ML20059L469
| ML20059L469 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/1989 |
| From: | Baker E, Cilimberg R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20059L465 | List: |
| References | |
| REF-QA-99901006 99901006-89-01, NUDOCS 9009270039 | |
| Download: ML20059L469 (8) | |
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o ORGAN 12AT10N: A&G ENGINEERING COMPANY AhAHElM, CALIFORNIA 1
REPORT INSPECTION
'lhSPICTION NO.: 99901006/89-01 DATE: May 15-18, 1989 ON SlYE HOUR $t se CORRESPONDENEE ADDRESS: Mr. Marvin L Thomas, President A&G Engineering Company,11, Incorporated 4640 East LaPair.a Avenue Anaheim, California 92807 ORGANIZATIONAL CONTACT: John Thalasinos TELEPHONE NUf1 DER:
(714) 779 4100 NUCLEAR INDUSTRY AC11YlTY: Manufacturerandsupplieroffasteners(bolts, nuts, and studs) to the nuclear industry, military, and comercial customers.
ASSIGNED lhSPECTOR:
M*f.(M.
./
t W
J/ff R. L. Lilinbetg. eactive Ins /hction Section No. 1 Date (RIS-1)
V OTHERINSPECTOR(S):
- 5. H. Matthews g
d r k [ /2 7/fff APPROVED BY:
C baker, Chief, RI5-1, Ye'nT6r Insp'ection Branch te INSPECTION BASES AND SCOPE:
-A.
BASES:
10 CFR 50, Appendix B; 10 CFR Part 21; and Section til of the A5RICoiler and Pressure Vessel Code.
B.
SCOPE:- Obtain information to determine if fasteners supplied to the nuclear industry met customer requirements.
PLANT SITE APPLICABILITY: RanchoSeco(50-312),WNP2(50-397) 9009270039 poop 37 01@g{99EECA G
ORGANIZATION: A&G ENGINEERING COMPANY, 11 INCORPORATED t
ANAHEIM, CALIFORNIA o
REPORT INSPECTION NO.: 99901006/89-01 RESULTS:
PAGE 2 of.7 A.
VIOLATIONS:
None B.
NONCONFORMANCES:
1.
Contrary to Criterion V of Appendix B to 10 CFR 50, Section 4.0 off the A&G Engineering Company 11, Incorporated (A&G) Quality Assurance Manual (QAM), and procedure No. 114 for the control of procurement of materials, comercial grade 5/16"-18 Hex Heavy Nuts were procured from a company, Uchimoto Mfg. Company Ltd.
(Uchimoto),thatwasneitherapprovednorontheQualifiedVendor List (QVL).
(89-01-01) 2.
Contrary to Criterion Vill of Appendix B to 10 CFR 50, Section 7 of the A&G QAM, and paragraph NCA-3866.6 of Section III of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Section Ill), S/16"-18 Heavy Hex Nuts were supplied to District (RanchoSeco),andWashington Sacramento Municipal Utility (WNP-2) with A&G certified material Public Power Supply)Systemthat do not describe the markings applied to testreports(CMTRs the nuts.
(89-01-02) 3.
Contrary to Criterion VII of Appendix B to 10 CFR 50 and paragraph NCA-3867.4(e)(2) of Section III, A&G did not perform a product analysis to verify the e.hemical composition of each piece (nut) of-stock material procured from Uchimoto, upgraded by A&G, and subsequently supplied to Rancho Seco and WNP-2 as 5/16"-18 Hex Heavy Nuts ordered to the requirements of SA-194, Grade 2H, Class 2B,Section III, Class 1 material. A&G was guided by Section Ill interpretation 111-1-83-146, to take advantago of an exemption provided in paragraphs NX-2610(b) and (c), to the each piece testingrequirementsofpangraphNCA-3867.4(e)(2). This interpretation (111-1-83-14b, permits an ASME H-type certificate holdertoinvoketheexemptionprovidedinpar0graphsNX-2610(b) and (c), that the other requirements of NCA-380c [eg. testk.s of each piece per paragraph NCA-3867.4(e)(2)] do not Sply, so long as the material is certified in accordance with NX-2130 andNCA-3867.4(b). Neither A&G, Rancho aco, or WHP-2 are c
ASME H-type certificate holders and therefore can not take advantage of the exemption.
Further, Section 111 Interpretation Ill-1-83-206R clearly requires that the authorization by the ASME N-type certificate holder must be obtained before a material manufacturer / supplier utilized the exemptions provided in paragraphsNX-2610(b)and(c).
(89-01-03) 1
l
)
ORGANIZATION: A&G ENGINEERING COMPANY, 11 INCbRPORATED j
ANAHEIM, cal.IFORNIA l
REPORT INSPECTION I
NO.: 99901006/89-01 RESULTS:
PAGE 3 of 7 l
4.
Contrary to Criterion VII of Appendix B to 10 CFR 50 and paragraph NCA-3867.4(e)(1)(a)of Section III, traceability to the Uchimoto i
CMTR, which is a certification that the requirements of the material i
specification have been performed during the melting, including the heat an. lysis frem the manufacturer, was lost by striking over i
the Uchimoto manufacturer's mark on the L/16"-18 Hex Heavy Nuts supplied tt, Rancho Seco and WNP-2.
(89-01-04)
C.
UNRESOLVED ITEMS:
1 (0 pen) Unresolved 1.
During the inspection the inspectors were advised that 500 5/16"-18
)
Heavy Hex Nuts, SA-194, Grade 2H, Class 2B,Section III, Class-1 i
material, had been.upplied to Rancho Seco with Uchimoto's manu-facturer's mark "U" stricken over by A&G and supplied with the same documentation as that provided to WNP-2. The status of these i
nuts at Rancho Seco was not known by A&G. This item will remain i
open until AAG provides the Nuclear Regulatory Comission (NRC) with sne status and final disposition of the material.
(89-01-05) 2.
DuringtheinspectiontheinspectorsfoundthattheA&Gmanufac-turer s marking evidenced in the first shipment of 200 nuts to WNP-2 is significantly different from that known to exist on the replacement shipment of 200. A$G believed the five discrepar.t nuts in the first shipment were from an overage from the 500 nut shipment to Rancho Seco. A&G could not explain the different j
markings observed in the replacement shipment until such time as they were made available to A&G for examination. WNP-2 has not J
l returned the replacement shipment to A&G. This item will remain i
open until A&G provides NRC with the rationale for the differing markings between the two shipments.
(89-01-06)
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Nonconformance (85-01 01):
Cor.trary to Criterion Vil of 10 CFR 50 Appendix B and Section V, Paragraph II.C.1 of the A&G QAM, sufficient objective evidence was not documented on vendor audit checklists to substantiate and/or-l verify the A&G auditor's findings.
t I
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- ORGANIZATION:{ A&G ENGINEERING COMPANY, 11 INCORPORATED.
ANAHEIM, CALIFORNIA j
REPORTL INSPECTION NO.:L 99901006/89-01 RESULTS:
. PAGE 4.of 7.
j The NRC inspectors determined that A&G-reviewed.an English transla--
L tion of-the Sanyo Steel QAM as objective evidence to substantiate the A&G auditor's findings, and also noted;that Sanyo Steel has
- not' been' an approved vendor since the 1985 NRC inspection of. A&G.
2.
(Closed) Nonconformance (85-31-02):
Contrary to Criterion XII of 10 CFR 50, Appendix B;Section XX, P6ragraph 11.1.2, of the A&G QAM; and A&G Quality. Assurance Procedure (QAP) PR XX-A. Rev. A,-paragraph VI:
i a.
the performance of the required " periodic checks" of measuring equipment could not be verified.
b.
g>uge' 92A was incorrectly color coded.
The 1M inspectors determined that gage calibration is.-
1
, ~l documt tad in. gage log book records and color coding is no J
l longer us M by A&G to designate when calibration should be
]
performed.
E.-
INSPECTION FINDIriGS AND OTHER COMMEt'S:
i 1.
Entrance and Exit Meetings o
l The NRC staff informed A&G management representatives of the scope d
I of.the inspection during the entrance meeting on May 15, 1989 and-f L
summarized the inspection findings during the exit meeting on May-18, 1989.
.a v
2.
Allegation-An allegation was received by the NRC that A&G had provided 1
i>
5/16"-18 Hex Heavy-Nuts ordered to the requirements of SA-194, q
~ Grade 2H, Class 2B, ASME Section Ill, Class 1, with manufacturer's markings that did not match the accompanying A&G CMTP to WNP-2.
As discussed in Section 3 below, the allegation was subt.tantiated in that the manufacturers' markings were not. described on the l
CMTR and A&G had partially identified the. order of 200 nuts with the A&G mark.
l 3.
Allegation Information Obtained from A&G A&G identified a need within the nuclear industry for 5/16"-18 Hex Heavy Nuts, Grade 2H, UNC 28, and ordered a bulk quantity l $.
1
.-. m
l ORGANIZATIONS. A&G ENGfMEERING COMPANY, II INCORPORATED 3'
-ANAHEIM,. CALIFORNIA 1
i REPORT-INSPECTION NO.:' 99901006/89-01 RESULTS:
PAGE 5'of.7
-(81,000) of commercial grade, ASTM A194, nuts from Hy-Port Hamanaka,-
Osaka, Japan, on purchase order No. 7399, dated October 1,1986.
1 The nuts.were received with a CMTR from Uchimoto which identified the nuts as Heat No. D4X279 and marked "2H U."
The nuts were.
assigned A&G heat code IZJ.
)
While reviewing the CMTR from Uchimoto, A&G stated that they.
noted that'the times and temperatures of the heat treating were 1
not reported on the CMTR. The SA-194, Grade 2H, material specifi-cation requires a minimum tempering temperature and NCA-3867.4(a)(2) 1 requires that the heat treating time and temperature be reported, when it is required by the material specification.
In order to fulfill these requirements of.the material specif' cation, A&G sub-contracted with Precision Heat Treating Co. to: perform a quench and tempering treatment to meet the requirements of 5/-194, Grade 2H.
Precision Heat Treating Co. reported the results of the quench and tempering treatment performed on 81,000 nuts on certified test report No. 151700.
A&G now had to perforn a?1 of the mechanical tests required after heat treatment for SA-194, Grade 2H, nuts. The material specifi-cation requires that for lot sizes of over 20,000 pic:es, 5 pieces be tested for:
a) hardness; b) proofload, and c)-24 hour elevated temperature hardness test. A&G subcontracted the performance of
- i
~
these tests to Atlas Testing Laboratories, Inc. and the results-were reported on laboratory -test report No. 13743-2.
In= addition A&G. confirmed the chemical composition of heat code IZJ on 5 samples tested.bv Atlas Testing Laboratories, Inc., laboratory test report No. 13743-1..A&G did not perform a product analysis to verify the chemical composition of each piece (nut) of stock material furnished by Uchimoto, as required by NCA-3867.4(e)(2).
uL, (SeeNonconformancei,9-01-03) l Af ter A&G had completed the treatments and tests necessary.to l
complete the requirements of the material specification, A&G considered themselves a material manufacturer,= as defined.in L
NCA-9000. The SA-194 material specification requires that all
+
nuts shall hear the manufacturer's identification mark and shall be legiHy Mrked to indicate the grade and the process of the manufacture, as described in Table 5 of the material specifice-l.
tion. The nuts were received by A&G marked with a "U" for the R
manufacturer, Uchimoto, and "2H" indicating a grade of nut that L
has acen heat-treated to meet the required mechanical properties, t
although the Uchimoto CMTR did not report the minimum tempering temperature. A&G considered themselves to be a material l
l
v ORGANIZATION:. A&G ENGINEERING COMPANY,11 INCORPORATED ANAHEIM,; CALIFORNIA-l y:
x
(
INSPECTION
=
L REPORT ~
'RESULTS:
PAGE 6 of 7 NO.: 99901006/89-01:
h manufacturer at provided for in NCA-9000'because A&G had1 supervised or directly controlled one or more operations which I'
affect.the material properties required by the material ~specifi-L cation and verified.the satisfactory completion of all the L
requirements of the material specification. Based on A&G's A&G manufacturer's mark "(quirements, A&G decided to apply.the interpretation,of these re l
-)" directly over the Uchimoto mark o
"U", thus obliterating the Uchimoto mark and consequently
. destroying the traceability of the nuts to the Uchimoto CMTR'.
L (SeeNonconformance 89-01-04)
According to A&G the strike over of the manufacturer's mark was I
done to fill a'500 nut order from Rancho Seco Nuclear Generating Station on purchase order No. RQ-88 30-39025', dated Octolier827, -
i 1988. This order was shipped on November 22, 1988.
Subsequently, WNP-2 placed an order for 200 nuts on purchase-order No. 098608, dated November 23, 1988. The order was shipped on December 22, 1988. WNP-2 discovered that the markings en 195 i
of the 200 nuts did not match the A&G CMTR.' The markings on 195 of the nuts was a "U" (Uchimoto). During the NRC inspection, A&G
~'
J advised the inspectors that the 5 nuts with the overstamped A&G marking must have been leftover from nuts overstamped for the Rancho Seco order. The 200 nuts were returned by WNP'2 to A&G on Decembc-30 -1988. The nuts were replaced by A&G and sent to
- WNP-2 on January'24,-1989.
During receiving inspection on the-replacement nuts, WNP-2 noted that the Nuts eppeared to have the original mark "U" removed by abrasivewans and Nsta.nped with the A&G mark.
Indication of the prevlous manufactuer s mark, "O," remained on 44 nuts. -A&G was'not able:to espitin the L
difference in markings observed on'the 5 nuts from'the original i
order of 200 verscs the markings observed on the re l
-This concern remains an Unresolved stem (89e0143). placement nuts.
(Alsosee~
Nonconformance 89-01-02)
Section 4.0 of the A&G QAM and procedura 114 requires all vendors /
suppliers to be on the QVL and s;rveyed annually.. The inspectors verified that all suppliers of iews and suvices were on the QVL except Uchimoto. Documentation indicates that vendors / suppliers are surveyed on an annual basis.
~(See Honconformance 89-01-01) n-4.
10 CFR Part 21 The inspectors examined several 3rocurement records to determine 1
whether the A&G procedures and t1eir implementation met the requirements of 10 CFR Part 21 and A&G QAM requirements.
Informa-tion pertaining to 10 CFR Part 21 is provided in procedure 104.,
-r i
=
7
.y
_~
V*
ORGANIZATION:- A&G ENGINEERING COMPANY, II INCORPORATED ANAHEIM, CALIFORNIA r
i RE/0RT RESULTS:
PAGE 7 of 7 INSPECTION-K0.: 99901006/89-01
" Reporting-of Defects and Non-Compliance," Revision C,. dated February 6,1989. ' The inspectors determined that 10 CFR Part 21 q
applicability appeared on A&G P0s to subvendors and the latest revision of 10 CFR Part 21 and Section 206 of The Energy Reorganiza-tion-Act of.1974 were posted in the plant..
5.
Training and Qualification The inspectors review of training records for eleven employees i
determined:that A&G inspectors and examiners were qualified according to procedure 112, " Qualifications Requirements for
-Lcvel I, II, and III Inspection and Examinatio.n Personnel,"
"j Revision 8, dated February 5, 1988.
- Qualifications for four lead auditors were documented on auditor-qualification sheets and consisted c,f education, experience,,
accomplishments, communication skills training courses, and t
--audits-performed.- Training is described in procedure 108, " Lead-Auditor Qualification," Revision A dated April 4,1985.
1
-F.
PERSONS CONTACTED: '
]
- W.
Cook
- J. Thalasinos' 1
- M. Thomas
- Attended exit meeting.
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Document Namer lA&G ENGINEERING REPORT l
' Requestor's ID:
HOWARDi Author's Name:.
Io L
=RAMON-CILIMBERG 1
Document' Comments:
. VENDOR INSPECTION AT A&G ENGINEERING " LIMITED DISTRIBUTION" ls 1
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