ML20028C850
| ML20028C850 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1982 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20028C843 | List: |
| References | |
| REF-QA-99900785 NUDOCS 8301140222 | |
| Download: ML20028C850 (16) | |
Text
.__.
ORGA'NIZATION:
THE ZACK COMPANY CHICAG0, ILLIN0IS Mtt'U n i 1N5Ftcl1UN IN5FtLl10N NO.:
99900785/82-01 DATE(S) 8/3-6/82 & 9/10/82 ON-SITE HOURS: 85 CORRESPONDENCE ADDRESS:
The Zack Company ATTN:
Mrs. Christene Zack DeZutel President 4600 W. 12th Place Chicago, Illinois 60650 ORGANIZATIONAL CONTACT:
Mrs. Christene Zack DeZutel TELEPHONE NUMBER:
(312) 242-3434 PRINCIPAL PRODUCT: Heating, Ventilation,andAirConditioning(HVAC).
NUCLEAR INDUSTRY ACTIVITY: Current activity consists of HVAC systems being furnished to the Commonwealth Edison Company's LaSalle County Station, Units 1 and 2; Illinois Power Company's Clinton Power Station, Unit 1; and Consumers Power Company's Midland Plant, Units 1 and 2.
Th dbfL,;b, 9//9/7A i
ASSIGNED INSPECTOR:
. t. Ellershaw, Heactive & Component Program-IIate/
Section(R& CPS)
OTHER INSPECTOR (S): J. T. Conway, R& CPS L. B. Parker, R& CPS APPROVED BY:
[ 73ws
?At/ec-I. Barnes, Chiet, R& CPS Date INSPECTION BASES AND SCOPE:
A.
BASES:
Appendix B to 10 CFR Part 50.
i B.
SCOPE:
This inspection was conducted as a result of the receipt by the Nuclear Regulatory Commission (NRC) of allegations pertaining to implemen-tation and enforcement of The Zack Company guality assurance program, and was performedinconjunctionwithaninvestigationbytheChicagoFieldOffice of the NRC Office of Investigation.
Specific findings pertaining to the allegations are contained in NRC Report No. 99900785/82-02.
The main (cont. on next page) l PLANT SITE APPLICABILITY:
gstonM9 03731st,hF 50-373; 50-374; 50-329; 50-330; 50-461.
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- !d8?? s=M 99900785 PDR l
ORSANIZATION:
THE ZA d COMPANY CHICAG0, ILLIN0IS
~
REPORT INSPECl10N N0.:
99900785/82-01 RESULTS:
PAGE 2 of 10 SCOPE:
Cont.
purposes of this inspection were to assist the investigative staff in the evaluation of identified concerns, and to establish whether HVAC system manufacture was consistent with applicable codes, contractual, and regulatory reguirements.
To make this determination, the primary areas selected for inspection were welding process control, nonconformances and corrective action, audits, indoctrination and training documcat control, QA records, procurement document control, walder qualifications, and implementation of 10 CFR Part 21.
A.
VIOLATIONS:
None 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 observed deviations being permitted and changes to essential variables being made without of duct rings for the Midland Plant, g gas metal arc welding (GMAW) the procedure being requalified durin in which the welder was using 0.035 inch diameter weld wire, 125 amps, and a gas flow rate of 30 CFH.
The procedure requires the use of 0.045 inch diameter weld wire, 195 amps, and gas flow rate of 20 CFH.
This was the only in-welding observed by the NRC inspector during this inspection. process 2.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Pro'edure c
QCP-29, the following conditions were identified:
a.
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 of actual welding on a specific Zack Company traveler.
3.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, QA Manual Section 6, and AWS D1.1-79, full and complete information requiring location, type, size,andextentofwelds,weldjoints,andmaterial preparation, was not shown on shop travelers / detail drawings provided to shop personnel.
The only information provided is the welding I
procedure specification number, which does not delineate the above information.
-0RGANIZATION:
THE ZACK COMPANY CHICAGO, ILLIN0IS REPORi IN5Ftti1UN NO.:
99900785/82-01 RESULTS:
PAGE 3 of 10 4.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 10, instructions, procedures,iteria for welds.or drawings did not include appropriate qualitative acceatance cr Therefore, without acceptance criteria aeing stipulated, specific inspection requirements were not set forth in welding procedures.
5.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 7, 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.
6.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and QA Manual Section 8, the following conditions were identified:
a.
The Zack Company placed purchase order (P0) Number C-4199 with Central-West Machinery Company in November 1980 for 152 gallons of Hardcast FTA-20.
This material was received and accepted.
Subsecuently, a verbal order for an additional 24 gallons was placec and received in November 1980, and as of the date of this inspection, no written confirmation has been made.
b.
The Zack Company placed P0 number C-874 with Griffiths-McKillen Steel Company on July 5,1979, for 3000 lbs. of 14 gage ASTM A-240 4 x l' x 1/8 Type 304-2B stainless steel and 600 feet of 12 1
stainless angles, ASTM A-276 Type 304, with certifications required.
The received and accepted certification, dated July 18, 1979, for the ASMT A-240 material showed the following:
tensile strength-66,000 psi, phosphorus-0.38; sulfur-0.06; and nitrogen content was not addressed.
The ASTM A-240 standard requires 70,000 psi tensile strength (minimum), 0.045 maximum phosphorus, 0.03 maximum sulfur, and 0.10 maximum nitrogen.
(NOTE:
This material was ordered as nonsafetyinspection function.)
related; however, it does indi-cate inadequacy of the receiving ~
c.
The Zack Com)any placed P0 number C-4458, dated July 30, 1981 with Hobart iorth for 30 lbs. stainless steel weld rod, 3/32",
Type 308.
The P0 stated " Actual or Typical Chemistry, RT (radio-graphy), mechanicals, Charpy V notch tests."
ORGANIZATION:
THE ZACK COMPANY CHICA30, ILLIN0IS s
REPORT IN5PEC110N NO.:
99900785/82-01 RESULTS:
PAGE 4 of 10 The Certified Material Test Report (CMTR) was received and acce)ted by Zack Company, but did not address RT or Charpy V notc1 tests.
(NOTE:
The material specification does not require RT or Charpy's; however, it is still a P0 requirement.)
d.
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 certification 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 certi-fication did not list a heat number and did not provide the actual chemistry.
The chemistry stated cn the certification was simply a reiteration of the chemistry requirements stated in ASTM A-240.
(NOTE:
This material was ordered as nonsafety-related; however, this does not negate the stated requirements.)
e.
The Zack Company placed P0 Number C-739, dated September 29,1978, with US Steel Company for 20 tons of ASTM A-527, A-525 galvanized coils.
Certifications were required.
The material and certifications were received and accepted i
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 the Clinton Power Station site and the Clinton specification did require physical properties to be reported.)
7.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraph 9.1 of Sargent & Lundy Engineers, Chicago, Illinois, Standard Specifi-cation J 2590 for HVAC duct work (Form 320), unapproved materials (Hardcast FTA-20 adhesive and DT tape) were used in sealing HVAC systems at LaSalle.
8.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and PQCP-7,
" Plant Document Control," there was no documented evidence that a voided document file was maintained up-to-date for the QA Manual for Clinton and welding procedure WPS-1.
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ORGANIZATION:
THE ZACK COMPANY
~'
CHICAG0, ILLIN0IS s
KbFURI IN5FtLl1UN N0.:
99900785/82-01 RESULTS:
PAGE 5 of 10 9.
Contrary"to Criterion V of Append'ix B to 10 CFR Part 50, Section 19,
" Audits, of the QA Manuals for LaSalle and Clinton, and PQCP-17,
" Training, Certification, and Evaluation of Quality Assurance Au~di-tors - Performance of Audits and Vendor /Su) plier Surveys," a review of internal audits conducted from 1979 througl 1981 showed all sections of the OA manuals were not audited on an annual basis, and 10 audit plans and 3 checklists were missing for the 17 internal audits performed.
10.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 2,
" Quality Assurance Program," of the QA Manuals for LaSalle and Clinton, a review of the QA records files for both the LaSalle and Clinton projectsindicatedthattherewerenodocumentedindoctrinationand training records maintained for one shop welder and two auditors.
11.
Contrary to Criterion V of Appendix B to 10 CFR Part 50; QCP-11,
" Training Procedures for Personnel performing Quality Control Inspec-tion;" PQCP-11, " Training, Certification, and Evaluation of Quality Control Inspectors;" and PQCP-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 following 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.
12.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and paragraph 4.1 of "The Zack Company Procedure for Compliance with l
10 CFR Part 21," written 10 CFR Part 21 evaluation reports had not been prepared or submitted to supervision with respect to identified deviations.
13.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and aaragraph 7.7 of QCP-8, three NCR's (LaSalle) were initialled for the )roject Engineer by an unidentified second party and one NCR (LaSalle) was unsigned.
14.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, QA Manual Section 10, American Welding Society (AWS) Standards 01.3-1978, D1.1-1979, and Welding Procedure Specifications WPS-7 and WPS-1, I
l y._.
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- -._. 4
iORGANIZATION: THE ZACK COMPANY CHICAG0, ILLIN0IS REPORT INSPECTION N0.:
99900785/82-01 RESULTS:
PAGE 6 of 10 inspection of records identified that a welder had been improperly certified to make groove and fillet welds using the GMAW process as evidenced by the following unqualified essential variable changes being made to the applicable welding, procedure specification (WPS-1) for performance of welder qualification testing:
a.
Welder 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 plates failed the required bend tests.
Subsequently, requalification test plates were made which were not in accordance with WPS-1 as shown by:
Wire Feed Melt Rate Gas Flow Gage Amperage (IPM)
(1bs/hr)
(CFH) 10 100 160 2.3 30 12 95 150 2.1 30 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.
WelderNo.34made2T-jointfilletweldtestplatesinaccordance with WPS-1 as follows:
Wire Feed Melt Rate Gas Flow Gage Amperage (IPM)
(lb/hr)
(CFH) i 22 90 105 1.73 20 One test plate failed on August 29, 1980.
Subsequently, requali-fication test plates were made which were not in accordance with WPS-1 as shown by:
1
J
'0RGANIZATION:
THE ZACK COMPANY CHICAG0, ILLIN0IS REPORT IN5PtG110N NO.:
99900785/82-01 RESULTS:
PAG $7of10 Wire Feed Melt Rate Gas Flow Gage Amperage (IPM)
(lbs/hr)
(CFH) 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.
C.
UNRESOLVED ITEMS:
None D.
OTHER FINDINGS OR COMMENTS:
1.
Areas Inspected a.
Welding Process Control - The NRC inspector reviewed the welding material control system including the issuance, documentation (weld material test reports), retrieval, and storage of welding materials.
The applicable welding procedure specifications, their procedure qualification records, and shop drawings / travelers were reviewed.
In process gas metal arc welding was observed being performed on duct rings being supplied to the Mialand Plant.
As a result of this observation and review,tionally, nonconformance nonconformances B.1, B.2, B.3, and B.4 were identified.
Addi B.5 was identified, although not a specific part of this area of the inspection.
b.
Procurement Document Control - A total of 94 procurement document tiles were reviewed.
Inese files consisted of Zack Company purchase orders and supplements, shipping documentation, material test reports, certificates of conformance, applicable correspondence, receiving inspection reports, and copies of nonconformance reports (if required).
As a result of this review, nonconformance B.6 was identified.
Further, review of Sargent & Lundy Engineers (S&L)
Standard Specification No. J 2590 and S&L's approved material list resulted in nonconformance B.7 being identified.
- However, on January 14, 1982, The Zack Company requested that S&L approve the materials shown in nonconformance B.7 for use at LaSalle.
As of the date of this inspection, S&L had not responded to The Zack Company request.
The NRC inspector expressed concern over the apparent failure of the receiving inspection function to detect the discrepancies /
anomalies between the purchase order requirements and the material certifications.
.0RGANIZATION:
THE ZACK COMPANY CHICAG0, ILLIN0IS REPORT INSPECI1ON N0.:
99900785/82-01 RESULTS:
PAGE 8 of 10 l
i c.
Document Control - A review of the master file for the QA manual.s and quality control and welding procedures, as well as the file on voided documents for the Clinton and LaSalle projects, resulted in the identification of nonconformance B.8.
d.
Audits - A review of reports for 17 internal audits conducted at tile lack, LaSalle, and Clinton sites from 1979 through 1981 and a review of 10 vendor / supplier audit reports conducted from October 1981 through May 1982 resulted in the identification of nonconformance B.9.
e.
QA Records - A review of the QA record file for 13 QC inspectors at LaSalle, 21 QC inspectors at Clinton, 4 welders, and 5 auditors resulted in the identification of nonconformances B.10 and 8.11.
A detailed evaluation of the QA, program for both the LaSalle and Clintonprojects,todetermineifactivitieswerebeingimplemented consistent with quality commitments contained in both QA manuals, and discussions with Zack personnel resulted in the follcwing additional comments:
The QA manuals and applicable procedures for both the LaSalle and Clinton projects appear to require updating to satisfy the requirements of Appendix B to 10 CFR Part 50.
Examples of observed discrepancies are as follows:
(1) The organization chart does not identify all the onsite and offsite groups which function under the cognizance of the QA program, and the QA responsibilities of each group are not described; (2) The organizational positions with stop work authority and the individual responsible for directing and managing the site QA program are not identified; (3) Numerous instances where indoctrination, training, and qualification sessions have not been documented; (4) Qualifications and certifications of inspectors and auditors are not being kept current; (5) The basis for selection of suppliers is not being documented and filed; l
l
'0RGANIZATION:
THE ZACK COMPANY CHICAGO, ILLIN0IS REPORT IN5PELl10N NO.:
99900785/82-01 RESULTS:
PAGE 9 of 10 (6) There was no documentation to indicate that supplier's certi-
~
ficates of conformance are periodically evaluated by audits, independent inspections, or tests to assure they are valid; (7) There were no requirements for in process inspection of work by individuals other than those who performed or dit ectly supervised the activity; (8) Qualification records of procedures, equipment and personnel associated with special processes (e.g., welding) had not
~
been fully established, filed, and kept current; and (9) There was no requirement for management (above or outside
~
the QA organization) to regularly assess the scope, status, and compliance of the QA program to 10 CFR Part 50, Appendix B.
f.
Implementation of 10 CFR Part 21 - The'NRC inspector reviewed the vendor's aracedure "the Lack company's Procedure for Compliance with 10 CFR Part 21," Revision 0, dated December 19 1978, to verify that adequate documented measures were available to meet the reporting requirements of 10 CFR Part 21.
Two reports were examined for completeness and adherence to notification require-ments.
These reports were:
(1) a 10 CFR Part 21 report to NRC Region III on June 9, 1982, concerning fire dampers; and (2) a potential 10 CFR Part 21 re] ort to NRC Region III on August 2, 1982, concerning weld records.
Tlese reports met the notification requirements of the vendor's procedure; however, the required written evaluations had not been prepared.
(See Nonconformance B.12.)
Observations of the employee's bulletin board verified that the above vendor's procedure and Section 206 of the Energy Reorganiza-tion Act of 1974 were properly posted.
g.
Nonconformances and Corrective Action - The NRC inspector reviewed the following vendor's procedure and two quality assurance manual sectionstodeterminetheQA/QCrequirementsforthesubjectarea at the LaSalle site:
Quality Control Procedure 8, Revision 4, l
i 1
- ORGANIZATION:
THE ZACK COMPANY CHICAG0, ILLIN0IS REPORT INSPECTION N0.:
99900785/82-01 RESULTS:
PAGE 10 of 10 dated October 2, 1980, "NCR"; Section 16 of the Manual (QAM), Revision 2, dated April 1,1981, " Quality Assurance Nonconforming Material, Parts or Components," and Section 17 of the QAM Revision 2, dated September 16, 1977, " Corrective Action.A 'Three books of completed NCR's (300) were reviewed in the process of determining specific NCR's to be examined.
Thirty-five specific NCR's and 20 Corrective Action Reports were examined for complete-ness and compliance with the above requirements.
Management review of NCR corrective action was lacking on four of the NCR's examined.
(see Nonconformance B.13).
h.
Welder Qualifications - The NRC inspector reviewed the qualification recoras of tne tour currently employed shop welders (nuclear) to verify that they had been qualified in accordance with the requife-ments of American Welding Society (AWS) Standard, identified.
D1.3-1978.
As a result of this review, Nonconformance B.14 was i
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