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{{#Wiki_filter:. (.. qq.? ( .'44 g ' ' ' ,s TYRONE C. FAHNER L ~ PRINCIPAL STAFFi ATTORNEY GENERM. STATE or stuNoes D/RA l -f 'N ygggpHong 160 NORTH LA S ALLC STpgg? p tss asco CHICAGO 6C601 dI gp k 0 l I September 7, 1982 1 1 Mt I F L James G. Keppler, Regional Administrator. ~ U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Re: La Salle Nuclear Station, Dkt. No. 50-373 and 50-374 /
Dear Mr. Keppler:
+ At a meeting in your office on July 19, 1982, you aksed Common-wealth Edison to provide a complete list of the results of de-tailed calculations on rebar damage for 647 concrete. elements affecting Unit 1 operation at La Salle. The public record which grew out of the request of this office under 10 C.F.R. 2.206 contained the results of onl~y 9 of the 647 structural elements, although Edison represented in its Final Report of May 7, 1982 that calculations o'f 'all of the elements had been made and that all had shown design margins greater than 1.0. Because 4 of the 9 calculations shown on Table 2.7-1 of Edison's Final Report show margins of less than 1.1 after accounting -for rebar damage, it is particularly important that a complete public record on the rebar damage be available. It was our understanding that Table.2.7-1.would be expanded to include all the concrete elements for which detailed calculations were made.. ~ Although I have personally inquired of your staff on more than one occasion concerning the whereabouts of the additional rebar damage information, I have been unable to learn whether or not Edison has submitted it. Please advise when copies of the complete results will be provided to the public. Also, at a meeting in your office on August 24, 1982, you stated that copies of Edison's final proposal for the scope and procedure of the independent HVAC review would be provided to all interested parties after approval by the office of Nuclear Reactor Regulation. Edison was expected to submit its final proposal, incorporating changes suggested by you and_your staff, shortly after the August 24 meeting. We have not yet received the copies promised, and are therefore without any information as to the final scope of the HVAC review. tbr have we received 8305190379 830311 S(p e PDR FOIA -12~N PRENDER82-366 PDR
e ...g ( ( s. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission Page 2 Soote aber 7, 1982 a response to our comments on the Request for Proposal, although it was apparent from your remarks of August 24 that some of our suggestions were shared by you and your staff. Kindly provide copies of the approved plan for the Braun study at your earliest convenience. As the target date for completion of the study,is only'a week away, may I also'take this opportunity to request notification as to its findings and disposition as early as possible. We appreciate the courtesy and cooperation extended'to this office by Region III concerning the many last minute problems associated wit.h ele' licensing of La Salle Unit 1. I trust that the lines of communication will continue to be open during the next round of decision-making. The information is requested to enable our consultant to consider the safety implications of the problems you are investigating and the decisions being made by the NRC. Very truly yours, D ,k)., 0-~ JU ITH S. GOODIE Assistant Attorney General Environmental Control Division 188 West Randolph, Suite 2315 Chicago, IL 60601 (312-793-2491) JSG:bp cc: Harold Denton, Director of Nuclear Reactor Regulation C. E. Norelius, NRC Region III." Thomas Devine i
7{'. PER HOEARD/ GAP CHROUGLOGY l 1920's Zack founded- ,l, 1970's Zack bid on nuclear picnts
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'N 8/80 Harry Geyer replaced as QC Mgr. by C. Richards. 11/05/80 Bechtel letter stop sending nonconforming material, t 11/6/80 1 % P.O.'s have stickers added to them. 1/6/81 many letters to vendors sent from Zack. 2/4/81 Delta Screw P0.0 C-4286 j, .. (:.. 6/81 Calkins hired as QA Manager. 8/26/81 Delta Screw P.O. C-4473 '[ 8/28/81 ' Letter to Midland from Zack. //W 9.bt;f IdG <) 8/31/81 C. DeZutel formally qualified (one hour training). 9/81 Ca m ns contacts Howard. 9/11/81 Delta Screw P.O. C-4484'. ~ y 9/14/81-Internal Zack audit identifies vender audit problem. 9/22/81 Edgecomb Matert.ls rated.macceptable vendor. 9/23/81 Audit of Ed ecomb Matericls. 6 9/22/81 Nonconformance Report on Delta Screw P.O. C-4484 p 9/25/81 Letter from Zack to LaSalle. (Calkins). 9 bt!d %C 9/25/81 CorrectiveActionReport(CAR)toClinton. l 10/81 HowardacceptsQAE/Documentposition. l 10/2/81 McGrane findings -Clinton purchases.' l 10/9/81 LETTERS TO UTILITIES FROM CALKDIS. 10/9/81 Ceco sends surveillance team to Zack. 10/19/81 HowardstartswoUtatZack. Late /81 Howard and six others hired by Zack. 10/23/81 Thirdinterimreport(?). 10/30/t@- f.emo: LaSalle super, advises of 10/23/81 report. 11/2/81 letter from CZCo (Donaldson) need additional information. 11/3/81 Meeting at Midland. (response to 10/23/81 letter). 2
r 11/5/81 Howarda(int:dsuper.cfdocumenta. 11/11/81 Howard posts notice re: alterations of documents. 11/12/81 C. Z. DeZutel letter to J. Cook, CPCo (misleading). 11/18/81 McGrane has Howard & Marello sign training form. 11/30/81 Calkins gives Howard series of documents, including 10/9/81 letter, 10/23/81 letter. 12/14/81 CalkinstellsHowardC.Z.DeZeut1wantstofifeS.Marello. 12/17/81 Eichsteadt BetsDeltaScrewtoagreetoreturnofmaterial(??). 12/21/81 Bechtel letter to Zack. 12/22/81 " Change number 1" to Delta S=rew p0. bichsteadtclosesoutNneonformanceonDeltaScrew. 12/30/81 1/4/82 Howard talks 'to Calkins re: 12/21/81 letter. 1/4/82 R. Perry, Howard, Calkirs meet re: 4threport(LaSalle). 1/5/82 "harrassment" begins. 1/ /82 Howard reads minutes of 11/3/81 meeting at Midland. 1/23/82 Request to U.S. Steel for certifications, test reports. 1//82 LaSalle sends sureveillance report to Zack. 1/22/82 Letter sent to RMC requesting certificate of confor::umce (Copied). 2/ /82 Howard, Perry discuss seriousness of QA breakdown. 2/'/82 Audit by Shaeffer(Zack) identifies Seas Corp. doc. problem. ss e. m. 2/ /82 R. Perry contacts.Shewski with concerns. 2/ 6-18/82 Baldwin audit of Zack 2/19/82 R. Perry's contract expim s, he is let go. ,2/22/82 Howard called to president's office and is questioned. 1 1 th.fa t - se eu. I 2/82 Delta Screw reinstated to AVL listing. ? 9.\\
- 3/1/81 Updated report for LaSalle complied by Howard.
O '3/1/82 A.Crawley(Clinton)broughtintohelp,staysoneweek. h 3/4/82 Calkins shows Howard collection of Zack documents. 3/4/82 CalkinscontactshI. Leonard. 3/8/82 l Calkins meets C. DeZuetel, gets $12,000 raise. 3/8/82 S. Marello hospitalized. 3/13/82 Howard caets with Calkins. 7 ---.._--.a.. _ ~.
F. sf -,f v. avwaa:u Au,6umuu lor position at nia.tand.(with & Le: nard)'. 4/5/82 Me:tinghemna)Howardaskedto1:adEDDRwritingBroup. -f. 4/7/82 Howard discussion with Calkina. 4/13/82 Howard calls H. Leonard. N y 4/15/82 x Howard calls H. Leonard, makes formal. allegation. 4/1h/82 Calkins calls Heward into office says he has betrayed him. ~ p 4/17/82 Leonard &2othersauditZack,questionpersonnel.(2 days). 4/21/82 Leonard meets with Howard at Holiday Inn. 4/27/82 Basia6a gives QA trafning. e 4/28/82 CAN20wri.tten,trainingneeded. 4/29/82 Howard responds to CAR //20 with training outline. 4/30/82 Howard Fired.
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GOVERNMENT ACCOUNTADlLITY PROJECT Institute for Policy Studies (202)234 9382 1901 ove Sueel N.W.. Washington. D.'C. 20009 -N November 19, 1982 Mr. Harold P. Denton Office of Nuclear Reactor Regulation Div sion of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Re: C. F. Braun: Independent Audit LaSalle Nuclear Power Plant
Dear Mr. Denton:
On November 9,1982, we received a four-volume report of the Braun Company's independent analysis of the heating, venti-C. F. at the LaSalle lation, air conditioning system.(HVAC system) Nuclear Power Station in Illinoisx Although we are submitting a report to your office today, we must We have detailed our - point out that it is an interim. report. concerns, and in some cases provided some detailed justification We were not able to get back to the two Zack for those concerns. witnesses, Mr. Terry Howard.and Ms. Sharon Marello, whose input into this analysis is critical. Our. final report will contain those comments, a review of the. Como'nwealth Edison Company's ;(CECO) 'f ailures to identify the NVAC quality assurance violations, and a more detailed justification of the items'high1ighted in thistreport. Within the cont' ext of this. interim report by the Government-Accountability Project (GAP) is a. request for further specific information not included or discovered within the C. F. Braun four-volume repcet. It is imperative for our consultants and staff to have this ~ additional infomation in. order to draw final conclusions about the reliability of this audit and the implications of the flndings af fecting the safety of the public and. of the site employees. .~ Our interim findings follow. ~ b -,108 h L % ......-..-u. ........a ....._..a_- ~. _.
} ~ ~ ~ nr. lisrold P. Denton e The C r. Braun independent review of the safety-related and REismic Nsupported.non-safety related systems at LaSalle comes to' the conclu-r s' ion that the " installation by the. Eack Company is in accordance with
- the'sargent and Lundy design and the' workmanship to be of adequate I
.,uality." ~ The Government Accountability. Project takes general and specific exception to this conclusion. We urge the' Nuclear Regulatcry Com-mission Office of Nuclear Reactor Regulation to take a number of { specific actions in response to this audit: 1) Require Commonwealth Edison to recall C.F. Braunt modify ,,7 the terms of' Brawn's contract, and continue with the probe at the La Salle facility. The' scope of their work simply include a more comprehensive view of the safety systems must at the facility. 2) Restricti the La Salle license to 48% power until there is further work done to identify the Zack errors that need to be repaired, replaced, or reworked, and that required repairs are completed. 3) Request Region III to consider enforcement action against Commonwealth Edison ifor falling to adequately supervise sub-contractor in their procurement and supply of materials to be used in the plant. 4) Assign a Region IV vendor inspector to audit / review these conclusions in the. light of specific C.F. Braun statements .. e c. ; :.. which disregard _1_0 CFR 5 0, Appendix E."' z.a........... - " '5) ' % consider this letter as an interim report, prepared for l @,u;. jbyour -immediate : consideration..p;Aanore. detailed analysis..of.the cc..:.m.L: specific zack allegations; as.'Qe.ll 'as.rgview by Zack iNuclear
- l t witnesses will follow.this ieport by t few days.
r: '~~ ' As you are aware we afre spec'ifically engaged in both the Midland and the Zimmer plants--both of which.are in intensely active stages of NRC involvement. At the William H. Zimmer plant in Ohio, GAP Legal Director Tom Devine is worAing with officers of the Federal Bureau of Investigations to review the massive amounts of evidence and talk to nuclear witnesses. Bis comprehensive, knowledge of the Zimmer plant is irreplacable and therefore he has been delayed from finishing the significant portions of his analysis. Bil e Carde, Director of GAPS Citizens Clinic has been equally as invbived in the investigation of the Midland Nuclear. Plant in Midland, l Michigan. The GAP investigation on the Midland site has become a full scale probe, and as you are, aware this is a particularly critical time period at Midland. l 7.., ....._..._,..,,...,....:_...m... t -4.c.c:m:.4.
&LN Mr. Harold P. Denton November 19, 1982 Further, those experts and analysts who-have made their services available to GAP have had only a very short time period to deal with
- an incredible amount of almost totally unorganized rkw data.
The first opportunity that was provided for us to review this four-volume report came last Tuesday, af ter GAP had contacted the NRC to receive a copy of the C.F..Braun study. We understand that there was a September 5th interim report provided to the NRC, of which we did not receive a copy; and that other individuals in the press and ~ Illinois received copies as much as ten days prior to our receipt of the final copy. This overs'ight unfortunately has caused unnecessary delay and expense for all parties. However, the most significant delay in finishing our analysis has come from the shocking conclusions reached by the C.F. Braun audit team. It has lef t us no -option but to go back-into the raw data of the report --almost item by item -- to scrutinize each conclusion reached by Braun. The NRR staff can expect our final analysis no l later than Tuesday, November 23, :1982. 1 ( Critique of C.F. Braun Summary The following comments summarize the major flaws that GAP analysts have found to date in the C.. F. Braun audit. of Zack's, work at the LaSalle Nuclear Power Station near LaSalle, Illinois. Further development of each item will follow in our expanded response to the C. F Bra.un,2,....a s s e s sm.en t. aa.9 ,s.... 3-i~ The' mef.hodology employed by I'.'.F.3r$6n'.~ih'Helectiriq * :a.I.~y, ~ the hangers, ducts,-and other pieces of equipment invalidate the'.'.p t:T conclusions.. During the hugust 24, 1982 Region 'III meeting', and in' his September 4, 1982 letter, GAP warn ~ed that the criteria to select items for the audit could prejudice the project. Unfortunately, our concerns were realized. In our opinion, it is clear that the study's conclusions were biased by the sample. Expert industrial quality control analysts contacted by GAP reiterate that for any sample to validly reflect the entire population (in this case total number of hardware items), that sample mqst be randomly selected freer. the entire range of possibilities. C.i. F. Braun did not employ this basic ' industry quality assurance standard. The " Summary cif Work" is clears the selection process is subjective: These selections for. inspection ~were made 5ased on their own engineering knowledge and experience in con-junction with some basic.gui'delines as follows. ~.. ... ~ _ ..~
Mr.- Harold P. Denton November 19, 1982 If Braun ' intended to limit its review to less than.a 100% inspection effort,.it should have employed a random selection process.for all l - pieces of equipment reviewed -- not for just a few systems. I i The consequences of Braun's risk are extremely serious. The NRC and the public are lef t with only two options: I 1) Reject the Braun report because of a basic generic flaw in its methodology; or 2) Accept the Braun report, pretend that it was a valid assessment and do an analysis of the conclusions based on the mythical assumption. Af ter several consultations With nuclear power analysts, statisti-clans, and industrial quality control professionals, it became clear that the only option available to.the NRC is to reject this report's general conclusions. In fact, it was the unanimous opinion of the analysts we contacted that without a random sample the conclusions are meaningless. As one person put it:~." Virtually all of the techniques used to analyze. data ' require that this data be obtained in accordance with well-speci'fied rules of random sampling." Although it would have been reasonable to conclude our review with a rejection of the Braun assessment purely on' the grounds of a flawed methodology, we nevertheless proceeded with our own assessment. Our review, however, should not imply that we accept the 335 selected pieces of HVAC equipment as a valid sample. Despite the conclusions the substance of the..Braun repor.t confirms Mr. Howar'd 's 'and Ms. Nor,e,llo 'sbnnrns f-hTE 'asino'nsti ates that., GAP's ini'tiiil'.Ee'servati'obs Mu6he 'wiaGesiies 6DThTNau' die ;wer'e~well - founded; ~ In fact, each unresolved concern raised by GAP in the series of meetings and. correspondence surrounding the beginning of ~ Braun's work has prov,pd to be a forewarning. 2. Of the 335 pieces of equipment reviewed, Braun concluded that 34% (117 items) hac discrepancies of_ varying significance. The extrapolation of a 34% error rate.to the entire BVAC system at. the Lasalle plant is frightening. What remains even more frightening is,the significance that thies error rate has for the rest of the i HVAC system. If the Braun sample tiuly,is representative, clearly ond-third of the NVAC system at LaSalle is in a discrepant condition. One NRC inspector estimated that there are 45,000 potential pieces of HVAC equipment (safety:and non-safety) on the Lasalle site. Because it has been impossible to. turn up more realistic data, that number is offered meiely to illustrate the significance of Braun's audit findings. A 100% review of the 45,000 pieces could ~ ...... x ;. ;...:... - u .--.-~ -. m --
c ~ f Mr. Harold P. Denton November 19, 1962 predictab1'y' produce 900 " findings,'" 30,600 observations, and only 12,150 non-discrepant conditions. Given that the 335 pieces actually. -. used reflected a biased sample, it is probable that the actual review ( would produce even worse results. In order to produce a more accurate assessment, GAP analysts need significant additional information missing from the current version i of the report -- l l 1) The total number of pieces of HVAC equipment on the f LaSalle site, broken down by safety or non-safety related functions; j 2) The total number of pieces in each system rather than just the percentage of hangers in the system that were reviewed; 3) The total ~ number of possible " finding" if all potential safety-related defects were actualized; and 4) In each instance, the variance for' acceptable limits of error as specified by the approved design. The most dramatic example of C. F. Braun's disrespect for NRC regulations is evident in. the study's conclusions on welder quali-fications: DJ.W.The Zack welding perfomance. qualification records (PQR) were reviewed. Although some PQRs are incomplete,
- .ill: ~Braun does 'not f eel that this degrades the welding a
Iir. fptogr'am since' Za'ck.was hot. required to. conform.;to a c'.3. c c:;.;f t 2: 2:.: specific code 'or ' standard. -:-fit has been detemined .that the weld quality la consistent on,Lall supports regardless of who performed'the welding. ~ Clearly, the Nuclear Regulatory Commission cannot accept Eack's willingness to v'aive nuclear safety laws. First, Braun's obser-vation that ".Zack was.not required to conform to a specific code or standard" is siinply wrong. The Atomic Energy Act requires welders to be qualified. Regardless of Braun's conclusion that 'all is well* despite an. inability to prove welder qualifications, 10 C.F.R. 50, Appendix B, Criterion II is clear that personnel participating in a quality assurance program must be properly trained and qualified. The.only;way to avoid this requirement would be to remove safety-related 'HVAc welding from QA coverage -- an illegal loophole that Braun tacitly accepts. At Zimmer the problem of-welders whose qualifications could not including a be verified has led to severe enforcement action massive recertification program. Continuing doul>ts about proof of welder qualifications played a major role in the i .e Mt
e 6-November 19, 1982 Mr. Harold P. Denton Commission's November 12,'1982 shutdown of the facility. In the documentation provided in the Braun report the're is little room for doubt about the qualification of Zack's welders. 14, 1982 review,of the 111 welders tested 42 failed In the September the test; in the second round of tests given in early October, 24 of 123 failed to-qualify. Even in the final qualification. review on October 26, 1982, there were 12 unqualified welders from the 52 tested. Braun's " feeling" that the lack of qualification for Zack's welders does not degrade the welding program casta serious doubt on all of Braun's assessments. It should not be necessary to debate that weld quality has a significant relationship to the verifiable qualifica-tions of individual welders. Other examples of major flaws that we have discovered within the Braun assessment are highlighted below 1) It is apparent that numerous design changes, designer justifications, and changes in the drawings resulteo.trom the errors found. It is not clear that the initially approved NRC design was signifi-cantly changed as a result of hundreds of changes, revisions, and. resolutions. Further, in most cases, Braun did not analyze the Sargent.& Lundy justification;.,3r.aun.merely accepted at f ace value whatever s&L concluded. ....,' :. i. ~."'*r
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n o,2.. ~;,;. s - ,2 ) .A review of the Inspection Report log reveals that . out of 335 alleged system inspections 7 pieces that were covered by the sample did not receive full-inspections. l The comment, " Hanger could not be inspected due to location," was i noted.for S-978, 5-964, S-987, 3-986, S-973, s-1327 :and E-1332. So even the number 335 is not an accurate reflection of what was inspected. 1 3) There are numerous exampics of Braun conclusions based on CECO's regularly schaduled tests or s_ tart-up tests. As. we had feared, the Braun audit appears to amount to little' more than an industry rubber stamp. 4) It is not clear how many findings were reported to the l Braun Internal Review Committee and Cotunonwealth Edison Company _ from the site team. .:;,.m c..: " *e. - ~ ~ ~
Mr. Harold P. Denton November 19, 1982 We do know that eventually three were reported to the NRC; however, since there were two levels of review prior to NRC notification, it is impossible to determine whether more of the observations \\were being considered as findings. 5) On page 23 of the summary there is an interesting but significant typographical error. The second paragraph has obviously been ' doctored." It is unclear by whom the changes.were made. The purpose of the doctoring appears to be to remove certain statements about the Zack non-conformance reporting system. We would like to' request' that the NRC review the initial page 23 -- prior to doctoring .- and make a determination of what was removed, why and by'whom. This unfortunate slip-up reveals last-minute company changes in the Braun report and under-mines.the credibility which it is supposed'to guarantee. The substance of Braun's acomments suggests that the numerous.Eack -nonconformance reports.should have been Quality Control Inspection ( Reports. Our experience with duplicate NR forms leads us to strongly disagree with this Braun conclusion. ( At Zimmer, there was a similar change made to undermine the NR procedure. This replacement. pro-cedure contributed significantly to the plant's condition being " indeterminate.") 6) Other observations that our staff has made that will be further. developed in our final report, are. listed below: l The lack of organizational. independence of C.'F. Braun from CECO. -- -. -;_- 9r 9.',,g.-;. :4@.:;,y..:,.. o 4f;pg,,.. _ ~. qr~<-~. n.+.~y y,,..v.p.,.$.., The' lack of informational independence of C.p. -Braun from CECO. The failure'of C.E. Braun to make independent evaluations of CECO and S&L judgement. The failure of C.F. Braun to extend the size of the sample after discovering critical. problems. The f ailure of C.E. Braun to follow through with disposition of their findings. t t The failure to cite relevant professional code requirements to justify their procedures. The failure to justify their conclusions with relevant professio code requirements. The absence of hardware tes,ts. The non-specific quantification of the numbers reviewed. . b.- -~^ a
4 4^ ~ . November 19, 1982' Mr. Harold P. Denton The reliance of C.F. Braun on Zack, S&L, and CECO tests and analysis. FAILURE TO ADDRESS SPECIFIC ' ISSUES RAISED BY THE WHISTLEBLOWERS The extraordinary remedy that created Braun's review is the direct' result of whistleblowing disclostres from Mr. Howard, Ms. Marello, Mr. Ronald Perry.and other former employees of the Eack If subjective assessments are to replace standard Corporation. statistical sampling techniques, no opinions come with better credentials than theirs. Unfortunately, Braun chose not to even attempt token communication with the whistleblowers, despite their announced eagerness to assist. As a result, Braun's report does not even report to address the specific concerns targeted by those responsible for the probe. To illustrate, the report.f ailed to --
- 1) guarantee that all relevant Nonconformance Reports ("NCR")
were reviewed. Although the report discussed a review of 1756 NCR'sj fewer than Mr. Howard and Ms_. Marello estimated were included in the scope of their equivalent effort, and fewer than the 2200 figure that Braun concedes it received.
- 2) review and establish current HVAC site specifications at Lasalle, which,were.unkgowny,Zack yhe(cergn materials were originally purchased.
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- 5) all, site records generated af ter January 1982, when Sargent and Lundy ceased indpendent reviews 'of Zack site documentation.
- 6) purchase orders from unapproved vendors, either because they never qualified for or were removed from the Approved Vendors-List.
- 7) purchase orders where there is evidence of questionable l
j records alteration or forgery. CONCLUSION To some extent the explanation for the flaws in the Braun z k t.
f' ~ Mi. Harold P. Denton November 19, 1982 j report is that the NRC exercised only token oversight. Whil's CEbo audited the " independent" reviewers, NRC site supervision was limited to one visit by one inspector. While staff priorities are understandable, the net result is that this third party report cannot legitimately serve as the basis for any final regulatory decision on Lasalle. The necessary f acts will not be in until the staff releases its own reports. If anything, the substance of the Braun findings are both/ ominous and understated in :the extreme. Despite its mandate, Eraun produced a paperwork review of a paperwork breakdown. It relied extensively on factfinding from the targets of the inquiry. It accepted at f ace value the suspect design changes approved without question by Sargent and Lundy, which rewrote tho' design requirements as needed to " legalize" Zack's violations. To approve full power for Lasalle on the basis of this report would represent a regulatory decision in spite of the. facts. Sincerely, Thomas Devine Legal Director ....,.o.... t l . ~ i '.' ' ~ Billie Garde ~. . Citizens Clinic Director cca Mr. Thomas Novak TD:BG/my ~~'"*** -. ^^ M m e-m w..~.. r., - r:... --
i EMICAe3 .872 47 Pbissf o A8t Y 984AMI fi t.'.. tbbleeGas emettete AM estC Hi". AN 188o TAN A P bOft t3A Qi g THE ZACK CO. L'a".= Teleybeest s 8h.s 2.uu 'T TRANSMITTAL NO 648 }.; ~ .,; p.g.. Nov. 24, 1982 .a___.. l 'TD:ln e sr n r-u.ninn Tv RE: DOCKET NO. 99900785/82-01 ! 6 :. ~ ~ l 611 Ryan Plaza Dr., Suite 1100 .y,7 ARLINGTON, TEXAS 76011 -[ ~:.,. - .. o.- ,.A.TTN. : MR. JOHN T. COLLINS _ pi[. p ~ l ' - - Rectional~ Administrator n.r gggglg.' .er.. -a fl_. ; . y. ~~ Wiere Sending'to yov].E..E BELO,W X Herewith ONE Copy
- .;. t...
Undw Seperate Covw Copies .-.==- y g. Following Drawings ' For .,X Approval .7 :.; Approved Dwgs. O ~ ' ? l 35 ;. . Cwt.ified Prints ~ Approval & Comment ~ Correction ,=, v. Approved Cwt. Prints (' ~ ~~ Your files & Distribution Your files s3.=.. Specifications W-Details ' $'. - ~_~ ~ Final Approval ,; QW X.NONCONFORMANCE RESPONSE Release for Producticri 15h For use on Job fi.' ~ .s;.. ~_- tielease for immediate Production Y.iur Estimate for work s 5' See Description Below .=:. ! .f?- l. Description RESPONSE TO NONCONFORMANCES ONE f1) THROUGH FOURTVTN (141 r l AS LISTED IN DOCKET NO.' 99'900785/82-01. !. Remarks l O Pleos. Acknowledge C.C. Yours very truly, THE ZACK CO. 4nt By: Wil Y Wssengw ~ %.9.E L h__ h .L 'iCindly return 0" Copy (s) Hosax of Transmi,ttal Martin L. Skates Q.A. Manager Note: If two copies of this lettw are enclosed, kindly acknowledge receipt by signing below and returning one copy to us. l \\ l
,s ,oamy (HOC A.e s o572 87 plint assaws IL 68 M LB tele 3403 AM est3Mt AM INllLN A PLemtDA t, THE ZACK CO.
- Ja>g; Telephemes Sieher 2.}434
} - TRANSMITTAL NO. 648 . 24, 19 8 2 'x s ~ ~ p.g.: Nov. .s. TO: n c n n c. t1=7 mn Tv RE: DOCKET NO. 99900785/82-01 4 611 Ryan Plaza Dr., Suite 1100 . ' ARLINGTON, TEXAS 76011 i ---~~. ATTN; MR. JOUN T. COLLINS pig y t l Regional Administrator ~~' l Gentlemeni Wa ore' Sending to you 3.E.E BELOW X H r.,ith ONE Copy Under Separate Cover Copies dtk ~ , Fallowing Drawings For 2, Approval Approved Dwg's. Cwtified Prints Approval & Comment Correction Approved Cert. Prints Your files. [ Specifications Your files & Distribution Final Approval Details X NONCONFORMANCE RESPONSE Release for Production ~ For use on Job Release fw immediate Production Yow Estimate for work See Description Below Description RESPONSE TO NONCONFORMANCES ONE (1) THROUGH FOURTEEN (14) ~ AS LISTED IN DOCKET NO. 9990079S/82-01? Remarks L.x.lPleos. Acknowledge C.C. Yours very truly, THE ZACK CO. %nt Byt Mail Y Messenew b.L %. 9.E h Tindly return ONE Copy (s) Hoeux of Transmittal Martin L. Skates Q.A. Manager Note:If two copies of this letter are enclosed, kindly acknowledge receipt by signing below and returning one copy to us. .e e
,= 4.500 W.12TH PLACE
- CHICAGO (CICERO)ILL 60650
- 312/242-3434
, 4401, WESTERN = FLINT MICHIGAN 48506
- 313/730-2040 3 the ZACK co.
CUSTOM METAL FABRICATION November 24, 1982 U.S.N.R.C., Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011 j Att: MR. JOHN T. COLLINS Regional Administrator Mr. Collins, Attached is the Zack Company response to NRC REPORT NO. 99900785/82-01 NONCONFORMANCES B-1 THROUGH B-14. Included in onr response is a description of corrective action taken, actions to prevent recurrence and projected or actual completion dates for corrective actions. All backup documentation not attached as part of this re-port is on file within the Zack Company and open for re-view at any time. Any questions concerning this report are welcome and should be directed to this office. We would like to thank those of the U.S.N.R.C. involved in this investigation for their cooperation, courtesy and-professionalism in the handling ~of this matt'er. 'We would also like to reaffirm the Zack Company position of.com-plete cooperation in resolving this matter. Very truly yours, THE ZACK COMPANY %dh A. ew-Martin L. Skates MLS/lf Quality Assurance Manager Encl. CC: CZDZ JCDZ D. Malzahn D. Calkins ., e Q.A. File _ c) 3 g,,D U { 6 b ,~r-G Ji) ti \\ e FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS OF INDUSTRY * . DEDICATED TO CLEANING AND CUSTOMlZING THE AIR OF THE WORLD *
.. s l REPORT'NO. 99900785/82-01 ,e m SECTION B NONCONFORMANCES: 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50, QA Manual Section 10, and AWS D1.1-79, the NRC Inspector ob-served deviations being permitted and changes to essential variables being made without the procedure being requalified during gas metal arc welding (GMAW) of duct rings for the Midland Plant, in which the welder was using 0.035 inch di-amater weld wire, 125 amps, and a gas flow rate of 30 CFH. The procedura requires the use of 0.045 inch diameter weld wire, 195 amps', and gas flow of 20 CFH. This was the only in-process welding observed by the NRC Inspector during his inspection. The Zack Company Corrective-Action: All in-process welding of angle rings was halted and all welds were identified (in-process and previous) under the Zack Company nonconformance system. Nonconformance Reports (405, 406 and 407) dispositioned to remove all welds in their entirety. This action was performed and verified by QC. Welding Procedure.(WPS-1 Rev. 11) being utilized at the time is in the process of being requalified to incorporate the use of 0.035 diameter weld wire and essential variables as required by AWS D1.1-79. Act'on to Prevent Recurrence: i On-going weekly surveillance is being performed and documented by the Quality control Department of in-process welding. Train-ing sessions are being conducted and documented as to the re-quirements of Procedures, AWS Standards, Quality Assurance Manu-al Program, and 10 CFR 50 Appendix B. Corr'ective Action Completion: a. Wald Procedure requalification, anticipated completion by - mid-November 1982. b. On-going training will continue as deemed necessary by Quality Assurance. On-going surveillance activity has been incorporated into $[_ c. 'ss/ the Quality Assurance Program and shall continue indefinitely. l
y ,s REPORT NO. 99900785/82-01 m SECTION B NONCONFORMANCES: 2A Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Procedure QCP-29, the following conditions were identified: Electrodes (bare wire on spools) were not being protected, in that three spools of stainless steel electrodes, each of a different type, were observed under a work bench in an uncovered condition. Further, two spools had been issued on December 17, 1981, and the other on April 16, 1982. b.
- Traceability of these electrodes would be precluded when used at a time later than the issue date, in that the date of issue as shown on the weld material control sheet would not coincide with the date or actual welding on a specific Zack Company Traveler.
The Zack Corrective -Action: Zack implemented a new weld filler metal control systsm on Nov-emner-2,'1982 precluding the repetition all aspects of the above' nonconformance. These. changes are documented in Procedure PQCP-6 (attached). The procedura was transmitted for approval for use on the Clinton.and Midland projects on November 5, 1982 (Transmittals attached). As the projected completion date for all Zack activit'y at the LaSalle project is December 20, 1982, Procedure.QCP-29 will not be revised and PQCP-6 will not be submitted to LaSalle for'ap-proval. Any remaining shop welding for LaSalle will be done with wire issued per the' requirements of the revised PQCP-6. Action to Prevent Recurrence: The requirements of revised Procedure PQCP-6 will prevent recur-rence of the above nonconforming activities in that it allows the welder to be in possession of one spool of wire at a. time. It also requires the welder to return his spool daily or lock,his spool to the machine at the end of the shift. The new Procedure also requires daily issue and return of Issue Documentation and requires the welder to record Traveler and piece part information on the Issue Document. Issue Documentation is forwarded to Q.A. on a monthly basis for review and filing. Corrective Action Completion: N/ All aspects of the new Procedure were implemented as an addition to current approved procedure requirements on November 2, 1982. Normal procedure approval turnaround is approximately six weeks.
a-v-
+----.w
~ ~ = = =.. =_ =, =, ~ _ 'aze *s9 THE ZACK CO.-
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si.n.,.uu Date: th S 0$I. To: W EA l ILM LJ f.Adff dGCA.. d-0Xl10[. &#t & E2 g 0bdcwh 17L. d06 03 h 2 9/o 2,90 O b. Ma> File i ATTN G:ntlemen: [b. Y Herewith / Copy ~ Wa oro Sending to you d B. N o.7-7 cv.O Under Separate Cover Copies of the Fallowing Drawings Approval Approved Dwgs. App oval & Coinment %p Correction Certified Prints Your files Approved Cert. Prints k Specifications , Your files & Distribution Z Final Approval Details Release for Production For use on Job l Release for immediot Production Your Estimate for work See Description Below ~ E' O b-M >I-b OWW' ht, l Dxicription l insoeck, ~ 5 esarN/'2 % w r d 0 d 4 4' / Remarks i 8Please Acknowledge C C. Yours very truly, THE ZACK Co. _ient By: Mall Messenser Kindly return I Copy (s) to us [ Note: If two copies of this letter are enciesed, kindly,ocknowledge receipt by signing below and returning one copy to us
~ ~ =:
- =
= =. =e. '#"' Wr THE ZACK'CO.. a ' = & So ~ h4 ae ~ . _s oote: 5. /88.2. 2!YlS 'YFS d2dt'd. 0 RE: To: P.o.~ % %oc M@mK M.h. G/727 W 19 /o File t 9d0 ATTN: 0 Gentlemen: Wo oro sending to you.dd.- h08-(- UO M Herewith / Copy C6 70cp.7 $p.o Und., s.ponte Cover Copi.s of the Fellowing Drawings . or Approval i Approved Dwgs. Approval & Comment Certified Prints Correction h Yow files . Approved Cert. Prints k 3 E Yow files & Distribution ~ Specifications Final Approval Details Release for Production For use on Job Release for immediate Production. Yow Estimate for work See Description Below I N ^' 0 Description (At YYi*n., d ec c qs Qn_a /W2' %LA ' / / Remarks blesse Acknowledge C.C. Yours very truly, THE ZACX CO. [ .mit By: Moll Messenger /A.
- 4.uz #
"( / Copy (s) to us Xindly return Note: If two copies of this lettw are enclosed, kindly ocknowledge receipt by signing below and retwning one copy to vs.
l ~ CB-PQCP-6, REV.0 INF0HfeAT!BN ONLY Hg"?SI=" m, - ~ (M '~ .n.114,6 g s THE ZACK COMPANY Procedure for: j ~ WELD FILLER METAL CONTROL and WELDING SURVEILLANCE INSPECTION e h CB-PQCP - 6 SECOND EDITION REV. 0 c COPYRIGHT 1980 THE ZACK COMPANY
- EN k.
Nov, 4,1982, n s_ CORPORATE Q.A. MANAGER DATE //- g-8 2. CORPORATE PROJECT MANAGER DATE d -Q~ ~
CB-PQCP-6, REV.0 NON W SECOND EDITION Page 2 of 6 1.0 PURPOSE l.1 The purpose of this Procedure is to define the system used by the Zack Company to control weld filler metal, and to prescribe and document surveillance inspections of welding operations. 2.0 SCOPE 2.1 This Procedure applies to the handling, storage, issu-ance, use and return of weld filler metal. 3.0 DEFINITIONS 3.1 Weld Filler Metal: The metal to be added in, making a welded, brazed or soldered joint. 3.2 Terms used in this Procedure are defined in ANSI N45.2.10, Quality Assurance Terms and Definitions.
4.0 REFERENCES
4.1 K2910 Specification 4.2 The Zack Company Quality Assurance Manual (ZQAM) 4.3 ANSI N45.2.10-1973, Quality Assurance Terms and Definitions 4.4 AWS D1.1-79 Structural Welding Code, Steel 5.0 RESPONSIBILITIES b5.1 Corporate Project Manager (CPM) ^ , Responsible for.the' proper handling, storage, issuance, use and return of weld filler metal. 5.2 Plant Superintendent (PS) - General Foreman (GF) Responsible for the control of weld filler metal per l the requirements of this Procedure. b 5.3 Quality Control Supervisor (QCS) Responsible for the verification, that weld filler metal is handled, stored, issued, used and returned in accord-ance with this Procedure. Responsible for verification of QCI's welding surveillance. 5.4 Quality Control Inspector (OCI) Responsible for performing inspections per~this Prccedure as assigned. Responsible for performing welding surveil-lance inspection per this Procedure. e n.
~ '. ~ ~ ~ ~ ' ~ ~ ~ ^ ~~- s. g CB-PQCP-6, REV.0 SECOND EDITION ~N Page 3 of 6 6.0 GENERAL 6.1 Weld filler metal is receipt inspected per PQCP-1 latest Revision. 7.0 PROCEDURE 7.1 Upon completion of receipt inspection, the QA/QC releases acceptable weld filler metal to the PS for storage. 7.2 The PS provides for the storage of accepted weld filler metal such that it is safe from damage and unauthorized
- issuance, i.e., clean, dry, and with controlled access.
/ 17.3 Materials released are transported t'o the weld material issue station, where it is removed from the shipping con-tainers, or the containers are placed on shelves in pre-paration for issuance. Low-hydrogen electrode, when re-moved from its hermetically sealed shipping container, is immediately placed in a holding oven. 7.4 Each shelf, within the weld rod issue station which ton-tains weld filler metal,_ including the shelves inside the rod holding ovens, are marked as to the type of weld fil-ler metal contained thereon. Holding oven shelf marking, due to heat, is applied to the exterior of the door. [g 7.5 Access to the weld rod storage is limited to CPM, PS, GF, and QA/QC Department Personnel. / .6 The PS, GF, and QCI are the only Plant Personnel author-7 ized to issue, for use and accept returned weld filler metal. 2[bg 7.7 Issuance and' return of weld filler m'etal is contiolled through the use of,a Weld Material Control Form (Attach-ment #1). This Form is initiated and maintained with issued material for the entire shift. WMCF's are main-t.ained in the QC file following the return of unused weld filler material or upon use of all issued weld filler material. WMCF's are forwarded to the Q.A. Manager for filing on the last working. day of each month. / (7.7.1 The PS', GF, and/or QCI shall fill out the portion of the WMCF pertinent to wire size, type, weld procedure, heat or lot number, control number, amount issued, amount returned and welder I.D. They shall also date and sign the form as appro-priate. i t . ~. _ - -
1 ~ RFORMATION WLY CB-PQCP-6, REV.0 l ._s SECOND EDITION Page 4 of 6 l / $7.7.2 The welder shall be responsible for maintaining the form for the entire shift, and filling in l Traveler and Part Identification as required. He shall also be responsible for returning the form l at~the end of each shift with any weld material I to be returned or the key for his particular weld-l ing machine. 7.8 Low Hydrogen electrodes are issued in portable rod warmer caddies. Each caddy is energized (i.e., plugged in) at l all times, except when in transit to and from the location in which welding is performed. /)i7.9 Returned weld filler metal is examined. Damaged.or wet items are discarded in locked disposal containers. -Re-usable items are stored at the weld rod issue station. - PS/GF/QCI annotes the amount returned on the WMCF. / 17.9.1 When low-hydrogen electrode is returned, PS, GF, or QCI removes it from the portable rod warmer caddies and returns it to the holding oven, if it is warm to the touch. Otherwise he discards it. Discarded low-hydrogen electrode is placed in locked disposal containers to prevent its use. 7.10 Weld filler metal, other than wire spools, is issued and returned on a daily basis. / 17.10.1 Wire spools may be issued for daily return or for locked storage on the welding machine. Wire spools returned on a daily basis are returned to.the weld material issue station and the returned weight is recorded on the WMCF. Wire spools'to be stored, locked on~the welding machine are "to'be locked;at the end of each shift as to make the machine inoper-able and prevent removal of the weld material. In this case the key is to be returned with the WMCF ~ to the issue station. Keys are to be maintained with the same controlled access as weld material and' issued"with the WMCF at the start of the next shift the same as weld. material. At.the time of return of wire spools previously locked on the welding machine, the returned weight is recorded on the WMCF. / $7.10.2 A welder is allowed to be in possession of only one wire spool at any time. If for any reason a dif-ferent wire spool is needed, the one already issued must be returned and processed as any other return- ~ ed spool and the new spool issued per the require-ments above. E m
v ~ CB-PQCP-6, REV.0 SzConD zDITIon INFORMATION ONLY -w Page 5 of 6 3 7.11 Holding ovens and portable rod warmer caddies are main-tained at the temperatures specified in AWS D1.1-79, Section 4, paragraph 4.5. Each is serialized, and their temperature is checked by the QCI every two months and documented in accordance with the provisions of PQCP-10, latest Revision. Holding ovens are maintained at a min-iman of 250 F. Caddies shall be functional. 7.12 Weld rod control verification and welding surveillance inspection. / 17.12.1 On a monthly basis, or as deemed necessary, the ~ QCI performs verification activities on weld rod control and in-process welding. The QCI visits all work stations. During the performance of this inspection, the QCI verifies through obser-vation that: 7.12.1.1 The' welder is qualified. 7.12.1.2 The procedure used is that which is noted.on the Travele'. r l 7.12.1.3 Welding parameters (i.e. current, voltage, polarity and gns flow) are within the limits required by the applicable WPS. 7.12.1.4 That filler metal i.e. size, type and position is as prescribed by.the weld procedure and that the welder has a properly completed Weld Material Con-trol Form in his possession. I 7.12.1.5 Preheat is as detailed in the app.li-cable WPS latest Revi~sion. 7.12.1.6 If low-hydrogen rod is used, then a portable rod warmer caddy is used and is energized.- 7.12.1.7 Observe the issuance and return of weld filler metal, and the condition of issue station for compliance to the provisions of 7.2 through 7.11. 7.12.1.8 Welding equipment conforms to para-graph 3.1.2 of AWS Dl.1-79. 7.12.1.9 The welders technique and performance meet the applicable requirements of Section 4, AWS D1.1-79. M 'e
e-CB-PQCP-6, REV.0 SECOND EDITION M Il$ N $ Nl,y Page 6 of 6 ~. N s N 7.12.2 The QCI documents his surveillance action on QC Inspection Report, Special Inspection, (Attachment #2), and transmits it to the QCS. The QCS files the original in the QC File. l , Problems noted during the surveillance actions are processed in accordance with PQCP-8, latest Revision. 8.O DOCUMENTATION 8.1 Documentation that is generated by'the use of this Pro-cedure is maintained in the QA/QC Files. 9.0 FORMS 9.1 Weld Material Control Form,. Attachment #1. 9.2 QC Inspection Report, Special Inspection, Attachment #2. 4 O* O i 4
O~ O O IMORIIAT10ll ORY N :z. 's M WEiD MATERIAL CONTROL-N Ed ,l ~ IO$ CLINTON @a@ FAB TICKET (S): Obk MIDLAND FAB TICKET (S) : LaSALLE FAB TICKET (S) : AMOUNT AMOUNT SIZE TYPE PROCEDURE
- HEAT OR LOT NO.
CONTROL NO. ISSUED RETURNED I estN 2 1 _ ed goy'#' \\SV Add .. q\\.NL zdA\\N sqJ #3goP 'ggens + DATE~ FOREMAN WELDER Q.C.I. 0 -3
4 CB-PQCP-6, REV. 0 Sk SECOND EDITION X ' CO.xrraCaxENr #2 45 le A ~ N \\ QC INSPECTION REPORT SPECI AL INSPECTION PAGE OF
- 1. DATE:
[jlf0RitATI0li OllLY
- 2. INSPECTOR:
- 3. ITEM INSPECTED:
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- 4. DESCRIPTION OF INSPECTIONi
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- 5. RESULTSOF INSPECTION:
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- /'
l
- 6. LEVEL 1/11 QC INSPECTOR DATE l
- 7. Q.A. / Q.C.
DATE s
= = =
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=.. 'exe"sg ~ THE ZACKiCO. L'O M gg Du:e: & l$$1-TD:2n />rb h 2 E: MZ dur:6 _ Y1ebfW 2h; kO - f Y 49 . ~dH O l% 20 - M @ DD x l ATTN: M File's 7MM i 1 .l - G:ntlemen: Wa ors Sending to you kO. d@(d: 4 kF. N - Hw.with Copy 80 89d8- /8 du d - Under Separate Cover f Copies of the A prevel Fellowing Drawines P Approved Dwgs. ~ 'Approvel& Comment Certified Frints Correction Approved Cwt. Prints ' Your files ~ b Specifications ~ b Final Approval Yow files & Distribution Details Release,for Production For ese en Jab Release.for immediate Production Yow Es'timate for wwk See Description Below D:scription MO A I '"b &YM ' #fd : U u d a/ M M v Remarks 8 ~ kPINs. Acknowlede.',,( l C.C=: l Yours very truly, l THE ZACK CO. A .t By: \\. Wil _'_ Y Wesengw ~ , (fa n,w a. Kindly return .k Capy(s) to vs Not:: If two copies of this lettw we enclosed, kindly ackas-lek, receipt by signing below and retwning one copy te vs. s \\,,, 4 .m,-.-_-
I MB-PQCP-6, REV.4 Page 1 of 6 ~ INFORMATION ONLY A dk2 n, s/g > V THE ZACK COMPANY Procedure for$. WELD FILLER METAL CONTROL and WELDING SURVEILLANCE INSPECTION O MB-PQCP - 6 REV. 4 k CORPORATE Q.A. MANAGER DATE J }fC ll ff/3- --E P-c, y a C COPYRIGHT 1980 THE ZAC [COMPKNY N
MB-PQCP-6, REV.4 Page 2 of 6 PURPOS$ ' INFONilATION ONLY 1.0 l.1 The purpose of this Procedure is to define the system used by the Zack Company to control weld filler metal, and to prescribe and document surveillance inspections of welding operations. 2.0 SCOPE 2.1 This Procedure applies to the handling, storage, issu-ance, use and return of weld filler metal. 3.0 DEFINITIONS 3.1 Weld Filler Metal: The metal to'be added in making a welded, brazed or soldered joint. 3.2 Terms used in this Procedure are defined in ANSI N45.2.10, Quality Assurance T,erms and Definitions. 4.O REFERENCES 4.1 Specification 7220,M-151 4.2 The Zack company Quality Kssurance Manual (ZQAM)' 4.3 ANSI N45.2.10-1973, Quality Assurance Terms and Definitions 4.4 AWS D1.1-77 Structural Welding Code, Steel 5.0 RESPONSIBILITIES 2 h 5.1 Corporate Project Manager (CPM) Responsible for,tdue proper handling,. storage, issuance, use and return of weld filler metal. 5.2 Plant Superintendent (PS) - General Foreman (GF) Responsible for the control of weld filler metal per the requirements of this Procedure. /hi5.3 Quality Control Supervisor (OCS) Responsible for the verification, that weld filler metal is handled, stored, issued, used and returned in accord-ance with this Procedure. Responsible for verification of QCI's welding surveillance. g h5.4 Quality control Inspector (QCI) Responsible for performing inspections per this Procedure as assigned. Responsible for performing welding surveil-lance inspection pe.r this Procedure. l l l l l l s
MB-PQCP-6, REV.4 Page 3 of 6 INFORMATION ONLY 6.0 GENERAL /hi6.1 Weld filler metal is receipt inspected per PQCP-1 vlat'iiist revision. 7.0 PROCEDURE 7.1 Upon completion of receipt inspection, the QA/QC releases acceptable weld filler met'al to the PS for storage. 7.2 The PS provides for the stora e of accepted weld filler metal such that it is safe from damage and unauthorized
- issuance, i.e.,
clean, dry, and with controlled access. /hi7.3 Materials released are transported to the weld mater,ial issue station, where it is removed from the shipping con-tainers, or the containers are placed on shelves in pre-paration for issuance. Low-hydrogen electrode, when re-moved from its hermetically sealed shipping contsiner, is immediately placed in a holding oven. 7.4 Each shelf, within the weld rod issue station which con-tains weld filler metal, including the shelves inside the rod holding ovens, are marked as to the type of weld fil-1er metal contained thereon. Holding oven shelf marking, due to heat, is applied to the exterior of the door. / $7.5 Access to the weld rod storage is limited to CPM, PS, GF, and QA/QC Department Personnel. / $7.6 The PS, GF, and QCI are the only Plant Personnel author'- ized..to issue, for use and, accept returned weld filler metal. j h7.7 Issuance and return of' weld filler metal is controlled through the use of a Weld Material Control Form (Attach-ment #1). This Form is initiated and maintained with issued material for the entire shift. WMCF's are main-tained in the QC file following the return of unused weld l filler material or upon use of all issued weld filler material. WMCF's are forwarded to the Q.A. Manager for filing on the last working day of each month. /(7.7.1.The PS, GF, and/or QCI shall fill out the portion of.the WMCF pertinent to wire size, type, weld l procedure, heat or lot number, control number, amount issued,; amount returned and welder I.D. They shall also date and sign the form as appro-priate. l b
MB-PQCP-6, REV.4 Page 4 of 6 INF0RilAT10N O!!LY .a 7.7.2 The welder shall be responsible for maintaining the form for the entire shift, and filling in Traveler and Part Identification as required. He shall also be responsible for returning the form at the end of each shift with any weld material i to be returned or the key for his particalar weld-ing machine. 7.8 Low Hydrogen electrodes are issued in portable rod warmer caddies. Each caddy is energized (i.e., plugged in) at all times, except when in transit to and from the location in which welding is performed. / h 7.9 Returned weld filler metal is examined. Damaged or wet items are discarded in locked disposal containers. Re-usable items are stored at the weld rod issue station. PS/GF/QCI annotes.the amount returned on the WMCF. jb7.9.1 When low-Hydrogen electrode is returned, PS, GF, or QCI removes it from the portable rod warmer caddies and returns it to the holding oven, if it is warm to the touch. Otherwise he discards it. Discarded low-hydrogen electrode is placed in locked disposal containers to prevent its use. 7.10 Weld filler metal, other than wire spools, is issued and i returned on a daily basis'. /hi7.10.1Wirespoolsmaybeissuedfordailyreturnorfor locked storage on.the welding machine. Wire spools returned on a daily basis are returned to.the weld material issue ' station and the returned ' weight is l recorded on the WMCF. Wire spools to be stored locked.on the welding machine are'to be locked at i the end of each' shift as to make the machine inoper-able and prevent removal of the weld material. In this case the key is to be returned with the WMCF to the issue station. Keys are to be maintained with the same controlled access as weld material and issued with the WMCF at the start of the next shift the same as weld material. At the time of return of wire spools previously locked on the welding machine, the returned weight is recorded on ?.he WMCF. /hi7.10.2Awelderisallowedtobeinpossessionofonlyone wire spool at any time. If for any reason a dif-farent wire spool is needed, the one already issued must be returned and processed as any other' return- ~ ~ ed spool and the new spool issued per the require-ments above.
- e
' 'i b MB-PQCP-6, REV.4 gg Page 5 of 6 3 i 7.11 Holding ovens and portabia rod warmer caddies are main-tained at the temperatures specified in AWS DI.1-79, Section 4, Paragraph 4.5. Each is serialized, and their temperature is checked by the QCI every two months and documented in accordance with the provisions of PQCP-10, latest Revision. Holding ovens are maintained at a min-imum of 250 F. Caddies shall be functional. 7.12 Weld rod control verification and welding surveillance inspection. /hg7.12.1 on a monthly basis, or as deemed necessary, the ^ 'QCI performs verification activities on weld rod control and in-process welding. The QCI visits all work stations. During the performance of this inspection, the QCI verifies through ober-vation that: 7.12.1.1 The welder is qualified. ~ 7.12.1.2 The procedure used is that which is noted on the Traveler. l [17.12.1.3 Welding' parameters (i.e. current, voltage, polarity.and gas flow) are within the limits required by the applicable WPS. A M 7.12.1.4 That filler metal i.e. size, type and position is as prescribed by the weld procedure and that the welder has a properly completed Weld Material Con-trol'Frma in his possession. l j bg7.12.1.5. Preheat is as detailed in the appli-cable WPS latest Revision. l 7.12.1.6 If low-hydrogen rod is used, then a portable rod warmer caddy is used and is genergized. 7.12.1.7 observe the issuance and return of weld filler metal, and the condition of issue station for compliance to the provisions of 7.2 through 7.11. jbg7.12.1.8 Welding equipment conforms to Para-l l graph 3.1.2 of AWS D1-1-79. l \\7.12.1.9 The welders technique and performance meet the applicable requirements of Section 4, AWS DI-1.1-79 l I
MB-PQCP-6, REV.4 S Page 6 of 6 WFORMATION ORY 2 jbg7.12.2 The QCI documents his surveillance action on QC Inspection Report, Special Inspection, (Attachment #2), and transmits it to the QCS. The QCS files the ori'ginal in the QC File. Problems noted during the surveillance actions are processed in accordance with PQCP-8, latest Revision. 8.0 DOCUMENTATION - 8.1 Documentation that is generated by the use of this Pro-cadure is maintained in the QA/QC Files. ~ 9.0 FORMS 2bg9.1 Weld Material Control Form, Attachment #1. j h9.2 QC Inspection Report, Special Inspection, Attachment #2. S e i 9 Wh M I
O 9 v lilFORilAT10llOllb 'g WELD MATERIAL CONTROL N J CLINTON 4 FAB TICKET (S): Su MIDLAND i FAB TICKET (S):
- $4 i
LaSALLE FAB TICKET (S): AMOUNT AMOUNT ~ SIZE TYPE PROCEDURE HEAT OR LOT NO. CONTROL NO. ISSUED RETURNED _ ntA \\N OSEN _a 4 pUo"' gWu-A ccMT\\b ,cdA\\N .c-g gg Y+ s r>'~~ p w _ynpTNEgo o Ad ' 'hgdf($gE SA# DATE FOREMAN WELDER Q.C.I. e I i a l ( ', \\ l
MB-PQCP-6, REV.4 the EA@X co.^= "-" '2 INFORMA110N ONLY 's QC INSPECTION REPORT SPECI AL INSPECTION PAGE OF
- 1. DATE:
- 2. INSPECTOR:
- 3. ITEM INSPECTED:
N f40% < O 5 JS Y
- 4. DESCRIPTION OF INSPECTION:
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- 5. RESULTS OF INSPECTION:
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- 6. LEVEL l/11 OC INSPECTOR DATE
- 7. Q.A. / Q.C.
DATE
"6 4 REPORT NO. 999.00785/21-01 SECTION B NONCONFORMANCES: 3. Contrary to criterion V of Appendix B to 10 CFR Part 50, QA Manual section 6, and AWS Dl.1-79, full and complete information requiring location, type, size, and extent of welds, weld joints, and material preparation, was not shown on shop travelers / detail drawings provided to shop personnel. The only information provided is the welding procedure specification number, which does not delineate the above information. The Zack Company Corrective Action: Zack believes that Shop Travelers provide sufficient welding in-formation through reference to "C" and "M" drawings, but realizes that at times incorrect drawing references were included.on the Travelers. To correct this situation and to avoid a total re-structuring of the Traveler System which would add confusion during the changeover, and consume ~an inordinate amount of time to implement, the Zack Company has taken the action below. Action to Prevent Recurrence: l In order to better assure proper drawing reference on the Trav ~ l eler, Zack has instituted a checker system under the direction of an assistant project engineer to check Travelers for proper i drawing reference prior to transmittal of.said Travelers to Chicago for _anrication. With proper drawin' reference,. a g direct line to all available welding information, this system l also eliminates the possibility of mistakes being made trans-ferring the welding information from drawing to Traveler. i Corrective Action Completion: This system was instituted at the Midland site on November 15, l 1982 and will be bnplemented at the Clinton site after the lift-ing of the current stop-work orders. 1 1 i t \\\\
r. REPORT NO. 99900785/82-01 O ~ SECTION B \\ v NONCONFORMANCES: s N 4. Contrary to criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 10, instructions, procedures, or drawings did not include appropriate qualitative acceptance criteria for welds. Therefore, without acceptance criteria being stipulated, specific inspection requirements were not set forth in welding procedures. The Zack Corrective Action: Specific inspection criteria are included in Procedure PQCP-19 (attached). This Procedure was approved for us,e on the Clinton project, has been revised and was resubmitted to both the Clinton and Midland projects for approval on November 5, 1982. As.the p.rojected completion date for all Zack activity cn1 the LaSalle project is December 20, 1982, this Procedure will not be submitted to LaSalle for approval. Action to Prevent Recurrence: ~ With the approval of PQCP-19 latest revision for use on both remaining projects, there will no longer'be a lack of documented acceptance criteria. Training will be provided to inspectors, welders, Q.A. and shop supervisory personnel upon approval of the revised PQCP-19. Corrective Action Completion: Average Procedure approval time is approximately six (6), weeks. Training will take place at that time. O ? l ~v--r. - - - + ---G---.-- -, ~ -. _ _ - -.. -, ,,-----._-----~_r. -,-,-y_-
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THE ZACK CO. n';n =. ; h._ Bishop 2.H H .s Dete: O'Y' S lNE TO: MDL/ RE: bsJ dtutA 0-d 2. MA als % sW _?A bob O$ A$/O ff' M IO ATTN: File t '/ / l Gentlemen: 8-d8 '88 d
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/ Copy Wo oro 5.nding to you Under Separate Covw Copies of the Fellowing Drawings Appeevel Approved Dwgs.. Appeovel & Comment Certifi.J Prints A Correction ( Approved Cen. Prints gY Your flies S Specifiestions / Your files & Distribution Details 8 Final Approvel Release for Production For vs. en Job Release for.immediate Production Yew Estimate for work - See Description Below Description / [ --I ALI / l Remarks hPlease Acknowledge C.C. Yours very truly, THE ZACK CD.. wt By: Mail Messenew Kindly return I Copy (s) to us If' \\ l Notet if two copies of this letter we enclosed, kindly ecknowledge receipt by signing below and returning e copy to us. =
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at. ee y ,g g ar gg;pg d2.C >,gyg , p*. v..; ' ' A C K C O e "*""~~ --s M cnicAco, su. 6oco 3 / Telephone: =* Stshop 2 3434 Date:
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'I+ Ef RE: M a. TO: Ro %ea d&;a % 4-x Jd k OAu% MWL u127 E 29/o N, d b E File F ATTH: y G::nt!. men: Wo ors Sending to you..b-Ndd8 d.O
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Herewith /
- opy Under Separate Cover
. C.p.e s afthe Fallowing Drawings Approval Approved Dwgs. Approval & Comment Certified Prints Correction .,.3 Ayoved Cwt. Prints Your files .d Sge: Tie:t: ens Your files & Distribution 3 De**st!s . ;-ol 1pproval ,.Ieto:se for Production For se on Job .hl2: e for immediate Production Y..r I:tfenote for work i I i See Dese,ription Below &'4 Drscription - V* 7 Remarks - b Please Acknowledge l C.C. Yours very truly, THE ZACK CO. ./ 'l I Messenger ent By: Mail ( $4 uzC6L 7 Xindly return / Copy (s) to us NIta: If two copies of this letter are enclosed, kindly acknowledge receipt by signing below sad ret:en! 3 one c, *'4.
l CB-PQCP-19, REV.0 SECOND EDITION Page 1 of 4 INFORMATION ONLY n !c aJ-BY DAT t ii THE ZACK COMPANY Procedure for: PLANT VISUAL WELD INSPECTION PQCP-19 SECOND EDITION REV. 0 l l-wk L skAm -i, /s /n l CORPORATE Q.A. MANAGER DATE dfC ///.sr/f2 w CORPORATE PROJEC MANpER ' '.DATE 1 C COPYRIGHT 1980 THE ZACK COMPANY
- CB-PQCP-19, REV.0 SECOND EDITION g .a x s 1.0 PURPOSE j[hl.1 To detail the "sek Company's visual Inspection Pro- .cedure for HVAC components -and' related fabrication. 2.0 SCOPE j h 2.1 This Procedure applies to all visual welding inspec-tion at the Zack Company Chicago and Cicero facilities. 3.0 DEFINITIONS / / 13.1 T' rms used in this Procedure are defined' in e ANSI N45.2.10, Quality Assurance Terms and Definitions.
4.0 REFERENCES
4.1 The Zack Company Quality Assurance Manual. 4.2 ANSI N45.2.10-1973, Quality Assurance Terms and Definitions. 4.3 Customer's Specifications. 4.4 The Zack Company Duct Standards and Construction Details. 4.5 AWS 3.0-76, Welding Terms and Definitions. 4.6 AWS D1.1-79, Structural Welding Codes - Steel. I 4.7 AWS D1.3-78, Specification for Welding Sheet Steel in l Structures, Paragraph 4.4d and.4.5. l 5.0 GENERAL b 5.1 Quality control ind!.viduals' who perform' visual examina-tion per this Procedure shall be trained, qualified, and certified in accordance with the Written Practice, latest revision. j(h 5.2 visual examination shall be performed only by authorized personnel who maintain current qualification in visual examination and have passed an annual visual examina-tion to assure natural or corrected near distance acuity such that they are capable of reading standard J-I let-ters on standard Jaeger Test Type Charts for naar vision or squivalent methods. 6.0 PROCEDURE /(h 6.1 When notified by the General Foreman to inspect welded components, the Quality Control Inspector, Level II, shall perform the inspection per this Procedure. i st j e ( l
CB-PQCP-19, REV.0 SECOND EDITION INFORETION WLY 'Page 3 of 4 ]: j[g6.2 Visual weld inspection of sheet to sheet, and sheet to structural shall be completed per AWS Dl.3-78. j(h6.3 Visual weld inspection of structural to structural shall be completed per AWS Dl.1-79. 7.0 ACCEPTANCE CRITERIA / h 7.1 The following paragraphs detail the acceptance criteria of this Procedure. / $7.1.1 The weldment and adjoining area to be inspected shall be clean and free to loose scale, rust, grease or any other foreign material. 7.1.2 Arc strikes located in the weldment are unaccept- ~ able and shall be considered cause for rejection. 7.1.3 Undercuts in excess of 1/32" shall be cause for rejection when identified in material 3/8" or greater. Undercuts in excess of 0.010" shall be cause for rejection in material less than 3/8" thick. 7.1.4 Any crack is cause for rejection. 7.1.5 Craters shall not encroach on the specified section thickness or theoretical throat size. l 7.1.6 Welds shall be inspected for fusion. Non-fusion i shall be cause for rejection. 7.1.7 Wald profiles shall be in accordance with Attach- [ .ments Number 1 and 2. 7.1.8 Location size and length of each weld shal'1 be per the latest applicable approved design document. 7.1.9 The sum of diameters of piping porosity in fillet welds shall not exceed 3/8" in any linear inch of weld and shall not exceed 3/4" in any 12 inch l length of weld. j(hg7.1.10Waldrepairsshallbeaccomplished,usingapproved weld repair procedures. 8.'O REJECTABLE WELDMENTS j h 8.1 Rejected welds shall be reported and documented per CB-PQCP-8, latest revision. l 9.0 FORMS / 19.1 Acceptable weldment shall be reported and documented on the following forms as applicable. l - -
~ CB-PQCP-19, REV.0 SECOND EDITION' lRTORMADOR W Page 4 of 4 s 's. b9.1.1 Fab Ticket Form, Attachment Number 3. 9.1.2 Fabrication QC Inspection Checklist, Attachment #4. /)i9.1.3 Nonconformance Report Form, for Conditional Release, Attachment Number 5. / (9.2 The Inspectors may identify with,a distinguishing mark all parts or weldments that he or she has inspected and accepted. Total traceability of acceptable weldment shall be documented on the appli' cable Inspection Form. h9.3 All inspection report documentation shall be forwarded to j the Document Control File for eventual implementation into the final turnover package. e w e .m' D 9 e I l
y CB-PQCP-19, REV.0 szCono sorrzow INFORMADON ONLY Attachnent #1 I Y g s g s,e i, .a' m,e v 4r. p".s si,e 1,e I[g, [_b.55U dk.?N 9. y r C' gas C + -Eas- - Eze-C _ sge-Note: Con.esity C shall not eussed 0.1 actual site + 0.03 in. c t l (A) Dairable fillet weld promes (B) Acceptab!e fillet weld proGu l t f>.*- l r,'.sg.. p%
- e N.
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r o -see - sse- -Size- -Size- -- Size ~ ~ Eas-In.afficient Enceni.e Ezees*we Overlap Insufficient. Inadequese throat. corwenity undercut tog peneiros; (C) Unscueptablefilletweld profiles
- n I
Q2p' I t l /E3h 1 1 tn Note:. Reinforcement R shall not. exceed 1/8 in. See 3.6.2. o (os Ae.pa,bi. wit.e!d p,om. j ^ I@e i
- C,,.
l <I v=u.Y I ,g ,b. ~. ,,$..n t 7 a / -p i i s,.essi.e in fneient r i.e-
- overes,
~ ' can euity throet undenut See 3AS See 3.8.2 See 16.3 See 3.6.4 e,.d 3.6.5 (a u,.sespeabie butt w.id promes Acceptable and unacceptable weld p mfiles .h. ---,.w
I .CB-PQCP-19, REV.0 INF0MEON ONLY sECono Eo1Tzon Attachment #2 s Convex Fillet Weld Concave Fillet 4 .../ Weld Size of Weld / q N 4 Siz e of Theoretical Veld Throat EQUAL LEG FILLET WELD ~ NOTE: Th s iz e 'o f a fillet veld is the leg length of the largest right triangle that can be inscribed within the veld. l Convex Fillet Weld Concave Fille-I Weld l N l Siz e of Weld s i N i Theoretical + c Weld Throat a UNEQUAL LEG FILLET WELD
112, / A ct. L O. a LLahulS PUVetiR COMPANY CLINTON POWER STATION UNIT 1 SF-4320 ]
- uECT: 453s:00 SPECIPICATION: K 2910 JOs NO: 2900 SAFETY RELATED WG. NO.
MARet CUST. Hs1LD POINTE VISION GAUGE D t WELD PROCEDURE NO. MEO. /EL SYSTEM DIM. TOLEMAMS s raftsR/oATg REviEwf0 ATE APPROVE /DATE \\ CB-PQCP-19, REV.0 INFORNATION ONLY SECOND EDITION Attachment #3 f. %. t -- ,. l l. . ~.' / " ' '. ',",. - a " r- ' ~ ' ' e.,,.,: e ]* y','.. " s !. ' h 5 00% i ' -}- $h - &+b.- sos **Q'Y q# ~ .,y s. CUTTING LIST a s ~. t-
- r..s
.~. .- OUALITY ASSURANCE MATERIAL USED OTICICET APPROVED /DATE L CONTROL NUMBEN ~ ELE IRON CONTROL NUM8ER 4 1.D. INSPECTOR /DATE
- P1NG FINAL INSPECTION /DATE I
SITE RECElVING/DATE
INFORMATION ONLY CB-PQCP-19, REV.0 SECOND EDITION Attachment #4 Fabrication QC Inspection Checklist
- .W Acceotl Reject N/A 1.
Material control Numbers Recorded n
- 2.. Welder ID No.
3. Weloing QualiTication 4. Welding Inspection (Configuration, size and visual characteristics)- 5. Duct 01mensions I. 6. Hancer Dire.ensions u 7. Gace of Sheet Steel 8. Size of steel snaces 9. Vanes
- 10. Cleanliness 11.
Internal Duct Reinforcement i i 12. Seaiants 13. Coatino of Welds .l 14. Paint concition t - 15.
- Item, ID Ho. (Mark No. )
1 . &wn DC Sign Leuel Date Leval Ji QC Review Date SAMPLE - ACTUAL FORM IN USE MAY VARY - THE ESSE '.TIAL CONTROL ELEMENTS OF THE FORM REMAIN THE SAME X - - - - - - + < - - -, - - -- - - - - - - - - - -. - - - - _, -, - - - - - - - - - ~, - - - - -, - - - - -r =
r thd 8&@% co. NONCONFORMANCE REPORT CB-PQCP-19,REV.0 SECOND EDITION , 5 , REPORT NUMBER: CR CODE: l 'ROJECT: DATE: N ITEM /PART NUMBER AREA / LOCATION TRAVELER NUMBER DRAWING NUMBER OWNER FURNISHED MATERIAL / EQUIPMENT YES O NO O SAF{'] NON SAFETY O _.mm m ir DESCRIPTION ON NONCONFORMANCE: et 1 A OI* , a ? L E ^ Y l l c c.t 4 T \\ b \\ W C 'l 'N a ;,say w r;m,po w w LumTs a 7;sut ( Q.C. INSPECTOR / DATE USE.AS.lS O REWORK O REPAIR O SCRAP O RECOMMENDED REMEDIAL ACTION: l PROJECT MANAGER /DATE APPROVED BY: O.A. MANAGER / DATE CONDITIONAL RELEASE REQUEST: l PROJECT MANAGER /DATE APPROVED BY: O. A. MANAGER / DATE I REMED -L ACTION TAKEN: \\ PROJECT MANAGER /DATE VERIFICATION OF REMEDIAL ACTION: ' ACCEPTED C REJECTED D Q.C. lNSPECTOR /DATE Q.A. MAN AG ER /D ATE
g L':',*.'!2 "I,5*L ' Oe':1.
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in't.'... Ea"qz THE ZACK CO.. '3'c TJ c Telepheme } Blehop 2 3434 Dose: So l$N Yns$ A7x W_ E: M ~0: p o. n '.a f xndAA % O kdA..trevo 72 zo - x is, (s) .TTH: 4 File 1 7408 6 entf: mon: 0.~ h &. W =.S.
- h. E Y b
HeeewIth Coyy o era 5:ndIne ta youll0 EQCP- /8 820-Under separate Cover F Copies Ithe sIlawing Drawings F Approval ~ Approval & Comment Approved Dogs. Certified Prints Correction Approved Cert. Prints D Your files b Specifications Your files & Distribution J Detalls 3 Final Approval Release for Production ~ Fw use en Job Release for immediate Production Your Estimate for werk l ..,;p,ie, iderD futAss &b 4 lS See Descripelen Below(de12~ '- dlt hh hh l ' #fd - /JtY u)A.J. Seh l v cmarks I kPl.ese Acknowledge
- .C.
Yours very truly, THE ZACK CO. 1 By: Wil Y Ws senger t ,o n 4s) 'inally return f Copy (s) to us \\ f ota if tw. c,ie.f this iett.,.,e encioned, kindry acknowleds. ree.rpe by signing b. tow and r. turning on. copy v. us.
MB-PQCP-19, REV.0 m Page 1 of 4 .] ~ x INFORMATION ONLY BY Daft // G ll \\ l t THE ZACK COMPANY Procedure for: PLANT VISUAL WELD INSPECTION MB-PQCP-19 REV. O. . % b L d d m_. drls/s2. CORPORATE Q.A. MANAGER DATE l I
- b. &~, C.
// S $2 = P -,,-, C COPYRIGHT 1980 THE ZACK COMPANY / d I l
MB-PQCP-19, REV.0 MMON ONLY Page 2 of 4 1.0 PURPOSE 1.1 To detail the Zack Company's Visual Inspection Procedure for HVAC components and related fabrication. 2.0 SCOPE 2.1 This Procedure applies to all visual welding inspection at the Zack Company Chicago and Cicero facilities. 3.0 DEFINITIONS 3.1 Terms used in this Procedure are defined in ANSI N45.2.10, Quality Assurance Terms and Definitions.
4.0 REFERENCES
4.1 The Zack Company Quality Assurance Manual. 4.2 ANSI N45.2.10-1973, Quality Assurance Terms and Definitions. 4.3 Customer's Specifications - 7220-M-151. 4.4 The Zack Company Duct Standards and Construction Details. 4.5 AWS 3.0-76, Welding Terms and Definitions. .4. 6 ' AWS Dl.1-79, S'tructural Welding Codes - Steel. 4.7 AWS Dl.3-78, Specificati'an for Welding Sheet Steel in Structures, Paragraph 4.4d and 4.5. 5.0 GENERAL 5.1 Quality Control' individuals'who perform visual examination per this Procedure shall be trained, qualified, and certi-fled in accordance with the Written Practice, latest re-vision. l 5.2 Visual examination shall be performed only by authorized personnel who maintain current qualification in visual ex-l amination and have passed an annual visual examination to assure natural or corrected near distance acuity such that l they are capable of reading standard J-I letters on stand-ard Jaeger Test Type Charts for near vision or equivalent methods. 6.0 PROCEDURE '6.1 When notified by the General Foreman to inspect welded components,the Quality control Inspector, Level II, shall perform the inspection per this Procedure. .i e w
INFONNADONONIY MB-PQCP-19, REV.O Pr.ge 3 of 4 ~ / 6.2 Visdal weld inspection of sheet to sheet, and sheet to ~ structural shall be completed per AWS D1.3-78. 6.3 Visual weld inspection of structural to structural shall be completed per AWS D1.1-79. 7.0 ACCEPTANCE CRITERIA 7.1 The following paragraphs detail the acceptance criteria of this Procedure. 7.1.1 The weldment and adjoining area to be inspected shall be clean and free to loose scale, rust, grease or any.other foreign material. 7.1.2 Arc strikes located in the weldment are unaccept-able and shall be considered cause for reiection. 7.1.3 Undercusts in excess of 1/32" shall be cause for rejection when identified in material 3/8" or greater. Undercuts in excess of 0.010" shall be cause for rejection in material less than 3/8" thick. 7.1.4 Any crack is cause for, rejection. 7.1.5 Craters shall not encroach on the specified s,ection thickness or theoretical throat size. 7.1.6 Welds shall be inspected for fusion. Non-fusion shall be cause for rejection. 7.1.7 Weld profiles shall be in accordance with Attach-i ments Number 1 and 2. i 7.1.8 Location size and length of each weld shall be'per I the latest applicable approved design document. 7.1.9 The sum of diameters of piping porosity in fillet l welds shall not exce.ed 3/8" in any linear inch of l weld and shall not exceed 3/4" in any 12 inch l length of weld. 7.1.10 Weld repairs shall be accomplished, using approved weld repair procedures. 8.0 REJECTABLE WELDMENTS l 8.1 Rejected welds shall be reported and documented per l CB-PQCP-8, latest revision. 9.0 FORMS l 9.1 Acceptable weldment shall be reported and documented on the following forms as, applicable. ~ t / .)_ l l l l
g* J INORMADON ONLY MB-PQCP-19, REV.O Page 4 of 4 9.1.1 Feb Ticket Form, Attachment #3. 9.1.2 Fabrication OC Inspection Checklist, Attachment #4. 9.1.3 Nonconformance Report Form, for Conditional Release, Attachment #5. 9.2 The Inspectors may identify with"a distinguishing mark all parts or weldments that he or she has inspected and accept-ed. Total traceability of acceptable weldment shall be documented on the applicable Inspection Form. 9.3 All inspection report documentation shall be fo'rwarded to the Document Control File for eventual implementation into the final turnover package. l' 1 1 l e j \\ l
5 ~: MB.PQCP-19, REV. O INFORilAileN ONLY s Attachtent il l f%'s g;,, I TV s / p 45* Stae s: e e..> 5; e, g y, l t,
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s ,\\ h 6,.#.,--- - g h...,... s . m; \\ -( -... s, es y -- - l
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~ She - - Size-C s,e - C g, + \\ 3 Note: Convesity C shall rios enceed 0.1 actual size 4 0.03 in. 4',. 3: (A) Desirable fittet weld promas (D) Acceptable fi!!ctweld promne .j j i -( i / Ofn%.. , h,. is, - M. f,,, s I sp s M
- jgs
-i l W:.:S V,. ?.;. 1 y. 2 6. c.u - ...@.n.% 1 . ftird. h &x. 1:w:.. u - SI:e---- ~ Sire---- - Sir e --.- - Sit e-- +- ]- Size-
- - Size-Insufficient Excessive Ezerssive Overlap Insufficient Inadeqvwe throat convesity undercut
, leg pene'tration (C) Unacceptable fittet weto promes c. la' 4 m W h.,/ .L t r s. 2.h... I w jR Note:. Reinforcement R sha!!_not oceed 1/31n. See 3.6.2. l = l (D) Acceptable butt wefd proms D. c, t. l M l 'GN,' l f%i 1 s,h..s 1 /.:. l ,r. -(,.,-
- . <. g.
p ) , Excassive Inn,tficieh Excessive
- Overfsp convenity throst ur dercut See 3.iB See 3.5.2 See 3.E.3 See 3.6.4 ar.d 3.8.5
.~ (E) Urucumpeable butt weld promus l t Acceptable and una cce'ptable weld ' roIIIes p g i 1 1 O e
%,, i ~ pa,. g ~ Y;.. , y.,, - y ( (. MB-PQCP-19, REV.0 1 t T' '] \\ Attachment #2 / x 3 ' ~ ~ 3 _ MFOMtATiON ONLY ~
- ."s
..s . t,; ,s / Convex Fillet' Weld Concave Fillet ~ \\u ,,,,A-* yeld S iz e o f., \\ [*s Weld ~ Siz e of 4 ,l T h eo r e t ic al Veld is ? Throat s i .' N , <T / s EQUAL LEG FILLET UELD t , t.. >s i 3 3 i. NOTI: The siz e of a filler {ueld is the leg len gt.h of the largest right, triangle that can be inscrihed wit hin the veld. 7 ,N,- I gh - **a,', gg <t N t '( \\' es i i 4 ( , f, i' 7 .,.3 '\\ N., \\ a, s Gonvex Fillet Weld Concave Tillet 1 Wald \\ Size of Weld N N s .s N l 1 Size of I Theo ret ical + w Veld Throat g-l l t s
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MIDLANL .VITS 1 & 2 i M MM M - M ECME UWe 8 '~ s MB-POCP-19, 'REV,0 - ATTACitMENT f3_ TiCxETuo.F25362 ,HlP: A$5EMOLE3. KNOCKEDDOWN l CHECKER: DATE: CRAWN GY: CATE: GUANTITIES e ases. s "'*"' CUTTING LIST N Level leem SHEET A M LE w,. Wee
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- UETOMER DIMENSIONAL TOLER ANCES
- 1 1/4 10L3 POINTS WELDING PROCEDUREl5): WPS a.
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MB-PQCP-19, REV.0 's. Attachment #4 i N O SEQN ONLY Fabrication QC Inspection Checklist lAcceDt(Reject N/A 1. 14aterial Control Humbers Recorded l-t 2. Welaer 10 Ho. l l 3. Weloino OualiTication l t 4. Welding Inspection (Configuration, size and visual characteristics) l l c 5. Duct Dimensions i I 6. Mancer Dimensions 7. Gace of Sheet Steel I 8. Size o+ 5tet:1 Snaces I c 9. Vanes I i 10. Cleanliness i I i 11. Internal Duct Reinforcement 12. Seaiants I i t 13. Coatino of Welds t 6 l 14. Paint Concition i t i 15. Item. ID Ho. (1: ark Ho.) 6 6 i .sMex OC sign Le"cl _Date tev31 11 OC Review Date_ e M / .) O
~ l 5 CQ NON CONFORMANCE REPORT MB-PQCP-19, REV.0 - ATTACHMENT #5
- 1. Rl! PORT NUMBER N.C.R. COD E:
' N ,2.DATE PROJECT:
- 3. ITEM / PART NUMBER
- 4. AREA / BUILDING
- 5. ORAWING NUMBER 6.
OWNER FURNISHED MATERIAL OR EQUIPMENT O YES O NO 7. O. LISTED O'YES O NO
- 8. DESCRIPTION OF NON CONFORMANCE:
j INFORMATION CMLY
- 9. REPORTED BY DATE
- 10. RECOMMENDED CORRECTIVE ACTION:
- 11. OC INSPECTOR / DATE
- 12. QA/OC MANAGER / DATE
- 13. PROJECT MANAGER / DATE
- 14. CORRECTIVE ACTION TAKEN:
7 I l I l I e
- 15. PROJECT ENGINEER / DATE
- 16. PROJECT MANAGER / DATE l
f
- 17. VERIFICATION OF CORRECTIVE ACTION TAKEN:
- 18. ACCEPTED O REJECTED O
- 19. OC INSPECTOR / DATE
- 20. MANAGER / DATE
y REPORT NO. 99900785/82-01 ~s. ..l SECTION B x NONCONFORMANCES: 'N s i 5. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 7, shop fabrication tickets were not l complete in all respects, in that they did not address cer-tain fabrication methods / operations, and their sequencing; l - e.g., rolling or forming and. galvanizing. l l The Zack Company Corrective Action: l [. It is the position of the Zack Company that due to the limited number of variable operations used in the sheet metal industry, i there is no need for detailed sequencing on the Shop Travelers. l In addition, sufficient design documents exist ("C" and "M" drawings and duct standards) and are in use to preclude in, correct fabrication of any given duct piece fitting or hanger. t Action to Prevent Recurrence: . The Zack Company QA Manual has been rewritten, submitted for approval at Midland and is currently approved for use at Clinton. The new QA Manual does not address the specifics of the Traveler System. Those specifics are contained in PQCP-3. Shop personnel have been trained in the applicable portions of the new QA Manual and plant fabrication procedures to assure compliange. Corrective Action Completion: l All submittals and approvals and all training ~of ' hop personnel s l was complete as of November 19, 1982. IG =*
REPORT NO. 99900785/21-01 SECTION B NONCONFORMANCES: 6A Contrary to Criterion V of Appendix B to 10 CFR 50 and QA Manual Section 8, the following conditions were identified: a. The Zack Company placed purchase order (PO) number C-4199 with Central West Machinery Company in Nov-ember 1980 for 152 gallons of Hardcast FTA-20. This inaterial was received and accepted. Subsequently, a verbal order for additional 24 gallons was placed and received in November 1980, and as of the date of this inspection, no written confirmation has been made. The Zack Company Corrective Action: Training has been conducted with the Purchasing Agent as to the requirements of follow-up action to be taken on verbal confirm. ations to the purchase order. An internal supplement change has been issued to PO No. C-4199. Due to the time span involved, this supplement change order will not be issued to our supplier, but has been incorporated in Zack's PO file. Action to Prevent Recurrence: The Zack Company Quality Assurance Manual Program, Procedures, a and. Training sessions have been upgraded.to incorporate a com-plate review of~all purchase requisitions, purchase orders, and ~ supplement change orders, by the Quality Assurance Department. 6B. The Zack Company placed PO No. C-874 with Griffiths-McKillen Steel Company'on July 5, 1979, for 3000 lbs. of 14 gage ASTM A-240 Type 304-2B stainless steel and 600 feet of 1-1/2"x1-1/2"x1/8" stainless angles, ASTM A-276 Type 304, with certifications required. The received and accepted certification, dated July 18, 1979, for the ASTM A-240 material showed the following: . tensile strength-66,000 PSI, p~hosphorus-0.38; sulfur 0.06; l and nitrogen content was not addressed. The ASTM A-240 standard requires 70,000 PSI tensile strength (minimum), ~ l 0.045 maximum phosphorus, 0.03 maximum sulfur, and 0.10 maximum nitrogen. (NOTE: This material was ordered for non-safety related applications. I T l l \\ \\ =...
~ REPORT NO. 99900785/82-01 SECTION B' s \\ NONCONFORMANCES: 'x N~ The Zack Company Corrective Action: The material was purchased for use on the Midland Project only. At the time of placement of this purchase order there were no requirements established for Zack Quality Assurance to review material certifications (nonsafety-related) for compliance. The material certification was submitted to our client on a supplier deviation disposition request (SDDR-2500) on May 10, 1982 and accepted by our client on August 16, 1982. Action to Prevent Recurrence: ~ The requirement for Zack Quality Assurance to review all mate-rial certifications for compliance was established in August 1981. This requirement has been incorporated into our Quality Assurance Program Manual and Procedures. On-going review of all purchase orders and material certifica-tions is being performed by Zack Quality Assurance Department. Revalidation of.all history certifications is being performed by Q.A., and all discr'epancies will be identified under the Zack Company nonconformance system. Anticipated completion of history documentation revalidation is July 1, 1983. 6C The Zack Company plac'ed P.O. Number C-4458 dated July 30, 1981, with Hobart North ~for 30 lbs.. stainless steel weld l rod 3/32" Type'308. The P.O. stated ~" actual or typical chemistry, RT (radiography),-mechanicals, Charpy V notch tests." The Certified Material Test Report (CMTR) was received and accepted by Zack Company, but did not address RT or Charpy V Notch tests. (NOTE: The material specification does not require RT or Charpy's; however, it is still a P.O. re-quirement,. The Zack Company Corrective Action: On August 11, 1982, a supplement change order #1 was issued for P.O. Number C-4458 to delete the requirements of RT (radio-graphy) and Charpy V. notch. All other requirements remain the same. _) 9
I REPORT NO.- 99900785/82-01 ) SECTION B.. NONCONFORMANCES: Action to Frevent Recurrence: All purchase orders for nuclear are being reviewed by Quality Assurance for compliance with the requirements of the specifi-cation. 6D The Zack Company placed P.O. Number C-9433, dated August 4, 1976, with Vincent Brass & Aluminum Company for 4000 lbs. of 20 gage and 2000 lbs. of 22 gage stainless coils, Type 316, ASTM A-240, with mill certifications. required. The material was received with certification, dated August 9, 1976. The 20 gage material was returned to Vincent due to damage. However, the 22 gage material was accepted, although the certification did not list a heat number and did not provide the actual chemistry. The chemistry stated on the certification was simply a reiteration on the chem-istry requirements stated on ASTM A-240. (NOTE: This mater'ial was ordered as nonsafety related. ^ The Zack Company Corrective Action: The Zack. Company obtained mill certification foi 22 gage ASTM A-240 material from the supplier. This material was identi-fied on Zack Nonconformance Report Number L297, and submitted to the client. The nonconformance was closed March.19, 1982. Action to Prevent Recurrencet All purchass orders and mill certifications' (where required) are being revalidated and any. discrepancy's will be. identified under Zack's nonconformance system. Anticipated completion f'or revalidation is July 1, 1983. 6E The Zack Company placed PO Number C-739, dated September 29, 1978, with US Steel Company for 20 tons of ASTE A-527, A-525 galvanized coils. Certifications were. required. The material and certifications were received and accepted showing the heat numbers as J 74531 and J 74278. - The certifications did not provide physical test reports for Heat J 74531. (NOTE: The ASTM material standard does not require physical properties to be reported; however, this material was purchased for use at Clinton Power Station and the Clinton specification did require physical proper-ties to be reported). s c I y.- -.e-g--,. .,9-.-m_. - ._9-9, ,..,,y y g. ,.-+w-.-- 3- 'N
t REPORT NO. 99900785/82-01 3. SECTION B NONCONFORMANCES: The Zack Company Corrective Action: The Zack Company obtained samples of material from Heat J 74531 (Coil #402) and sent the samples to P.T.L. for physical proper-ties analysis. Certification is on file in the purchase order package.
SUMMARY
OF' ITEM NO. 6 All purchase orders for nuclear safety-related and nonsafety-related materials are being reviewed by Quality Assurance for compliance to the required program. All Mill Certification Reports are being reviewed by Quality Assurance and where re-quired, (1) corrected certifications are being pursued, (2) material samples are being sent to test labs for analysis and/ or (3) identified under Zack's nonconformance system and for-warded to the Design Engineers for disposition. e 4 4 P 5 Y. d' o 4 ,y
REPORT NO. 99900785/82-01 . SECTION B NONCONFORMANCES: 7. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraph 9.1 of Sargent & Lundy Engineers, Chicago, Ill-inois, Standard Specification J2590 for HVAC ductwork (Form 320), unapproved materials (Hardcast FTA-20 adhesive and DT tape) were used in sealing HVAC systems at LaSalle. The Zack Corrective Action: The Zack Company had revised Class I (Safety Related(Seismic)) duct plate D1-02 to include Hardcast FTA-20 with DT tape on December 9, 1981 and transmitted it for approval as part of a group of duct plates to Sargent & Lundy on January 14, 1982 (duct plate and transmittal attached). Sargent & Lundy approved duct plate D1-02 on August 27, 1982 making Hardcast FTA-20 with. DT tape acceptable for use. Action to Pre' vent Recurrence: For approximately the past 13 months, part of the Zack Company Q.4. Manual of purchase orders is a review of applicable tech-nical Specifications to verify that the product being ordered is l an approved product for use on the applicable project. No pur-chase order for unapproved products will be approved by Q.A. thereby. making purchase impossible. Corrective Action Completion: I Corrective action is complete. O e e L
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..s . h. d Date: 1/14/82 Sargent '& Lundy RE:.. Commonwealth Edison Co. O, '55 E. Monroe St. La Salle County Station Chicago,-Ill. 60603 HVAC/J-2590 - E.P.Ricohermoso 3300 TTN: - File F D.R.Spisak entlemen: o ar. 5:nding to you X H.,,,ith 1 Micro ~ Copy Under 5.poret. Cov.) Xerox Copi.s the allowing Drawings ~ Approval & Comment For Approval Approved Dwgs. Correction Certified Prints Approved Cert. Prints Your files Specifications Your files & Distribution D tells Final Approval Release for Production X Aperture Cards p,,,,, 3 R.I.ose for immediot. Production Yow Estimate for work X 5.. Descripeien B. low We are submitting herewith aperture cards with revised and I oeerspe,_ cdditional details required tio complete Zack Co. duct construction brochure in accordance w/ project requirements and as built conditions. i See attached sheet for listing of Zack Plates. e.morks iNFRMAllON ONLY b Pleo:e Acknowledge .C. x.s. n wpn -y .r / 7.....,..:,. THE ZACK CO. /* By: Mail Mess nger j i indly r: turn 1 Copy (s) to us fo~ifie R. OcT1oa ot:: If two copies of this I.tter are enclosed, kindly acknowledge receipt by signing below and returning on. copy to us. }
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y REPORT NO. 99900785/82-01 4 ,m g ,j SECTION B NONCONFORMANCES: 8. Contrary to Criterion V of Appendix B to 10 CFR Part 50, and PQCP-7, " Plant Document Control", there was no docu-mented evidence that a voided documett file was maintained up-to-date for Q.A. Manual for Clinton and Welding Proce-dure WPS-1. The Zack Corrective Action: Research into site files and previously identified Chicago History Files has brought to light all previous revisions of the ZQAM for Clinton. All revisions of said manual are on file in.the Chicago office. WPS-1 is a Welding Procedure that_ superceded Procedure QCP-1 P9CS. QCP-1 P9CS went through four (4) approvals for use on the Clinton project, Revision 4 being the last. WPS-1, Rev. 4, was submitted for approval to supercede QCP-1 P9CS Rev. 4 while QCP.-l P9CS Rev. 4 was still pending approval. WPS-1 was sub-mitted the first time as Rev. 4 to maintain continuity of revi-sion level with the Procedure it was replacing. l When both Procedures were approved as Rev. 4, Zack personnel realized that WPS-1 should have bee'n submitted as Rev. 5.to' maintain continuity. The final error.was submitting the next WPS-1 as Rev. 6 thus never issuing a Rev. 5 or changi All copies of the affected Procedures are,ng Rev. 4 'to Rev. 5. 'on file. Action to Prevent Recurrence: Training has been provided to Document Control Personnel l stressing the requirements of maintaining a~ file of voided documents. l Corrective Action Completed: A review of all history fil'es is on-going with a projected ~ completion date of March 1, 1983. J l
~ REPORT NO: 99900785/82-01 ) SECTION R - NONCONFORMANCES: 9. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 19, " Audits," of the QA Manuals for LaSalle and Clinton, and PQCP-17, " Training, Certification, and Eval-uation of Quality Assurance Auditors - Performance of
- Audits and Vendor / Supplier Surveys," a review of inter-nal audits conducted from 1979 through 1981 showed all sections'of the QA Manuals were not audited on an annual basis, and 10 audit plans and 3 checklists were missing for the 17 internal audits performed.
The Za'ck Corrective Action: t As auditors involved with the audits in question are no longer with the Zack Company and conditions at the time of the actual l audit cannot be recreated, audit plans and checklists cannot be generated at this time. Action to prevent recurrence is the only applicable corrective action. Action to Prevent Recurrence: Audit'or training has been upgraded and is now documented in the Zack Written Practice for Auditor / Lead Auditor training. All audits conducted since October of 1981 are complete in all respects. Training of Auditors / Lead Auditors in the new Writ-ten Practice will take place as time allows. Corrective Action Completed: ~ ~ Training of Auditors / Lead Auditors should be complete by' January 15, 1982. G
- e l
O O TABLE OF CONTENTS s 1. WHAT IS AN AUDIT? 2. WHY AUDIT? 3. WHO AUDITS? 4. HOW TO AUDIT (TECHNIQUES) 5. WHEN TO AUDIT & RE-AUDIT 6. AUDIT FORMS ~ INFORMAT10N ONLY. ~ 91 0 ,, a h/n ( .i l ~ .J'r
O O l m s .) lilFORMAi!O!! EU s SECTION 1 WHAT IS AN AUDIT? GLOSSARY DEFINITIONS CLASSIFICATIONS AND DESCRIPTIONS O a a e ew* en m e e \\\\
-'S /~ O o g GLOSSARY i AUDIT An evaluation of the effectiveness of the s y quality program. "It may be. performed'as a product, process, system or operational i audit. AUDITOR Individual performing audit. Usually a member of the Quality Assurance Department, but also includes other members of audit team not part of QA. CHARACTERISTIC Any property or attribute of an item, process, or service that is distinct, describab1'e and measurable, as conforming or nonconforming to specified quality re-quirements. Quality characteristics are INF0llMAT10N ONLY generally identified in specifications and drawings which describe the item, process, or service. DOCUMENTATION Any written or p'ictorial information de-scribing, defining, specifying, reporting, or certifying activities, requirements, procedures, or results. NONCONFORMANCE A deficiency in characteristics, documen-tation, or procedure which renders the quality of an itam unacceptable or inde-terminate. Examples of nonconformance include: physical defects, test failures, incorrect or inadequate documentation, or deviations from prescribed processing, in-spection or test procedures. s
~ o O OBJECTIVE EVIDENCE Any statement of fact, information, or N record, either quantitative or qualita-tive, pertaining to the quality of an item or service based on observations, measurements, or tests which can be verified. ~ PROCESS AUDIT In-process check of an operation or series of operations to assure that the process consistently produges items of good quality. PRODUCT AUDIT Random sample of final product, checked to determine quality of the output of the-system and used to judge the effectiveness of the quality system. SURVILLANCE The continuing analysis and evaluation of records, met. hods, and procedures including the act of verification to assure conform-ance with technical requirements. l INFOMATION ON!.7 A system whereby supplies and e'quipment in st'orage are subjected to, but not limited to, cyclic, scheduled, and special inspec-- l tion and continuous action to assure that material is maintained in a ready-for-use condition. SYSTEM AUDIT An evaluation of the existence, awardness and implementation of the Quality Assurance system. I VERIFICATION A combination of monitoring actions, inspec-tion or both for the purpose of determining ~ compliance of the contractor with the pro-visions of the contract and evaluating the / effectiveness of propriety of his inspection j or quality control system.
/' = L-O O ) Auditor - Any individual who performs any portion of N an audit, including Lead Auditors, techni-s\\ cal specialists and others such as management representatives and auditors-in-training. Lead Auditor - An individual qualified to organize and direct an audit, report audit findings and evaluate corrective action. Audit - A documented activity performed in accordance ~ with written procedures or checklists to ver-ify, by examination and evaluation of objective ~ evidence, that applicable elements of the Qual-j ity Assurance. Program have been developed, doc-umented and effectively implemented in ac. cord-ance with specified requirements. An audit ~ should not be confused with surveillance or inspection for the sole purpose of process con-trol or product acceptance. Referenced Documents Documents that are referenced in this standard are identified at the' point of. reference and described in Section 6 of this standard. INFORMATION ONLY l m
t O o Ther,e are a number.of different classifications and types of 'S audits that may be utilized to evaluate a Quality Assurance Pro-gram. In this Chapter, the various classifications and types of aadits are discussed. In Chapter 5, the plan and sequence of events of an audit are covered; Chapter 6 and Appendix B provide l typical methods of evaluating a Quality Assurance Program while the criteria for acceptance is covered in Chapter 7. CLASSIFICATION OF AUDITS Audits may be classified by the organizational location (where) of the audit or by the sequence in time (when) of the activity to be evaluated. Some typical classifications of audits are: { Internal Audits of a Quality Assurance Program under an organization's direct control and within its organizational structure. External Audits of a Quality Assurance Program not under an organiza-tion's direct control, and not within its organizational structure, such as a supplier. -- INFORMATION ONLY Pre-Award' Audit of the Qu.31ity Assurance Program of a potential suppli-er of a product or service prior to the placement of the pur-chase order or contract. Post-Award Audit of the Quality ~ Assurance Program of a supplier of a product 'or service af t.er the placement of a purchase order-or ~ contract and before or during the. production activities on the specific purchase order or contract. Supplemental Special audits, in addition to regularly scheduled audits, which are performed due to significant changes in the Quality Assurance Program, the organizational structure or the prod-uct or service quality. Pre-award, post-award and supplemental audits may be either in-ternal or external audits. \\ \\
f' ~ O O . Subclassification of audits may be made by the activities to.be covered, (what) which then determines the specific form of the ) evaluation process. s
- Program s
) Evaluation of'the existence, documentation, compliance with and effectiveness of a Quality Assurance Program that meets the customer requirements and company policy. Product Evaluation of the effectiveness of the Quality Assurance Pro-gram through the assessment of the output of the plant, facil-ity, or manufacturing process. Process Evaluation of the effectiveness of the Quality Assurance Pro-l gram through evaluation of the knowledge of, adherence to and adequacy of specific production methods. j System Evaluation of effectiveness of the Quality Assurance Program through the determination and evaluation of the existence, personnel awareness and the actual practices of the individu-al functional systems that compri- '"e Oc:'_it; ' ;;.;;..;; Program. NOMON ONU Accounting (Operational) A review and appraisal of the effectiveness of the operation-al elements of control of an organization such as organiza-tional structure, authority and responsibility, policies and procedures, and documentation. Partial An examination' of a Quality Assurance Program that embraces a - brief observation of only a portion of the organizations ac-tivities at one time. Follow-up A reinvestigation of some previously known weak area.or_situa-tion of the Quality Assurance Program or a determination if previously committed corrective action was taken and is effective. The areas of process, product, and system audits are really sub-sets of the program audit. The process audit evaluates existence of and compliance with specific operating (manufacturing, test, etc.) instructions. The product audit is an item evaluation of the results of the systems of operations and controls, and the systems audit is a detailed examination of systems and procedures for adequacy and compliance thereto. These three types of audits provide an in-depth analysis of the entire Quality Assurance Program. s
Depending upon the particular portion of'the program being inves-g tigated, partial or follow-up audits are nothing more than limit-ed (by the area of concern to be evaluated) product, process or e system audits. Other Audit-Type Activities There are other activities that are of ten confused with auditing, but they are not the same as auditing as defined in this test. For example: Survey A comprehensive review, analysis and evaluation of the facil-ities, financial resources, personnel, and technical capabil-l ity as well as the Quality Assurance Program of a supplier or contractor is called a survey. It is an overall assessment of a supplier's capability to deliver a product or service on l time at the specified price and in compliance with contract l requirements. It is used to evaluate and assist in selecting potential suppliers and contractors. The techniques employed in performing audits are applicable to surveys. i Surveillance - Witnessing or monitoring, on a statistically sound basis, processes, systems and operations is called surveillance and is similar to process audits except that it is usually per-formed by supervision rather than by inspectors or auditors. Inspection The act of verifying by examination and testing conformance of a product or service to predetermined requirements for purposes of. acceptance or rejection is called, inspection. Management Audit Periodic,and planned witnessing or monitoring o.f processes, systems, and operations by sup'ervision directly or indirectly responsible for the quality-related activities being observed is called Management Auditing and should be performed using sound statistical techniques. Management Auditing is prac-tically the same as' surveillance. l AUDIT ACTIVITIES i Introduction The types and kinds of audits as well as activities similar to audits have been clarified. We will now discuss in more detail the activities involved in the principal mechanics of the audit-ing function. ) d \\ \\
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lilFORilATION ONLY SECTION 2 WY AUDIT? e G INDUSTR M 6 NUCLEAR l l I l l l I m .-.- --- - - - - + - - - - -a w
(,) \\ \\ MATRIX OF RELATIONSHIP BETWEEN SURVEY AND QUALITY ASSURANCE REQUIREMENTS SURVEY SECTION ANSI N45.2 10CFR50 APP.B ASME-NA 4000 i A. Administrative '1,2,3 I,II 4100,4200,4300 B. Procurement Control 5,8 IV,VII' 4441 C. Receiving Control 5 VIII 4442 g* D. Material Storage and Handling 9,'14 'VII, XIV 4442,4460,4540 E. In-Process Control 6,9,15,18 V,VII,XIV, XVII 4420,4442,4450,4460,4540,4900 P. Final Inspection Acceptance and/or Test 11,12,15,18 X,XI,XIV, XVII 4442,4510,4520,4530,4900 G. Packaging and Shipping 6,14 V,XIII
- 4420,4442,4460 11. Drawing and Change control 4,7 III,VI 4410,4430 I.
Tool and Gage Control 13 XII 4600 J.
- 1on-Conforming Material Control 6,16 V,XV 4550 m
K. Sampling Inspection 18 XVII 4900 L. Corrective Action 17 XVI 4800 5 o M. Conformance Specification 2 II 4100 H. Control of Special Processes 10 IX 4450 Es o( O. Audits (Covered in Chapter III) 19 XV77I 4700
2447M AUDITS 3 A comprehensive system of planned and periodic audits shal_1 be carried out by the Manufacturer's or Insta11er's organizatfon to / s assure compliance with all aspects of the Quality Assurance Pr'o 1 ~ The gram and to determine the effectiveness of the Program. audits shall or checklists'by personnel not having-6ffect responsibilities in N . Audit results shall be documented by the areas being audited. the auditing personnel for review by management having responsi-Follow-up action, including re-audit bility in the area audited. Results of. ~ o'f deficient areas, shall be taken where indicated. audits shall be made available to the Inspector., INFORilATION ORY '/ l XVIII. Audits * (Per, 10CFRSO Appendix B) A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the Quality The audits shall be performed in accordance Assurance Program. with the written procedures or checklists by appropriately ' trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and re-viewed by Management having responsibility in the area audited. shall Follow-up action, including re-audit of deficient areas, be taken where indicated [ NA-3720 -QUALITY SYSTEM CERTIFICATE (MATERIALS) A Material Manufacturer shall hold a Quality r l (a) (Materials) verifying the ad-System Certificatea Material Manufacturer's Quality equacy of th' System Program, or alternatively the Material Manufacturer shall have his Quality System Pro-gram surveyed and qualified by the Materials Supplier or by the Manufacturer or Installer of items (NA-3361 or NA-3451). A Materials Supplier shall hold a Quality (b) verifying the System certificate (Materials) adequacy of _tdue Material Supplier's Identifica-tion and Verification Program or Quality System Alternatively, the Material Supplier Program. shall have his Idintification and Verification Program of Qualit'/ System Program surveyed and qualified by the Manufacturer or Installer of items (NA-3361 or NA-3451). A Material Manufacturer or a Material Sup-(c) plier may obtain from the Society a Quality for the manu-System Certificate (Materials) atfacture or supplying of materials which are to The inform- 'S be in compliance with this section. _/ ation to be supplied by the Material Manufacturer or Material Supplier when making application is and N-70C. given in Forms N-70A, N-70B, B-6
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~' O XIX. Audits (Per, ANSI N45.2) A comprehensive system of planned and documented audits shall be q carried out to, verify compliance with all aspects'of the Quality ./ Assurance. Program. The audits.shall be performed in accordance with written procedures or checkli3ts by appropriately trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reviewed by Man-agement having responsibility in the area audited. Responsible Management shall take necessary action to correct the deficiencies revealed by the audit. INFORMATION ONLY Audits should be performed: (1) to provide an objective evaluation compliance with establi'shed requirements, methods and procedures; (2) to assess progress in assigned tasks; 1 i (3) to determine adequacy of Quality Assurance Program I performance; and (4) to verify implementation of recommended corrective action. Deficient areas should be re-audited until corrections have been I accomplished. Audits should include an evaluation of quaiity assurance practices, procedures and instructions; the effectiveness of implementation; and conformance_ with policy directives. In performing this eval'ua-tion, the audits should include evaluation of work areas, activi-ties, process, and items, and review of documents and record. l An audit plan should be developed to provide information about the audit, such as the functional areas to be audited, the names and assignments of those who will perform the audit, the scheduling arrangements, and the. method of' reporting findings and-recommenda-l tions. Audits should be conducted periodically or on a random, unscheduled basis, or both. It is desirable to conduct audits when one or more of the follcwing conditions exists: (1) When it is necessary to determine the capability of a sub-contractor's Quality Assurance Program prior to awarding of contract or purchase order. (2) When, after award of contract, sufficient time has elapsed for the implementation of the Quality Assurance Program, and it is appropriate to determine that the organization is performing the functions as defined in the Quality Assurance Program de-scription, codes, standards, and other contract documents. (3) When significant changes are made in functional areas of the Quality Assurance Program, including significaat reorganiza- ) tions and procedure revisions. l l '
~ g N s w (4) When it is suspected that safety, performance, or reliabil-ity of the item is in jeopardy due to deficiencies and non-conformances in the Quality Assurance Program. (5) When a systematic, independent assessment of program effec-tiveness or item quality or both is considered necessary. (6) When.it is considered necessary to verify implementation of required corrective actions. INMRMATION ONLY 9 6* l* e 4 5 h 4
O o o j INFORMATION ONLY SECTION 3 ~ WH 'AUblTS2 ANSI'N45.2.23 l DEFINITIONS a REQUIREMENTS s 4 9 O e N. q.. ,.,f -) /-
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O O ] l lNFORilATION OliLY BECAUSE QUALITY PEOPLE ARE MANY TIMES INVOLVED IN 'DIFFERENT FUNCTIONS THEY MUST BE VERY CAREFUL THAT THEY ARE ~ AWARE OF WHICH FUNCTION THEY ARE IN AT A GIVEN TIME, e i l > -) 0 NMN O NM
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SUMMARY
- ANSI N45.2.23 I
~} QUALIFICATION OF QUALITY ASSURANCE PROGRAM AUDIT PERSONNEL FOR NUCLEAR FACILITIES l Covers Auditors and Lead Auditors INFORMAD0N ONuf Both must have: Experience and training in scope and subject. l Understanding of ANSI N45.2 and.other standards. Training / orientation in auditing procedures of organization l Training - general, specialized and on-the-job. keadAuditormusthaveatleastten (10) points: Education - up to 4 Experience - up to 9 Professional Credentials - up to 2 Rights of Management - up to 2 - 17 maximum Lead Auditor must also have attested to: Elements of Communication skills T, raining in: Codes QA Programs Audit Techniques Regulation QA Costs Audit Planning. Standards QA Information Feed Back On-the job training.per 45.2.12 elements ~ Audit participation - 5 minimum, one (1) in past year-Examination - ORAL, WRITTEN, PRACTICAL, or COMBINATION l l Both require qualification maintained and documented: Active participation Update review of governing requirements Training Annual evaluation Requalification of Lead Auditor possible by: ' (If, inactive for two (2) years.... Retraining ) Re-examination One audit as Auditor q O
~ 9 9 3 INFONilATION ONLY Certification is transferable Appendix B to 45.2.23 provides form for Lead Auditor i Responsibilities: Employer - training, examination, documentation Auditing organization - personnel selection & assignment Lead Auditor - concur in adequacy of personnel Examination: Can delegate development and administration Maintain integrity by confidential files and' proctoring examinations Must keep copies of type and content Must maintain results 1 l ~ I = e
1, - .a 7-O
SUMMARY
3, ANSI N45.2.12 s INFORMATION ONLYs\\ s " AUDITING OF QUALITY ASSURANCE PROGRAMS" Provides definitions of audit, internal and external audits, auditor, lead auditor, program deficiencies. Covers personnel qualifications, training and maintainance of proficiency. Provides details of audit system content, methods of implement-ing and performing audits, follow-up audits, corrective action and records. Applies to both internal and external audits performed by or for the plant owner, contractor, and other organizations participat-ing in activities affecting the quality of structures, systems, and components of nuclear power plants. Does not apply to surveillance or inspection for the purpose of process control or p.roduct acceptance. Requires responsibility and authority for auditing implementation to be defined and documented. Requires documentation of organization structure, functional re-sponsibilities, levels of authority,.and lines of internal and external communication.for management direction of audits of the ~ quality assurance program. Does not relieve audited organizations or contractors from audit-ing their portion of the Quality Assurance Program. Elements of system to be considered: - Resources - Planning - Scheduling - Preparation - Team Selection and Orientation - Performance - Pre-audit Conference - Post-audit conference - Reporting - Follow-up Actions - Records g gg gg Procedure Qualification Record WPS A
O o ..) SECTION I4 INf0RE.U10N ONI.Y HOW TO AUDIT (TECHNIQUES) . PLAN ASK ~ LISTEN WRITE REPORTS RE-AUDIT ~ I') i abb R A@fl caa Procedure Qualification Record WPS-g
7-O O ~ ^PP'"di*' A INFORMATION ORI.Y x An audit plan should be developed to provide information about the audit, such as the functional areas to be audi~ted, the names j and assignments of those who will perform the audit, the schedul-ing arrangements, and the method of reporting findings and recom-mandations. Audits should be cond'ucted periodically or on a random, unsched-uled basis, or both. It is desirable to conduct audits when one or more of the following conditions exists: i 1. When it is necessary to determine the capability of a sub-contractor's Quality Assurance Program prior to awarding of contract or purchase order. 2. When, after award of contract, sufficient time has elapsed for the implementation of the Quality Assurance Program, and it is appropriate to determine that the organization is per-forming-the functions as defined in the Quality Assurance Program description, codes, standards, and other contract documents. 3. When significant changes are.made in functional areas of the Quality Assurance Program, including significant reorganiza-tions and procedure revisions. I 4. When it.is~ suspected that safety, performance, or reliability of the item is in jeopardy,due to deficiencies and noncon-i formances in the Quality Assurance Program. 5. When a systematic, independent assessment of program effec-l tiveness or item quality or both is considered necessary. i 6. When it is considered necessary to verify implementation of required corrective actions. l y i 1
O i AUDITING TECHNIQUES IN4tMADON 0nd - [ m ..) 1. Written questions in audit procedure are intended to give the auditor a general idea of the subject. The auditor should phrase the questions in the best way for him. Seldom will questions be asked verbatim. It is the audit-or's responsibility to obtain answers. 2. Ask open questions: why, when, how, who, what. 3. The auditor doesn't even ask some questions. Answers are obtained by observation. 4. The auditor may often have to go beyond the scope of the written questions and dig deeper into problem areas. Follow your nose. 5. The same question is often asked several times and of several different people. This uncovers problems in communicati'on and allows the auditor to get the.real answer or make a judgment on what the real answer is. 6. The auditor must be sure to gee the response from the person being interviewed, not from the boss, a staff man, etc. 7. Tell me! Show me! - the by-word of operational audits. Verify and evaluate all findings. This technique quickly dispels any thoughts about not giving the auditor the true facts and also gets the auditor intimately involved in what is actually being done. 8. Separate levels of supervision when asking questions. This way the auditor gets the facts as they are - not as they should be. 9. Obtain copies of local practices - not Company plans which you are. familiar with. This gives the-auditor a chance to evaluate local practices at leisure. 10. Inform people that you,will' be writing notes in front of them. This is not for the purpose of taking down quotes - only to maintain accuracy. Make quick notes and go over notes each evening and fill in more detail while subject is fresh in your mind.
- 11. 'Each evening take time to figure out where you are in time schedule and what you have to go back to on the next day.
12. Don't be critical of an operation unless you have a con-structive recommendation on how to improve it. ] J o'
o ~ (g) q3, AUDITING TECHNIQUES (Cont'd) ' ~ -s 13. Temper your recommendations according to the size of the operation. Be careful not to be too lenient. Recommend the best way, in your, opinion, the responsible personnel can then take the pieces which they can best use. 14. Recommend concepts - not plans. 15. Don't make recommendations right off the bat. Make sure you have the facts first. Avoid early " junior" feedi.acks and basket recommendations. 16. Emphasize weaknesses in the job or the administration of the job rather-than personalities. 17. Don't comment on other organizations by name - especially negative comments. 18. Don't talk about the way you or your organ'ization did it. 19. Start of fast. Take off your coat and blend into the group. l Ask for copies, avoid long breaks and lunch hours. Make l them know you're there with a job to do. 20. Don't reveal your opinion (good or bad) of the answers given through either' comments or facial expressions. Instead,~use the clues to develop further questions in order to get the whole story. 21. Learn as much as possible about your audience. 22. Keep promises - Don't make them. ~23. Be prepared - Know subject material. INF0nNATION ONLY 24. Compliment the contractor. 25. Always maintain control of the interview. 26. Provide assistance in areas where mininterpretation has occurred. 27. Be a good listener. 28. Cultivate a proper attitudo. 29. Observe business ethics. 30. Be professional. -r M ~
AUDITING TECHNIQUES (cont'd) $$) 31. Keep questions short and to the point. ~ 32. Write the' summary of results promptly after the audit. 33. Don't be sarcastic. 34. Don't drink before the interview. 35. Don't get into personalities. INFORMAD0N ONLY 36. Don't argue. 37. Do not criticize a contractor's effo'rts. 38. Recognize that your position may be an imposition. 39. Don't be late for interview. 40. Don't criticize people in front of the boss. Don't be negative. 41. 42. Don't question beyond your level of knowledge. 43. Don't name other companies where you have audited. 44 Don' t discuss politics or Company policy. 45. Don't use Yes or No questions. 46. Don't use_ profane language. 47. Don't allow disagreement between team members durin~g interview. 48. Don't make the audit too secret. e G s//9
l G) o l $[) QUESTIONING TECHNIQUES s PURPOSE OF QUESTIONING p-The skillful use of meaningful questions provides a highly effec-tive means of channeling the thinking toward the desired objec-tives of the session. And in process it can become your most effective " selling" tool. INFORMATION ONLY IMPORTANT FACTORS IN USING QUESTIONS The power of a question in developing constructive thinking, lies in its requirement of an answer so that the individual is stimu-lated to think and mccivated 'to discuss. There are three import-ant factors within your control that affect the level of stimula-tion and motivation. -- Framing the question -- Choosing the right tjpe of question -- Phrasing questiona I l 1 h FRAMING THE QUESTION Some general rules for framing a good question are: j 1. Be brief. 1 1 2. Cover a single point. l 3. Be directly related to the topic. 4. Develop thinking from a constructive point of view. 5. Use words that. have meaning to participants. 6. Use words that are easy for you to use. 7. In most cases, be phrased to avoid "Yes - No" answers by using Why, Where, When, Who and How. 4 9
CHOOSING THE RIGHT TYPE OF QUESTION IRf0tMA110RONU T9 pes-of questions most commonly used in discussions are listed below with some general guideposts for their effective use. TYPE WHEN USED EXAMPLES Factual To get information or opinions. What is a factual Question It can be used successfully to question? Wha't, test for understanding or mater-where, why, when, ial presented or to start con- .how many, etc. versation. Good for discussion starters. L'eading To broaden discussion and chan-Does efficiency Question nel it along certain lines. In enter this picture? this case the instructor sus-Is time the only gests an answer and the group factor involved? analyzes the result. To intro-What about the ef-duce additional facts. To sug-fects on the people gest an answer. (Since this involved? Would type is often Yes-No-type, must you agree that this bn followed with additional is a leading factual or justifying question.) question? Justifying ~To dt pen the discussion by Why do you think it ~ Question having others analyze and justi-is important to by their reasoning. To chal-know good question-lenge old ideas and develop ing technique? How new ones. To avoid snap judg-will.your sugges-ments. To find the real causes tions help? In or problems. In this type of what way wi.11 that questioning, the participants solve the' problem? use'the information they have Why can't we do learned to think out problems tha and draw conclusions or make decisions. (Most effectively used to follow up responses to all other types of questions. ) Alternative The participants must make Which would you pre-Question decisions between two or more fer to use, open or possible courses of action. closed questions? In this case the participants which of these solu-must compare and evaluate sug-tions is best? Can gested solutions and choose we all agree on this ~ the one they like best. solution? (If nec-essary, justify de-cision. Why is A better than B?) l
Q Q ~ a TYPE WHEN USED EXAMPLES Hypothetical"'Makes a tentative assumption Suppose this was a Question in order to draw out and test class in mathemat-the consequences. It involves ics, which types of using what has been learned questions would be and applying it to a possible most applicable and situation. why? Rhetorical To address the entire group We are all interest-Questien but no answer is required or ed in how effective expected. It is used to questions can aid us stimulate thinking, often to be better train-at the beginning of a pre-ers, aren't we? sentation. Direct To ask one specific person. What is a direct Question-This can be used to test question, John? ~ their knowledge or to draw ~ them into the conversation. In this type of question, the participant's name INFORMATION ONLY should be used at the end of the question. ~ General To ask the group at large. Are there any Question It is used to stimulate questions? j discussion, obtain feed-back and give the partic-ipants a chance to ask questions. Controversal When two or more answers Which is more effec-Question are possible. The par-tive - an opened or 'ticipants must give rea-closed question? sons to back their posi-tion and yet understand the merits of both ans-wars. Phrasing Questions Questions can be phrased in either of two (2) ways: ~~ As "Open" questions, or as " Closed" questions.
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7 .J Open: - Questions are "Open" when phrased so that they cannot be answered "Yes" or "No". For example: "How do you feel about this?" What, When, How, Who, Where and Which Closed: Questions'are " Closed" when phrased so that they can be answered "Yes" or "No". For example: "Do you feel this is fair?" Is, Do, Has, Can, Will and Shall INF0ltMAT10N OP.lY As a final word on questioning. Above all, let your questions ccme as a natural part of the discussion. Ask questions because they are important to the development of the discussion. Never take the position of a school master with a list of questions that you must ask or die trying. l l C O m m J
Q 3 THE USES OF QUESTIONS .) lilFORMAT10ll OllLY l l 1. To open discussion. 2. To stimulate interest. 3. To provoke thinking. 4. To accumulate data. 5. fo get individual participation. 6. To develop subject matter. 7. To determine a member's knowledge. 8. To change the trend of discussion. 9. To arrive at a conclusion. 10. To terminate or limit a discussion. f a .)
l ~5 KEY WORDS FOR QUESTIONS ./ INFONilATION ONLY x CLASSIFY oemands arrangement, assembling, or grouping of facts according to some common characteristic. COMPARE Requires detection of the resemblance and the differences among facts. CRITICIZE Exacts good judgement and careful analysis. DEFINE Determine the boundaries of a subject and fixing of a clear meaning. DESCRIBE Select and portray the characteristics of a subject. DISCUSS ' Present the pros and cons of a subject and come up with arguments supporting a position. EXPLAIN - Clarify points which_ obscure a subject. ILLUSTRATE calls for examples to clear up a discussion. INTERPRET Bring out the meaning of a subject as the Teri~on responding sees it. JUSTIFY Show that a thing is reasonable or warranted. OUTLINE Indicate.the main points of a subject. REVIEW-compels.. going over a. subject completely and giving it a critical examination. SUMMARIZE Asks for the presentation of a subject in a concise and compact manner. TRACE Follow in detail the development or progress of some subject. VERIFY Exacts proof that a thing is true. ,. - - - - + -, - _
l t, s,. LISTENING TECHNIQUES TYPES BASIC IDEA PURPOSE EXAMPLES NEUTRAL------Use non-committal words,
- i. Convey ideas of interest.
1. "I see." ~ Don't agree or disagree.
- 2. Keep person talking.
- 2. "Uh-huh."
with person.
- 3. "That's very 23 in teres ting. ",.
ll
- 4. "I understand."
l l EXPLORATORY--l. Who
- 1. Gather additional facts.
- 1. "Who was near the 2.
What
- 2. Help him explore all sides machine at the time
,U 3. Where of a problem. of the accident?" 1 4. Why 2. "What do you feel 5. When the real problem i is?" l RESTATEMENT -Re-state all or part ofk____1. Show him you are li' sten-
- 1. "If I understand, person's last sentence, ing and understand what your idea is.."
or basic idea. he is saying. 2. "This is your de-
- 2. Encourage him to talk.
cision and'the reasons are..." REFLECTIVE---Similar to re-statement
- 1. Show you understand how 1.
"You feel that..." - but you reflect the he feels about what he is 2. "It was a shocking feeling he has expressed. saying. thing as you saw it."
- 2. Encourage him to, and ex-3.
"You felt you didn't O ', plore his problem. get a fair shake." SUMMARIZING--Add up the ideas and/or
- 1. Serves as a base line for 1.."These are the key feelings; and re-state further Giscussion.
ideas you have ex-and/or reflect.
- 2. Brings problem into per-pressed."
spective. 2. If I understand how you feel about the situation..." B
/- o ) INFORilATION ONLY s. SECTION 5 i l WHEN TO AUDIT & RE-AUDIT e h e 0 ed * / 4 e e t W e s l l
Q 7 APPENDIX A ~ An audit plan should be developed to provide information about the audit, such as the functional areas to be audited, the names and assignments of those who will perform the aud- _it, the sch,eduling arrangements, and the method of reporting findings and recommendations. WHEN: Audits should be conducted periodically or on a ran-dom, unscheduled basis, or both. It is desirable to conduct audits when one or more of the following con-ditions exists: 1. When it is necessary to determine the capability of a sub-contractor's Quality Assurance. Program prior to award.- ing of contract or purchase order. 2. When,.after award of contract, sufficient time has elapsed for the implementation of the Quality Assurance Program, and it is appropriate to determine that the organization is performing the functions as defined in the Quality As-surance Program description, codes, standards, and other contract documents. 3. When significant changes are made in functional' areas of the Qual ~ity Assurance Pro, gram, including significcit re-organizations and procedure' revisions.
- 4. 'When it is suspected that' safety, performance, or reli-ability of the item is in jeopardy due to deficiencies and nonconformances in the Qaality Assurance Program.
5. When a systematic, independent assessment of program effectiveness or item quality or both is considered necessary. 6. When it is considered necessary to verify implementation of required corrective actions. t t
s 4 4 .% i . j m INFORMATION ORY SECTION 6 e AUDIT FORMS O d e O G e 0 f a2! ) p h*
i A A ,V w the 8&@M co. 0 A Avoir aeront w
- 1. PROJECT
- 4. AUDIT NO.
- 2. ORGANIZATION AUDITED
- 5. AUDIT DATE(S)
- 6. AUDITORS
- 3. AUDIT LOCATION i
~ A
- 7. AUDIT PURPOSE & SCOPE:
/ k /s *'/ s ell \\ 7 i V
- 8. INDIVIDUALS CONTACTED:
NAME POSITION PRE-AUDIT ENTHANCE I EXIT OTHER ~ l
- 9. AUDIT
SUMMARY
K__AUPI E - _ACTI_J A_l_ FO_ R M IM I IG_ _ U.A.v. \\,Y KY - THE E55EiNiiki. CONIKOL l El EMENTS OF THE FORM RFMAlhi l ~ i nC JMlVIC J
- 10. LEAD AUDITOR DATE A
i t f ( the 8&@M CO. AUDIT CHECKLIST O SURVEY C/L NO. AUDIT DATE REPR2SENTATIVES SUPP,L{ER / DEPARTMENT AUDITORS \\ S - SATISFACTORY U - UNSATISTACTORY N/A - NOT APPLICABLE O - OPEN CHARACTERISTICS FINDINGS SECT. NO. COMMENTS ,u. s 4 f, l m eq l \\ SAMPLE - ACTUAL FORM IN USE MAY () VARY - THE ESSENTIAL CONTROL ELEMENTS.OF THE FORM REMAIN THE SAME / 4 \\ ~
n v v the E&@M CO. QUAUTY ASSURANCE FINDING i PAGE OF
- 1. PROJECT / DEPARTMENT / SUPPLIER
- 2. TYPE OF AUDIT / SURVEILLANCE OFFICE Q DIT I DENT.
FIELD C
- 4. AUDITOR S. DATE OF FINDING
- 7. DISCUSSED WITH C. CONTROLLING DOCUMENT. SECTION. PAR AG R APN. ETC.
- 4. R~fQUIREMENTS SAMPLE - AciUAL FORM IN USE MAY VARY - THE ESSENTIAL CONTROL ELEMENTS OF THE FORM REMAIN THE SAME
- 9. FINDING
-/
- 10. CLECOMMENDED ACTION /S
- 11. SCHEDULED COMPLETION DATE
- 12. RESPONSIBILITY FOR CORRECTIVE ACTION
- 13. CORRECTIVE ACTION TAMEN l
s a 1s. DATE COMPLETED
- 15. SUOMITTED SY RESPONSISLE AUTHORITY
- 16. CORRECTIVE ACTION ACCEPTED lNOT ACCEPTED
~
- 17. VORIFICATION ACTIONS
~~
- 18. IMPLEMENTATION DATE ACCEPTED l NOT ACCEPTED
- 19. DISTRIOUTION
i REPORT NO. 99900785/82-01 7 / ' w SECTION B ' NONCONFORMANCES F 10. Contrary to Criterion V of Appendix B to 10 CFR Part 50 - x and Section 2, " Quality Assurance Program," of the QA Manuals for LaSalle and Clinton, a review of the QA re-cords files for both the LaSalle and Clinton projects indicated that there were no documented indoctrination and training records maintained for one shop welder and -two auditors. The Zack Corrective Action: Training of shop personnel, including welders, has been started. Training is planned to include applicable portions of the Q.A. Manual, 10 CFR 50, 10 CFR 21, plant quality con-trol procedures, and welding procedures. QA and Engineering personnel will likewise be, trained as will shop supervisory personnel and corporate management. Requests for training records from-all sites have been made and some records have been received. At the LaSalle site the i i Q.C. Manager (also a qualified lead auditor) is responsible for providing training and is therefore considered trained by-virtue of prior knowledge of the subject matter. Other lead auditors are the corporate Q. A. Manager, Co: porate Lead Q.A.E. (training Engineer) and a Clinton site Q.A.E. The.Q.A. Manager and~ Lead Q.A.E. are considered trained by' virtue of praining given and.p'rior knowledge of the material. The Clinton. site Q.A.E..has.had on the job training in audit-ing, formalized training in auditing (documents) and has re-cently received training on site. l 1 Action tc Prevent Recurrence: Zack has created and Laplemented a new training progrram. The new program details the requirements for training identifying personnel to be trained, lesson plan and scheduling require-ments. Corrective Action Completion: Training is expected to be complete by February 1, 1983. .) l t i i
REPORT No. 99900785/82-01 ~ SECTION B NOUCONFORMANCES: 11,. Contrary to Criterion V of Appendix B to 10 CFR P' art 50; i QCP-ll, " Training Procr.dures for Personnel performing Quality Control Inspeccion;" PQCP-ll, " Training, Certi-fication, and Evaluation of Quality Control Inspectors;" and PCCP-16 "On-going Training," a review of the QA files for 13 QC Inspectors (LaSalle), 21 QC Inspectors (Clinton), and 4 Welders revealed a lack of documentation for the fol-lowing items: a. Annual eye exam - 14 (Clinton) and 6 (LaSalle) Inspectors; b. Certification Form - 13 (Clinton) and 1 (LaSalle) Inspectors; c. Performance Evaluation - 16 (Clinton) Inspectors; and d. On-going Training - 8 (Clinton) Inspectors and 4 Welders. The Zack Corrective Action:. t Requests have been nade to both the Clinton and LaSalle jobsites for ~all available records pertaining to Inspectors. Information has been received for Inspectors at Clinton and for Inspectors at LaSalle. Training is on-going for all site personnel and for l Chicago Shop and office personnel. Personnel files are being updat'ed as new information'1s rece1tred. I Action to Prevent Re'currence: Written instructions (letter attached) have been sent to all necussary site personnel detailing requirements for forwarding qualification / certification and Training Records to Chicago. Personnel files for Chicago personnel, including welders, were~ audited on November 12, 1982 and deficiencies were noted and are scheduled for completion on December 12, 1982. Annual audit will verify compliance to stated requirements. i 1 Corrective Action Completed: Completion of corrective action is anticipated Dicember 12, 1982. I _/ l i
4650 W.12TH PLA,CE
- CHICAGO (CICERO)lLL 60650
- 312)242 34 4401 WESTERN
- FLINT M4CHIGAN 48506
- 313/736 2040 7 the ZACK co.
CUSTOM METAL FABRICATION NOVEMBER 19, 1982 To : - DISTRIBUTION From: R. BASIAGA Re: PERSONNEL QUALIFICATION / CERTIFICATION & '" RAINING RECORDS
- Sirs, It was noted during a recent audit that Chicago Personnel files are incomplete in content for Zack Site Personnel.
You have already been contacted and have supplied requested dccumen-tation for Site Inspectors pertinent to past records. This letter is to serve as a guideline for future documentation requirements. 'fou shall be required to forward the following Personnel Documents tc the Chicago office as noted for the following personnel. PERSON DOCUMENTS ~ 1. OCI Qualification / Certification Forms Eye Exam Forms Training / Test Forms Performance Evaluation Forms On-Going Training Re':ords Reading Lists Diplon s 2. QAE/QAM/QCM Qualification / Certification Forms Training / Test. Forms Performance Evaluation Forms On-Going Training Records Reading Lists Auditor Qualification / Certification Forms Auditor Evaluation Forms 3. HELDERS Cer'tification/ Qualification Forms On-Going Training Forms 4. ALL OTHERS On-Going Training Forns (cont'd on page 2) %)
- FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NEEDS CF INDUSTRY *
- DEDICATED TO CLEANING AND CUSTCMl2]NG THE AIR OF THE WORLD +
o ~' . To.: DISTRIBUTION (Brought Forward) November.19, 1982 i Please forward these records to the Chicago Quality Assurance Department as soon as possible after generation. Any deficien-cies or inabilities to comply should be noted in writing and forwarded to this office. Your cooperation in this matter will help eliminate the'possi-bility of audit findings in this area in the future. _Very truly yours, THE ZACK COMPANY c z~ pg g Ik.I m~ zut,&r ' R.g. Basiag% RJS/lf Lehd Q.A. Engineer CC: JCZDZ JCDZ l D. Malzahn l D. Calkins l M. Skates N. Rosa B. Prim R. McCarley J. O'Connel R. Usinger G. Moseby G. Larkin C. Baumgardner H. Geyer ' ~ Q.A. File ) I i l
J REPORT NO: 99900785/82-01 ~f ,,o SECTION B NONCONFORMANCES: 12'. Contrary to criterion V of Appendix B to 10 CFR Fart 50, and Paragraph 4.1 of "The Zack Company Procedure for Com-pliance with 10 CFR Part 21", written 10 CFR Part 21 Eval-uation Reports had not been prepared or submitted to super-vision with respect to identified deviations. The Zack Corrective Action: The Zack Company in reporting of 10 CFR Part 21 met the intent of our Procedure to the extent of notifying responsible Zack management personnel. There is evidence of this action in file. The Zack Company Procedure for compliance to 10 CFR Part 21 it in the process of being revised to incorporate the current organization structure. l Action to Prevent Recurrence: Training session to be administered of reporting requirements of Zack's Procedure for compliance to 10 CFR Part 21, and re-vise Procedure to incorporate current organizatior. structure. l Corrective Action Completed: i completion date for training of personnel and r, vision to Procedure: January 14, 1983. O e N \\
J - ~ / REPORT NO. 999000785-82-01 ') SECTION B x NONCONFORMANCES: i n 13. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Paragraph 7.7 of QCP-8, three (3) NCR's (LaSalle) were-initialled for the Project Engineer by an unidentified second, party and one (1) NCR (LaSalle) was unsigned. The Zack Company Corrective Action: The Zack Company.has performed a complete review of NCR's for correct signature. Corrective Action Request (CAR) was issued to correct this deviation from the Procedure. NCR's refer-enced in this Finding are on file at Zack Document Control Center. Action to Prevent Recurrence: Training session performed with personnel who are required to sign NCR's and'a written directive to the Quality Control Man-ager to review all NCR's for compliance, prior to his sign-off. Corrective Action Completed: Training should be complete by December 15, 1982. e e .)
4600 Wi12TH PLACE
- CHICAGO (CICERO)ILL 60650
- 312/242-3434 4401 WESTERN
- FUNT MICHIGAN 48506
- 313/736-2040 D
the. co. CUSTOM METAL FABRICATION November 22, 1982 To: H. GEYER From: R. BASIAGA
Subject:
NCR SIGN-OFF Mr. Geyer, In light of the recent NRC investigation and circumstances leading to the issuance of CAR 019 concerning NCR process-ing at the LaSalle Site, this memo is to serve as your directive to provide documented training to all persons involved in the NCR process in the, requirements of QCP-8 latest revision. Documentation should be forwarded to Chicago Quality Assurance for filing. This memo is also to serve as your directive to review all NCR's prior to final disposition for proper signatures and to correct all deficiencies. All questions ccacerning this matter should be directed to this office. Very truly yciurs, THE ZACK COMPANY R jJ. Bad).aga Lead Q.X. Engineer RJE/lf J f \\ \\ . FOUNDED TO SOLVE THE UNIQUE METAL FABRICATION NF.EDS OF INDUSTFiY +
- DEDICATED TO CLEANING AND CUSTOM 12!NG THE AIR OF THE WORLD
- J REPORT NO: 99900785/82-01, SECTION B
- NONCONFORMANCES:
\\ 14. Contrary to Criterion V of Appendix B to 10 CFR Part 50, QA Manual Section 10, American Welding Society (AWS) Standards D1.3-1978, D1-1979, and Welding Procedure Spec-ifications WPS-7 and WPS-1, inspection of. records identi-fied that a welder had been improperly certified to make groove and fillet welds using the GMAW process as evid-enced by the following unqualified essential variable changes being made to the applicable welding procedure specification (WPS-1) for performance of welder qualifi-cation testing: a. Walder No. 34 made square groove welds in 10, 12, and 14 gage sheet metal test plates in accordance with the requirements of WPS-1 which are as follows: Wire Feed Melt Rate Gas ' Flow Gage Amperage (IPM)- (lbs/hr) (CFH) 10 145 204 3.3 25 12 120 190 3.1 20 14 .100 182 2.9 23 On August 27, 1980, the test platas failed the required bend. tests. subsequently, requalification test plates were made which were not in accordance with WPS-1 as shown by: Wire Fee'd Melt Rate Gas Flow Gage Amperage (IPM) (lbs/hr) (CFH) ' 10 10'O 160 2.3 30 150 2.1 30 12 95 14 70 108 1.62 30 These test plates passed the bend tests on October 23, 1980, and the welder was certified as being qualified for GMAW groove welds. Welder No. 34 made 2 T-joint fillet weld test plates in accordance with WPS-1 as follows: Wire Feed Melt Rate Gas Flow Gage Amperage (IPM) (lbs/hr) (CFH) 22 90 105 1.73 20 One test plate failed on August 29, 1980. Subsequently, requalification test plates were made which were not in accordance with WPS-1 as shown by: ____u____.__..._____
J ~ REPORT NO. 99900785/82-01 SECTION B
- l NONCONFORMANCES:
Wire Feed Melt Rate Gas Flow Gage Amperage (IPM) (lbs/hr) (CFH) ~ I 22 50 105 1.73 20 The test plates passed the bend tests on September 19, 1980, and the welder was certified as being qualified for GMAW fillet welds. The Zack Corrective Action: Welder No. 34 was utilized to perform the 10, 12 and 14 gage square groove procedure qualification test welds when WPS-1 was being requalified. The PQR's are attached and indicate that all. test welds were acceptable. By virtue of qualifying the procedure, the welder is considered qualified. The structural fillet portion of WPS-1 is being requalified by.Zack personnel on the Midland jobsite. Upon completion of this requalification, Welder No. 3'4'will be requalified for this joint configuration. Action to Prevent Recurrence:, A weekly (monthly is current procedure requirement) surveil-lance of welding operati'ns has been instituted to insure that o welding parameters are being adhered to. This surveillance b will continue on a weekly basis for an indefinite period. Corrective Action completion: Requalification of Welder No. 34 projected to be complete by January 2.5, 1983. O e e
Proc;duro Qualificctirn Rec:rd, WPS-1 Test Specifications POP #1 ".at'1. Spec. a m / con Single / Multi Pass sinale cid:d to Single / Multi Arc sinole ~ c-f,'l. Thickness mb_ Current / Polarity Dc/ Reverse 4elding Process cuaw" Amperage Range 65 f-54) r,quipment um 4.,,* n..,4 e. Voltage Range 16-23 ( 10%) Position in 2c. ac ac Travel Speed N/A S l Progression 1c un. 1c on Wire Feed Rate 120 IPM (-54) samplos per Posit. 2 Melt Rate 1.80 Lbs/Hr (-54) Fillar Spec. A 5.is Ambient Temp. 70* rillor Class E-70s-3 Preheat Temp'. N/A 'loctrode Dia. .035" Postheat Temp. N/A Plux N/A Welder Name !.J. Gonzales 3hielding Gas 2 Welder S.S. No. 341-20-9961 ' low Rate _30 CFH Date 8/7/82 Joint Detail Actual Welding Parameters Pass # Elect.@ Amps Volts Wire Melt Trav Gas Feed Rate Spd Flov Tll 1 .035" 70 17 140 2.10 N/A 30 9 e 4x .gr INFORfMi l0H CElY 0AT8 / j y // Test Results cet Type 1 2 3UP 3DN 4 Test Type 1 2 3UP 3DN 4 1 1 A A A A A ceroetch 2 2 A A A A _A 3 Reduced Section 1 1 Tension (KSI) 2 Visual Exam A A A A uid d Bend, 80 4 A= Acceptable R= Rejected enting Crg. h'TTTSBUFhTESTINGLABORATORY [ ( ', h gMg .AB # 10850 9-22-82
- M 5742 Inspector / Level '
Date .2 Oda lity Asisur#nce Manager Date ,artify by signature above that the statements in this record are correct and that the elda were prepared, welded and tested in accordance with the requirements of AWS tendtrd D Section
7-Preccdura OualificttiCn Rerccrd' WPS _* Test Specifications POR #2 F.at'1. Spec. . ' x s2s /cgo Single / Multi Pass Sincle Waldsd to same Single / Multi Arc Sincle 'l j. Thickness 10 'Ga Current / Polarity DC/ Reverse W21 ding Process GMAW Amperage Range 90(-SU Equipment Semiautomatic Voltage Range 17-23 (* 10%) Position IG, 2C, 3G, 4G Travel Speed N/A Progress. ton 3G Up, 3G Dn Wire Feed Rate 90 IPM (-St) Samplos per Posit. 2 Melt Rate 2.40 Lbs/Hr (-54) Fillor Spec. A 5.18 Ambient Temp. 70* Filler Class E-70S-3 Preheat Temp. N/A Electrode Dia. J 45" Postheat Temp. N/A Flux N/A Welder Name T.J. Gonzales CO [ Shieldi.g Gas 2 Welder S.S. No. 341-20-9961 Flow Rate 30 CFH Date 8/10/82 Joint Detail Actual Welding Parameters Pass # Elect Q Amps Volts Wire Melt Trav Gas l Feed Rate Spd Flok Tll 1 .045" 100 17 105 2.80 N/A 30 p -gx gr 1 NFORhW101 OLY l DAT8 / M gy v Test Results ~ rest Tvpe 1 1 2 3UP. 3DN 4 Test Tvpe 1 l2 3UP 3DN 4 ^ ^ Bend Test ccroatch 2 2 A A A A A 3 Reduced Section 1 1 Tension (KSI) 2 1 A A A A A
- uid-d Bend Visual Exam 3
2 A A A A A d 4 A= Acceptable R= Rejected recting orh. SBUR"H TESTING LABOFATORY h,d.b nt( m/7/c LAB #10851 9-22-82 .-u 10851 . Inspector / Level ~ cate 'pu(dlity Asdurabee Manager Date _ crtify by signature above that the statements in this re' cord are correct and that the acida were prepared, welded and tested in accordance with the requirements of AWS 5tandard D Section
1 g,]gg{ Procsduro Qualificatica Rectrd WPS-1 i Test Specifications POR # 1 Mat'l. Spec. A 5267G90 " Single / Multi Pass Sincia W21 dad to _ Sand __ Single / Multi Arc Sincle N . 'I'l. Thickness I2'Ga. N Current / Polarity DC/ Reverse Wolding Frocess GMAW Amperage Range 60 (-54) '.quipment Semiautomatic Voltage Range' 16-23 (* 10%) Position 1G, 2G, 3G, 4G Travel Speed N/A : s Progression 3G Up, 3G Dn Wire Feed Rate 100 IPM (-St) Samplos per Posit. 2 Melt Rate 1.50 Lbs/Hr (-54) Filler Spec. A 5.18 ' Ambient Temp. 70* Filler Class E-705-3 Preh at Temp. N/A Electrode Dia. .035 Postheat Temp. N/A Flux N/A Welder Name T.J. Gonzales Shielding Gas 2 Welder S.S. No. 341-20-9961 Date 8/7/82 Flow Kate 30 CFH Joint Detail Actual Welding Parameters Pass # Elect.@ Amps Volts Wire Melt Trav Gas Feed Rate Spd Flos j 7ll 1 .035" 65 16 104 1.56 N/A 30 ~ Y l,q f INFORf AA1 10N ON LY A BY l> ATE h t~% g // 1 Test Results est Type 1 2 3UP 3ON 4 Test Type 1 2 3UP 3DN 4 Macroetch 2 2 A A A A A 3 Reduced Section 1 1-Tension (KSI) 2 ^ Guidad Bend e Visual Exam g Tast 4 l A= Acceptable R= Rejected Tasting Org. P TTSBURGH TESTING LA30RATORY f[, ,, fg [ y g,g, jc/7/p LAB # 10849 9-22-82 ~' 574 2 Inspector /La'el Date oublity Asshrarice Manager Date v ~ ortify by signature above that the statements in this record are correct and that the welds were prepared, welded and tested in accordance with the requirements of AWS Standard D Section e ee a um
J -s Procedure Qualification Record WPS-~1 gg Test Specifications POR # 4 ' Single / Multi Pass sinole 'il. Spec. A s2s/coe sided to c[ ' Single / Multi Arc sinale ~ s Current / Polarity DC/ Reverse st'l. Thickness J4 cm olding Process GMAw Amperage Range 55 f-54) quipment Semiautomatic Voltage Range ,,16-23 (+ 10%) ~ c0iticn 1G, 2G, 3G, 4G Travel Speed N/A 1 regrGesion 3G Up, 3G Cn Wire Feed Rate 90 IPM (-54) ampica per Posit.. 2 Melt Rate 1.35_Lbs/Hr (-54) illsr Spec. A 5.18 Ambient Temp. 70 l *illar Class E-705-3 Preheat Temp.. N/A l
- lcetrode Dia.
.035" Postheat Temp. N/A ' lux N/A Welder Name T. J. Gonzales 2 Welder S.S. No. 341-20-9961 ihiolding Gas 8-7-82 30 CFH Date
- low R ta Actual Welding Parameters Joint Detail Pass 9; Elect.@ Amps Volts Wirel Melt Trav Gas Feed Rate Spd Flov I
1 .035" 60 16 95 1,43 N/A 30 4" Tg:n liU0 !AAll0K OELY BY - UAT8 g // // ~ 4-v i Test Results Tc::t *ype 1 2 3UP 3DN 4 Test Type 1 2 3UP 3DN 4 ^ ^ l Bend Test 2 A A A A A 'Macroetch 2 Reduced Section 1 3 Tension (KSI) 2 1 ^ Visual Exam g Guided Bend 3 A= Acceptable R= Rejected ~ 4 l ulat b m. t_.S. /o/7!s3 uting org. PITTS URGH TESTING LABORATORY j JB #10723 Mw 8-17-82 CH 5742 Inspector / Level Cate ouaC.ity As era 6ce Manager Date I c:rtify by signature above that the statements in this record are correct and that the welda were prepared, welded and tested in accordance with the requirements of AWS Standard D 1.3-78 Section 6 _}}