ML19344F349
| ML19344F349 | |
| Person / Time | |
|---|---|
| Issue date: | 07/10/1980 |
| From: | Oller R, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19344F346 | List: |
| References | |
| REF-QA-99900726 NUDOCS 8009150173 | |
| Download: ML19344F349 (12) | |
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U.S. NUCLEAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ETICRCE..ENT REGION IV Report. No. 99900.726/80-01 Program No. 51400 Company:
Bostrom-Bergen Metal Products Cocpany 4700 Coliseum Way Oakland, California 94601 Inspection at: Oakland, California Inspection Condteted:
June 24-27, 1980
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Inspectors: !
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/-6V R. E. Oller, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch A
Approved by:
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Uldis Potapovs, acting Ch ief Date ComponentsSection II l
Vendor Inspection Branch Summarv Inspection on June 24-27, 1980 (99900726/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B criteria and other applicable NRC requirements including: initial management meeting, QA program rev;ew, review of vendor activities, welding control and followup to assess the cause, corrective action and generic considerations relative to 10 CFR 30.55(e) reported deficiency involving inadequate records of welder certifi-cations for welders who worked on structural steel for the South Texas Project.
The inspection involved 20 inspector-hours on site.
Results:
In the five (5) areas inspected, no deviations or unresolved items were identified. The following was found:
Action with Regard to the Recorted 10 CFR 50.55(e) Deficiency Prior to January 1,1980, a weakness in the implementation of the Bostrom-Bergen Metal Product (BBMP) QA Program existed.
Although all of the welders were qualified in accordance with AWS D1.1 Structural Welding Code, some had not been certified by BBMP. Also, readily available records to show welder enom 373
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2 qualification continuity had not been generated from information contained in production records. Adequate corrective action was implemented during the period of January through June 1980.
Also suitable measures to preven,'
recurrenc'e are now available. The above condition was applicable to work for the South Texas Project I and 2 and the WPPSS Haniford Units 1 and 4.
(Details Section, paragraph G.3.b).
3 DETAILS SECTION A.
Persons' Contacted
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- T. Devlin, Production Manager
- D. Johnson, Vice President - General Manager I. Lawson, Shop Superintendent P. McCrary, QA Technician K. McMahon,_ Inspection Supervisor H. Plough, Assistant Shop Superintendent
- D. Rigge, QA Manager
- S. Webb, Assistant QA Manager
- 3. Whitely, QA Technician
- Attended the Exit Meeting.
B.
Preinspection Meeting A preinspection meeting was held on June 24, 1980, with the QA Manager.
The NRC inspector discussed the areas to be inspected and the purpose and objectives of the inspection.
In addition, a time was set for post inspection exit interview.
C.
Initial Management Meeting 1.
Objectives The objectives of the Initial Management Meeting were to meet with Plant Management to establish communications, discuss the purpose and intent of the Vendor Inspection Branch (VIB) direct inspection program and to learn the basic functions of the plant.
2.
Method of Accomplishment The preceding objectives _were accomplished by the inspector's pre-sentation and the resulting discussions covering the following:
a.
NRC policies and organization.
b.
VIB program objectives and how these objectives are to be accomplished.
c.
VIB organization.
d.
Inspection areas to be covered.
r e
4 e.
Basic taspection techniques of the VIB.
f.
Enforcement procedures applicable to vendors, including Section 206 of the Energy Reorganization Act of 1974 and Part 21 of 10 CFR.
h.
The White Book.
i.
Questions.
3.
Results No unusual questions or discussions developed or occurred during the initial management meeting.
D.
QA Program Review 1.
Objectives The objectives of this area of the inspection were to verify that the QA Program has been documented in writing to provide measures to control quality related activities. Also, ta ascertain whether the program provides for the following:
(a) Management's policy statements concerning QA.
(b) The QA organization structured to achieve organizational independence and freedom to:
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(1)
Identify quality problems.
(2)
Initiate appropriate resolutions.
(3) Verify corrective actions.
(c) The QA staff with the authority, and access to a level of management that ensuret effective implementation of the QA Program elements, and enforcement of positive and timely corrective action.
(d) The duties, responsibilities and the authority of the QA staff are clearly delineated in writing.
(e) Detailed written procedures, properly reviewed and approved, are available to control quality activities.
(f) A training and indoctrination program to provide and maintain the proficiency of:
5 (1), Personnel performing quality activities.
(2) Personnel verifying that quality activities are properly performed.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the entire QA Manual (dated 3-21-76) Sections 1 through 18, with special emphasis on the policy statement, QA organization, assignment of responsibility and authority and QA reporting; to verify that the QA Program was designed to meet the requirements of Appendix B to 10 CFR 50 and ANSI standard N45.2.
b.
Review of ten (10) Quality Assurance Procedures generic to the QA Program and specific for implementing the QA Manual on nuclear contract job No. 2444.
c.
Review of several nonconformance reports.
d.
Review of records of training sessions (dated 3-21-80) held at the Oakland plant.
e.
Discussions with cognizant personnel.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Other Findings - Comments Discussions with the QA Manager established that the QA Manual is being revised to reflect the current orgaaization structure and other needed changes.
E.
Review of tJendor's Activities 1.
Objective The objective of this area of the inspection was to assess the vendor's activities and their impact on future NRC inspections.
2.
Method of Accomplishment The preceding objective was accomplished by:
6 a.
Discussions-with cognizant personnel, b.
Review of specifications for three (3) active contracts covering miscellaneous' structural steel _and iron for nuclear sites including some safety related items.
c.
Review of approved Quality Assurcnce Instruction' No. Q1-15.1
'Rev. O, " Notification of Defect or Nonconformance (10 CFR Part 21)."
d.
Observed that 'the above Part 21 procedure was properly posted.
e.
Observed various areas of the Oakland shop including receiving inspection, saw cutoff, fitup, welding, weld material storage cage and small conconforming items segregation cage.
3.
Findinas a.
Within this area of the inspection,' no deviattons or unresolved items were identified.
b.
Other Findinas - Comments (1) BBMP fabricates structural steel / miscellaneous iron items for both nuclear and nonnuclear applications.
(2) BBMP has production plants in Oakland and Fresno, California.
Items for nuclear application are fabricated at both plants.
The Fresno plant facilities are newer than those at Oakland and.the lifting devices have greater capacity than those at Oakland. This inspection was limited to the Oakland plant.
-(3) There are three (3) active contracts at BBMP for material for' nuclear sites. These are BBMP Job No. 2424, Brown and Root (B&R) South Texas Projects; Job 2444, Atkinson and Wright - Schuchart - Harbon (AWSH), WPPSS, l'andford Units 1 and 4 and Job No. 2447, Boecon Corporation, WPPSS, Handtord Untis 1 and 4.
The work on these contracts is
- being done at both plants.
_(4) BRMP has completed Job 2311 (about two (2) years ago) for Pacific Gas and Electric's Diablo Canyon nuclear power station'and still supplies some material on an occasional change order.'
W ldina Control-
'F.-
e 1.
. The objectives of this area of the inspection were'to verify that
'the following activities were controlled in accordance-with appli-
- cable NRC and code-requirements:
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7 a.
A system has been established to assure that welding is controlled in accordance with the applicable codes.
b.
The Welding Procedure Specifications (WPS) used in production welding are prepared, qualified and controlled in accordance with the QA program.
c.
That welding materials purchase, acceptance, storage, issuance and use are controlled and documented in accordance with detailed procedures.
l d.
The welders are qualified in accordance with the applicable code.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of the QA Manual Section 9, paragraph 4.1 " Welding".
a.
b.
Review of 20 (AWS D1.1 Structural Welding Code type) welding procedures and the related procedure qualification records, use to control the welding on BBMP Job No. 2444.
Review of procedure No. QAP-2, Revision. 3 " Welding Control c.
Procedure."
l d.
Observation of the welding material locked cage facilities l
Lacluding hot rod holding issue ovens, and hot rod baking ovens.
Review of records of " Weld Material Control" issue / return slips l
e.
l for the period of April 14-18, 1980, to determine completeness of data entries and authori:stions, f.
Observation of the shop welding equipment.
I g.
Review of records of inspection travelers to determine that welders, weld saterials and dates of welding were properly entered.
l h.
-Observation of the current list (dated 4-9-30) of qualified welders posted in the shop office.
i.
Review of records of (AWS DI.1 Structural Welding Code) manual welder's and weld tacker's qualifications, certifications and welding continuity records for four (4) tackers and 11 welders
8 who worked on BBMP Job No. 2424 (South Texas Projects), and four (4) tackers and sir (6) welders who worked on BBMP Job No. 2444 (WPPSS Handford Units 1 and 4).
J.
Review'of the AWS DI.1-1976 " Structural Welding Code."
k.
Discussions with cognizant personnel.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Other Findings - Comments See paragraph G.3.b. for findings related to welding control.
G.
Follovup on the 10 CFR 50.55(e) Report Concerning Possible Welder Certification Deficiencies at Bostrom-Bergen Metal Products Company 1.
Introduction On December 4, 1979 by verbal report, and on January 4,1980 by written report, the NRC was notified by Houston Lighting and Power Ccapany pursuant to 10 CFR 50.55(e), of a breakdown in the quality assurance program of Brown and Root, Inc. at the South Texas Project Unit 1 and 2, in that an audit of Category I miscellaneous steel suppliers' QA Program showed that the supplier, Bostrom-Bergen Metal Products (BBMP) was unable to provide adequate documentation of welder certifications.
This deficiency had not previously been reported by Brown and Root's vendor surveillance personnel even though the activity had been audited. As a result of the EL&P report, this followup inspection was performed.
2.
Objectives The objectives of this area of the inspection were to ascertain that BBMP had:
a.
Performed an evaluation of the condition relative to possible deficiencies in welder certifications for the personnel who worked on the South Texas Project Units 1 and 2, including making and assessment of generic considerations related to other nuclear power plant sites.
b.
Assigned responsibility and implemented a plan of corrective
- action, c.
Initiated preventive action within the QA Program.
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9 2.
Method of Accomplishment The precedina, objectives were accomplished by:
a.
Discussions with cognizant personnel, b.
Review of the NRC Daily Report on 12-5-79 and of the Houston Lighting and Power Company's final 10 CFR 50.55(e) construction deficiency report, dated January 4, 1980, to the NRC.
c.
Review of the AWS D1.1-1976 " Structural Welding Code."
d.
Review of Brown and Root, Inc., South Texas Project (STP)
Specification No. 3AC10SS026, Revisions E and F, P. O. No.
35-1107-6008, BBMP Job No. 2424.
e.
Review of 11 Inspection Travelers in the record packages for the Seismic Class 1 vertical and lateral reactor vessel steel supports furnished for the STP Units 1 and 2, to identify the welders and weld tackers and dates on which the welding was performed.
f.
Review of the original qualification records required by the AWS D1.1 Code and Revision E of the B&R specification for the 11 welders and four (4) weld tackers who performed the work on the STP reactor vessel steel supports. Also, review of backfit certification records for these welders and tackers, as required by Revision F of the B&R specification.
g.
Review of welder, continuity records, recently generated by BBMP's research of production records, to verify that velder's qualifications were not expired during the welding on the STP reactor vessel supports.
h.
Review of Specification No. 9779-208, Revision 0 for 3BMP Job No. 2447 froci Boccan Corporation, covering furnishing of mis-cellaneous steel items, United Engineers and Constructors (UEC)
Quality Class G, for WPPSS Handford Units 1 and 4.
i.
Review of Specification No. 9779-253, for BBMP Job No. 2444 from Atkinson and Wright - Schuchart - Harbon (AWSH) contractors, covering furnishing of miscellaneous steel items to UEC Quality Class 1, for WPPSS Handford Units 1 and 4.
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j.
Review of AWS D1.1 Code required qualification records and UE&C specification required certification records for six (6) welders and four (4) weld tackers who performed work on fabricated steel items for Job No. 2444.
10 k.
Review of BBMP's "Stop Work" order letter dated 12/11/79 to AWSH, covering the Handford Units 1 and 4 work at the Oakland and Fresno plants.
3.
Findings a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
Other Findings - Comments
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(1) Review of the circumstances surrounding the deficiency identified by Houston Lighting and Power Company regarding BBMP's inability to furnish adequate documentation of welder certifications prior to December 4, 1979, established that the report was partially true. The deficiency involved two (2) conditions as follows:
(a) Although all of the welders who worked on the reactor vessel support steel for the South Texas Projects (STE) were qualified in accordance with the AWS DI.1 Code, for some of the welders BBMP, did not have documented certification as required by Revision F to Brown and Root (B&R) Specification No. 3A010SS026. This speci-fication revision was issued to BBMP on 1-22-79 after completion of the welding of the reactor vessel support steel. Revision E of the specification in effect during the above fabrication period did not require welder certifications.
(b) The AWS D1.1 Code, Part C, paragraph 5.30 " Period of Effectiveness" provides that a welder's qualification remains in effect indefinitely unless, ".
. the welder is not engaged in a given process of welding for which he is qualified for a period exceeding six sonths.
Prior to January 1,1980, BBMP had not generated welder continuity records from Produc-tion records to provide readily available records to show that their welder's qualifications were in accor-dance with the AWS D1.1 Structural Welding Code. The needed information was contained in production records.
(2) Review of records and discussions verified that adequate corrective action was implemented.
Also, that the above problems and corrective action applied to the work performed for the WPPSS Handford Units 1 and 4 under the AWSH contract Job No. 2444.
The BBMP management indicated th'ey had notified their customer AWSH and had sent a "Stop Work" i.
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11 order dated 12-13-79, to AWSH covering the WPPSS work in both the Oakland and Fresno plants, but had not filed a 10 CFR Part 21 Report with the NRC.
With regard to pre-ventive action, the BBMP management indicated that they will continue to maintain their velder's qualificatica continuity records and will include a review of welder certifications in their internal audit program.
(3) The corrective action implemented by BBMP included the following actions:
(a) BBMP implemented a "Stop Work" order on the Brown and Root (B&R) work at both the Oakland and Fresno plants when they received the B&R "Stop Work" order for the Oakland plant in October 1979. On December 13, 1979, BBMP also initiated a "Stop Work" order for the AWSH work at both the Oakland and Fresno plants.
The "Stop Work" order was sent to their customer, AWSH, and an internal "Stop Work" order to both plants, was issued with the condition for start work being, that all welders and tackers to be used, must have current certifications. The order was lifted on the B&R work at the Fresno plant only, and for the AWSH work at both the Oakland and Fresno plants on May 28, 1980.
Currently all of the remaining B&R work has been trans-ferred to the Fresno plant.
(b) Between January and June,1980, BBMP researched their production records and generated welder qualification continuity records for all welders who had worked on the STP reactor vessel support steel and for those who are working on the WPPSS miscellaneous structural steel. Also during this period, BBMP issued backfit welder certifications for those welders and tackers for whom original certifications were missing.
- Then, to provide additional assurance of current welder capabilities, BBMP retested, requalified, and recerti-fled all of their welders during the period of January throughto June 1980.
(4)
In conclusion, it appears that a weakness existed in the BBMP QA Program prior to October 1979, with regard to certification of welders and maintenance of welder quali-fication continuity records.
This condition appears to have been adequately corrected and there are now adequate acasures to prevent recurrence of the condition. All BBMP welder's records are controlled from Oakland.
A
e 12 H.
Exit Interview 1.
The inspector met with the persons denoted in paragraph A, at the conclusion of the inspection on June 27, 1980.
2.
The following subjects were discussed.
a.
Areas inspected.
b.
The inspection findings identified in this report.
3.
Management's questions related to clarification of the above items.
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