ML20054D031
| ML20054D031 | |
| Person / Time | |
|---|---|
| Issue date: | 06/19/1980 |
| From: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fraser A VERMONT, STATE OF |
| Shared Package | |
| ML20054D015 | List: |
| References | |
| FOIA-82-85 NUDOCS 8204220258 | |
| Download: ML20054D031 (1) | |
Text
UNITED STATES
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631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA 19406 k.'.D
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Mr. Albert A. Fraser Deputy Comissioner State of Vermont Department of Labor and' Industry 118 State Street Montpelier, Vemont 05602
Dear Mr. Fraser:
Mr. J. E. Fothergill, Director of Occupational Safety, forwarded all_egations filed with your office concerning Hayward-Tyler Pump Company of Burlington, Vemont, in a letter dated October 29, 1979. My letter of December 10,1979 described our planned investigative actions. That investigation has now been completed. The investigation report has since been reviewed for proprietary infomation by Hayward-Tyler representatives.
Copies of the investigation report (No. 99900345/80-01) and the memorandum forwarding the report to the Hayward-Tyler Pump Company are enclosed for your information.
Duplicate copies of those documents are included for your transmittal to the individual filing the allegations, should you wish.
With the performance of this investig3. tion, this matter is considered closed.
Should you have any further questions concerni.ng these allegations, please contact this office.
C Sincerely, T
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s James M. Allan Deputy Director
Enclosures:
As stated cc w/encis:
J. E. Fothergill, Director of Occupational Safety, Dept. of Labor and Industry, State of Vermont
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UNITED STATES
[f s, NUCLEAR REGULATORY COMMISSION
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-C-REGION IV
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jd 611 RYAN PLAZi oRivE, SulTE 1000
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,e ARLINGTON, TEXAS 76012 20 liar 1980 Dock:t No. 99900345/80-01 Eayward Tyler Pump Company Division of Stone Plant Atta:
Mr. D. W. Chalmers President P. O. Box 492 Burlington, Vermont 05401 Centlemen.
This refers to the QA Program inspection conducted by Mr. Ross L. Brown of this office on February 25-27, 1980, of your facility at Eurlington, Vermont, associated with the =anufacture of nuclear pumps and to the discussions of our findings with you and members of your staff at the conclusion of the inspection.
This inspection was =ade to confirm that, in the areas inspected, your QA Program is being effectively i=ple=ented.
The inspection effort.is not designed to assure that unique quality requirements i= posed by a customer are being implemented; nor to assure that a specific product, ccaponent or service provided by you to your customers, is of acceptable quality.
As you know, the NRC requires each of its licensees to assume full responsibility fer the quality of specific products, components or services procured from others:.
You should therefore not conclude that the NRC's inspection exe= pts you from inspections by an NRC licensee or his agents nor from taking effective cor-rective action in response to their findings.
Areas examined and our findings are discussed in the enclosed report.
Within these areas, the inspection consisted of an eurnination of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection it was found that the imple=entation of your QA Program failed to meet certain NRC require =ents.
The specific findings and references to the pertinent require =ents are identified in the enclosures to this letter.
Since corrective and preventive actions were taken and verified before the conclusion of this inspection, no further written response is necessary.
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Hayward Tyler Pu=p Co=pany 2
In accordance with Section 2.790 of the Commission's " Rules of Practice,"
j Part 2, Title 10, code of Federal Regulations, a copy of this letter with enclosure and your reply, together with the enclosed inspection report will be placed in the Commission's Public Docu=ent Room.
If this report contains any information that you believe to be proprietary, it is necessary that you cake a written application within thirty (30) days to this office to withhold such infor=ation from public disclosure.
Any such application =ust include a full state =ent of the reasons on the basis of which it is clai=ed. that the infor=a-tion is proprietary, and should be prepared so that proprietary infor=ation identified in the application is contained in a separate part of. the docu=ent.
If we do not hear from you in this regard within the specified period, the I
report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss the= with you.
Sincerely, LLtd te Uldis Potapovs, Chiqf Vendor Inspection Branch
Enclosures:
1.
Notice of Deviation 2.
Inspection Report No. 99900345/80-01
=_
Hayward Tyler Pump Company Docket No. 99900345/80-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on February 25-27, 1980, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
Criterion V of Appendix B to 10 CFR 50 states:
" Activities affecting quality 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, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Hayward Tyler Pump Company's Quality Assurance Manual, Section 16.0, Subsection 16.5 states, "The responsible supervisor or vendor shall document on the NCR the cause and the corrective action required to be taken to prevent recur-rence and the date the corrective action will be completed."
Contrary to the above, only three (3) of the seven (7) Nonconformity Reports reviewed by the inspector indicated the cause of the discrepancy and the cor-rective action required to prevent recurrence.
Corrective and preventive measures were taken concerning this deviation prior to the conclusion of the inspection, therefore no further response to this item is necessary.
(Details Section, Paragraph B.3.c.(2)(a).)
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF LNSPECTION AND ENFORCEMENT REGION IV Report No. 99900345/80-01 Program No. 51300 Company: Hayward Tyler Pump Company Division of Stone Plant Burlington, Vermont 05401 Inspection Conducted:
February 25-27, 1980 7/ d Inspectors m
Ross L. Brown, Cons. tractor Inspector Date ComponentsSection I Vendor Inspection Branch m A^
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D. E. Whitesell,'CNief
' Date ComponentsSection I Vendor Inspection Branch Aypraved by W
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03/}4/PD D. E. Whitesell, Chief Hate ComponentsSection I Vendor Inspection Branch Summary Inspection on February 25-27, 1980 (99900345/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, including special inspection related to reported construction deficiencies and allegations of disregard for product safety.
The inspection involved forty (40) inspector hours on-site by two (2) NRC inspectors.
Results:
In the areas inspected there were no unresolved items identified in any of the areas, no deviations were identified in two (2) of the areas, and the following deviation was identified in the remaining area.
Deviation:
The cause and corrective action item of Nonconformity Reports had not been filled in as required (See Notice of Deviation enclosure).
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2 DETAILS SECTION (Prepared by Ross. L. Brown and D. E. Whitesell)
A.
Persons Contacted
- D. W. Chalmers, President
- R. C. Groeschel, Quality Assurance Manager
'*S. E. Bushey, Quality Control Supervisor
- Attended Exit Interview.
B.
Inspections Related to the Allegations of Disregard for Product Safety
===1.
Background===
The NRC Region I office received from the state of Vermont, Depart-ment of Labor and Industry a letter forwarding a copy of allegations filed with that office.
Four items identified as signifying disregard for nuclear product safety were referred to the Vendor Inspection Branch for investigation.
These items are as follows:
Quality Level 1 parts have been machined even though the parts a.
were on conditional hold not to be released for machining until inspected by an A. I. inspector.
b.
Skipping N. D. T. tests on a job route sheet.
Because it would mean breaking down the set-up resulting in lost machining time, then testing-for defects, then setting the part back on the machine.
Liquid penetrate tests are to be done in proper order according to a level I route sheet and not to be changed.
c.
Quality inspection have not been followed according to level I standards.
The Hayward Tyler in house inspectors reject parts, then they.are over-ridden by Hayward Tyler management to use as is.
d.
Hayward Tyler Pump Management has modified contract prints and parts dimensions to allow for their misjudgements when in fact changes were only to be made by the customer.
The enclosure also included several items relative to the health and safety of the plant and equipment.
The inspector did not inspect these items, but was informed that these items were looked at by the Vermont office of safety and health.
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3 The inspector selected the following two (2) inspection modules l
to be used for the inspection effort relative to these allegations:
Manufacturing Process Control and Control of Nonconformances and
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Corrective Action.
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2.
Manufacturing Process Control l
a.
Objectives The objectives of this area of the inspection were to verify
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that:
1 (1)
The manufacturer operates under a controlled system using process sheets or equivalent for all operations including inspections pertinent to component production.
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(2)
The system requires all processes and examination / tests i
to be performed by qualified personnel using qualified procedures.
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I (3)
The process sheets are required to be prepared including document number and revisions to which production and l
examinations must be performed.
i (4)
The process sheets include provisions for the identification i
of hold / witness points and signoff and date.
b.
Method of Accomplishment i
The preceding objectives were accomplished by a detailed i
1 review of:
I (1)
Hayward Tyler Pump Company (HTPC) Quality Assurance f
i Manual (QAM), Section 10, Process Control.
(2)
Customer Specification for Contract No. 3240-116H.
(HTPC Job _No's 8108/8107).
(3)
Engineering Standard, Section 3.0.6/4-1, Quality Grid.
I (4)
Route Sheets for Job No's. 8108, 8049, and 8050.
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(5)
Master Route Sheets for Mechanical Seal Gland Plate, Back Cover, Casing Upgrading and Casing Machining.
c.
Findings No deviations from commitment or unresolved items were identified in this area of the inspection.
The inspector verified the following information:
(1)
The customer specification includes the following submittal requirement:
QAM, Route sheets for determination of inspection points, and documentation for approval.
(2)
The Quality Grid standard governs t quality requirements for all pumps and pump parts.
The scandard describes the six levels of quality, with level I having the most requirements.
It also assigns Quality Level 1 as applicable to ASME Code Section III Class 2 and 3 pumps.
(3) The QAM states in part:
All manufacturing shall be controlled by Route Sheets which shall travel with the material throughout the many sequencies; the route sheets shall include the HTPC, customer and Authorized Nuclear Inspectors inspection, witness or hold points.
The manual also states the following operations shall not be performed out of sequence; all Inspection and QA operations and examinations, all hold and witness points, all tests, including Hydrostatic Test, Performance Tests, and Balancing, all welding and welding-related operations, including excavations, allocation of welding material, and repair mapping and all cleaning, assembly, and packaging operations.
The QAM further states that machining operations may be performed in any logical sequence.
(4)
The Route Sheets includes as a minimum, the job number, part name, drawing number, quality level, operation sequence numbers, operation sequence, route sheet approvals, operation and inspection sign-offs, and dated as appropriate by HTPC, ANI and customer procedure i
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1 numbers, and references inspection reports and noncon-formity reports.
No irregularities were noted during the review of the route sheets for the job selected.
3.
- Control of Nonconformances and Corrective Action a.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for:
(1) Disposition of nonconformances that provide for:
(a) The control of nonconforming materials, parts, or components to prevent their inadvertent use or installation.
(b)
Identification, documentation, segregation, and disposition of nonconforming items and notification to affected organizations.
(2) Corrective action that provides for:
(a) Review and evaluation of conditions adverse to quality to determine the cause, extent, and measures needed to correct and prevent recurrence.
(b) Reporting these conditions and the corrective action to management.
(c)
Assuring that corrective action is implemented and maintained.
b.
Method of Accomplishment The above objectives were accomplished by a review of the following documents:
(1) QAM, Section 16.0, Nonconformities and Corrective Action.
(2) Nonconformity Report (NCR) No's. B0033, B0038, B1195, B1194, B1199 and B1202.
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6 (3)
Periodic Review of Audit Reports dated April 4,1979, August 29, 1978 and November 6, 1979.
(4)
Internal Memorandum, dated February 27, 1980,
Subject:
NCR's and Corrective Action.
(5)
Internal Audit Report Date February 27, 1980.
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c.
Findings l
(1)
Unresolved Item No unresolved items were identified.
t (2)
Deviation One deviation from commitment was, identified (See Notice l
of Deviation, enclosure).
The internal audit report (B.3.b.5) and the interdal memorandum (B.3.b.4) describes the action to be taken:
to correct the deficiencies, to prevent recurrence and states the completion date for each activity.
Therefore this deviation is considered closed.
(3)
The inspector verified implementation of the following requirements; (a)
The QAM provides for the identification, documentation, and disposition of nonconforming items.
The manual also provides for the review of conditions adverse to quality to determine the cause and actions to be taken to prevent recurrence, it also requires followup audit to verify implementation of the specified actions.
(b)
Except the deviation described in the, Notice /.
of Deviation, the NCR's reviewed were in accordance with specified requirements, relative to identification, disposition and appropriate approvals (always the Project Engineer and Quality Assurance Manager).
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Conclusion The inspector was not able to verify the validity of the allegations identified in Paragraph B.1. above.
1 C.
Reported Construction Deficiencies 1.
Background Information
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On January 17, 1980 the licensee verbally notified the NRC Resident Inspector at Comanche Peak, that the Hayward Tyler Pump Company (HTPC). had informed them that one of the 4 safety related Service Water Pumps, contain potential construction deficiencies as follows:
a.
The material of one of the shaft split coupling rings could not be identified and the pedigree traceable to ensure compliance with contract requirements, and b.
A possibility that a bottom bearing lubrication hole had not been' drilled in the shafts of one, and perhaps, two of the pumps.
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The licensee plans to evaluate these p,os'sible eficiencies in compliance with 50.55(e).
2.
Objective The objectives of this area of inspection were to ascertain the following:
a.
Were these potential construction deficiencies the results of a breakdown in the Vendor's QA prdgram; b.
What corrective action has been, or will be taken; t
c.
What steps have or will be taken to prevent recurrence; i
d.
The generic impact; and e.
Is the problem reportable under 10 CFR 21.
3.
Method of Accomplishment The foregoing objectives were accomplished by:
a.
Review of the customer's Purchase Order (PO) number CP-0010, dated July 28, 1975, Revision 3, dated December 9,1977; and Design Specification (DS) number 2323-MS-10, Revision 1
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dated December 9,1977; and Design Specification (DS) number 2323-GS-903, with Appendix 3, to ascertain the governing code edition and addenda. the Code Class and Seismic category, and quantity of the Service Water Pumps.
Also to ascertain what QA requirements were imposed on the vendor to control the design, manufacture, inspection and tests of these pumps.
b.
Review of Drawing numbers 01-600-061 Revision A,' dated August 7, 1978, titled " Sectional Arrangement;" 71-320-289, dated April 18, 1977, Revision A, dated December 13, 1977, titled Machining " Split Coupling Ring;" to ascertain whether the material specified for the split coupling ring, was in compliance with the. contract documents.
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Review of the Master Material Bill for Contract number 2-0173-8173, and pump S/N &l74-01&O2 for Comanche Peak Unit 1; and S/N 8175-01&O2 for Unit 2.
To ascertain the~ part number (PN) of the split coupling ring (P/N 5703), and to verify that the type of material specified was ASTM B164 Class A (monel),
as identified on the drawing.
d.
Design and Seismic Analysis Report Number 01-007-005, dated October 28, 1977 to verify that the allowable material stress used co6 plied with the allowable design stress as identified in appropriate ASME Tables for the material type and grade to be used in the manufacture of the pump parts.
Also to verify that the minimum dimensions identified on the drawings were supported by the design and earthquake analysis, e.
Review of the "as built" drawing number 01-400-389 to verify that the callout for the three. split coupling rings on each of the four (4) service water pumps, were identified as being ASTM B164 Class A.
f.
Review of the data package for pump No. 8174-01 containing the following:
(1)
Gibbs and Hill QA Release No. 2463 dated September 24, 1978, Final Inspection for Shipment.
Signed TUGC0 QA inspector dated September 29, 1978.
(2) Data Report, signed by the ANI. NB No. 7569 on September 28, 1978.
(3) Facsimile of plate and Stamp for 8174-01.
(4)
Performance curve No. 7308-5001 Test No. 265.04 for pump No. 8174-01 to demonstrate capability to meet design specification of 17000 GPM at 140 ft. head.
9 (5)
Work sheet of test results from which the performance curve was plotted.
(6)
Hydrostatic Test Report dated August 25,1978 for pump No. 8174-01 to verify that the test procedure was identified, the test pressure and holding time was recorded, and the test pressure was 1.5x the design pressure.
Also to verify that the ANI had witnessed the test and found the item acceptable.
(7)
The "As Built" Master Material Bill Tabulation for J/N 8174-01, to verify the material' identified for item 5703 (splity ring coupling) was identified.in accordance with the as built drawings No. 01-400-389.
(8)
CMTR from Huntington Alloy, dated October 3, 1975, for ASTM B164, Class A, for a 6.5" diameter x 720.00" Bar; Heat number M15084B.
(9)
Certification of Test dated July 12, 1978 by Canadian Forging identifying the physical properties of Heat No.
M150840.
(10)
Inspection Report dated September 28,1978 of the dimensional verification of split ring shaft coupling.
Identified nonconforming dimension tolerances.
(11) Nonconformance Report No. B0033 dated September 28, 1978 which described the nonconforming dimension tolerances and was dispositioned to "use as is" and had been appropriately reviewed for disposition concurrence in the manner prescribed.
It was observed that the cause was identified as a machining error, and not repeatable, therefore no action to prevent recurrence was required.
g.
Discussions with the cognizant HTPC engineers and managers concerning the deficiencies identified, and reported by them, to both the customer, and NRC in compliance with 10 CER 21.
4.
Findings l
From the discussions and the pertinent QA/QC documents reviewed, the following determinations were made:
a.
The contracts for the four 24VSN Verticle two stage service water pumps was initially let to Babcock Wilcox Pump Co. in Cambridge Canada, and was identified as BW Gault, Contract O
10 number 2-0173-8173, and later transferred by B&W, with the concurrence of the buyer, to Hayward Tyler Pump Company (HTPC) in Burlington, Vermont.
Under the initial contract B&W was responsible for the design of the pumps, and had accomplished the following work on the contract, prior to the date of transfer.
(1)
Perpared the pump design and machining drawings, procured material for the manufacture of the following items for the first pump.
(a) First and second stage pump housings, (b) First and second stage impellers, and (c)
Shaft with one split ring coupling to connect the drive shaft of the motor, and had performed a test to determine whether the pump, as designed, would achieve the specified capacity and head.
(2)
Hayward Tyler Pump Co., as subcontractors to B&W Gault, had performed the Design Calculations and Seismic Analysis Report for the first pump.
(3)
Upon completion of the test by B&W, the responsibilities for the balance of the contract was transferred to HTPC.
b.
HTPC upon receipt of the contract, assigned job number 8174 for Comanche Peak Unit one pumps and job number 8175 for the Unit 2 pumps.
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c.
The title blocks of the B&W drawings were voided and HTPC title block added, and HPTC accepted the responsibilities
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for updating and revising the drawings as necessary to accommodate engineering change notices (ECN) and/or revisions to the buyer's P0.
d.
The items manufactured by RER were received by HTPC, disassembled and each. item assigned a unique batch number l
which identified the part as having been manufactured by B&W.
l e.
The pumps for Comanche Peak 1 was assembled and shipped.
All the materials used by B&W for the items manufa~ctured by B&W j
were traceable to CMTR except the split coupling ring l
manufactured by B&W to connect the impeller shaft to the drive motor.
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11 f.
The assigned Project Engineer, reported to the Manager of QA in July of 1979 that they did not have documents which provide the pedigree of the split ring material.
Both HTPC and B&W searched for such teaceability and in January concluded that a replacement split coupling ring should be installed, and on January 16, 1980, JWX 9108908660 was sent to TUGC0 reporting that there was no evidence to ensure that the split ring material met contract specifications.
g.
The TWX also identified that the lubrication holes may not have been drilled in the shaft manufactured by B&W for the two stage performance test, and requested any installation work on the pumps to be halted until HTPC could install the replacement part and inspect the pumps to determine what other rewort may be required.
h.
HTPC manufactured a replacement split ring from traceable material and a service crew was dispatched to the site to replace the suspect split ring, and rework the lube holes as necessary.
i.
The service crew reported that only one of the two radial lube holes had been drilled in the shaft of pump number 8174-01.
The shafts of the remaining three pumps had been properly drilled to lubricate the bottom bearings of the first stage-pumps.
j.
No breakdown in the HTPC QA program was identified.
Con-cerning the split ring coupling, the lack of material identification was apparently due to lost documents during the transfer of contract, and the oversight of the lube holes appears to be partially a lack of communication, and also the lack of specific instructions to the receiving inspector concerning receipt of the pumps from B&W.
This could be considered a deviation, however due to the unique circumstance, the corrective action taken a citation after the fact does not appear to be warranted.
k.
The corrective action was to replace the unidentified split coupling ring with one of material which is traceable, and drill the second radial lube hole in the shaft of pump no.
8174-01.
As part of the corrective action, it was verified that HTFC, had issued a requisition to purchasing to send the split-ring with unidentified material to a laboratory for analysis to ascertain whether the material was monel as specified.
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1.
Since the problem was created in the confusion of the transfer of the contract from B&W, Cambridge, Canada to HTPC.
The porblem is an isolated case and not repeatable.
Therefore corrective action to prevent recurrence is not required.
m.
The problem is unque with Comanche Peak and not generic.
n.
The service water pumps were identified as safety related; and both the customer and NRC were appropriately notified in accordance with HTPC procedure No. 8.3.0/1-0 dated January 4, 1978, developed by HTPC to be responsive to 10 CFR 21.
D.
Exit Interview The inspector conducted an exit meeting with the Hayward Tyler Pump Company management representative at the conclusion of the inspection.
Those persons indicated by an asterisk in Paragraph A, were in attendance.
In addition, the following were present:
R. W. McMillan, Quality Assurance Engineer R. M. Kleckner, Consultant R. A. Gosser, Authorized Nuclear Inspector, Kemper Insurance Companies (Immbermans Mutual)
The inspectors discussed the scope of the inspection and the details of the findings identified during the inspection,.
The inspector stated that the identified deviation will not require a response because the corrective action and preventative measures were taken prior to the conclusion of the inspection.
The HTPC management's comments were for clarification only, i
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o 2 0 HAR 1980
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J'. M. Allan, Deputy Director,,R "n.
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ALLEGATIONS CONCERNING HAYWA.
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February.
s, In response'to the subject.AITS, an,nn ' Vermont, was conducted on cu d iti
,, Company; Burlin to,and findings are reporte -
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riers' nnd his attorney, Jir.
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.g9900345/80{01',1co-e from,approximately 4:30 PM unt
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.l allegations, which were,of Oc L
, A. meeting was held with David Des au
- Vermont, written in Burlington, rning his
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the RadissSn Hotei, Mr. ' John E. Forthergill, DirectorDuri'n[ the rc 25,1980, conce 7,
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-He stated tlGt'he hal boring.;,'
6:00 PM on February trancmitted to you liy made by him.
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ha'd.been for the State reaffir: icd that the,allegationbeen employed by the1 Ha
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He'applid. o machine operator.f rom Septed 'his employment.Since. he had voluntarily 8
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voluntarily terminatewith the State'of Vermont.
- for unemployment ditions.' He did
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ecployment,'his applicat onstated that he appealed t eallege on.which operations n'nd'vorking con job numbers ts.
h b Muebers for.non-nu. clear.,contrac worked and. 'r ;, ',
h However, he could not reca11't e the Hayward Tyler'sf'urni.sh. the NRC.. Inspector two Jo J;
which he may havel ted to nuclearfe'. Y.',
were based.
could not be directly re awhich ' vere subjec contracts on h
his, allegations quality levels of any l nuclear
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_ herefore the specific allegat onsNevertheless, the QA p ts
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proper implementation (. The.roby th,e alleger were reviewed
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2 J. M. Allan ASMEforrenewal'ofitsCertificates'Af'Authori=ation,andthesurveyteam-would not recommend the renewal of 'the certificate until the company revised the program to provide more rigid and positive control and compliance with the NRC ' regulations, c. ode and contract requirements, and the vendor's commit '
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While the allegations could not.be substanEihted, h'owever,.if true, 'the ' revised,
QA program as accepted by the ASME Survey Team in November 1979, provides adequate control,of the manufacturing processes to prevent or mitigate the A. *,.
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With this memo, and-Inspect, ion Report No. ' #900345/80-01,'
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S.hould you have'any questions concerning this matter please h..{".
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contact D. E. Whitese11 or myself. *'.
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