ML20028F013
| ML20028F013 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1983 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20028F010 | List: |
| References | |
| REF-QA-99900364 NUDOCS 8301280346 | |
| Download: ML20028F013 (9) | |
Text
.
ORGANIZATION:
MIDLAND-ROSS CORPORATION SUPERSTRUT DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION INSPECTION NO.:
99900364/82-01 DATE(S) 12/6-8/82 ON-SITE HOURS: 18 CORRESPONDENCE ADDRESS:
Midland-Ross Corporation Superstrut Division ATTN:
Mr. A. M. Kridle, QA/QC Coordinator 845 Embarcadero Oakland, CA 94604 ORGANIZATIONAL CONTACT:
Mr. A. M. Kridle, QA/QC Coordinator TELEPHONE NUMBER:
(415) 839-9690 PRINCIPAL PRODUCT: Channel struts, supports, and fittings.
NUCLEAR INDUSTRY ACTIVITY: No work is currently being performed for the nuclear industry at the Superstrut Division Oakland fecility.
ASSIGNED INSPECTOR:
8w
/ P3 g e L. E. Ellershaw, Reactive and Component Program Date Section (R& CPS)
OTHER INSPECTOR (S):
APPROVED BY:
be%
/ r 5
- 1. Barnes, Chief, R& CPS Date INSPECTION BASES AND SCOPE:
A.
BASES:
B.
SCOPE:
This inspection was conducted as a result of allegations received by the NRC Region V office pertaining to:
(1) the use of materials which do not comply with the applicable American Society for Testing and Materials (ASTM) standards, (2) the use of unqualified welders and welding procedure (Cont. on next page)
PLANT SITE APPLICABILITY:
50-275, 50-323, 50-528, 50-529, 50-530, 50-460, 50-513, and 50-443.
...t hh E
W R
99900364
ORGANIZATION:
MIDLAND-ROSS CORPORATION SUPERSTRUT DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NA -
QQQAn7Ad/A?-n1 RF9tH T9-PARF 9 af 7 SCOPE:
(Cont.) specifications (WPSs), and (3) not performing destructive and nondestructive testing of welds.
A.
VIOLATIONS:
Contrary to Section 21.6 of 10 CFR Part 21, Midland-Ross Corporation, Superstrut Division, had not posted:
(1) a copy of 10 CFR Part 21, (2) Section 206 of the Energy Reorganization Act of 1974, (3) procedures adopted pursuant to the regulations, or (4) a notice describing the regulations and procedures.
B.
NONCONFORMI.6?ES:
None C.
UNRESOLVED ITEMS:
None D.
OTHER FINDINGS OR COMMENTS:
This inspecticq was conducted as a result of the receipt of the ellegations identified in the Scope, above.
The allegations were potentially generic in nature; thus, the identities of nuclear power plants to whicn Superstrut has supplied components were obtained and are as follows:
Diablo Canyon Nuclear Power Plant, Units 1 and 2; Palo Verde Nuclear Generating Station, Units 1, 2, and 3; and WPPSS Nuclear Project Nos. 1 and 4.
It was further identified that a very small quantity of items was supplied to Public Service Company of New Hampshire's Seabrook Nuclear Station, Unit 1.
1.
Allegation - Use of materials which are not in compliance with the requirements of the applicable ASTM standards.
Prior to 1980, Superstrut did not maintain any type of material traceability.
During 1980 and after, mill test reports (MTRs) were filed and maintained; however, they cannot be matched with specific end proJJcts.
The NRC inspector reviewed 15 MTRs for material used in fabricating struts and fittings.
The MTRs were in accordance with Superstrut's purchase order requirements; i.e., they stated the appropriate ASTM designation and included physical and chemical property test results.
The test results were in accordance with the applicable ASTM standardc
ORGANIZATION:
MIDLAND-ROSS CORPORATION SUPERSTRUT DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NO.-
99900364/82-01 RESULTS:
PAGE 3 of 7 Findings - It could not be demonstrated that material traceability requirements were imposed on Superstrut.
The only requirement was for Superstrut to provide a certificate of conformance with each shipment.
The MTRs were found to be in accordance with the purchase order requirements, thus, this allegation could not be substantiated.
2.
Allegation - Use of uaqualified welders and WPSs.
a.
Superstrut had structural welder certifications for three welders which indicated that they were qualified for the gas metal arc welding (GMAW) process.
(1)
Welder No. 1 - The certification showed that he was qualified by radiography to perform fillet and groove GMAW on April 16, 1979.
This welder left Superstrut's employment in January 1982.
(2)
Welder No. 2 - The certification showed that he was qualified in accordance with American Welding Society (AWS) Code D1.1-79, to perform fillet and groove GMAW on May 25, 1979.
The certi-fication further showed that he was qualified by mechanical tests; i.e., satisfactory guided bend tes.s.
An anomaly was identified in that the certification showed two side bend tests were performed whereas AWS D1.1-79 requires one face and one root bend test for 3/8" joint thickness.
This welder left Superstrut's employment on November 19, 1982.
(3)
Welder No. 3 - The certification showed he was qualified in accordance with AWS D1.1-82 to perform fillet and groove GMAW on July 21, 1982.
An anomaly was identified in that the certification showed that 1500 amps was used during the qualification welding.
This apparently is a typographical error in that a correct value would be 150 amps.
This welder is currently employed at Superstrut.
b.
The NRC inspector reviewed a GMAW WPS which was identified as WPS No. WP1, Revision 0, dated November 16, 1982.
Superstrut was unable to provide evidence that earlier GMAW WPSs existed.
WPS No. WP1 was identified as a prequalified joint welding procedure which would exempt it from qualification testing, thus, there was no procedure qualification record.
- However, a review of the procedure revealed it to be short circuiting transfer GMAW.
Paragraph 2.6.1.2 of AWS 01.1 states, in part,
ORGANIZATION:
MIDLAND-ROSS CORPORATION SUPERSTRUT DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NO -
444001Ad/A7-01 RF911l TS-PACF d nf 7 "The joint welding procedure for all joints welded by short circuiting transfer gas metal arc welding shall be qualified by tests.
As of the date of this inspection, Superstrut did not have a qualified GMAW WPS.
r c.
Resistance WPS No. QCP-4, " Spot Welding of Low Carbon Coated And Uncoated Sheet Steel," was reviewed.
This WPS was istued as Revision 0, da'.ed Januarv 9, 1980, and is currently Revision 1, dated May 8, 1.dl.
AWS 01.1 does not address resistance welding; thus, there are no qualification testing requirements.
The equipment setting parameters contained in the WPS are a function of the resistance welding equipment.
There apparently was no formal resistance WPS prior to 1980.
d.
Findings - There were no available records to indicate that welders were qualified prior to April 1979.
The allegation would, therefore, appear to be valid with respect to past use of unqualified welders.
However, review of available documentation showed no requirement for Superstrut to formally qualify welding personnel.
Inspection of existing WPSs showed that:
(1) the GMAW process had not been qualified in accordance with AWS D1.1, and (2) no requirement exists for qualification of the resistance welding process.
The inspection findings thus substantiate the allegation of use of unqualified welding procedures.
However, no requirement for the use of qualified welding procedures was identified.
3.
Allegation - Failure to perform required destructive and nondestructive testing.
a.
Destructive Testing - WPS No. QCP-4 addresses destructive pull tests which are to ta performed on test specimens taken from the first piece each day.
The test results must meet or exceed 2350 lbs.
force per weld.
It also requires that test specimens be pull tested whenever the welding tips are changed.
Superstrut placed an additional pull test requirement on their catalog number A1262 strut, in that it undergoes a destructive pull test every 500 feet, regardless of weld tip condition.
L
ORGANIZATION:
MIDLAND-ROSS CORPORATION SUPERSTRUT DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NO.-
99900364/82-01 RESULTS:
PAGE 5 of 7 While not addressed in the WPS, destructive shear testing is performed on a sample basis.
Performance of destructive testing was verified by review of approximately 30 spot welding process records. These records are the vehicle used to document destructive testing.
b.
Nondestructive Examination (NDE) - Prior to 1980, visual examination was the only mode of NDE performed.
As a result of identified resistance weld failures (August 1979) in strut material supplied to WPPSS Nos. 1 and 4, the site electrical contractor imposed an ultrasonic examination (UT) requirement on Superstrot.
The requirement is addressed in WPS No. QCP-4 which references UT proceaure No. 42-UT-049.
The UT procedure, original issue dated May 6, 1980, through Revision 2, dated December 11, 1980, is a Nuclear Energy Services, Inc. Conam Inspection Division procedure.
All UT is performed by Conam personnel at Superstrut's facility.
The procedure requires the first 4 welds on each end of the 1st length, 13th length, and last length of each lot of 25 struts to be examined.
The UT results are documented either on the spot welding progress record or on a certificate of inspection attached to this record.
The shop order / contract number is referenced on the record.
This was verified by review of approximately 15 different records.
The UT requiremant was originally developed for the WPPSS Nos. 1 and 4 job.
Subsequently, Superstrut invoked this requirement on all strut material in about October 1980.
c.
Findings - A very limited number of quality assurance type records was available for manufacturing prior to 1980, and these records cannot be related to a given lot, shipment, or customer.
Verification of destructive testing, therefore, could not be l
performed.
UT was not a requirement at that time and currently is the only NDE discipline performed, and then, only on resistance t
l welds in strut material.
4.
Review of QA Program and Customer Quality Requirements The NRC inspector reviewed Superstrut's QA Manual in terms of compliance with the 18 criteria of Appendix 8 to 10 CFR Part 50.
Revision 2 of the QA Manual dated November 16, 19E?, was originally issued in l
February 1979, and basically addr esses inspection system requirements.
l L
ORGANIZATION:
MIDLAND-ROSS CORPORATION SUPERSTRUT DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION Pln OOOnn1RA /Q9-n1 DFR!!! TC.
DacC A nf 7 The QA Manual does address some of the 18 criteria, but only in terms of indicating that implementing procedures shall be established and maintained.
A review of the implementing procedures showed that they were primarily related to special processes; i.e.,
rolling, plating, GMAW and resistance welding, and UT.
Further, paragraph 4.1 of the QA Manual specification states, "'.his specification will apply to the procurement of supplies and services specified by the military procurement agencies or nuclear facilities.
Standard catalog items are not covered under this specification." Virtuylly all items fabricated by Superstrut, and destined for nuclear facilities, are standard catalog items.
A review of customer purchase orders to Superstrut and a customer equipment specification revealed that 10 CFR Part 50, Appendix B criteria had not been imposed.
A review was made of Bechtel Power Corporation purcnase order No. 10407-13-EM-076 and Equipment Specification No. 13-E-037A.
These documents pertained to the procurement of items for Arizona Public Service Company's Palo Verde Nuclear Generating Station, Units 1, 2, and 3.
The specification states, in part, "... The material in this specification will be used for both Class 1E and Non-Class 1E systems.
Class 1E systems as indicated in the IEEE standards are those essential to the safe shutdown of a nuclear power generating station." The purchase order states " Quality Class R."
Appendix 4D to the specification states, " Quality Class R designates any material, structure, service, or component which, as a result of being defective, could cause a safety hazard to station personnel, or unscheduled reduction or loss of unit output."
The Palo Verde contract is the only contract for which Superstrut received an equipment specification.
The purchase order was placed by Bechtel to Superstrut, Inc., through Graybar Electric Company, a distributor for Superstrut.
In the case of Diablo Canyon, the typical procurement cycle was as follows:
H. P. Foley (site electrical contractor) placed purchase orders with Amfac Electric Supply Company and Electric Supply of Vallejo, who then placed the orders with Lectrowest (Superstrut's agent), who in turn, telephoned the orders in to Superstrut.
In many cases, the only documentation available was Superstrut's internally generated order acknowledgements.
Regarding WPPSS Nos. 1 and 4, from 1977 to 1981, Foley-Wismer & Becker (site electrical contractor) placed orders with Amfac Electric Supply Company, who ordered from Superstrut.
During 1981 and later, Foley-Wismer & Becker procured directly from Superstrut.
ORGANIZATION:
MfDLAND-ROSS CORPORATION SUPERSTRUT DIVISION OAKLAND, CALIFORNIA REPORT INSPECTION NC -
99900364/82-01 RESULTS:
PAGE 7 of 7 In all cases, the only documentation ever required from Superstrut was a Certificate of Conformance.
The purchase orders pertaining to Diablo Canyon and WPPSS Nos. 1 and 4 did not contain quality requirements, as the items purchased were catalog items.
The only available, documented, customer audits of Superstrut were performed by H. P. Foley-Wismer & Becker (WPPSS No. 1 and 4).
The first audit was performed on February 3-5, 1981, and related to UT of spot welds.
The second audit was performed on February 3-5, 1982, to assess Superstrut's corrective action on an observation identified during the first audit.
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