ML20028C844

Notice of Nonconformance from Insp on 820803-06 & 0910

ML20028C844
Person / Time
Issue date:	10/12/1982
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20028C843	List: ML20028C842 ML20028C844 ML20028C850
References
REF-QA-99900785 NUDOCS 8301140214
Download: ML20028C844 (9)

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~ y; ~. % f,74 % ;. ~ c p e n i. a. y / r - 3 q/ - n 3 j-".. , ~F; ; y s w 7.- . cr.p J. f, ~, ' L; y Q-m ~ APPENDIX'A ' s'.C 1 1 '? ? e J' ^ n~ The Zack Company... - ~ 1 Docket No. 99900785/82 Iy t+ 14 x s ' NOTICE OF NONCONFORMANCE e + i .~ . ^ Based on the results of an NRC~ inspection ~ conducted on' August 3-6, and e September 10,-1982,:it appears that certain of your-activities were not con - ducted in accordance with NRC requirements as indicated below: 1 Criterion V of Appendix B to 10 CFR Part 50 states: - Activities affecting qualh.y shall.be prescribed by documented instructions, procedures, or_ drawings,. of a type appropriate to the circumstances' and shall be accomplished in ~ accordance with these instructions, procedures or drawings. Instructions,. t ' procedures, or, drawings shall include appropria,te quantitative or qualitative _ s acceptance criteria for determining that'important activities have been-4 I satisfactorily accomplished." Nonconformances with these. requirements are as fol, lows: A. Section10oftheQAManual, Revision 3,statesinpart,"Allweldingfor standard duct work,ith these established procedures,'and deviations of any Class 1 duct work, and Seismic duct work shall be in. i strict accordance w kind shall not be permitted...." Welding Procedure Specification WPS-1, a Gas Metal Arc Welding procedure, paragraph 13.0, states in part, "This procedure is qualified in accordance with AWS D1.1-79, Section 5, Part B...." AWS D1.1-79, Section 5, Part B, states in part, "In preparing the procedure specification, the manufacturer or contractor shall report the specific values for the i ' essential variables that are specified... : The changes set forth in 5.5.2.1 through.5.5.2.5 shall be considered essential changes in a welding procedure and shall require establishing a new procedure by qualifica-tion....~" a j Part5.5.2.3,"GasMetalArcWelding"(GMAW),identifiesthefollowingas j essential variables: A change in electrode diameter; a-change ~of more than 10% above or below the specified mean amperage.for each diameter i electrode used, and an-increase of 25% or more'.a decrease of 10% or more in the rate of flow of shielding gas or mixture.' WPS-1,-when used for 4 the welding of ASTM A-36 material, was qualified with a 0.045 inch diameter electrode J t 195 amps with a gas flow rate of 20. cubic feet perhour(CFH). 4: 8301140214 821012 1 PDR GA999 EMVZACK {- 99900785 PDR ) 1 L A .j I j. ~* c 4 x s v., ,,,..,_.r .,y, n ,,,,,o ..av.y..h,b, _.m"w,,,,,,,_,,-c,yw,my,.yy.,,,,,,vv.,- ...,.w- .e. .,,..-,-e ,,e..~w_y.,-w.m.,.,e-.,.d,,,,,.,r,,,

+ . x Contrary to the above, the NRC inspector ~ observed' deviations being permitted and changes to essential. variables being made without the. _ -procedure being requalified during-GMAW of duct rings for the. Midland . Plant, in~which the welder'was~using 0.035 inch diameter weld wire, 125 amps and a gas-flow rate of 30 CFH. This was the only in process welding o,bserved by the NRC, inspector during this inspection. B. Procedure QCP-29, " Plant Procedure for Welding Electrode Control," Revision 0, dated September 5, 1979, Section 5, states in part, "... The Foreman will record daily on-the Weld Material Control Sheet: -The welder's name and symbol; date; weld procedure to be used; type, size,. 4 and amount of rod issued; rod heat number... and amount returned Section 7 states in part, "... After electrodes have been removed from its original package,~it shall be protected so that its' characteristics or welding properties are not affected.... Traceability of electrodes is accomplished by checkin and weld material control.g dates in (the) specific Zack Company traveler sheet." Contrary to the above,- the following conditions were identified: 1. Electrodes (barewireonspools)werenotbeingprotected,inthat three spools of stainless steel electrodes each of~a different type,~were observed under a work bench in a,n uncovered condition. Further, two spools had been issued on December 17, 1981, and the other on April 16, 1982. 2. 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 of, actual welding on a specific Zack Company traveler. C. gAManualSection6, Revision 3,datedSeptember26,icatio,n~shopbystates 1977 Fabricationinstruction(s)areprovidedtothefabr Engineering in the form of Shop Travelers that specifically set forth all necessary data. This will include:... any special processes to be used such as machine rolled, welded construction, etc...." AWS D1.1,- Section 2, Part A, paragraph 2.1, states in part, " Full and complete information regarding location,, type, size,- and extent of all welds shall be clearly shown on the drawings.... Detail drawings shall clearly indicate by. welding symbols or sketches the details of groove welded joints and the preparation of material required to make them...."

T ^ -Contrary to the above, full and complete information regarding location, type,: size and extent of welds weldjoints-andmaterialpreparation, wasnotsho,wnonshop-travelersIdetaildrawin,gsprovidedtoshoppersonnel. . number,y information provided was the welding procedure specification The onl which does not delineate.the above information. states in D. -QA Manual Section 10, page 2-Revision 3, dated April 1, 1981,lished part,"Allwelding...shallbe4inaccordancewith'ourestab welding procedures,he welding procedures.guirements, tests, and inspec-andsubjectto.there ~ tion set forth in t Contrary-totheabove, instruction ~s, procedures,orldrawingsdidnot include appropriate qualitative acceptance criteria for. welds. Therefore without acceptance criteria being-stipulated, specific. inspection require, ments were not set forth in welding procedures. E. QAManualSection7,page4, Revision 1 dated March 1, 1977 states in part,"Thecontrolledmanufacturingsystemiscontinuedinth,efabrica-tion shop to insure that the activities employed affecting quality are-being satisfactorily accomplished. " Shop supervisor shall be responsible for checking all shop ~ fabrication tickets to insure that they are complete in all respects _.... "They shall be checked for method of fabrication, ired and the extent of welded seams or machine rolled, or any other special process that is requ supervision or inspection required during production." . Contrary to the~above, shop fabrication tickets were not complete in all respects, in that they did not address certain fabrication methods / operations and their sequencing; e.g., rolling or forming and galvanizing. F. QAManualSection8 page 1, Revision 2, dated September 16, 1977 states inpart,"...allpurchasesthataremadewillbemadebyusing,awritten purchase order. Any verbal orders shall be confirmed in writing as soon as possible." Page 2 Revision 1 dated March 1, 1977 states in part, "...ForNuclearPlantand/ ors,eismicapplication,p,hysicalandchemical material certifications will be supplied by vendor. All purchase orders will contain specific statements requiring certification and physical and chemical properties of materials as required...." Section 9, page 1, Revision 1, dated March 1, 1977, states in part,ing "... The plant Quality Control Inspector shall inspect the incom material to insure that it meets the recuirements of the purchase order and that it is acceptable for its intenced use...."

Contrary to the.above, the following conditions were identified: 1. The Zack: Company placed purchase order (P0):NumbeVC-4199 with ~

Central-West Machinery Company in November 1980,d 'accep,ted.

for 152 gallons of Hardcast FTA-20. This material was received an a verbal order for an additional 24-gallons'was placed Subsequently,in November 1980, and as of the date=of this inspection, and received no written confirmation has been made.. 2. The Zack Company placed P0 Number C-874 with Griffith's-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 x1 x 1/8 stainless angles, ASTM A-276 Type 304 with certifications required. The received and acce)ted certification, dated ' July 18, 1979, for the ASTM A-240 material slows the following:. tensile strength-66,000 psi; phosphorus-0.38; sulfur-0.06; and nitrogen content'is not addressed. The ASTM A-240 standard requires-70,000 psi tensile strength minimum, 0.045 maximum phosphoru's, 0.03 maximum sulfur, and.0.10 maximum nitrogen. (NOTE: This material was ordered as non' safety-related; however, it does indicate inadequacy of the receiving inspection function.) 3. The Zack Company placed P0 Number C-4458, dated July /32" Type 30 30, 1981, with Hobart North for 30 lbs. stainless steel weld rod, 3 The P0 stated " Actual or Tygical Chemistry, RT (radiography), mechani-cals, 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: Thematerialspecificationdoes.notrequireRTorCharpy's.) 4. The Zack Company placed P0 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 certifi-cations required. The material was received with a 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 actu:1 chemistry.

The chemistry stated on the certification was simply a reiteratio'n of the chemistry requirements stated in ASTM A-240.- (NOTE: This material was ordered as nonsafety-related; however, this does not negate the [ stated requirement). L I i

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s x- .-5 ~ ~ ^ + 5. 1The Zack Company:placed P0 Number: C-739, dated September 29,1978, l with.U.:S.-Steel Company for 20 tons of ASTM A-527,-A-535--galvanized-coils. Certifications were required.- The material and certifica s i -tions were received and accepted Jshowing:the heat numbers as' .J 74531..and J'74278. "q -The certification did not' provide physical' test reports for heat

J 74531.

(NOTE: The-ASTM material standard does not require physical: properties ~ to be re)orted; howeveri~this material was purchased for use at the~Clinton %wer Station site,and the Clinton specification j did require physical properties to be: reported.). ~ - G. Section'7.1!2ofPQCP-7, Revision 8;"PlantDocument'Co'ntrol"statesin~ -part, " Customer approved editions /re, visions toithe ZQAM'are controlled by-r theQAM. Such control to include as a minimum the:following: -... ~7.1.2.4 Establishment,byproject,Lofa.fileofvoideddocuments. 7.1.' 2. 5 i i Documented distribution. requiring written acknowl.edgment of' receipt." t p y; Section 7.2.2 of PQCP-7, Revision 8, stat'es in part, "New or. revised... WPS's approved by:the customer, are controlled by;the QAM. Such control-j to include as a minimum the provisions of paragraphs:7.2.1.2 through 7.1.2.5 above." ~ ' ~ ~ ~ Contrary to the above the file of voi ed'documerits' did not?contain Revi-sion-0totheZQAM(CiintonProject)norRevisions1,'2,-3,and5of-l Welding Procedure WPS-1. TherewasnodocumentationtoshowthattheQC Manager at Clinton, who is on the Controlled Copy' Distribution List, receivedacopyofWPS-1, Revision 10(June 1,1981)~ortheZQAM, Revision 1 l (September 30,1980). H. Section 19, " Audits" of the QA Manual (ZQAM-Revision 3) for LaSalle states i in part "In plant audits shall be performed a minimum of once a year by i the Quality Control Department Manager...." Section 19," Audits" of the QA Manual (ZQAM-Revision 1) for Clinton states in part, " Audits are performed in accordance with written procedures or - check lists... Audits will be performed as follows: (1) Zack-Site-Every twelve months for all sections of-the manual; (2) Plant-Every twelve months for all sections of the manual...." l 1 'i Section 7.0 of PQCP-17, Revision 1, '! Training, Certification, and Evaluation ~ ofQualit Surveys" y Assurance AuditorsPerformance of Audits and Vendor / Supplier c states in part, "~. 7.3 Auditors / Lead Auditors prepare a-. written audit plan identifying the activity and organization to be audited j 7.7 Audits shall be performed by use of chec( lists (ZQF-86)...." i i r-yv .,,-.=a w,,.#.,,y. ,.,. _,. -,, ~ ,me,., ~.,,, _..,y,,w .-c-p .,,,..,----.,m ,,,m.-,.,,,,,,.,, gi,, ,.,,.,,.,._-,,yv,,

= y ^ g - 1 . Contrary to the above, a review of the internal audits conducted'at the Zack planteand the LaSalle and~Clinton sites from 1979 through 1981-s (no audits were performed in 1982) showed that all sectionsof.the manuals were.not audited on an annual basis. There was also no evidence of 10 audit plans or 3 checklists for the 17 internal audits performed. I. Section2,"QualityAssurance'Proram".oftheQAManual(ZQAM-Revision 1) for Clinton states in part, ion an uality Assurance Program provides the "The following: (1)Indoctrinat training of personnel performing acti-vities affecting Quality.... Any activities affecting quality shall be documented." Section 2 "QualityAssuranceProgram"of-theQAManual(ZQAM-Revision 3), for LaSalle states in part, "... Th'e Quality Assurance Manager shall be Quality Control personnel.g a permanent file on all-Quality Assurance and responsible for maintainin This shall include education, background, training, experience and the results of testing and examination." Contrary to the above, a review of the QA record files for both the LaSalle and'Clintonprojectsindicatedthattherewerenodocumentedindoctrination-and training records maintained for one shop welder and two home office auditorsassociatedwithbothprojects. J. Procedure QCP-11, Revision 6, " Training Procedures for Personnel Performing Quality Control Inspection" requires that QC inspection personnel for theLaSalleprojectmeetvisualandcolorvisionstandards,andthe visual requirements be verified annually by reexamination. In addition, certification forms which will be completed for'each person who performs inspections willberetainedintheprojectfiles. ProcedurePQC.7-11 Revision 1 " Training, Certificationi and Evaluation ofQualityControlInspectorsfrequires-thatQCinspectionp'ersonnelfor-theClintonprojecthaveanannualexaminationforvisualacuity,and the results of these examinations be maintained in the files. The certification is also documented on a form which is maintained in the files. In addition, the inspectors are evaluated 30 days after certifi-cation and annually thereafter, and the evaulations are documented,on a form. Procedure PQCP-16, Revision 1, "On going Training" requires that QC and plant fabrication personnel receive monthly training from both the Quality Control Manager and the Production Manager, and each training session is documented and retained in the QA files. i i l l l L

o + >T '.j -7. Contrary)to the'above, a review of.the QA files for 13 QC inspectors (LaSalle of documentation for the following items: 1. AnnualEye~ Exam-15(Clinton)and6(LaSalle) inspectors; ~ 2. Certification Form - 13 (Clinton) and 1 (LaSalle) inspectors;- PerformanceEvaluation-16(Clinton) inspectors;and 3. 4. OngoingTraining-8(Clinton)inspectorsand4 welders. K. = Paragrap"h 4. of "The Zack Company Procedure for Compliance with 10 CFR Part 21, Revision 0, dated December 9, 1978, states in part, "Any; employee of The Zack Company who has reason to believe a deviation exists, is required to supply this information both verbally and in writing to his immediate supervisor... The manager or supervisor to ~ whom'the deviation is reported shall review all details concerning the deviation to determine if a defect exists. If, in his opinion, the deviation is a defect, or is potentially a defect or if he is uncertain whether it is a defect, the manager or supervisor,shall forward the writtenreport,jectmanager." which shall include the results of his evaluation to the appropriate pro Contrary to the above, written 10 CFR Part 21 evaluation reports had not been prepared or submitted to supervision with respect to identified ~ deviations. L. Paragraph 9.1 of Sargent & Lundy Engineers, Chicago, Illinois, Standard Specification J-2590 for HVAC Duct work (Form 320) states in part, "The Contractor (Zack Company) shall be responsible for the leak tightness of each duct system. To assure minimum leakage the Contractor shall seal alljointsandseamswhicharenotgasketedwithand(sic) approved material as specified in Article 3.5 for all nonnuclear applications, and shall be in accordance with Article 3.6 for all nuclear plant systems, except HVAC systems in the service building, which can be the same as nonnuclear applications...." Contrary to the above, unapproved materials (Hardcast FTA-20 adhesive and duct tape) were used in sealing HVAC systems at LaSalle. M. Paragraph 7.7 of QCP-8, "NCR," Revision 4, dated October 2, 1980, requires thesignatureoftheProjectEngineerinBlank15 of The Zack Company NonconformanceReport(FormZQF-11) acknowledging,correctiveaction taken. e i l

y m ,s 's 4 = ~ n q- ..+ f-4 ' ~ -Contra 4to the'above Jthree NCR's' 622 776, 781, LaSalle)wereinitialled-r Jfor.th Proiect Engine,er by an unid ntified second party, and one NCR -(475,LaSalle)wasunsigned. e N. QA Manual' Suction 10, pase 3, Revision 2, dated September 16 1977,: states 'in part, "...... The welcers performing the' work shall on1,be those. -welders who:have successfully demonstrated through proper esting that they.have.the skills necessary to do quality welding of the specified qualit level required. :When-seismic class weldin _is required, -only't ose welders and welding procedures qualifie in.accordance with o the re uirements.of-A.W.S shall be used."- WPS-7 "Weldin P d ~ Revision 8pparar. Qualification / Certification of, Wel Specif cation fo page 2, _ qualification,-(graph l6.3, states in part, "The specifics of welder ' i.e., gage / thickness of< steel, size,and classification: o .of filler metal, ;aps, -volts, wire-feed-speed,1 melt rate gas flow,and-g 4 Lpositions of test, may... be revised to facilitate job needs. Such revisions shall be consistent with the requirements of AWS D1.1-79 Sections 3 and Si AWSD1.378Section6(and)theapplicable. Welding Procedure Specification :...." AWS D1.3-78 Section 6, parag aph 6.8.2.9, 1 states in part "The welding procedure used in a welder-i shall~bea_qualifiedweldingprocedure...."qualificationo AWS D1.1-79 and D1.3-78, Section 5.5 and 6-respectively,' address" essential- )., variables which, if change ; require establishing _a new procedure by qualification. Such essen 1al variables include: an increase of 25% or more or a decrease of-10% or more in the shielding gas flow rate a reduction in melting rate, welding current or wire feed speed of ;-and i more than 5%. 1 Contrary to the above inspectionLof records. identified that a welder had been improperly certified to make groove and fillet welds using the GMAW as evidenced b the following ungualified essential variable process,being.made-toteapplicableweldingprocedurespecification(WPS-1) changes for the performance of welder qualification testing: WelderNo.34madesquaregrooveweldsin10,12,and14ghesheet. ~ 1. metal test plates in accordance with.the-requirements of S-1, ) which are as follows: l Gage Amperage WireFeed(IPM) MeltRate(lbs/hr) GasFlow(CFH) i -10 145 204-3.3 25-12 120 190 3.1 20 14 100 182 2.9 23 l On August 27, 1980, the test plates failed the required bend tests. L I x A_

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-' g s l 'g ;.,_ ~ 9; t_ v-t 1 3 1., 1 r Qf Subsequently,1re ualification t'est latis in accordance wi h WPS-14as shown, y:j/were'made~which'were z: ..;:. J., ,y Gage JAmperage / Wire Feed (IPM)ZMelt' Rate (lbs/hr) Gas 1F1ow(CFH) ./ 10 100 160 f 2.3. ',230' ^ 12. 95 ~ 14- ~70- ~ 150 2.1 30 108 LL 625 i -. ._ c. 30 .t These test plates passed the bend' tests on October 23,=1980,- and-the welder.was certified as being qualified for GMAW groove welds. 4 2. 'withWPS-1~asfollows: joint:filletweldtestplat.esinaccordance. Welder No.-34 made.2 T-1 Gage Asperage' WireFeed(IPM) MeltRate(lbs/hr) GasFlow(CFH) 22 90 105 1.73 20 One-test plate failed on August 29, 1980. i-2 Subsequently, requalification test plates were made which were not j in accordance with WPS-1 as shown by: i Gage -Amperage WireFeed(IPM) MeltRate(1bs/hr) GasFlow(CFH) l 22 50 -80 1.2 s30~ These test. plates passed the bend tests on September 19 1980, and the welder was certified as being qualified for GMAW filletwelds. i - 3 ) i e I e f i I l l-l- .~ l I 1 ? j La,,, L..,._.,-~..--.~...--,--,,-.}}