ML20028D802
| ML20028D802 | |
| Person / Time | |
|---|---|
| Issue date: | 04/23/1982 |
| From: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Fortuna R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20027A771 | List: |
| References | |
| NUDOCS 8301190468 | |
| Download: ML20028D802 (12) | |
Text
{{#Wiki_filter:_ _ _ / *, uNITEo STATES [.. 1 NUCLEAR REGULATORY COMMISSION 1 / E REGloN IV %..'..[.8 [ k 611 RYAN P'/.ZA DRIVE. su!TE *:M ARUNGioN, TEX AS 75011 i APR 2 31552
- 'E'O.ASDUM FOR
Roger A. Fortuna, Acting Director, Investigation Staff, IE i FROM: John T. Collins, Regional Administrator, Region IV
SUBJECT:
HkY'.!ARD TYLER PUMP COMPANY (HTPC) - IE REVIEW 0F INVESTIGATION /IHSPECTION FINDINGS
REFERENCE:
MEMORANDUM, FORTUNA TO COLLIHS, DATED APRIL 2, 1982 A review has been made by the Region IV staff of the referenced memorandum which. transmitted questions resulting from IE review of the HTPC final draft investigation and inspection reports. In addition to providing the requested specific responses, we have included a general statement on investigaticn/ inspection bases and approach which we believe will assist in clarifying any misunderstandings that may exist as to the scope of the Regicnal follow up of allegations at HTPC. I. Investication/Insoection Bases and Acoroach It would appear from our review of the transmittal' enclosure, that there is a misconception as to the methods and bases used for investigation of allegations. Investigative effort is not applied uniformly to a simple tabulation of items contained in documented allegations. Rather, the approach utilized focuses on that subject material which has specificity in regard to identification of the nature of the deficiency, affected items and responsible personnel. The approach is reflected by the sworn statements which, as referenced in your memorandum, are in effect a distillation of alleger concerns. Similarly, investigative reports are written to document findings with respect to specific concerns provided to the investigative staff, and would not normally address in any detail, concerns resolved by interview as being non-factual and/or non-productive, generalized statements made without any, substantiating basis in fact, or items of clearly established non-safety concern. t The inspection role in this investigation was to: (1) provide to the investigative staff technical guidance and assessment of the signif1-cance of information develcped; (2) ascertain, if possible, the validity of specific ccncerns through eya.mination of manufacturing / QA recceds or direct cbservation of activities, and (3) measure QA program compliance by inspection, in these subject areas where allegations hcd been made. 8301190468 830104 PDR COMMS NRCC CORRESPONDENCE PDR
i Memo to Fortuna. These inspecticns.iere perfcrmed by selection of a sample of subject material per-inent to the QA program area to be inspected, and a review ade of QA prccram ccmpliance. Discrepancies identified by inspecticn were cccumanted as nonconformances in the inspection l repcrts, in order to provide both a scope of required corrective i acticns and a basis for evaluation of required enforcement actions after receipt of the vendor corrective action respense. These inspections were acccmplishcd using the same basic concepts employed in all MRC inspections; i.e., a sampling technique, and no attempt was made, or believed necessary, to use 100% of the information provided in order to assess QA program compliance. II. Soecific Issues This part of our response has been prepared using the same nemen-clature for ease of reference, as utilized in the enclosure to your memorandum. A. Issues Not Addressed 1. Statement by A-1 that 20-30 pumps, about 6 feet tall with 28" outlets, were shipped to an unknown nuclear site with some pumps out_ of specification,' and of A-l's ccmcent that A-35 informed him that out of specification pumps would be downgraded to non-nuclear. Region IV Response - A review was performed of HTPC nuclear contracts in regard to this item, without identification of any safety related pumps with 28" outlets being furnished to any customer. This information, coupled with the non-specificity of the allegation, resulted in the issue not being fu'rt'her pursued or documanted in the investigation / inspection reports by the staff. 2 2. Statement by A 6 t' hat he cbserved yielding of pump bolts during assembly prior to hydro test, and that the same bolts,were used in final assembly'of these pumps. Region IV Response - To clarify the reported issue, it is our understanding that A-6 stated that he saw 6 foot ex-tensions used on wrenches for torqueing of bolts and he knew the yield point was passed. He did not, in fact, claim that he cbserved yielding of pump bolts during pump assembly. The alleger did not provide any specific basis for his belief that yield point had been exceeded.
Memo to Fortura An inspecticn was perfor:ed in regard to this item and his additional sta a.ents en absence of written assembly or torque procedures. The primary sample utilized for this evaluation was records pertaining to a Class 2 pump furnished to Hope Creek. The inspection results which are summarized in paragraph D.6 of VPB Inspection Report l'o. gg900345/82-02 indicated that written assembly and torque procedures had been prepared and referenced on the Assembly Route Sheet for the pump. Further, a torque wrench and multiplier which were included in the HTPC calibration program were assigned to the assembly area. Failure to establish required accuracy standards for the torque wrench was reflected by the issue of a nonconformance. Direct verification of adequacy of applied torque values cculd not be accomplished, as a result of the absence of any assembled pumps in the facility during the inspec-tion. It was additionally pointed out to HTPC management during the exit meeting conducted on January 29, 1982, that HTPC torque procedures specified only minimum torque requirements and did not define maximum allowable values. This subject was identified as one that would be considered for possible follow up at customer sites. 3. In his affidavit, A-5 indicates that certain original pump bearings caused overheating and replacement bearings had been ordered, but original bearings were installed because the replacement bearings had not a. rived in time to be used. Region IV Response - Please refer to Document 6 in the investigation report (99900345/82-01) wherein A-5 denied making the statement and declined to anwer any questions as to: a Who - Supervised or made decisions. b. What - Pumps (Identification). c. When - Time Frame. d. Type - Nuclear or ncn-nuclear. Further, as indicated in his alleged affidavit, "I never knew the whole story," could be one reason why this indi-vidual refused to answer questior.s. Due to a lack of datailed infcreation, the issue was not further pursued by the investigator.
1 i / Memo to Fortuna a-4 Statement by A-6 that a casing wear ring (Contract 8106, Dwg. 01-200-422) was tapped all the way through and should not be. Region IV Response - This item was not followed up by the investigative staff and was not included in the sample used by the inspection staff to evaluate manufacturing process control QA program compliance. 5. Investigation / Inspection of "related" activities conducted by the Ccde Authorized Inspector. Region IV Response - An interview of the referenced Authorized Nuclear Inspector was not conducted, as a result of the individual not being currently assigned to HTPC. This matter was further pursued during the investigation by interviews of other welding personnel. These interviews did not support this allegation, in that the personnel stated that the Authori7ed Nuclear Inspector did witness reouired hold points. The issue was, therefore, considered unsubstantiated and/or non-productive and was not specifi-cally addressed in the investigative report. 6. HTPC activities of Design Control General - procedures / responsibilities, a. b. With respect to the AMPC0 seismic support, was there any design control over a change in the hole location? Was the seismic analysis affected by this change? If so, was the analysis revised to reflect this change? Do you consider this matter resolved? Region IV Response - An overall review of design centrol was not performed during the investigation / inspection, in that review of allegation subject material did not indicate potential improprieties on the part of design engineering personnel. Compliance of manufactQring personnel with engineering requirements and engineering change practices were examined and documented in Inspection Report No. 99900345/82-02, in that these subject areas were pertinent to the allegations. With respect to AMPC0 seismic supports, dccumentation for 6 pairs of Class 3 seismic supports was reviewed for the identified time frame. No ( documentation; e.g., nonconformance reports, repair route sheets, was located which would indicate repair welding had been performed, or that changes had been mace in hole l l l
Memo to Fortuna locations. Accordingly, to date we have no infornation which would either substantiate this specific allegation, or be pertinent to the specific questions asked. Final resolution of this item will depend, in part, on site inspection of the supports with respect to fabrication
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drawing requirements. S. Issues Addressed by Region IV 1. Testing of Pumos Were the tests that were performed by Hayward Tyler in accordance with code and purchaser's design specifications? Identify examinations conducted and summary of information collected regarding pump test. Region IV Response - No information was developed which would provide any basis for the non-specific allegations by A-1 in regard to pump performance testing. In addition to detailed examination of Hope Creek Class 2 punp testing records, reviews were also made of route sheets (during inspection of manufacturing process control) for testing performed on pumps furnished to Yellow Creek and South Texas. The information generated from the inspection sample indi-cated that: (a) each pump was..ydrotested in accordance with ASME Section III Code requirements with custcmer. and/or Authorized Nuclear Inspector witness; and (b) all of the examined pumps were performance tested to defined standards with customer witness. l It is expected, hcwever, that additional performance testing will be addressed by the vendor in response to the investi-gation/ inspection findings, primarily as a means of verifying adequacy of pumps for intended service. 2. Castings (Casings, Suction Bowls,.etc.) (a) Were castings non-destructively examined by or for HTPC in accordance with ASME Code requirements? Who performed the non-destructive testing of raw castings? (b) Was repair work required on castings examined in accordance with ASME Ccde requirements? ho performed the examinations? (c) What type of non-destructive examinations were par-formeo? ~.
f i t'.emo to Fortuna -C-(d) Did Region IV review the results of the non-estruc-tive examinations? If so, what were the results of L the Region's review? Region IV Response - An inspection was performed of this activit S/Nos.1-4) y utilizing four Hope Creek pump casings (Pump ~ as a sample. The information generated frcm this inspection was as folicws: Castings were procured from the supplier foundby to a. visual examination requirements only. b. HTPC performed visual and liquid penetrant examina-tions of the castings on both rough and final machined surfaces and also on excavations and repairs. Review of the liquid penetrant examination procedure, c. personnel qualifications, NDE reports and applicable ASME Code requirements, showed no nonconformance. Region IV considers this subject adequately addressed, with the exception of the issue identified in paragraph D.4. of Inspection Report No. 99900345/82-02 pertaining to suction bowl material defect nonconformance control. 3. Pumo Cleanino It was stated that pumps were cleaned in a 140*F solution in lieu of the 180*F solution called for in the procedure. This was approved by the shop supervisor. Did the design / process engineer also okay the use of the 140*F solution? If so, what was the purpose of specifying 180 F solution and the basis for approving the 140*F solution? Provide any infor-mation regarding this area and state conclusions as to the acceptability of using a 140 F cleaning solution. Region IV Response - Review of investigative notes indicates i that the referenced supervisor identified Contract 8049; i.e., Hope Creek, as the applicable contract where a 140*F cleaning solution was allegedly used. These notes also show that approval for use of cleaning solution at this temperature was given only by the Vice President-Manufac-turing. We have no information to indicate the technical basis for this approval, in that this specific subject was i not addressed durinc interview of the latter individual. ~ Detailad inspection of control of cleaning was not perfor ed during the investigation / inspection, in that in-prccess l cleaning was not being perforced and the only available, documentation was cperaticn sign off on assembly route sheets. i
? Memo to Fortuna : t An examination was performed cf the assembly route i j sheets for Contract No. 8019 which included cleaning in the sccpe of the review. Results of this review are i par-ially reflected in Notice of Nonconformance, Item D.2, in which it was identified that Pump Serial No. 804901 was assembled and subsequent operations performed on Revision B ' of th'e route sheet, without sign off to dencte performance i of required QC operations. One of the affected operations was Operation No. 140-Inspection for cleanliness prior to assembly. A Nonconformance Report (NCR B 1202) was written by QC in regard to the passed cperations, but an NCR was not identified on the route sheet with respect to use of a 140*F cleaning solution. The applicable cleaning operation, J Operation No. 130 (Clean wetted parts per 2.3.7/5-1) was-signed off as being satisfactorily accomplished on December 22, 1979,-by a person with the initials "J.L." Inspection for cleanliness and preparation of a cleaning ~ report were ultimately signed off by QC on June 19, 1980, in Operation No. 140 of Revision F of the route sheet. It is the intent of Region IV to address the basis for issue of a cleaning report in enforcement correspondence with the vendor. This is as a result of NRC review of the assembly l route sheets for Contract No. 8049 pumps not indicating total disassembly was performed after identification of the passed l QC operations. Consequently, we currently have not esta-l blished how an effective cleanliness inspection could have i been performed. 4. Bol tino. 1 Were any incorrect sized (length) bo'lts or studs found to be used in the assembly of the pumps? If so, what is the basis for acceptance? Did a review of the records indicate that the correct material was used in the fabrication of bolts and nuts? Region IV Response - Review of A-l's statement, in which this allegation was made, shows that the alleger was ncn-specific with respect to use of incorrect length bolts. i During the investigation / inspection, a review was made of studs and nuts used in the assembly of Pump Serial No. 80a901, Hope Creek. Summary documentation of this subject is contained in paragraph D.6 of Inspection Report i j No. 99900245/82-02. This inspection ccmpared Engineering j Bill of Materials requirements with respect to precurement 4 4 a .,e ..--_.w, ,-m.. ,m.-..-,r-, - -, -- -,. - ---- -. -.,.----....e.mm ,.,e e--
Memo to Fortuna -a. documentation and vendor Certified Material Test Reports, with no discrepancies noted. Review of inspection notes also indicated a similar review was performed of casing studs utilized for Pump Serial No. 822304, Yellow Creek, viith again no discrepancies identified. We consider this subject adequately addressed when viewed in the context of the nature of the allegation. 5. Weldino (a) Was welding required on any pressure retaining part? (b) If, so, what type of non-destructive examinations were performed by or for HTPC on G ese parts? Did those examinations meet ASME Class 2 or Class 3 requirements, as appropriate? Were X-ray examinations required to meet ASME Code requirements? (c) Did the region review any of the results of the non-destructive examinations? If so, what were the results of the region's review? (d) With regard to WPS 6.3.3/3-11, were there any horizon-tal welds completed for which welders were not quali-fied? If so, how was acceptcbility'of these welds determined? (e) Were there any cases where incorrect welding rod material was found to be used? Region IV Response - As indicated in the Region IV response to II.B.2 'above; i.e., Castings (Casings, Suction Bowls, etc.) welding upgrading of pressure boundary castings is performed by HTPC. Additionally, pressure boundary welds are made in VSN design pumps, as referenced in the Motice t of Nonconformance, Item E, Inspection Report No. l 99900345/82-03. Only liquid penetrant examinations were performed by HTPC for the referenced welding activities and this was determined to be consistent with ASME Section III Code, Class 2 and 3 requirements for applicable pump sizes. As indicated previously in II.B.2, liquid pene-g trant examination reports were reviewed by Region IV personnel, without identification of any deficiency or nonconformance with respect to ASME Code or QA program requirements. I f
9 = I Memo to Fortuna In regard to the question on welding ;:sition application of WPS 6.3.3/3-1.1, we have no information in regard to v.h' ether a 23 horizontal position was used. Documentation of actual welding position used was not made or required, l so we are unable to state whether the horizontal position was ever actually used. It should be noted, however, ~ that liquid penetrant examinations were performed of I repair welds which provides some basis for determination } of weld acceptability. No cases were identified during } the investigation / inspection where incorrect welding materials were found to have been used. As indicated, however, in "otice of Nonconformance, Item E, Inspection Report No. 99900345/82-03, at least one case was noted where the identity of welding materials used was not established. We consider the subject of welding controls to have been adequately addressed by the investigation / 1 inspection effort and consistent with the guidelines contained in the applicable inspection plan. 6. Base Plates Were the changes in dimensions or layout resulting from the " mapping" technique of cutting base plates incorporated in the design drawings and reviewed by the design engineers to determine acceptability? What was the basis for accep-tability? Region IV Response - Regional review of this issue (A-4 statement) during the investigation / inspection indicated that the allegation was non-specific, i.e., nature of problem and affected contract (s) were not defined; and also applied to an item subject to inspection at several stages of pump j. manufacture. Accordingly, the allegation was finally categorized as lacking sufficient significance to make j investigation / inspection effort productive. 7. Lona Tubes l With respect to the long tube fcbricated for pumps to be I used at the South Texas plants, was the type of material used in accordance with the design specifications and applicable code requirements?
!!emo to Fortuna Region IV Response - Investigation / inspection effort was nct applied to this issue, in that review of contracts during the investigation / inspection did not indicate Contract Nos. 5077/2078 were either nuclear, or applicable to Scuth Texas. 8. Flame Straightening Indicate whether flame straightening was used en or could have affected material other than Type 410 ferritic stain-less steel. (Note - Inspection plan references Type 30055). Region IV Response - Considerable investigation / inspection effort was made during Ja.nuary and March 1982, to establish the materials scope and practices used for flame straight-ening of pump shafts. The information contained in Inspection Report No. 99900345/82-03, pertaining to straightening to Type 410 shaft materials, represents the total information Region IV was able to develop en this subject. 9. ECR's Clarify the technical issues related to ECR's 254, 260,261, and 279 and discuss whether any issues identified in these ECR's relate to allegations. Region IV Response - Notice of Nonconformance Item B, Inspec-tion Report No. 99900345/82-02, which pertains to ECR Nos. 254,260, 261 and 274 (not 279) was written as a QA program-matic finding. The referenced ECRs have no specific-technical significance and do not relate to the allegations The reasons for the ECRs were not recorded and were not considered sufficiently significant to require detailed evaluation during the inspection although appropriate resolution / corrective actions are expected to be included in the vendor's response to the generic nonconfermance. We cannot, therefore, comment any further with regard to the identified ouestions. The reasons for reviewing ECRs are illustrated by Notice of Ronconformance Item F, Inspec-tion Report No. 99900345/82-02. 10. Glue There has been a question raised as to whether the consti-tut..ts in the Eastman 910 cr Duro Super Glue could have a deletericus effect en pump-c:crenents. Frcm the infccma-tion ycu accuired on this.atter can ycu answer this cues-ticn?
Memo to Fortuna Region IV Response - In recard to this additional subject, Region IV has no information c indicate bonding of 0-ring joints wi-h the aforementioned adhesive would have a deletericus effect on pump ccmponents. 11. Calibration Tools In th'e investigation report (pg. 6(d), notes that " indivi-dual A-20 states that numercus pleas to upper management to acquire more QC equipment such as micrometers, depth mike and other tools were largely ignored." Please discuss the results of your review regarding this matter. Region IV Response - Region IV considers the above of importance only in the context of QA/QC perceived support of the HTPC QA program by upper management. No informa-tion was provided during interviews, or obtained by review of statements, which would indicate product quality was impacted in any way by absence of a necessary measuring device. 12. Nonconformance Items Inspection Reports 99900345/82-02 and 82-03 identify noncon-formance items and findings. Mcwever, it is not clear whether Region IV determined the technical significance regarding each nonconformance item and finding. Please state whether Region IV's evaluation of all data on the records examined determined the technical significance (i.e., effect on tne quality of the product) of each nonconformance item and findings. (If issue was answered in response to one of the above, please reference the above response as an answer to the question). Provide the results of your evaluation for each of these items. If your examinations do not address this area, how did Region IV intend to establish the technical adequacy of the component or components in question (i.e., via HTPC response to your items of nonconformance and findings or other options). Region IV Response - Regional review of the above indicates a line of questioning which may be consistent with evalua-tion of severity of findings with respect to enforcement policy for licensees, but is not particularly appropriate a
F.emo to Fortuna for non-iicer. sees. Eeciese of generic considerations and varying cuality/er.gineering criteria applicable to program-catic nonconformances (ex. manufacturing process control), for the fina! evaluation of findings with respect to r.on-licensees, it is considered a prerequisite that vendor proposed corrective actions and steps to preclude recurrence be reviewed for adequacy and responsiveness to identified deficiencies. Accordingly, we do not consider this particular subject can be further constructively addressed until after issue of the referenced inspection reports to HTPC. No items were identified during this inspection which were considered of imediate safety concern and in need of immediate corrective action by the pump recipients. 13. Open and Follow-uo Items Please evaluate the results of your past and current action on this matter and please identify those items which you consider will be open items requiring ~ followup. Region IV Response - In response to the above request, the following tabulation identifies those items, which the Region considers require follow up: a. Disposition of NCR A0593 and processing of NCR B 2047 (Inspection Report No. 99900345/82-02, paragraph D.4). b. Manufacturing Process Control Inconsistencies (Inspec-tion Report No. 99900345/82-02, paragraph D.5), c. Monitoring of welding (Inspection Report No. 99900345/82-02, paragraph D.7). -d. Evaluation at Scuth Texas of seismic suppcrts with respect to fabrication drawing requirements. e. Manufacture of spare, parts. Applied torque values to bolting in delivered pumps. We trust that this response is sufficiently detailed to enable finaliza-tion of IE review. Please contact us should you require any additicnal ciarification. -{yy i 4' [UchnT. Collins Regional Administrator}}