ML19289E019
| ML19289E019 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1978 |
| From: | Ellershaw L, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19289E012 | List: |
| References | |
| REF-QA-99900349 NUDOCS 7903210357 | |
| Download: ML19289E019 (16) | |
Text
@
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF ITISPECTIO:; AND ENFORCEMENT REGION IV Report No.
999C0349/73-01 Program No. 44070 Company:
Corner and Lada Ccmpany, Inc.
~
1341 Elm.vood Avenue Cranston, Rhode Island 02910 Inspection Condycted:
November 13-17, 1978 I
~b f
3 G
1 v '_ M ou niv M^,/ /
Inspectors:
-t c
Li E. Ellersnaw, Contractor Inspector
/De.te Vendor Inspection Branch h' b w w a;df
/A/Il7:~
D. M. Hunnicutt, Chief, ComponentsSection II,
'Date Vendor Inspection Branch Approved by: A 2' c m,-yam-
/J/?/ ??
D. M. Hunnicutt, Chief, Components Section 11
'Date Vendor Inspe ion Branch Sunmary Inspection conducted November 13-17, 1978, following an Initial Management Meeting (99900349/73-01)
Areas Inscected:
Impiementation of 10 CFR 50 Appendix B Criteria, and applicable codes and standards including:
control of nonconforming parts and material; corrective action; material identification and control; manufacturing process control <, nondestructive examination personnel qualifications; nondestructive Examinations; weld material control; joint fitup and welding; weld procedure specification; welder qualifications; product acceptance, and design process management, design verfication and design document control. The inspection involved fifty-six (56) inspector hours on site.
Resul ts :
In the twelve (12) areas inspected, eleven (11) deviations from commitment and one (1) unresolved item were identified.
Deviations:
Control of Monconforming Parts and Material-Purchased nonconforming material reports and their respective hold tags were incorrectly cross 3
7903210 referenced to each other (Enclosure Item A), nonconforming material reports did not exhibit full material Review Board concurrence and certain nonconformities were not addressed in the disposition (Enclosure Item B.1.,
B.2. and B.3.); Corrective Action - written reports based on quarterly reviews of nonconforming material reports were not submitted to higher management, and there has been no follow-up corrective actions taken (Enclosure Item C.1. and C.2.); The QA Manual does not address the corrective action requirements of Criterion XVI of Appendix B to 10 CFR 50 as being extended to the performance of subcontractor's corrective action measures, as required by ASME Code, flCA-4134.16 (Enclosure Item D); Material Iden-tification and Control - certain material / parts whose identity had been lost, were not subsequently identified as being nonconforming ( Enclosure Item E); Manufacturing Process Control - certain parts were identified in a location contrary to the drawing requirements and which, when assembled, would preclude the ability to ascertain material and heat codes (Enclosure Item F); tiondestructive Examination Personnel Qualifications - two (2) Level II Examiners were certified as being qualified even though they had no training and experience, and they had not taken a specific written examination (Enclosure Item G); fiondestructive Examination - The Visual Examination procedure had not been demonstrated to the satisfaction of the Authorized fiuclear Inspector (Enclosure Item H); Weld material Cantol - low hydrogen electrodes were not stored in a heat, holding oven after their containers had been opened (Enclosure Item I); Joint Fitup and Welding - the heat code of welding material being used and as recorded on the traveler did not agree with the heat code as recorded on the weld material requisition, and just one of two joints had been stamped with the welders identifying stamp (Enclosure Item J.1. and J.2), tack welds were not being removed or prepared and visually examined prior to incorporation into the final welds (Enclosure Item X).
Unresolved Items: Joint Fitup and Welding - welders are not being monitored to assure compliance with the requirements of the Weld Procedure Specification (DetailsSection I, paragraph J.3.b.).
DetailsSection I (Prepared by L. E. Ellershaw)
A.
Persons Contacted W. T. Allen III - Project Supervision R. A. Dionne - Plant Manager J. Falcone - Plant Superintendent D. Hanrahan - Quality Control Inspector A. W. Rogers - Manager, Quality Assurance R. Shea - Quality Control Clerk B.
Initial Manacement Meetina (IMM)
The objectives of the IMM were to meet with Corner and Lada Comoany, Inc.
(C&L) management and establish lines of communication, acquaint them with the tiRC organization, its policies and Vendor Inspection Program, explain our inspection basis and manner of reporting, and explain the issuance and contents of the White Book.
The NRC inspectors were informed of the following:
a.
C&L holds the following ASME Certificates:
(1)
Certificate of Authorization, "NPT" 1776 for Class 1, 2, 3 and MC Component Supports with an expiration date of June 10, 1980 (2) Quality System Certificate (Materials), N-1780, material supplier of carbon, low alloy and stainless steel and nickel base alloy materials.
Qualification of material manufacturers is included, with an expiration date June 10, 1980.
b.
CSL's overall manufacturing commitment to the commercial nuclear industry is 30%.
C.
Control of Nonconforming Material and Parts 1.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for the control of nonconforming material and parts in accordance with the QA Manual and applicable NRC and ASt:E Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section QN-10.0, Revision 0, "Nonconformities."
b.
Review of the following Standard Specifications:
(1) ST-642, Revision 0, "flonconformities, Identification Procedure, In-Housa Material and Activities."
(2) ST-643, Revision 0, "Nonconformities, Disposition Procedure, In-House Material and Activities."
(3) ST-644, Revision 0, "Nonconfornities, Identification and Disposition Procedure, Vendor Material and Services."
Review of open Purchased Nonconforming Material Reports (PNMR).
c.
d.
Review of open and closed Nonconformirg Material Reports (PNMR).
e.
Observation of nonconforming material / parts segregated ii.
the Hold area, for identification.
f.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitments (1) See Enclosure, Item A.
(2) See Enclosure, Items B.1., B.2., B.3.
Item B.2.
NMR No. 726 noted the following discrepany:
"The cotter pin hole is drilled out 9/32." The drawing calls for a 7/32" hole."
The comment in the disposition was:
" Drawing is in errnr-Pins manufactured to the correct jig."
Corrective Action was recommended and the cisposition was signed off by Quality Assurance as being complete on August 10, 1978.
There was no MRB concurrence and a corrective action request was not issued. However, a document / drawing
~5-change request was issued on August 10, 1978 requesting
" Change Pin Hole size to 9/32" to agree with the drill jig."
As of November 17, 1973, no action had been taken regarding the drawing change request and there has been no follow-up.
Item B.3.-
NMR No. 715 noted two (2) discrepancies:
" Heat Number not visible after forming.
'D' dimension not neld to toicrance." The disposition stated:
" Rework
-Re-mark heat number on opposite side of old marks in pieces." However, nothin; in the disposition dealt with the fact that the
'D' d'.cension was out of tolerance.
It could not be determined whether or not the 'D' dimension had even been corrected.
There was no evidence to indicate that the inadvertent use of these nonconforning parts had been prevented.
b.
Unresolved Item None.
D.
Corrective Action 1.
Objecti ves_
The objectives of this area of the inspection were to verify that C&L had implemented the requirements for documenting and determining the cause of nonconformances and that corrective action was taken to prevent recurrence in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section QM-10.1, Revision 0, " Corrective Action.
b.
Review af Standard Specification ST-645, Revision 0, " Corrective Action Procedure."
Review the seven (7) closed Corrective Action Requests, dated c.
from August 26, 1977 throrgh July 24, 1978.
d.
Discussions with cognizant personnel.
Fil stg1 3.
d a.
Deviation From Commitments (1) See Enclosure, Item C.
(2) See Enclosure, Item D.
b.
Unresolved Item None.
E.
Material Identification and Control 1.
Obiectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for the control and identification of material / parts in accordance with the QA Manual and applicable
- !RC and ASME Code requirements.
2.
Metnod_of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section QN-4.1, Revision 0, " Material Identification."
b.
Review of the following Standard Specification:
(1)
ST-202, Revision 0, " Material Identification Procedure, "on-Traceable."
(2) ST-202, Revision 0. " Material Identification Procedure, Traceable Material."
Observation of parts in process and in storage.
c.
d.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Ccmmitments See Enclosure, Item E.
b.
Unresolved Item None.
F.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requiremants for the control of manufacturing process in accordance with the QA Manual and applicable NRC and ASMt Code requirements.
2.
Method of Accomplishement The preceding objectives were accomplished by:
a.
Review of QA Manual Section QM-4.0, Revision 0, " Process Con trol. "
b.
Observation of in-proces. manufacturing operations and a review of associated drawings, procedures and travelers.
c.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitments See Enclosure, Item F.
Unresolved Item c
None.
G.
Nondestructive Examination (NDE) Personnel Qualifications 1.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for the qualification and certification of NDE personnel in accordance with the QA Manual and applicable NRC and ASME Code requriements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section QN-6.0, Revision 0, " Nondestructive Examina tion. "
b.
Review of NDE personnel qualification records.
c.
Review of SNT-TC-1A,1975, " Personnel Qualification and Certification in Mondestructive Testing."
d.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitments See Enclosure, Item G.
b.
Unresolved Item 4
None.
H.
Nondestructive Examination (Visual Examination) 1.
Objectives The objectives of this area of the inspection were to verif;i that C&L had implemented the requirements for the control of nondestructive examination (NDE) in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishmen_t_
The preceding objectives were accomplished by:
a.
Review of QA Manual Section QN-6.0, Revision 0, " Nondestructive Examinatica."
b.
Review the following Procedures:
(1) ST-305, Revision 0, " Visual Examination Procedure, Materials and Welds."
(2) ST-306, Revision 0, " Visual Examinatica Interpretation mid Acceptance."
c.
Review NDE Procedure qualifications.
d.
Discussions with cognizant personnel.
3.
Findings
-9_
a.
Deviatie From C - i'ments See E.icloc a, Item H.
e.
Unresolved Item t'one.
I.
Weld Material Contro_1 1.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for the control of weld material in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Manual, Section QN-5.0, Revision 0, " Welding."
a.
b.
Observation of weld material storage area.
Observation of weld material storage ovens used for low c.
hydrogen electrodes.
d.
Review of weld material certifications.
e.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Cnmmitments See Enclosure, Item I.
b.
Unresolved Item None.
J.
Joint Fitup and Welding 1.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for the control of in-process welding in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment e
The preceding objectives were accomplished by:
a.
Review of QA Manual, Sectinn QN-5.0. Revision 0, " Welding."
b.
Review of weld material requisition slips, c.
Observation of in-process Shielded Metal Arc Welding (SMAW) and verification of weld procedure specification requirements.
d.
Observation of welded joint identifications.
e.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitment (1) See Enclosure, Item J.1. and J.2.
(2) See Enclosure, Item K.
b.
Unresolved Item ASME Code Section III, Subsection NCA-4134.2, requires that the quality assurance organization review and monitor all activities concerned with the Quality Assurance Program.
At the present time, C&L does not monitor the activities of their welders. There is no means to verify whether or not a welder is complying with the requirements of the weld procedure specification. The power sources that were being used in the performance of shielded metal arc welding do not have ammeters and voltmeters, and tnere is no tong meter.
C&L did take the necessary steps to procure a tong meter and discussions took place relative to establishing methods for implementing a monitoring program.
This item shall be reviewed during the next scheduled inspection.
K.
Weld Procedure Soecifications (WPSJ_
1.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for the control and qualfication of WPSs in accordance with the QA Manual and applicable NRC and ASME Code requirements-2.
Method of Acccmplishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section QN-5.0, Revision 0, " Welding."
b.
Review of WPSs and their respective procedure qualification records (PQRs).
c.
Verification that the WPSs included all required essential and non-essential variables.
d.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitment None.
b.
Unresolved Item None.
L.
Welder Quafifications 1.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for qualification of welders in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section QN-5.0, Revision 0, " Welding."
4 b.
Review of welder qualification records.
c.
A review of the Welder's Log which is the record for the qualification status.
d.
Discussions with cognizant personnel.
3.
_ Findings a.
Deviation From Commitments None.
b.
Unresolved Item None.
M.
Product Acceptance _
l.
Objectives The objectives of this area of the inspection were to verify that C&L had implemented the requirements for product acceptance when material is received from subcontractors, in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
Review of QA Manual, Section QN-3.1, Revision 0, " Receiving a.
Inspection."
b.
Review of Standard Specification ST-602, Revision 2, " Receiving Inspection Procedure."
Observation of receiving inspection activities during receipt c.
of in-coming material.
d.
Review of shipping documents, niaterial certifications, purchase orders, and the daily receiving log.
e.
Discussions with cognizant personnel.
3, Findings a.
Deviation From Commitments None.
b.
Unresolved Item None.
N.
Exit Interview A meeting was held at the conclusion of this inspection on November 17, 1978 with the following management representatives:
W. T. Allen III - Project Supervisor R. A. Dionne - Plant Manager J. W. Fenny - Engineering Manager N. R. Kirby - Executive Secretary W. Lada - Vice President A. W. Rogers - Manager, Quality Assurance The scope and findings of this inspection were summarized. Managemen t acknowledged the statements relative to the findings.
. DetailsSection II (Prepared ty D. M. Hunnicutt)
A.
Persons Contacted J. W. Fenny, Manager of Engineering W. T. Allen, Project Supervisor B.
Desian Process Management, Design Verification and Design Document Control 1.
Objectives The objectives of this area of the inspection were to:
a.
Ascertain that procedures have been prepared and approved by Corner and Lada Co., Inc., to prescribe systems for design process management, design verification and design document control which are consistent with the commitments of their QA Program.
b.
Determine that the design process procedures, the design verification procedures and the design document control procedures are properly and effectively implemented by Corner and Lada Co., Inc.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section QN-2.0, Revision 0, dated April 27, 1977, entitled, " Order Entry and Design Control."
b.
Review of Speci#ication No.13-PM-209, " Price and Schedule Data for Nuclear Pipe Supports... Quality Class Q."
c.
Review of Bechtel Power Corporation Proposal and Supplement to Proposal, dated October 26, 1977, including procedures and verification documents.
d.
Review of the following Special Engineering Instructions:
(1) Magnetic Particle Inspection (Dry Method Using Prod) for welds - Memo #1095-1228, June 28, 1978, Revision 1.
. (2)
Liquid Penetrant Inspection Procedure for weld Inspection
- Memo 1034-122, Revision 1, June 28, 1978.
(3) Hot Dip Galvanzing i;o. ST-447, Revision 1, June 28,1978.
(4) Zinc Plating (Electro Galvanzing) No. ST-448, June 2E, 1978.
(5) Packaging and Package Marking No. ST-496, June 28,197t'.
(6) Weld Material Distribution Procedure No. ST-549, June 28, 1978.
(7) QW-482 Welding Procedure Specification (,;PS) example.
(8) QW-483 Procedure Qualification Record (PQR).
(9) Heat treatment - General No. ST-351, Revision 0, May 10, 1977.
(10) Surface Preparatior solvent cleaning No. ST-450, Revision 0, March 29, 1976.
e.
Review of Engineering ad Drafting - Standards, Procedures, Instructions, No. ST-1(, Revision 0, July 28,1977.
f.
Review of Control of Contract Drawings and Specifications, No. ST-140, Revision 0, August 10, 1977.
g.
Review of Engineered Hanger Design - Design, Aporoval, Shop Release Procedure, No. ST-141, Revision 0, October 28, 1977.
h.
Review of Product Design, No. ST-145, September 26, 1977.
i.
Review of Hanger Design and Analysis - Engineering Department Analytical Group, No. ST-146, September 26, 1977.
j.
Review of Drawings, No. ST-150, September 19, 1977.
K.
Review of (Drawing Records) Progress Report by Hanger Number (Job No. 78001).
1.
Review of Component Support Materials (Bulk) -release to production package.
. m.
Review of seven (7) shop travelers and enclosed records of hangers under fabrication and on pallets for final inspection.
n.
Discussions with cognizant personnel.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Corner and Lada Co., Inc., (C&L) have performed very little actual design work to date.
C&L have demonstrated that with their engineering staff and the available approved procadures the required design functions to meet hanger and pipe support criteria can be adequately accomplished.
.