on the inside of the ducts is not required as they are considered inaccessible. The touch-up of these welds on the outside of the duct is required.
The insulation pin to duct welds shall be considered inaccessible and do not require touch-up."
During the period May 29-June 5, 1981, inspections of the interior of Zack installed HVAC systems on the 751', 781' and 825' elevations of the Control Building were conducted by RIII personnel. These visual inspections were done on both safety related and nonsafety-seismic HVAC ducts.
Several instances of non painted interior welds were observed and these areas were identified to Zack and BA personnel.
As a result, BA NCR No. 4766, dated June 10, 1981, was prepared.
The description of the nonconformance was " prior to the issuance of ECN 2134 no touch-up of the galvanizing was done to the internal of the duct work. Where the hanger to duct welds were made and where the pin spot welding was done for the application of the insulation."
The recommendation was to " Accept-as-is. ECN 2134 allowed the use of the nonconformance listed above." A final disposition, dated June 10, 1981, was to " accept BA recommendation. ECN 2134 is appli-cable to all duct work already installed and yet to be completed."
During the coarse of the RIII inspection of the duct interior, no instances of pin holing were identified. Additionally, the American Welding Society (AWS) Code does not require the grinding of welds for the visual inspection of the HVAC systems.
Allegation No. 3 - Hangers are not being fabricated and installed according to design. The hangers are being installed as-built and Field Interference Notices (FIN) are being prepared to show the difference between design requirements and the as-built hangers.
However, nothing is being done to followup on the discrepancies (NCRs). One example being, Hanger No. C-6350 at 800' elevation of t,he Co< trol Building, where the diagonal brace (web of the angle)
was huag backwards.
Findings - On June 2, 1981, the cbove allegation wat reviewed with Thomas Packey, Zack Quality Control Manager. Drawing No. M14-1108-5, Revision D was, according to Packey, "a typical detail." Packey advised the installed hanger (C-6350) was the same as shown on detail 4 of drawing M14-1108-5 (D).
Packey stated the hanger was installed according to design, but the drawing on the field fab-rication ticket (traveler) was wrong. Packey further advised the Quality Control inspectors utilize the traveler drawing as an aid in their inspection. Packey concluded, Traveler No. SF-1438 was drawn incorrectly. Packey stated there was no requirement to write a NCR against the traveler drawing; however, had the actual installation of the hanger been in error, a NCR would have been required.
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-A review of Zack Field Interference Notices (FIN) disclosed FIN No. 2-1160 was prepared on April 29, 1981. This. FIN dealt with HVAC Inverted Diagonals, and referenced drawing No..M14-1108-1 -(D).
The text._of the FIN was "just recently we have received many pre-fabricated hangers with inverted diagonals. For example:
the schedule' print will call for a type H-102-3 and the hanger will be fabricated as type H-102-3 but one or two diagonal braces, _ the web
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of the angle will be inverted." Zack requested " approval for inverted diagonals and/or horizontals, except for duct supporting horizontals."
On May 18, 1981, BA FCR No. 9146 was prepared, referencing Zack FIN-Z-1160.
The text of this ICR was " allow Zack the option of placing the diagonal and horizontal members of a hanger (except the duct supporting horizontals) in either position." This FCR was closed on June 3, 1981, with the design organization's disposition " accept BA's recommendation Tntegrity of the hangers will not be affected-by inverting diagonal or horizontals members."
(Note: The Zack FIN Procedure was reviewed during the investigation of Allegation No. 15)
Allegation No. 4 - Roman Karpinski, S&L Design Engineer, has been pencilling-in changes to drawings at the request of a Zack production foreman. Karpinski was not following any procedures (FIN, NCR, or, ECR) when making the pencil changes.
Findings - On June 10, 1981, Karpinski, S&L Designer, was interviewed:
Several months ago, a Zack foreman (possibly Stcve Johnson) stopped Karpinski in the plant and asked Karpinski a question about a drawing.
Karpinski could not recall the specific drawing, but remembered the question dealt with the dimensions of an angle iron between the top-of the duct to the top of the member. Johnson told Karpinski an answer was needed immediately because production workers were awaiting a decision. Karpinski reviewed the drawing for Johnson and provided Johnson with an explanation. Karpinski stated the problem arose during a NCR review and was a draftsman's error. Karpinski stated he did not change the drawing, caly pencilled an explanation for Johnson, and his only reason for making the pencil markings was for clarification.
Several hours after his encounter with Johnson, the Zack Site Manager-came to him and asked for an explanation.
On June 10, 1981, Ron St. Onge, Zack Project Manager, advised a Steve Johnson had never been employed by the Zack Company at the Clinton site.
St. Onge advised a Steve Jones was employed by Zack as a General Foreman.
On June 10, 1981, Stephen K. Jones provided the following information:
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On several occasions he has stopped Karpinski in the field and asked i
Karpinski to clarify drawings. Jones could not recall any specific conversations with Karpinski, other than to clarify drawings. He never l
observed Karpinski making pencil changes to any drawings.
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On June 10, 1981, Ron St. Onge, Project Manager, and Vincent Pemberton, Assistant Project Manager were interviewed and provided the following information:
Each recalled that several months ago Karpinski had been stopped in the " power block" by Zack foremen and requested to provide information regarding drawings. One instance involved a safety-related HVAC banger on elevation 781' of the Control Building.
(Note: Jones stated he has not worked on elevation 781' of the Control Building, for the last 1 1/2 years). St.Onge and Pemberton brought this matter to the immediate attention of BA and Karpinski and resulted in the preparation of Zack NCR ZC-CB-454 on April 8, 1981 (Exhibit I).
Allegation No. 5 - In-process inspection of Zack work did not begin until November 1980.
Prior to that time in-process inspection did not exist.
Findings - On June 2,1981, Vincent Pemberton, Zack Assistant Project Manager, and Thomas Packy, Zack Quality Control Manager, provided the following information:
Pemberton advised safety-related HVAC installations began in approxi-mately November 1979 in the Control Room. Pemberton recalled QC inspectors were on the floor at all times and were conducting in-process inspections.
Packy provided hanger inspection packages covering the approximate period November 1979 through January 1981.
A random review of hanger inspection packages disclosed the following information:
Hanger No. C-5002, installed on elevation 781' of the Control Buil-ding (Drawing No. M14-1060-1), was fabricated at Zack's Chicago plant on October 26, 1979, with the hanger being received at the Clinton site on November 7, 1979. An undated, in process inspection record signed by Zack QC Inspector Mike Franchuck was in the hanger document package. The inspection of this hanger was not complete with the most recent inspection being conducted on January 22, 1981.
Hanger No. C-5003, installed on elevation 781' of the Control Building (Drawing M14-1060), was fabricated at Zack's Chicago plant on October 26, 1979, and received at the Cliaton site on November 7, 1979. An undated, in-process inspection record signed by Franchuck was located within the doenment package.
Hanger No. C-5004, installed on elevation 781' of the Control Building (Drawing No. M14-1060) was fabricated at Zack's Chicago plant on October 26, 1979, and was shipped to the Clinton site on October 31, 1979. This hanger underwent receipt inspection at the Clinton site on November 7,1979. An undated, in process inspection record signed by Franchuck was found within the hanger documentation package.
Zack Nonconformance Report (NCR) No. ZC-CB-102, dated December 6, 1979, was referenced in the hanger inspection package.
This NCR noted the hanger had been installed with 5/16 inch instead of 3/8
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inch gusset plate. Zack Field Interference Notice (FIN) No. Z474, dated October 22, 1980, and BA Field Change Request (FCR) No. 6670, dated October 27, 1980, were also referenced in the hanger documen-tation package. The FIN and FCR noted the penetration was out of elevation. Additional inspection of this hanger was conducted on April 2, 1981. At the time of this investigation the final in-spection of the hanger had not been completed.
Hanger No. C-50005, installed on elevation 781' of the Control Building (Drawing No. M14-1060-1) was fabricated at the Zack Chicago plant on October 26, 1979, and was shipped to the Clinton site on October 31, 1979. Receipt inspection of this hanger was conducted at the Clinton site on November 7, 1979.
An undated, in-process inspection record signed by Franchuck was located within the hanger inspection package. Additional inspections of this hanger were conducted on January 15, 21, and 29, 1981.
Allegation No. 6 - The Zack Company does not audit any of its pro-duction functions, only the quality control function.
The Zack Company coes not have an audit schedule.
Findings - Investigation by RIII personnel at the Zack Glinton job site and the Zack corporate offices during the period J tne 2-18, 1981, disclosed the following information:
The Zack audit schedules for 1979 and 1980 could not be located.
The 1981 audit schedule was reviewed and disclosed an audit had been scheduled fer March 25-27, 1981.
A second audit was scheduled for the period September 30 thru October 2, 1981.
A review of the July 11, 1980, revision of the Zack Company Quality Assurance Manual, Section 19, revealed, " Audits will be performed as follows:
(1) Zack's site - Every twelve months for all sections of the manual." The February 28, 1979, revision of Section 19 stated
" site audits shall be conducted once every thirteen weeks by the Quality Assurance Department on selected phases of the manual.
These quarterly audits shall be conducted such that the entire pro-gram is covered yearly."
On February 14, 1979, Roy L. Wilson, QC Manager, and Harry Geyer, QC Shop Inspector, conducted an audit of the Zack Clinton site. This audit covered Sections 1 through 9 of the Zack Quality Assurance Manual.
These sections were:
Introduction, Quality Assurance l
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Program, Organization, Design Control, Procurement Documents, Drawings and Procedures, Document Control, Procurement Control, and Material Control.
On June 6, 1979, Wilson conducted an audit of the Zack Clinton site.
Sections 10 through 15 of Zack's Quality Assurance Manual were audited. These sections were Control of Special Process, Inspections, Tests Control, Control of Measuring and Test Equipment, Handling, Storage and Shipping and, Inspection and Testing.
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On October 25, 1979, Geyer conducted an audit of the 7ack Clinton j
site. This audit covered Sections 4 and 16 through 19. These sections were:
Design Control, Nonconformie g items, Corrective Action, Quality Reports, and Audits.
On March 4, 1980, Edward A. Thompson, Zack QA Manager conducted an audit of the Clinton facility. This audit included the following areas:
1.
Reviewed procedures to assure employed personnel have
" suitable proficiencies achieved and maintained in all activities affecting qualities;"
2.
Reviewed index of status of Quality Control Procedures; 3.
Reviewed receipt inspection procedures; 4.
Reviewed in process inspection procedures;
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Reviewed QC training documentation; 6.
Checked document control and drawings; 7.
Reviewed travelers; 8.
Checked material certifications, 9.
Checked material control and storage; 10.
Reviewed weld rod control and welder qualification; 11.
Checked marking and identification of material; 12.
Reviewed testing procedures; 13.
Checked rod oven, micrometer, and torque wrench calibrations.
On July 21, 1980, Thompson audited the Zack Clinton operation. This audit covered the following areas: review of procedures for currency; review of welder qualifications for proper maintenance of records; review of open NCRs for issue and pattern of non-conformance; checked QC inspector records for completeness; checked calibration dates on
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instruments; checked job site stock for traceability; and, reviewed
" hold" file.
On October 14-15, 1980, Thompson and Rcn L. Aker, Zack QC Manager,
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Hidland Project, conducted an audit of the Zack Clinton operation.
This audit covered the following Zack Quality Control Procedures
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(QCP):
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Training Procedure for Personnel Performing QC Inspection; 12.
Design / Change Control Procedure; 15.
Site Procedure for Installed and Set Own r and Zack Equipment; 16.
Site /Ouality Welders on Safety Related Systems; 18.
Site Storage Procedure; 19.
Site Procedure for Field Fabrication and Installation; 20.
Procedure for Visual Inspection of Welds HVAC Installation; 23.
Sit / Field Anchor Bolt Installation HVAC Work, and 31.
Calibration of Measuring and Testing Equipment, Plant and Site.
The most recent audit of the Zack Clinton operation was conducted during the period, March 25-27, 1981, by Michael D'Hame, Zack QA Manager, and Ken Schafer, Zack QA Engineer. This audit covered the following Zack Field QCPs:
1.
Requisition and Receipt Inspection; 2.
Storage and Maintenance; 5.
Installation; 6.
Weld Rod Control and Welding Surveillance Inspection; 7.
Site Document Control; 8.
NCR; 10.
Calibration; 11.
Training Certification and Evaluation of Quality Control Inspectors; 13.
Touch-up Painting; 16.
On going Training; 19.
Field Visual Weld Examinations.
A review of all Zack audit reports for the Clinton Site, beginning February 14, 1979, disclosed the requirement to conduct a quarterly audit of site activities was not met; however, all facets of the Quality Assurance Manual had received the required annual review.
Allegation No. 7 - The Zack Company does not do any trend analyses of identified deficiencies at the Clinton power station. For example, during January 1981 numerous deficiencies were identified with hangers not meeting requirements set forth on Drawing M14-1108-6 and a trend analysis was not performed.
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Findings - During the period June 3-18, 1981, a review of Zack trend analysis reports and Zack QCP 20, Procedure for Trend Analysis, as well as interviews of the following individuals were conducted:
Ron St.Onge, Zack Project Manager; Vincent Pemberton, Zack Assistant Project Manager; Thomas Packey, Zack Clinton QC Manager; Dave Caulkins, Zack QA Manager; Carl Eichstaedt, Zack Vice President; Ken Schafer, Zack QA Engineer; Mike D'Hame, previous Zack QA Manager; J. W. Smart, BA QA Manager; and L. B. Browne, BA Subcontracts. The following in-formation was obtained as the result of the interviews and reviews:
Browne and Smart, stated that BA had been tracking Zack's performance at the Clinton site.
Since BA was following Zack's performance, there had not been any need for the Zack Company to conduct its own trend analysis. However, in late 1930 the BA tracking program identified numerous fabrication problems dealing with Drawing No.
M-14-1032-8.
At this point BA required Zack to prepare a procedure for conducting trend analyses.
On November 28, 1980, Zack Company Procedure for Trend Analysis, PQCP 20, was written. The procedure was approved by BA for Zack's use on December 18, 1980. A copy of the procedure was transmitted from the Zack corporate office in Chicago on December 29, 1980, and was received by Zack at the Clinton site, on January 2, 1981.
Trend Analysis Reports for February, March, and April 1981 were re-viewed. Caulkins advised the data for the May 1981 Trend Analysis was being compiled and publication of that information was not anticipated until June 24, 1981. Caulkins stated PQCP 20 did not require publication of that information until the 24th day of fol-lowing month (i.e. the Trend Analysis Report for May was due on June 24th).
A Trend Analysis Report for January 1981 could not be located. On June 18, 1981, a telephone interview of D'Hame was conducted. D'Hame stated he did not have any reason for not compiling a trend analysis for January 1981 and surmised the data for the trend analysis had not been gathered because of the problems in explaining the new procedure to field persoanel prior to implementation. Additionally, D'Hame stated trend analysis had not been conducted prior to writing PQCP 20.
While reviewing audit reports (Allegation No. 6), it was noted on the July 21, 1980, audit that the auditorc had reviewed "Zack's open
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NCR's for issuance and patterns of nonconfo:mance."
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A review of the Zack Clinton NCR Log, pages 29-33, for the period January 12-30, 1981, disclosed thirteen NCRs had been prepared for
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hangers not meeting the 1" dimension described on detailed drawing M-14-1108-6.
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10 CFR 50, Appendix B, Criterion V, states in part... " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate.to the circumstatnces and shall be accomplished in accordance with these instructions, procedures, or drawings..."
Clinton Power Station Quality Assurance Manual, Chapter 16 (Cor-rective Action) states in part, "IP and its contractors shall meet the following requirements:
... conditions adverse to quality shall
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be systematically analyzed for causes and referred to management for resolution..."
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Zack Company Procedure PQCP20 states, in part,
"On or before 14th of every month each NCR, Surveillance and Audit finding initiated and/or closed by the Zack Company is reviewed by the QAM (Quality Assurance Manager)...On the 24th of every month a graph...is prepared which details the grosc quantities of open items location / category for the preceding month...on or before the 24th of every month the focuments generated in paragraph 7.2 through 7.4...
. transmitted to...Zack Company personnel for review and for action..."
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Contrary to the above the Zack Company did not prepare a Trend Analysis Report-for the Clinton Site for January 1981, even though 13 Noncon-formance Reports were prepared against drawing No. M14-1108-6 during that month.
Allegation No. 8 - The thickness of steel coils received at the
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Clinton site differ from the thickness of the materials stated on the material certifications; however, Individual A could not provide a specific example. Also, steel produced in Argentina had been received and installed at the site. This steel, manufactured by Hermosa Steel, was not accompanied by a material certification.
Findings - Since specific information was not developed regarding the specific coil numbers and material certification this allegation could not be pursued. The general requirements section of ASTM Section A-525 permit certain tolerances between the thicknesses of steel and the material certification.
On June 3, 1981, Vincent Pemberton, Zack Assistant Project Manager, provided the following information:
The Argentinian steel was purchased from Northwestern Steel. North-
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western Steel sent a material certification to the Zack Company, but this material certification did not match the steel received at the Clinton site. The certification was for steel manufactured by Northwestern Steel and not for the Hermosa Steel. The Hermosa Steel f
has been received on the site, but had not has been installed. One l'
piece of steel was located within the " power block" and the remaining steel has been located in the " lay-down" area. All of this material has been placed on " HOLD." This matter is currently under investi-gation by Zack site Quality Control Department.
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Allegation No. 9 - Control numbers are being removed from steel coils and angle iron during fabrication. When the steel is cut the control numbers are not being transferred to the remaining stock.
Findings - On June 3, 1981, Ron St. Onge, Zack Project Manager, stated that failure to transfer control numbers from one segment to the other had been a continuous problem.
St. Onge further stated that training sessions were conducted for Zack employees during the period August 20-October 1,1980, concerning this problem. These
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training sesions specifically dealt with transferring material
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control numbers from one piece to another.
St. Onge stated a part of the training sessions included an instruction to destroy all stock found without control numbers.
On June 11, 1981, Zack's Clinton field fabrication shop was inspected by RIII personnel.
In all instances control numbers had been applied to all steel stock and fabricated duct pieces. The fabrication shop foreman stated no angle iron was in stock at that time.
Allegation No. 10 - On three occasions ducts have been fabricated and installed without being marked with control numbers. These dis-crepancies were found during Zack QC Inspections and NCRs were prepared.
Individual A was concerned that other pieces may have been fabricated and installed without control markings.
Findings - On June 3, 1981, Thomas Packey QC Manager, provided the following information:
During March 1981 the QC Department conducted an inquiry into a similar allegation. Their inquiry resulted in the issuance of three NCRs. NCR ZC-CB-419 pertained to an unidentified duct piece installed on elevation 781' of the Control Building. The recommended corrective action was to " remove unidentified duct pieces and scrap.
Lefabricate a replacement duct piece." The other NCRs dealt with improper duct piece length (NCR ZC-CD-420), and a violation of QC Hold Points during the installation of fire and balance dampers (NCR ZC-CB-422).
S&L Specification K-2910 requires the identification of all duct pieces on two adjacent exterior sides and the interior. During the period May 28 - June 11, 1981, inspections of Zack facilities and operations at the Clinton site, including the field fabrication shop, the " lay-down" area, and all elevations of the " power block" in which Zack Company was installing the HVAC system, disclosed all observed duct pieces and hangers were identified as required in S&L Specification K-2910.
Allegation No. 11 - Purchase documents for Ruskin fire dampers specified ASTM A526 and A527 coatings. However, the fire dampers have been received and accepted by the Zack Company with coatings conforming to ASTM A446.
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Findings - The ASTM specification dealing with the general require-ments of coatings is A-525.
A-525 requires zine for galvanized plates, and includes A-446, A-526 and A-527 within A-525.
The base metal of A-446 is of higher quality than that of A-526 or A-527.
On June 3, 1981, Vincent Pemberton, Zack Assistant Project Manager, stated fire dampers had not been received at the Clinton site. Only balancing dampers have been received at the Clinton site.
On June 3, 1981, Thomas Packey, Zack QC Manager, stated that problems with the material used in the balancing dampers was identified in Zack NCR ZCCB-425 on March 16, 1981. A review of this NCR disclosed the description of the nonconformance was " balancing damper listed on the attached sheet, manufactured by the Ruskin Manufacturing Company and received on site by the Zack Company for fabrication using ASTM-A446-76 galvanized sheet steel." Sargent and Lundy's Technical Specification K-2910, Article 304-1062, states, where
" galvanized steel dampers are specified on the balancing damper list, would be constructed of ASTM A526 or A527 coated in accordance with ASTM A525, G-90."
On June 3, 1981, disposition of the Zack NCR could not be determined, because the corresponding BA NCR could not be located.
L. B. Browne (BA Subcontracts) stated the NCR appeared to have been lost within the BA system. As a result BA NCR No. 4751 was prepared on June 8, 1981. The recommendation on BA NCR No. 4751 was to " allow Zack to use the damper as-is." The design organization disposition was,
" accept BA recommendation. ASTM-A 446 is equivalent to the specified materials for this application. Coating (G-90) is still required."
The BA NCR 4751 was closed on June 8, 1981, and approved for con-struction on June 9, 1981.
Allegation No. 12 - Fire dampers have been received and accepted with the material thickness of the access doors in the range of 18-24 gauge with 12 gauge hinges. This was contrary to S&L Specification No. K-2910 Finding - Neither ASTM nor S&L Specification No. K-2910 have requirements on the thickness of access door hinges.
On June 3,1981, Ron St.Onge, Zack Project Manager at the Clinton site, provided the following information:
S&L Specification No. K-2910 required the access doors to be con-structed of 22 gauge material with the frame made of 18 gauge material.
The Zack vendor changed the specifications without notifying the Zack Company and fabricated the doors from 24 gauge material.
Upon receiving the doors, the discrepancy in the thickness of the material was noted and the 24 gauge doors were discarded. The Zack Company plant in Chicago is presently constructing new doors of 22 gauge material.
These doors are to be delivered to the Clinton site l
within the next several months.
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Allegation No. 13 - During December 1980, it was discovered none of the Zack welders were qualified to American Welding Society (AWS)
Code D-1.1-77, Section 5, Part C, or to Zack Clinton Quality Control Procedure 24, Paragraph 14.1.
This matter was identified on Zack NCR 319 dated December 5, 1980. The recommended corrective action on this NCR was to requalify all welders.
Individual A stated all welders were successfully qualified, however, Individual A was concerned that two years cf on-the-job experience was the reason the welders were able to qual _ e and the original welds made two years prior to the NCR may not be r.cceptable.
Findin_gs; - During the period June 3-9, 1981, L. B. Browne, BA Sub-contracts and Thomas P. Packey, Zack QC Manager, provided the following information:
The Zack Company at the Clinton site has had three instances of welders not qualified to procedure. All three of these instances were reported on Zack NCRs. A review of these NCRs disclosed the following:
NCR No. ZC-CB-200, dated August 28, 1980 identified the conconformance as "14 Zack welders qualifying to Zack Welding Procedure CB-QCP-1 (P9CS) performed a Welder's Qualification Test on 3/8 inch coupons.
This is not in accordance with the requirements of procedures CB-QCP-1 (P9CS) nor AWS D1.1-79.
The required thickness of the coupon is 1/2 inch minimum." The recommended corrective action was " welder CC8 has not performed any welding so immediate cancellation of his certification will suffice for him. The balance of the welders require the following:
(1) Cessation of all field welding CB-QCP-1 (P9CS).
(Notify Baldwin of corrective action.)" The corrective action taken, was " complete as per Baldwin Associates NCR 3675."
Baldwin NCR No. 3675 dated September 19, 1980, recommended " accept as is - requalify all welders who are presently qualified to CB-QP-1 (P9CS) - based upon all welders passing, and the procedure being requalified. All welde have been inspected and documented as being acceptable." The IP Engineer disposition was " accept BA recommen-dation.
Prior welds are acceptable based on current requalification of welders to Procedure CB-QCP-1 (P9CS)." BA NCR 3675 was closed without verifying all Zack welders had been requalified. On October 10, 1980, BA NCR No. 3723 was prepared to assure all Zack welders had successfully requalified.
BA NCR No. 3723 was closed on October 20, 1980.
Browne stated all original welds performed by Zack welders were accepted during the first visual inspection.
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Zack NCR No. ZC-CB-319 dated December 5,1980 identified the non-conformance as " welder qualification for SMAW were not performed in accordance to AWS D1.1-77, Section 5, Part C, as required by CB-QCP-24, Pa ragraph 14.1... " The BA recommended disposition for this NCR was to accept all welds as welded and to requalify the 51 welders involved.
All but two of the 51 welders have been requalified.
BA NCR No.
3872, referencing Zack NCR No. ZC-CB-319, was still open because S&L has twice returned the NCR to BA for additional information.
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Zack NCR No. ZC-CB-325 dated December 12, 1980, identified the non-conformance as, " site fabricated ducts having closed corner welding.
(1) To-dr.te no Zack welders are qualified to perform butt welding.
(2) Fabrication Tickets as listed are lacking welders ID".
The recommended corrective action for this NCR was " qualify Zack welders who butt welded on site fabricated ducts." The corrective action taken was "six welders qualified and weldera ID cards noted."
During the review of Zack NCR No. ZC-CB-325, it was noted the NCR had been completed by the Zack Company on March 13, 1981, but the NCR had never been forwarded to BA for their review.
Further, the NCR did not reference any NCR tags for the fabricated ducts in question under NCR No. ZC-CB-325.
10 CFR 50, Appendix B, Criterion XV, (Nonconforming Materials, Parts, Components), states, in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include as appropriate, procedures for identification, documenta-tion, segregation, disposition, and notification to effected organiza-tions...."
Clinton Power Station Quality Assurance Manual Chapter 15 (Noncon-forming Materials Parts, or Comp ents) states in part, "IP and its contractors shall meet the requirements:
3.
Nonconforming items shall be clearly identified....
4.
Measures shall be established which control further use or installation of nonconforming items pending disposition...
5.
A technical re<iaw shall be performed to determine the disposi-tion of nonconforming items. Technics 1 review shall be reviewed by the same or equivalent organization which established the original design requirements....
8.
Procedures for control of nonconformances shall include measures for notification to affected organizations....
"
Clinton Power Station Quality Assurance Manual Chapter 16, (Correc-tive Action) states in part, "1P and its contractors shall meet the following requirements:
4.
Conditions adverse to quality shall be systematically analyzed for causes and referred to management for resolution....
Zack Company Procedure No. CB-FQCP-8, Revision 1 (Procedure for NCR)
states in part:
"5.1 Project Manager... responsible for resolution of nonconforming conditions relating to material or fabrication....
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5.2 Quality Control ;anager... responsible for inspection of material or equipment...to insure that proper controls are maintained to prevent material or equipment that is nonconforming from being incorporated into work... responsible for controlling non-conforming items until the non-conformance has been corrected or the item removed from the project..."
Contrary to the above, Zack NCR No. ZC-CB-325, prepared on December 12, 1980, pertained to the qualification of Zack welders performinF butt welds. This NCR was closed-out by the Zack Company on March 1.'d, 1981, and the NCR was never forwarded to BA for review. Addition-ally, the nonconforming duct pieces were never individually tagged to identify the items as being nonconforming.
Allegation No. 14 - Individual A was concerned with the sufficiency of the BA answer to a Zack Field Interference Notice (FIN) No. 2-678, dated January 19, 1981. The FIN dealt with slotted hole clips for auxiliary steel, spesifically " designed criteria gives no tolerance for deviations (reference hole size) or bolt-up.
Slotted holes for building expansion, contraction, or for ease of installation? If e:, what dimensional tolerances are allowed for hole size and bolt location?" The BA response was "there is no tolerance for vertical deviation. Slotted holes in horizontal direction of the clip angle are designed for heat expansion. There is no dimensonal (sic)
tolerances bolt location.
(Location of the bolts is for location of the holes and clip angles and aux steel)."
Individual A contended, if during installation the bolt was forced to one side of the clip hole, the purpose the elongated hole would be defeated and expansion movement in that direction would not be available.
Background - A review of IE Inspection Report No. 50-461/81-16, August 26, 1980, disclosed:
"10. HVAC Hanger Installations
"a.
The resident inspector performed a surveillance of the installation of safety related HVAC hangers in the 800'
le el of the Control Building. Four hanger installations were checked against the design drawings.
Installation attachment checks were made in the area of ceiling structural beam to ar, clips to auxiliary beam to HVAC hanger. The inspector ye.ed that the clip installation to auxiliary steel beam did not agree with Sargent and Lundy drawing M14-11108D Sht. 11, in that the clip bolting slots were vertical rather than horizontal.
The inspector notes however, that this nonconformance was detected and corrected
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by NCR 3030 on March 24, 1980. Continued investigation by I
the resident inspector revealed that the installations of three out of four hangers did not agree with the disposition of NCR 3030:
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(1) the bolts were not supported at the bottom of the vertical slots.
(2) the auxiliary steel was not furnished with horizontal slots at the opposite end from the vertically slotted clips.
" Auxiliary steel slots were at the wrong end or not present.
A later survey indicated that approximately 38 of 70 clip to auxiliary steel hangers in the Control Building had
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incorrect installations as noted above.
"This item is considered in noncompliance with the re-quirements of 10 CFR 50, Appendix B, Criterion V; Sargent and Lundy Design Drawing M14-111 Revision D; and Zack Procedure CB-QCP-15 Section 6.
(461/80-16-05)
"b.
Continuing with the surveillance of the afsrementioned
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HVAC hangers, the resident inspector revis,ed Zack QC records on the three subject hangers (C-6027, C-6030 and C-6083). There were ra sign offs by QC indicating that the slot modification (NCR 3030) was complete. The re-sponsible Zack inspector verbally verified he had bought
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off the incorrect installations and had so marked with yellow marker on the clip installation steel. The resident inspector noted that Hanger Installation (ZQF-07) and Repsir Job Ticket (ZQF-14) QC Inspection Reports had not been filled out and data recorded although the actual work had long since been completed on the three subject hangers.
The inspection reports did not reflect ongoing or completed work such as:
(1) Mill certification acceptance (2) Correct type and location (3) Dimensional check and control of hanger (4) Signoff of welds on ZQF-14 form configurat2on pictures (5) Forms ZQF-14 did not reflect the proper identification of each hanger member to account for the interchange-ability that had taken place on all three hangers.
"The inspection records did not reflect the as-built status of each hanger.
"This item is considered in noncompliance with the requirements of 10 CFR 50 Appendix B, Criterion X and Zack Procedure CB-QCP-15 Section 5.
(461/80-16-06)"
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Findings - On June 10, 1981, L. B. Browne, BA Subcontracts, pre.ided the following information:
The installation of slotted clips for IIVAC hangers was a problea at the Clinton site until initiation of Zack FIN No. 2-678, January 19, 1981. Many slotted hole clips were installed with slots running in the vertical direction, rather than horizontailly. The clips with the vertical holes have been identified and mar ed with NCR tags.
v The hangers installed with the vertical hole ss Id allow the hanger to move up and down. To eliminate this movement the bolt will be solidly welded to the slotted steel clip.
It was felt the temperature
variations outside the containment were not sufficiently different to be affected by the welding.
The installation of the slotted steel clips inside containment has not begun. Since there is a possibility of temperature fluctuation inside the containment, S&L has been notified of Individual A's concern as to location of the bolt in the slotted clip. A Field Change Request was sent to S&L on June 10, 1981, to address this matter. The NRC, Senior Resident Inspector - Clinton will follow this matter until it is resolved.
Allegation No. 15 - Individual A stated on April 21, 1981, the Zack Project Manager, Ron St.Onge, had issued a memorandum authorizing three Zack employees to sign FINS for field implementation.
In the memorandum St. Onge wrote " FIN's may be used to change or deviate from the requirements of Sargent and Lundy design, when signed by the Zack PM or designee."
Individual A contended St.Onge's memorandum was in conflict with S&L Specification No. K-2910, page 11, Paragraph e which states " deviation to seismic duct construction, hanging, attachment, or location of hangers must be documented and reported to the consulting engineers for review and confirmation of seismic integrity prior to installation."
Also, Individual A stated, that personnel designated by St. Onge in his April 1 memorandum were not qualified to sign these documents.
Findings - On June 11, 1981, L. B. Browne (BA Subcontracts) and Ron St.Onge (Zack Project Manager) provided the following information:
Prior to April 1981, a Field Interference Notice (FIN) was written whenever a problem with hanger installation was encountered. The process of preparing the FIN amounted to a Zack employee preparing the FIN, then forwarding the FIN to BA.
BA would make a determination to refer the FIN to S&L for an engineering determination. A Field Change Request (FCR) would be prepared from the information contained in the FIN in order to forward the information to S&L. Work would not proceed until the FCR was fully processed. This usually took 6-8 weeks to accomplish.
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Since April 1981, a FIN is written whenever a Zack foreman identifies a problem in the field. The FIN is given to a field engineer and the Zack Project Manager, and a sketch of the problem is made for review with IP.
Coordination between IP and Zack project management is accomplished twice daily to rectify FINS.
If the problem described in the FIN cannot be resolved during the daily conferences, a FCR is written and forwarded to S&L for review. The S&L review takes five to six weeks to complete. All FINS are maintained in a log, and field drawings are annotated with the FIN number. St.Onge continued, the FIN allows Zack, at their commercial risk, to continue production with the concurrence of BA and IP while waiting the S&L answer to the FCR generated as a result of the Zack FIN.
Zack Procedure No. CB-FQCP-5, Rev. 2, Procedure for Installation, was written by the Zack Company on April 3, 1981.
It was reviewed and approved by S&L on April 13, 1981, and approved for use by BA Quality Control on April 14, 1981, and forwarded to the Zack Company at the Clinton site on April 17, 1981.
Paragraph 7.2 of this procedure states, "during installation en-countered problems / questions, which cannot be adequately resolved by the (foreman) are documented on a " Field Interference Notice" (FIN)
... FIN's may be used to change or deviate from the requirements of Sargent and Lundy design, when signed by The Zack Company PM (Project Manager) or designee...."
St.Onge stated the three individuals he designated in his memorandum for signing FINS were the Zack Assistant Project Manager, the Site Superintendent, and the Assistant Site Superintendent.
St.Onge characterized these three positions as being a part of Zack site management. St.Onge estimated each of the three had in excess of twenty years experience in the fabrication of HVAC systems.
A review of Section 17 (Corrective Action) of the Zack Company Quality Assurance Manual dated July 11, 1980, disclosed:
" Procedures are established to assure that conditions adverse to quality are identified and corrected.
These procedures are outlined in the Zack Company Quality Control Procedure Manual (Plant / Field) and provide for:
"(1) Review of non-conforming condition by Project management..."
Further, S&L Engineering Change Notice (ECN) No. 2177, dated May 1, 1981, addressed FINS. The reason for change was "to delete... the requirements for the Consulting Engineer to review changes in seismic design before changes are made. This does not delete the requirements for S&L's review of the changes." The description of the change was
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to revise S&L Specification K-2910 to read "303.3e any deviation in l
seismic duct construction, hanging, attachment, or location of hangers l
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must be documented and reported to the Consulting Engineers for review and confinmation of seismic integrity," and "303.12b field interfaces involving seismically designed ductwork shall be reviewed by the Consulting Engineers." The Zack Company was authorized to proceed with this change on June 1, 1981.
Allegation No. 16 - Anchor Bolts installed during the period June 10 -
September 10, 1980, were not torque tested until December 1980; which did not meet the requirement to torque test the anchor bolts within twenty-one days of installation.
Findings - On June 9,1981, HVAC anchor bolt inspection records for the following areas were reviewed:
737' elevation, diesel generator building.
762' elevation, diesel generator building.
707.6' elevation, auxiliary building.
762' elevation, auxiliary building.
781' elevation, auxiliary building.
781' elevation, control building.
800' elevation, control building.
This review indicated all anchor bolts were torque tested within one to twenty-one days, usually within the first day, following installation.
The records did not indicate any over-torqueing. Torque on installed anchor bolts was an optimum 250 pounds, plus/minus twenty foot pounds, as specified in Table 38.8 of Zack Quality Control Procedure No. 12, Concrete Expansion Anchor Installation. Testing torque was a minimum 160' foot pounds, per table 38.10 of the Zack procedure.
On June 9, 1981, Thomas Packey, Zack QC Manager, provided the fol-lowing information:
The reinspection and torque testing of anchor bolts was done during November 1980 as a result of concerns of Zack QC inspectors. Zack NCR No. ZC-CB-314 was prepared to show that reinspection found two anchor bolts to be over-torqued. Packey stated this reinspection and torque testing was done outside of the twenty-one day period specified in the Zack Procedure. Packey stated the two identified bolts have been replaced.
Packey advised the specification for torque testing is open to inter-pretation; whether it requires one anchor bolt be tested per hanger, or one anchor bolt be torque tested per base plate.
(NOTE: Two base plates were used per hanger.) Packey stated he has advised his QC inspectors to torque test one bolt per base plate; therefore, two anchor bolts are torque tested per installed hanger instead of one.
Packey continued, QC anchor bolt inspection records do not identify the specific bolt tested.
Packey stated the anchor bolts were randomly selected for reinspection. Retesting was not done within the required twenty-one day time frame although original torque tests were conducted within the required time frame. Additionally, Packey stated the original tested bolt and the retested bolts were not necessarily the same.
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Ron St.Onge, Zack Project Manager, stated that correct torque on the anchor bolts is only guaranteed for the first twenty-one days.
After that time frame the natural movement of the nuts and bolts could result in a change in torque.
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Allegation No. 17 - Ace Hardware Stores were listed as an approved vendor for the Zack Company at the Clinton site.
Individual A questioned how the Zack Company could maintain the required material traceability on items purchased from a hardware store.
Findings - On June 3, 1981, Vincent Pemberton, Zack Assistant Pro-ject Manager at the Clinton site, stated that Ace Hardware Store at 114 North Madison Street, Clinton, Illinois, was indeed an authorized vendor for miscellaneous items. Pemberton characterized the mis-cellaneous items as necessary to perform the HVAC contract. Pemberton stated Zack Company did not purchase any nuclear grade materials from Ace Hardware Stores. Pemberton cited as examples of the mis-cellaneous items welders gloves, flashlight batteries, portable heaters, padlocks, and the office Christmas tree with decorations.
Allegation No. 18 - Individual A stated the griset plate on hangers C-5114 and C-5007 were installed across the jv int in the embed plate These items were identitied on two Zack NCRs (ZC-CB-340, January 15, 1981; ZC-CB-335, January 13, 1981). The recommended corrective action was to conduct a training session for the craft personnel and not to remove the gusset plates from crossing the joints of the embed plates.
Findings - A review of the two Zack NCRs disclosed hangers listed on Drawing No. M14-1060-1, installed at elevation 781' of the Control Building, were involved. The description of the nonconformance was listed as "the... gusset plates on hangers...are located across a joint in the embedded plate in the ceiling. No documentation was obtained to cover this condition." The recommended corrective action was, " conduct and document a training session with responsible traft Personnel covering the requirement of having approved documentation (FCR, ECN) prior to performing Safety-Related work. Use as-is aferred to Baldwin Associates." The corrective action taken was "this matter has been discussed during a S&L-Zack Engineering onsite meeting on January 29, 1981." On February 17, 1981, Zack NCRs were rejected by Zack QC as corrective action had not been taken. A review of Revision No. I to both Zack NCRs, dated February 23, 1981, stated under Cor-rective Action, "...this problem taken to S&L in January 1980, waiting disposition on FCR 7440."
BA Field Change Request (FCR) No. 7440, subject "HVAC burset Plates Spanning Joints in Embeds," was reviewed. The existing condition was listed as, "at present no criteria exists for gusset plates for HVAC hangers which, in their design locations span the joints of installed strip embeds." The BA change request was, " allow the gusset to be welded across the joint provided the following criteria is met.
(1) There does not exist a difference in elevation between the two plates.
(2) The gap between the embeds does not excecd 3/162."
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The Illinois Power Company engineering disposition was, " accept BA change request. Will not affect hanger integrity". This was cono rred with and accepted by S&L on March 3, 1981. The FCR was closed on March 4, 1981, and the Zack Company was notified that the change had been approved on March 5, 1981.
Allegation No. 19 - Individual A had the following questions con-cerning definitions utilized by S&L in documents pertaining to HVAC installations:
The S&L Mechanical Department Equipment List utilized the following terms in its Equipment List Quality Control codes glossary:
" Specification Title Describes Scope of S&L Specification.
Equip. CL.... Refers to equipment quality group A, B, C or D listed in SAR (Section 3.2.2)
"Seis.CL refers to safety category as listed below:
A-refers to safety category I SAR (Section 3.2.1.1)
N-refers to safety category II SAR (Section 3.2.1.2)"
Individual A stated the Mechanical Department Equipment List used the numbers 0 thru 3 under the "Eqpt CL," instead of the letters A, B, C and D; and used the letter
'I'
instead of the letter ' A' under the Seis CL."
Findings - A review of the Clinton Power Station Final Safety Analysis Report (FSAR) Table 3.2-1 disclosed the following information: The numbers 0 through 3 referred to the Safety Class as specified in the appropriate ASME section.
I and II were Seismic Category; where I was interchangeable with
'A' (applicable) and 'N' meant "not applicable."
The let*ers A, B, C and D were taken from the Quality Group Classifi-catioes specified in Regulatory Guide 1.26, " Quality Group Classifi-cations and Standards for Water-Steam-and Radioactive-Waste-Condrining Components of Nuclear Power Plants."
4.
Other Areas Investigated A.
On June 10, 1981, Warren Sobolewski, BA Lead Vendor Surveillance
.
Engineer, provided the following information:
He is responsible for vendor surveillance, both on and off site, including the Zack Company.
Until April 1981, his surveillance of the Zack Company consisted
,
[
of a random check to determine Zack's adherence to S&L's K-2910 l
Specification. Most of his inspections dealt with the review
'
of material and welder qualifications. Since April he has con-ducted random, bi-weekly inspections of Zack Company using a
- 26 -
checklist (Exhibit II).
In addition to the areas itemized on the checklist he performs a visual inspection of those hangers already inspected by Zack QC inspectors. He has never had to reject any hangers Zack QC had accepted. A full, indepth inspection of Zack's work is scheduled as Zack completes areas of the plant.
In conclusion, Sobolewski stated his random inspections of Zack work have not identified any problems areas.
B.
On May 29, 1981, while inspecting Zack HVAC installation on elevation 825' of the Control Building, an unplugged weld rod warmer was discovered. The weld rod issue slip indicated Welder R. Carrillo, Zack welder No. 10, was issued 3 pounds of 3/32" diameter, 7018 welding electrode. Examination of this electrode revealed it was still warm to the touch, although the weld warmer was unplugged.
Carrillo advised he had instructed his helper to plug in the rod warmer, and he (Carrillo) was not aware the warmer had been unplugged. Carrillo advised he had not used any of the electrode. The welding electrodes from Carrillo's rod warmer were returned to the weld rod issue room.
No other instances of unplugged Zack weld rod caddies were identified during the course of field observations by RIII personnel.
C.
While reviewing the S&L Specifiction No. K-2910 it was noted the HVAC Systems within the Containment Building were considered to be non-nuclear-safety-related. Specifically, Paragraph 114 of Specification No. K-2910 states:
" QUALITY VERIFICATION REQUIREMENTS (NON-NUCLEAR SAFETY-RELATED EQUIPMENT)"
"This article applies to the supply and installation of sheet metal ducts, built-up sheet metal plenums, duct work accessories and other indicated equipment; erection of stored equipment; and painting of duct welds of the following non-Nuclear Safety Related HVAC Systems:
k.
" Containment Building (VR)-inclu-ag Containment Building Supply Air Filter (1VR05F)."
On June 4 and 9, 1981, John S. Spencer, IP Director of Design Engineering, L. B. Browne (BA Subcontracts), Ron St.Onge Zack Project Manager, and Thomas Packey Zack QC Manager, provided the following information:
The Clinton Nuclear Power Plant Final Safety Analysis Report (FSAR) defined a nuclear safety-related system as system a
which is necessary for the safe shutdown of the facility and the maintenance of the facility in a safe shutdown mode. The FSAR identifies the HVAC system not necessary for the safe
- 27 -
shutdown or maintenance of safe shutdown of the facility.
Therefore, the FSAR considers the HVAC systems as being non-nuclear safety-related. S&L has designed the HVAC hangers to meet all dynamic and seismic loads and has termed the HVAC hangers within containment to be " seismic, nonsafety."
Only the following HVAC subsystems, or portions thereof, were considered to be nuclear safety related equipment in accordance with Paragraph 113 of S&L Specification No. K-2910:
VC-Control Room HVAC System (except for shower exhaust system and humidification system).
VD-Diesel Generator HVAC System (except for make-up system).
VG-Standby Gas Treatment System (erection of package filter units only).
VH-Shutdown Service Water Pump Room HVAC System.
VX-Essential Switchgear and Battery Room Heat Removal System.
VY-Emergency Core Cooling System Equipment Cooling System.
VF-Duct work between the secondary containment isolation dampers 1 VF04Y and 1 VF06Y.
Since the HVAC systems were considered to be seismic non-safety related, except those listed in the previous paragraph, the HVAC installations.ere not receiving any inspection by the Zack QC inspectors. However, a seismic non-safety related equipment inspection was being conducted by the Zack production foremen. The foremen were responsible for the inspections, as well as completion of the " Hanger Inspection Report (Non-Safety, Seismic)" (Exhibit III). A copy of the inspection report is retained in the hanger documentation package.
The mitter of seismic, non-safety HVAC hangers within the containment structure, as it pertains to Regulatory Guide 1.29,
" Seismic Design Classification," is being followed by the NRC Senior Resident Inspector - Clinton.
D.
On May 29, 1981, RIII personnel were informed that Zack fab-rication shop at the Clinton site was fabricating both safety related and seismic HVAC components at the Clinton site.
A review of S&L Specification No. K-2910, Paragraph 303.12, Duct Modifications, states:
- 28 -
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" Contractors will be permitted minor duct modifications in the field with approval of Purchaser's or Owner's representative for non-seismic ducts systems only provided such changes are consistent with the design intent of the drawing is reviewed by the Purchaser's representive or Consulting Engineers.... All field modification shall meet the design and quality standards of shop prepared duct work."
" Field interfaces seismically of designed duct work shall be reviewed by the Consulting Engineers before the work progresses."
John S. Spencer, IP Director of Design Engineering, advised Paragraph 303.12, Subparagraph A, applied only to non-safety-related H'.'AC work, and Sub-paragraph B was applicable to safety and seismic HVAC duct work.
Spencer stated the Zack Clinton fabrication shop was considered to be an extension of tha Zack plant in Chicago and, therefore, the Clinton fabricatior, shop was considered a plant. Spencer further advised the definition of " field" was, "all HVAC duct work within the power block."
The fabrication of safety-related and/or seismically qualified HVAC components at the Zack fabrication facility at the Clinton site is considered to be an item of noncompliance.
10 CFR 50, Appendix B, Criterion V (Instructions, Procedures, and Drawings),
states, in part, " activities affecting quality shall be prescribed by documented instructions procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings."
Clinton Power Station Quality Assurance Manual, Chapter V (Instructions, Procedures and Drawings), states, in part, "IP and its contractors shall meet the following requirements:
1.
Written procedures, instructions and drawings shall be developed and used, as appropriate, for activities affecting quality..."
S&L Specification K-2910, Paragraph 303.12a, states, in part,
" Duct Modifications... Contractor will be permitted minor duct modifications in the field with approval of Purchaser's or Owner's representative for non-seismic duct systems only pro-vided such changes are consistent with the design intent of the drawings as reviewed by the Purchaser's representative or Consulting Engineers...."
Contrary to the above the Zack Company fabricated duct pieces and hangers for safety-related and seismically qualified sys-tems at the Clinton Power Station fabrication shop.
During the course of the investigation, it was determined S&L Engineering Change Notice No. 702 was initiated on June 10, i
1981. This ECN revised Paragraph 303.12 of S&L Specification l
No. K-2910 to read, "303.12 Duct Modifications.
l l_
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.
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_
a.
Nuclear-Safety-Related Contractor will be permitted to modify nuclear-safety-re-lated duct systems in the field provided such modifications are reviewed and approved by the Owner and the Consulting
<
Engineer.
b.
Non-Nuclear-Safety Related (i) Field interferencre and modifications involving
" Seismic Category I" duct. systems shall be reviewed by the Consulting Engineer.
(ii) Minor field interferences and modifications involving
"non-Seismic Category I" duct systems may be made with the approval of the Purchaser's or Owner's representa-tive, provided such changes are consistent with the design intent. Contractor shall submit record drawings
[
for any such changes. All field modifications shall meet the design and quality standards of shop prepared work. Major field interferences and modifications shall be reviewed by the Consulting Engineer."
With respect to this item of noncompliance, the S&L i removed
.
the nonconforming condition and prevented its recurrence.
5.
Discussion with Plant Management On June 10, 1981, the results of this investigation were discussed with Messrs. G. M. Brashear (Manager, Clinton Site Activities) and j
J. O. McHood (Vice President-Project Manager) and the members of their staff indicated in paragraph one.
l Exhibits:
I Copy of Zack and Nonconformance Report No. ZC-CD-454, April 8.
1981 II Copy of Baldwin Associates Supplier Quality Control Surveillance Check Plan III Copy of Zack Hanger Inspection Report, i
Non-Safety; Seismic
.
.
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2C-CB-454 Sheet 1 of 3 j
1. REPORT NUMBER April b, 1981 2. DATE gjp,f g l
Hanger C-5123(FCk 8045,Sh. 4 of 5) Control EL 781'
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3. ITEM / PART NUMCER 4. AREA / BUILDING EDRAWING NUMBERe///J///
6.* OWNER FURNISHED MATERIAL OR EQUIPMENT O YES 00 NO 7.
O. LISTED 00 YEs O NO j
t 8. DESCRIPTION OF NON CONFORMANCE:._. Unauthorized change to Ff eld Change Request (FCR) #8045, Shut 4 of 5. (See attachments) was made by unknown party.
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- Tag #04597 9. REPORTED BY
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10. RECOMMENDED CORRECTIVE ACTION:
1.
Investigate circumstances surrounding this situat. ion and implement corrective action as deemed necessary to preclude repetition, j
2.
Quality Control to inspect hanger to verify acceptability to original FCR #8045.
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.L 11. OC INSPECTOR / DATE 12. OC MANAG Efl / DATE 13. ROJECTMGR./PLANTfUPT./D TE 14. CORRECTIVE ACTION TAKEN: __S/_* ff.___ AJ_ TACH //O 1.t3_7 o_P M f_Gu.fr_S 7 f 4 c 4*3 A.sLQ_
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4600 W.12TH PLACE * CHICAGO (CICERO)ILL So65o * 312/242 3434
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44o1 WESTERN * FLINT MICHIGAN 4:506 * 313/733-2040 NCR ZC-CB-454, ATTACHMEITT #1
,
.
the ZACK co.
CUSTOM METAL FABRICATION April 10, 1981
-
DATE:
April 8, 1981
TIME:
4:30 PM SUBJECT:
FCR-8045 " Whiting Out" of an Approved Document
... _.
Attendence:
Mr. John Neuhoff, Vince Pemberton, Allen Hinds, Craig Bracken, Bruce Overstreet, Jay Rogers and Ron St. Onge.
The meeting commenced with Ron St. Onge informing all present I
that an NCR had resulted from an " Approved for Construction" document being altered, " Whited Out" by an unknown party and that those in attendence are the supervisors for the area in which the incident had transpired.
f At that time, Mr. Allen Hinds stated that he has general foremen in that area who did, in fact, " white out" FCR 8045, only because an S&L representative and the Zack drafting department addressing the problem of a wrong dimension and that S&L representative would correct the dimension that day.
He also stated that he now knew better and that he must " cover his ass".
Mr. Craig Bracken and Bruce Overstreet stated that they did not i
tell anybody to change an FCR or any " approved document".
Roman Karpinski, as quoted by Allen Hinds and Bruce Overstreet, stated that he did make the mistake but forgot to correct the dimensions of the subject FCR and he (Roman Karpinski) would be back that day with the revised inform 9. tion.
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- FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY *
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NCR ZC-CB-454, ATTACHMENT #2
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Mr. Allen Hinds stated that someone told him from the day shift that Mr. Frank Lanham gave, or pointed out to Zack's QC depart-ment that FCR 8045 had been changed.
Zack QC took subject FCR, the one " whited out" back to the QCM of Zack.
Mr. Allen Hinds i
also stated he talked to Roman Karpinski, of S&L, in Mr. Karpinski's
,
office, but does not remember when he changed (whited out) subject FCR or on what day but it was sometime between April 1, 1981 and April 6, 1981.
Meeting was adjourned at this time to do more investigating.
'
Mr. Roman Karpinski was unavailable for comment, as he had left
-
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the site for the day.
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4,600 W.,12TH PLACE * CHICAGO (CICERO) ILL 606'50 * 312/242-3434 4401 WESTERN * FLINT MICHIGAN 4 506 * 313/733 2040 NCR ZC-CB-454, ATTACHMENT #3
the ZACK co.
CUSTOM METAL FABRICATION i
April 10, 1981
'
.
DATE:
April 9, 1981 TIME:
10:30 AM SUBJECT:
FCR'8045 7 FIN Z-1058, and NCR ZC-CB 454
-
" Whiting Out" of an approved for construction document.
Attendance:
Mr. Bennett Brwone (BA), Roman Karpinski (S&L),
Vince Pemberton and Ron St. Onge (ZACK).
Questions were presented concerning FCR 8045 and incorrect dimensions.
Roman Karpinski stated that a mistake was made on his part which would change on a new FCR or Zack would resubmit a new FIN, but did not tell anyone to change the contents of the subj ect FCR.
Mr. Bennett Browne told Mr. St. Onge to check with Zack's QA manager, informing him of the results.
The meeting was adjourned.
DATE:
April 9, 1981 TIME:
12:10 PM Ron St. Onge called the home office and conversed with Mr. Mike D' Haem, Zack's QA % nager.
Mr.
D' Haem said to check on any similar incidents of this nature, to conduct extensive training on " approved for construction" documents, to investigate the circumstances and to document and take corrective action.
. FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY *
- DEDICATED TO CLEANING AND CUSTOMlZlNG THE AIR OF THE WORLD +
.
- , 4600 W.12TH PLACE * CHICAGO (CICERO)ILL 60650 * 312/242 3434
'
,' 4401 WESTERN * FLINT MICHIGAN 48503 * 313/736 2040
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NCR ZC-CB-454, ATTACHMENT #4 the ZACK co.
CUSTOM METAL FABRICATION April 9, 1981 A meeting was held on April 9,1981, with the following people in attendance:
A. Hinds - General Foreman R. St. Onge -- Project Manager
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V. Pemberton - Assistant Proj ect Manager
-
D. Boyd - Assistant Site Superintendent T. Packy - Quality Control Manager R. Hines - Steward P. Klindworth - Quality Control Secretary i
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4401 WESTERN o FLINT MICHiG AN 4:506 e 313/732 2040
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NCR ZC-CB-454, ATTACHMENT #5 the co.
CUSTOM METAL FABRICATION April 13, 1981 MEETING OF APRIL 9,1981 - CLINTON PLMER STATION.- 2:00 p.m.
SUBJECT: Unauthorized change to Field Change Request (FCR) #8045 - Referenu !'? Zack company Nonconformance Report (NCR) ZC-CB-454, dated April 8, 1981.
.
.
. _ _ _
St. Onee Talked to Alan Hinds about NCR.
Had a meeting with Jay Rogers and Bob Casper.
Hinds Could I please explain what happened? We got the FCR back and started to do the work. We found that the dimensions were wrong from the top of the horizontal to the bottom'of the horizontal. The Drafting Department made the mistake.
It went on to S&L.
I talked to Roman.
He had not caught the mistake. He said there was no problem with hand-changing the mistake and asked to have a new FIN issued and I would hand-carry it.
I then went to the Drafting Department and they said they would issue a new FIN and hand-carry it through.
Everything was fine with Roman.
St. Onge We are going to have a training session on documents.
If the design is wrong, then build it wrorig. We can not just sit down and change or mark a document.
Looks like there was some lack of communication.
I can see what you did.
Asked Packy if there was any way that we can spot check to see if there has been any other changes made by people. How do I know that this is not going on all of the time?
Packy I do not know.
You just have to inform your people.
St. Onge Your Inspectors have not found any other changes?
Packy I have told my Inspectors that I want all of the documents they find that have a problem with them.
It got close to having one of my people threatened. When one of my Inspectors sees one of them, then I want them.
You better tell your people. We can not have that kind of thing going on out here.
Pemberton Asked Packy to tell him what his Inspector was threatened about.
Packy Was not about the same problem.
Pemberton If this is going on out in the field, then I want to know from now on.
St. Onge Told Hinds that if he sees a document that is wrong, then tell the l
Draf ting Department and we will get it changed.
+ FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY *
- DEDICATED TO CLEANING AND CUSTOMlZING THE AIR OF THE WORLD *
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NCR ZC-CB-454, ATTACHME?TT #7 the co.
CUSTOM METAL FABRICATION April 10, 1981
.
DATE:
April 9, 1981 TIME:
3:30 PM SUBJECT:
NCR ZC-CB-454 Correct.ive Action The site Zack Quality Control Manager was asked if his inspectors had found any other unauthorized documeaca in the field.
Mr. Packy (QCM), stated that at present FCR 8045 had been the only one.
In talking to all personnel, I believe there was a lack of communication in that the general foreman was indirectly notified by an S&L representative, that there was a mist: 1<e on FCR 8045 and that he would correct the dimensions that day and/or Zack drafting would submit a new FIN, which did in fact take place 6 days later.
The general foreman was informed, along with all general foremen and superintendents that under no circumstances can any " approved for construction" document be altered or changed in any way, including the " whiting out" for any reason, no matter who directed them to do so.
I believe that the parties involved as well as the remainder of Zacks su,ervision understand the seriousness of this NCR, and I do hope this incident will abate all future problems of this manner.
+ FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY +
- DEDICATED TO CLEANING AND CUSTOMlZING THE AIR OF THE WORLD +
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A55 O CE ATES SUPPLIER FUNCTION:
QUALITY CONTROL R _ Review SURVEILLANCE CHECK PLAN W = WITNESS
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SPEC.
DATE Clinton Power Station Unit 1 C-14081 K-2910 11-14-78
$UPPLIER MAT *L/ ITEM CLASS The Zack Company HVAC Work Safety Related
.
Surveillance Points Funct.
%
Surveillance Points Funct.
%
Surveillance Points Funct.
%
'3 5"*" Relief 25. ASME Code Stansping 1. Materials R
Rece pt OC 14. Heat Treatment 26. +++ Fer sonnel 2. Material R
100 R
ouai, fica,,ons C.,ti f ic at.on s 27. w. id"'s R
100 15. Final As sembi'
W
3. Material R
Test Reports cualific ation s 4. Start of 16. Leak Rate Testing 28 Mechanical operation
@
W
@
W 100 Test Fabrication 5. F.t Up or initial Assembly 17. Hydrostatic 29. Sequence Tests or Rough Machining W
Testing 6. Inproces s Welding or 18. Pneumatic 30. Electrical opeeotion intermediate Assembly W
Testing Tes 7. FinabhMin "dY * @
W/R 19. Performance 31. Document Control r.a u '
=9 R
Tuting Drawing Review R
D 8. Radiography 20. Final Cleaning 32. Other
W/R
- /
v 21. habe nsYons W/R
- 33, 9. Magnet c Particle
R
10. Liquid Penetrant 22. Preparation for Shipment
II. Ultrasonic 23. Shipment Release 35.
Required
_
12. Bend ng or Forming 24. ASME Code Report /s 36.
.
AC')lTION AL INSTRUCTIONS & REM ARKS Item 4 applies to start of job only.
Item 15 applies to installation only.
Items 7 and 21 - one hold point for shop work only.
No notification required for field installation.
All hold points require 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> advance notice.
NOTE: Vis.es to Supplier f acilities by the B A ovality Control Representatives are on a Surveillance basis, *o establish and maintain confidence that purchase order requirements are complied with during manuf acturing or f abrication. Fonc tions are indecored in percentage terms of intended surveillance, and may be increased as required. Functions listed in terms of percentage will reqv;re notification by the supplier; other items listed will be covered on a routine basis at the time of scheduled visits or as specified. Functions will require notification by the Supplier at least seventy-two (72) hours prior The purchaser reserves the rig t to waiver surveillance at the time h
to the start of specified tests and surveillance points.
of notification.
O REV EWED/INITI ALLY DATE REVIEWED / COMPLETED DATE
//-M-7$
i n
~ t4-APbRO E INITI LLY[
DATE APPROVED COMPLETED DATE x._.
_'
It IlA '1h a _-
l N1
.4 8.77) Jv.lls EXHIBIT 11 J
--
TERF ZACK CO.
HANGER INSPECTION REPORT (NON-SAFETY ----- SEISMIC)
____________________________________________________________________________
_-____-________________________________________________________________
_____
l. DRAWINGS:
HVAC PLAN:
REV:
HGR SCHEDULE:
REV:
2. BLDG, 3.ELEVAT10N
.4. SYSTEM 5. HANGER ID#
- CHECKLIST WELDER I.D.
ACCT, REJ. N/A DATE:
REMARKS:
b.
LOCATION / ELEVATION:
7.
PAINT CONDITION:
EEXYEIIIIIIIIII1IEIE II IRIIIIIXXXXX11EIIA i 8.
WELDS AND DIMENSIONS:
GUSSET PLATE
__.
CLIPS HANGER AT_TACHMF NT B.D. SUPPORT OTHER:
...
REMARKS:
FOREMAN:
/DATE:
_
ZQF-30 A exn1317 111