ML19340E830
| ML19340E830 | |
| Person / Time | |
|---|---|
| Issue date: | 09/25/1980 |
| From: | Barnes I, Oller R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19340E821 | List: |
| References | |
| REF-QA-99900028 NUDOCS 8101150910 | |
| Download: ML19340E830 (12) | |
Text
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h U.S. NUCLEAR REGUI.ATORY CG2 FISSION OFFICE OF INSPECTION AND ENFORCDIENT REGION IV Report No. 99900028/80-01 Program No.
51300 Company Tube Turns Division of Chemetron Corporation 2900 W. Broadway Loui.sville, Kentucky 40201 Inspection Conducted: August 25-29, 1980 Inspector:
O
[~M' R. E. Oiler, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch d fwo 9 ' 2. 5 - F O Approved by: M I. Barnes, Chief Date Components Section II~
Vendor Inspection Branch Summary Inspection on August 25-2'i,1980 (99900028/80-01)
Areas Inspected: Implementation of 10 CFR 50, Appendix 3 criteria requirements and other applicable requirements including: action on previous inspection findings, procurement control for commodity seamless fittings, manufacturing process control for seamless fittings, material identification and control for seamless fittings, and followup on a Tube Turns' Part 21 Report, dated July 3, 1980. The inseterion involved 29 inspector-hours on site.
Result: In the five (5) areas inspected, no deviations were identified in four (4) areas.
The following deviation was identified in the remaining area:
Deviation From Commitment Contrary to Criterion WI of Appendix 3 to 10 CFR 50, and the QA Manual pro-cedure TT-22-237, Revision 2, paragraphs 7.2 and 7.5, a Corrective Actica Request was not issued by Tube Turns to Ar=co National Supply Company to preclude repetition of the mixup of unqualified J-55 alloy material with WF-02 carbon steel material ussd for manufacture of A-234, WP3 fittings.
(See Notice of Deviation).
910 Ua1150
,8
2 DETAILS SECTION A.
Persons Contacted R. Burke, Buyer D. Carson, Foreman - Raw Material Receiving and Disbursement E. Elliot, Chief Chemist
- L. Hayden, Vice President - Engineering T. Gallalee, QA Engineer M. Hansen, Manager - Metallurgy M. Justice, Sr. Production Control Coordinator
- B.
J. Prather, Supervisor - Quality Product Control
- J.
Seay, Manager - Quality G. Sweazy, Contract Administrator W. Trent, Supervisor - Metallurgy
- S.
Vitatoe, Quality Assurance Manager R. Wheeler, Sr. Inspector
- Attended the exit meeting.
B.
Action on Previous Inscection Findings 1.
(Closed) Deviation (Report 79-02): Failure to control the welding procedure TT-12-0114, Revision 0, parameters of amperage and welding gas flow while welding of a guard pipe subassembly for Order Item 070195-001. The inspector found that in accordance with Tube Turns response letter dated 1-31-80, corrective action consisted of a written notice to all welders in the believs expansion joint depart-nent, requiring that welding procedures must be followed. To verify that the notice was read, all welders and foremen signed it, as required. Preventive action was accomplished by performing several special audits in the expansion joint department during February, 1980, while production welding was in process.
2.
(0 pen) Unresolved Item (Report 79-02): Corrective action requests for nonconformities were beirg generated in a different manner than that described in procedure TT-22-327 of the QA Manual.
The QC Mannger indicated he wished to continue *.nis practice and would revise the QA manual to provide for this activity.
The inspector fcund that a duf t revision of this Cr manual procedure to provide the needed measures, had been generated, but not yet accepted by the Authorized Inspection Agency and the ASME.
3 C.
Procurement Control For Commodity Seamless Fittings Material 1.
Obj ectives The objectives of this area of the inspection were to verify that:
a.
A written system has been established to assure that procurement control is performed in accordance with NRC and the manufac-curer's QA program requirements.
b.
Written procedures have been prepared and approved by the company to provide control of procurement documents, source selection and product acceptance for materials.
c.
Procurement documents suitably include or reference necessary requirements for procurement of materials.
d.
The procurement documents, to the extent necessary, require subcontractors to provide a quality assurance program approp-riate to their activities.
e.
Evaluation of subcontractors include such :neasures as: on-site survey of subcontractor's capabilities including a quality assurance program; or acceptance based on a subcontractor being a holder of a valid ASME N type symbol authorization applicable to the items or services to be supplied; or a history of sub-contractors' performance, and evaluation of other applicable requirements specific to the purchaser.
The results of product acceptance activities are documented and reviewed for acceptability by responsible personnel.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the following QA Manual procedures:
(1)
TT-22-323, Revision 2 " Procurement Control."
(2)
TT-22-328, Revision 3, paragraph 3.0 " Vendor Surveys."
(3) TT-22-352, Revision 0, " Procurement, Receiving - Storage -
Inspection."
4 b.
Review of " Raw Material Planning Sheets."
c.
Review of " Traveling" purchase requisitions for A-106, Grade B, carbon steel piping of 2.875 X.226 inch wall ordered to TTL Specifications MS-dO4, covering piping ordered from Armco and from US Steel.
d.
Review of ITL Purchase Order No. 33092, dated 11-27-79, to Armco and TTL Pu. chase Order No. 34541 to US Steel. Both of these P.O.s were for 2.375 inch 0.D. by 0.226 fcch wall carbon steel pipe identified on the above traveling r.quisition.
e.
Review of TTL's " Approved Vendor List" dated 7-1-80.
f.
Review of records of surveys tf the following: Armco's steel plant located in Ambridge, PA. surveyed in April,1979 and April,1980, and of the US Steel plant located in Lorain, Ohio, surveyed in April, 1980.
g.
Observation of the raw material piping in the receiving and storage yard for identification markings and storage segregation.
h.
Review of Purchase Orders, Raw Material Receiving Inspection Reports, and the Raw Material Lot Number Log Book, maintained in the Receiving Inspection Offices.
i.
Observation of the test equipment in use in the storage yard and at a cutoff saw for alloy identification; consisting of a Hentschell Model MP-04 Eddy Current Tester and a portable Quantotest No. 36000 spectograph.
J.
Review of the TTL Draft procedures for using the Eddy Current Tester.
k.
Review of the TTL approved procedure No. TT-17-172, Revision 1,
" Receiving Inspection of Raw Materials."
1.
Review of laboratory records of spectrographic tests for alloy identification of materials in the storage yard during the period of January through May, 1950.
m.
Review of a TTL memorandum dated May 20, 1980, with an attached plan for 100% raw material inspection.
5 n.
Review of TTL's standard documencs for receiving inspection, which were used on Armco 2.750 "O.D. X.226" wall pipe, TTL Lot No. W-8806.
The documents consisted of completed Raw Material Receiving Inspection Reports and Receiving Notices.
o.
Discussions with cognizant personnel in production control, pur-chasing, receiving inspection and quality assurance departments.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Other findings - Comments (1) TTL purchases the seamless pipe raw material, used for manufacture of stock fittings in sizes from less than 1" 0.D. through 26" 0.D.
These purchases are from raw materials manufacturers listed on the TTL " Approved Vecdcr List." This list is updated by the QA Department on a quarterly basis.
(2) Purchase Orders for raw seamless pipe material contained quality requirements which reference TTL's Materials Speci-fication MS-804, and also required that the materials supplied must be manufactured under the Quality System which was surveyed by TTL on a specific date. TTL also requires that a Certified Material Test Report of chemical and physical tests of the material must be furnished. The materials are normally identified by the manufacturers heat numbers and his proprietary alloy number such as WF-02 as the equivalent of A-106 Gr. B material.
(3) TTL's standard raw material inspection method is delineated in the QA Manual and procedure TT-17-172, Revision 1.
It includes visual examination of the piping for physical damage, marking identification and dimensions. The certi-fied material test reports received with the material are reviewed for acceptance by the quality control departuent.
Each different heat and size of material is then assigned a unique TTL lot number. This is the manner in which the Lot W-8806 material from Armco was received and inspected.
(4) It was established that some alloy identification testing j
by TTL using a portable spectograph in the yard, was per-j formed during the period of December, 1979, through June, 1
1980.
l 6
This testing was ineffective due to the large volume of fitting material being processed, and the yard testing was discontinued in June, 1980.
In place of the yard
- testing, a trial program to 100% test all pipe material at the cutoff saws using an Eddy current Tester, is being initiated. -This program was started in August, 1980 at a large diameter pipe saw for training purposes. This program is not yet an approved formal TTL procedure.
D.
Manufacturing Process Control For Commodity Seamless Fittings 1.
Objectives The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QA Manual, NRC and applicable code requirements.
a.
A written system has been established to assure that manufacturing processes are controlled in accordance with applicable require-
- ments, b.
Measures have been established and implemented to control the manufacturing processes by use of process sheets, travelers, checklists or procedures.
The process sheets, travelers, checklists or shop procedures c.
used included:
the document numbers and revisions to which the processes, inspections or tests conformed; the results of completion of the specific operations, and the signature, initials or stamp of the manufacturer's respons.ible representative and 'date were shown for operations completed.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the QA Manual,Section IV " Seamless", Procedure TT 353, Revision 0 " Process Control" b.
Observations of manufacturing activities, and review of con-trolling " Move Tickets" in the following shop areas:
(1) Saw Cut-off Department (2) Elbow Automatic Hot Forming (3) Elbow Resizing
7 (4) Elbow Weld Bevel Machining (5) Elbow - Final Inspection (6) Tae - Hot Forming (7) Fittings Final Inspection (Other Than Elbows)
(8) Painting c.
Review in the QC Release Area, of an Inspection Characteristic Checkoff sheet for elbows in Lot W-9025 assigned to IIL customer P.O. 062630, Item 012 SA-234, WPB, ASME Section III, Class 3.
d.
Observation of the above elbows for identification.
e.
Review of the completed Short Form A (shipper) for the above elbows.
f.
Review of records in the completed documentation package for TT Order 063765 for fittings, to verify that the Short Form A (shipper) had Item 2 fittings, Lot Nos. W-7988 and W-8717 and Item 3 fittings, Lot Nos. W-8906 and W-8907 assigned, repre-senting documentation at the point of dedication to SA-L
- WPS, ASME Section III, Class 3 fittings.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Other Findings - Comments In revier hg the manufacturing process, it was established that commodity seamless ASTM A-234 WP3 fittings are manufactured and stored in the warehouse as inventory controlled items.
Any number of a specific lot of fitting maybe selected to fill an ASME See 1on III Class 2, 3, or MC customer order.
The contract Administrator prepares a Short Form A (shipper) for selection, inspection, and marking to meet ASME III requirements for parts to Class 2, 3, or MC.
When these activities are complete, the fittings lot numbers are assigned and the Short Form A (shipper) is signed and dated by QC/ Product control, and becomes the QA Release for shipment.
E.
Material Identification and Control for Commodity Seanless Fittings 1.
Objectives i
8 The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QA Manual NRC and Code Requirements.
a.
A written system has been established to assure that material identification and control is performed in accordance with applicable requirements.
b.
Documented measures have been used for identification and control of materials.
c.
Identification is maintained either on the item or on records traceable to the item.
d.
Permanent or temporary identification marks or numbers are legible and are not detrimental to the item quality or inter-fere with the function of the item.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the QA Manual Procedure TT-22-353, " Process Control."
b.
Observation in the receiving and storage yard of TIL Lot numbers assigned to raw piping materials for seamless fittings.
c.
Observation of permanent identification metal stamping, at the cutoff saws, on each piece of tubing cut for forming and process-ing.
d.
Observation of permanent identification stamping of fittings in the final inspection area and examination of the identity on the accompanying " Move Tickets."
e.
Observation of permanent identification stamping and vibro etch identification on fittings dedicated to ASME Code Section III use.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
F.
Reported 10 CFR Part 21 Deficiency 1.
Intrnduction j
9 The Tube Turns Division of Chemetron plant (TTL) management located in Louisville, Kentucky, submitted a 10 CFR Part 21 Report, dated July 3,1980, to the USNRC, OIE, Region 4, Vendor Inspection Branch, regarding ASTM A-234-WPB pipe fittings manufactured at the Tube Turns Louisville plant, which contained an improper J55 Grade drill casing material. TTL investigation verified that two (2) nuclear shipments had been sade from the affected heat of saterial. The nuclear cus-toners were contacted immediately by telephone with a followup letter dated May 21, 1980. As of the Part 21 Report date of July 3, 1980, both orders had been shipped from the nuclear job sites, but had not been received by TTL. IrL will advise the NRC at the time the items are received, tested and dispositioned.
2.
Objectives The objectives of this follow-up inspection were to ascertain that the reporting organization had implemented the requirements of 10 CFR Part 21 and had:
a.
Met the requirements for reporting the deficiency.
1 Performedasafetyhazardhvaluationofthecondition,andmade i
b.
an assessment of generic implications.
I c.
Assigned responsibility and implemented a plan of corrective action.
d.
Reviewed preventive action measures.
3.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Discussicas with cognizant personnel.
b.
Review of TTL's Part 21 Report letter dated July 3, 1980, to verify the following:
(1) The reporting requirements of 10 CFR Part 21 were met.
(2) The deficiency was properly evaluated and an assessment of generic implications was made.
(3) Adequate corrective action was brplemented in a timely manner.
c.
Review of Procedure TT-21-002, Revision 1 " Tube Turns Procedure to Report Deviations In Accordance with 10 CFR Part 21."
10 d.
Review of TTL's Durchase Order No. 33092, dated 11-30-79 et, Armco National SuppAy Co., Ambridge, Pa. for the original pipe material ordered to Armco specification WF-02, from which the t
A-234 WPB, commodity fittings were to be manufactuted.
e.
Review of a TTL internal memorandum dated 5-15-80, from the Manager of Metallurgy to the Manager of Quality, advising him that Armco called to report that unqualified J-55 drill casing material had been mixed in with WF-02 material in Armco Heat No. 200245 ordered for manufacture of A-234 kPB fittings.
f.
Review of the notes of a meeting on 5-21-80 between TTL and ARMCO personnel, wherein a plan of testing of contaminated Lot W-8806 fittings was agreed on.
J g.
Review of Armco's " Reports of Tests" dated 2-28-80 and 4-4-80 for TTL's Order No. 33092 covering the material supplied in Armco heat 200245.
h.
Review of Armco's Specification WF-02/WF-22LS " Seamless Steel Pipe for Manufacture of Welding Fittings."
i.
Review of TTL's computer printout for April and May 1980 covering all customers to whom TTL 1 ad supplied carbon steel fittings during the time period when possitla unqualified fitting may have been shipped.
I j.
Review of TTL's Detailed Analysis Reports to their customers Hube, Inc. and Chicago Tube & Irca Co., showing fittings certified to SA-234 WPB, ASME Section III, Class 2 requirements.
k.
Review of TTL's recall notice letters dated 5-23-80 to %be, Inc.
and to Chicago Tube & Iron Co. advising them of possible unqualified materials in their fittings order marked with Lot No. W-8806 and asking them to segregate and return fittings containing this lot number and also notify their customers who may have received this material. Also advising that if any fittings have been installed to advise TTL of the quantity, geographical location and name of 1
person acquainted with their location.
1.
Review of draf t memorandums dated May 23, and 28,1980, by the TTL contract Administrator indicating that Hube had located their order of 19 pieces at the Duke Power Company's Catawba sit and
)
that the pieces were segregated.
m.
Discussions with ITL's Contract M ministrator that indicated that he was verbally advised by Hube and Chicago Tube and Iron, that Hube's order was furnished for the Catawba site and the Chicago Tube and Iron Order was furnished for the Clinton, Illinois site.
11 3.
Findings a.
Deviation From Commitment See Notice of Deviation.
Discussions with TTL management concerning the mixup of Armco J-55 alloy material with the Armco WF-02 carbon steel material, established that, no documented formal action had been take; by TTL to require that Armco National Supply Company provided a written commitment to provide corrective action to preclude repetition of the mixup. Armco is one of two major suppliers to TTL of raw pipe for use in manufacture of A-234, WPB fitting.
Review of purchase records verified that additional purchases of Armco WF-02 material have been made since the purchase in November, 1979, of the contaminated material.
b.
Unresolved Items None.
c.
Other Findings - Comments (1) TTL's Part 21 Report failed to include TTL's evaluation which showed the deviatica could create a substantial safety hazard. Due to this omiss an, TTL was requested by the NRC inspector to submit a ca rrected Part 21 Report.
(2) Independent verification by the NRC inspector of the actions by TTL in connection with the material mixup, indicate that responsibility was assigned to the Manager of Quality and appropriate corrective action, in the form of a recall /
verification program for all of the contaminated L9t W-8806 fittings, was initiated.
(3) All of the fittings shipped to the two (2) ASME Code Section III customers (19 pieces to Hube, Inc. and 22 pieces to Chicago Tube and Iron Co.) were accounted for and segregated.
(4) TTL has reviewed preventive measures and has initiated in their plant an alloy identification program by Eddy Current Testing of raw material pipes as tney are processed through the cutoff saw department.
The program is in an initial training status, and is now being implemented only one saw for 8" 0.D. pipe. The program is not in an approved TTL procedure.
Previous attempts to test 100% of the raw
12 I
material piping in the storage yard, using a portable spec-trograph, proved to be inadequate due to the large volume of raw material piping being processed. As a result, these tests were discontinued.
U.S. Steel, a supplier to TTL of raw pipe material has instituted 100% spark testing of their pipe, but no information was available on any Armco testing.
(5) The subject Lot W-8806 of contamined piping consisted of 2.750 "0D X.226" wall piping, was not tested by spectro-graph during the test period of January through June, 1980.
This material received only the standard receiving inspec-tion as identified in TTL's ASME accepted QA Manual pro-cedure TT-22-352 in for seamless fittings.
G.
Exit Interview 1.
The inspector act with management representatives, denoted in paragraph A, at the conclusion of the inspection on August 29, 1980.
2.
The following subjects were discussed:
a.
Areas inspected.
b.
Status of corrective and preventive actions for the previously identified deviation and unresolved item.
c.
Findings identified in this report.
3.
Management's comments related to the above items.
The Manager-Quality indicated that he thought the entire pipe fittings industry should be required to perform 100% alloy verification on materials used for seamless fittings.
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