ML20099H728

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Affidavit of Tj O'Neill Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Matl Licensing Issues Resolved by NRC on Basis of False Statements & Omissions.Failure of Diablo Canyon Allegation Mgt Program Described.New Info Encl
ML20099H728
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Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 02/22/1985
From: Oneill T
GOVERNMENT ACCOUNTABILITY PROJECT
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2.206, NUDOCS 8503190472
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I I Exhibit 10 -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE NUCLEAR REGULATORY COMMISSION In the matter of )

) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC . ) 50-323 COMPANY )

)

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF TIMOTHY J. O'NEILL State of California )

) ss County of San Luis Obispo )

City of San Luis Obispo )

The above being duly sworn deposes and says:

My name is Timothy J. O'Neill. I am providing this state-ment to describe the actions of the NRC Region V (hereafter re-ferred to as RV) staff in regard to investigating my concerns of quality-related deficiencies at Diablo Canyon. I will also present new information material to issues that I have raised, which has only recently become available. It is my firm belief that the RV staff did not investigate my concerns in a competent and objective manner. As a result, the RV staff concluded in almost ovary instanco thet ry allegations were unsubstantiated, however I believe this was the implicit goal of the Diablo Can-yon Allegation Management Policy (DCAMP).

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a I. MATERIAL LICENSING ISSUE RESOLVED BY THE NRC ON THE BASIS OF FALSE STATEMENTS A;iD OMISSIONS The issue of improperly welded ASTM A-307 material as welded studs was considered material before the Atomic Safety' Licensing Appeals Board ( ASLAB) in denying a mo-tion to reopen the record on construction quality assurance.

I identified this discrepancy to the RV staff in January, 1984. New information recently obtained places the con-clusions by the RV staff and the Commission on this issue in serious doubt, and shows a blatant disregard for fact-ual information available within the NRC at the time of the licensing vote.

1. On January 13, 1984, I identified widespread use of ASTM A-307 material in welded applications without a qual-ified welding procedure. This is a significant breakdown in both design and construction quality assurance, and was reported to both the licensee and the NRC RV staff by a discrepancy (nonconformance) report.2 My report was cen-sored by the Pullman QA department to omit all reference to ASTM A-307 material.3 1

See ALAB-775, dated June 28, 1984, at Footnote 21.

2 Refers to original draft discrepancy report submitted as Exhibit 2 to Petition under 10 CFR 2.206, dated July 27, 1984, and ammended July 29, 1984.

3 Attached as Exhibit 3 to Petition under 10 CFR 2.20'6 referenced in (2) above. This is the official report sub-mitted to the licensee as Discrepancy Report 5739.

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2. Use of ASTN A-307 material in welded applications can-not be considered conservative engineering practice, as the quality assurance requirements normally associated with the manufacturing of bolts for flanged joints are wholly in-adequate to ensure weldability for critical installation'. s Welding of this material m'stu be in accordance with the ASME Boiler and Pressure Vessel (B&PV) Code,Section IX.4 Section IX requires chemistry controls not found in the A-307 specification to ensure weldability. There was no procedure qualified to weld this material, and as're-cent new information indicates, serious doubts as to the adequacy of the quality assurance program of a vendor iden-tified in my report. The quality of these installations is not assured, it is indeterminate.
3. I provided my report to the staff at the same time as it was submitted to the Pullman QA department for two rea-sons; this was a serious, plant-wide deficiency and I felt -

the on-site QA system would not consider this a problem, although it clearly violated the ASME Section IX require-ments for weldable materials. I cautioned the staff to watch the process of how the deficiency would be accepted, which in fact, was attempted by the licensee.

4 To weld this material with welding procedures pre-viously qualified, additional chemical requiremen:s in the form of stock traceability to a certified chemistry or cer-tified material test report (CMTR) showing that the mat '

erial conforms to one of the ASTM specifications listed in AS!2 Section IX, Part QW 422 1:.as a P-1 matericl, is required.

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4. Withhn a week.of submitting my report, NRC RV staff i

inspector Dennis Kirsch was questioning Pullman's QA man- i ager over this discrepancy. Instead of observing from a  !

distance, Kirsch plainly violated my confidentiality by  !

the fact that he was asking questions about the problem. ,

At this point, Pullman became significantly more hostile to me as an employee.

5. In a meeting with QA manager Harold Karner on January 18, 1984, I was told by Karner that "all A-307 material was produced from A-36 steel", although Karner had no ob-jective evidence to prove this statement. I explained the  !

technical requirements for weldability of carbon steel,

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specifically carbon content control and material trace-ability, to refute the assertion that weldable grade mater- l ial is universally used to produce bolts. There is no as- r surance that weldable grade bolts were supplied at Diablo (

Canyon, and used extensively in safety-related pipe supports. j

6. In the above referenced meeting, Karner produced a chart .

from ASME B&PV,Section III which listed ASTM A-307 as a P-1 material. .I replied that the section was not applicable, j as it concerned bolting stress allowances for design. For [

weldability,Section IX is the controlling document and does not recognize A-307 as a weldable (P-1) material. Karner re-fused to include A-307 in the official report, which is in l reality falsification of a document by omission.

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ASME B&PV Code,Section III, Table 1-13.3, entitled ,

" Yield Strength Values for Bolting Materials", Winter Add- [

enda, 1978. ,

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7. The use of ASTM A-307, A-325, A-194-B7, and other mat-erials as well in welded applications clearly indicate a pervasive breakdown of quality assurance in regard to weld-ed studs. Also, there was no design review by PG&E for weldability of the materials, as the ASME Code clearly prohibits welding of these specifications with the pro'-

cedures qualified and in use at Diablo Canyon.

8. For PG&E to admit that a breakdown in quality assur-ance of this magnitude existed, it would have to be cor-rected prior to licensing the plant. At this time, PG&E.

was requesting an operating license for Unit 1. New in-formation only recently made available indicates a ser-ious breakdown in the quality assurance program of a sup-plier of ASTM A-307 bolts referenced in my original report.

9. Exhibit 1 is the June 29, 1984, NRC Information Notice 84-52. entitled, " Inadequate Material Procurement Controls on the Part of Licensees and Vendors". The information con-tained in this report infers significant deficiencies in the quality assurance program of Cardinal Industrial Prod-ucts, a supplier referenced in my original report on this issue. This information was also available to the RV staff throughout the licensing process, but was not mentioned as being applicable to Diablo Canyon. The fact that the NRC cited Cardinal for poor quality assurance can not lend any credence to the idea that A-307 bolts were produced from weldable stock material.

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10. Exhibit 1 references NRC Vendor Inspection Report No. 99900840/83-01, which concerned the specifics of the NRC inspection of Cardinal. In a February, 1984 cover letter, the Chief of the NRC Vendor Program Branch (VPB),

Division of Quality Assurance, Safeguards, and Inspection Programs tells Cardinal:

"... Serious deficiencies existed in implementation of quality assurance relative to manufacturing and supply of materials to the nuclear industry."

and "...The nature of the inspection findings is such, particularly with respect to the use of stock mat-erials for nuclear orders and certification with-out assuring performance of required examinations and tests, that it raises concerns in regard to the propriety of your actions and both the cred-ibility and adequacy of the quality assurance function..."

11. As a result of the NRC audit, PG&E's own auditors co-incidentally found the same deficiencies in Cardinal's past

. quality assurance program approximately six months after the NRC released Information Notice 84-52, and nearly a year after the release of VPB Inspection Report 99900840/83-01.

These findings were conveniently ignored until well after any licensing impact, and are detailed in a PG&E letter dated December 20, 1984, which is included as Exhibit 2.

12. In classic style, PG&E describes a serious breakdown in quality assurance, yet then offers only superficial cor-rective action. It has been my experience that this type of response to deficiencies is PG&E's ide,a of correcting I

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the problem. PG&E's letter, identified as Exhibit 2 states, inter alia, that:

... audit 84408S of Cardinal Industrial Products, Las Vegas, Nevada, December 6-7, 1984, identified significant deficiencies.in (Cardinal's) past qual-ity assurance program. We are providing this no-tification prior to the formal audit report because the findings may have an adverse impact on material supplied by Cardinal."

and from Page 2:

...the quality of the fascener materials (PG&E) has received on the purchase orders listed above is in-determinate at this time."

and "

...after a few more corrective actions are verified, (Cardinal) could be reinstated as a qual-ified supplier..."

13. From the above statomonts, PG&E has inferred that the current program at Cardinal is not quito acceptable, yet the discrepant materials are the product of the prior qual-ity program at Cardinal which wasn't identified by PG&E un-til lato 1984. This admission raises questions as to the adequacy of the vendor audits performed by PG&E and their subcontractor, Pullman, which should have found those con-ditions prior to late 1984.
14. The letter included as Exhibit 2 instructs PG&E sito personnel to locato and identify materials supplied by Car-dinal for "rovalidation tosting". The context of this lotter, and subsequent sito actions, indicato that the material will be accepted as-is on the basis of evaluation of field samplos.

As procurement controls on the stock used to produce those materials in suspect, "rovalidation" could simply mean fal-n

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sification of material test reports. If safety-related i materials cannot be supported with certifications to the source supplier, the material must be replaced with mat-l erial that can meet this requirement. In the case of weld-1 ed ASTM A-307 studs, all installations of this type sho61d be replaced with certified, weldable material of P-1 chem-( ical composition or verified as to chemistry limits.

15. Although PG&E site personnel are instructed by PG&E corporate quality assurance personnel to identify all Car-1 dinal material, the instructions relayed to the subcontractor Pullman have changed. Exhibit 3 is the letter describing l

the deficiency to Pullman. ,Instead of identifying all Car-i' l dinal material and placing it on hold, Pullman is directed

! to place only the material on ander or in storage on hold, and this is only a temporary hold. In this manner, the mat-l erial installed in the plant, which presumably came from the past quality program in question, is excluded from any l evaluation or corrective action.

16. Although PG&E is ultimately responsible to report con-l ditions to the NRC, PG&E directs Pullman to use their in-l house discrepancy reporting system to identify the indeter-l minate Cardinal fasteners. Pullman identified this on Dis-l l

crepancy Report (DR) 9173, which is included as Exhibit 4.

This report was evaluated by Pullman not to be reportable under the requirements of 10 CFR 21, although it could des-cribe widespread use of indeterminate material throughout both Unit 1 and 2.

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17. Discrepancy Report 9173 is written against mater-ial that is on order or in storage, and only for Unit 2.

This type of " corrective action" is a smoke screen, designed to confuse site personnel as to the actual discrepancy.

Notice that DR 9173 hardly defines the deficiency, but is more concerned with allowing the discrepant material back into the field for use. All of the activities as-sociated with identifying the discrepant material are to be completed in one day,. December 21, 1984. This is an example of the unrealistic deadlines imposed by an in-competent management, which clouds the real issue. To identify all installations of Cardinal material.would be a formidable task, considering the volume of records that would require review.

l'8. From the example above, PG&E is allowed to evade the requirement to report this condition to the NRC under 10 CFR 21. This is accomplished by telling Pullman to evaluate the condition for reportability. Pullman finds the condition non-reportable (in every case), PG&E agrees, and the NRC finds that "the licensee met their reporting requirements in a responsible manner". This is the method of reporting and correcting deficiencies at Diablo Canyon.

19. Exhibit 5 contains additional purchase orders from Cardinal, as did the draft discrepancy report I submitted on January, 13, 1984, as Cardinal was a supplier of the A-307 bolts referenced in that report. .

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20. A recently-released Region V Inspection report, '

dated February 5, 1985, contains some glcring false state-ments regarding the issue of welded ASTt: A-307 material.

In Report Nos. 84-42 and 84-31, I: spector Dennis Kirsch states, "The staff satisfied itsoif that A-307 was a mater-ial which was properly approved for AStiE or AWS usage and the use of welding procedure 7/8." This statement is false, as neither AWS or ASME recognize the use of this material without first oualifying a welding procedure usina this material. A further aspect of this is that conservative engineering groups would require more quality assurance of matorials than is required for A-307 in welded applications.

21. Dennis Kirsch uses the same flimsy excuse that Har-old Karner attempted to use more than a year ago by re-forring to ASME Section III, Table I-13.3. The P numbers listed in this table are for information only, and one must reference ASME Section IX for woldable materials.
22. The fact of this matter is that ASME Code Inter-protation NI-84-041, which is to be published in the next addenda to the Code, specifically citosSection IX as the controlling document as an answor to the very question posed in this case. The P-numbers listed in Tablo I-13.3 cannot be used to datormine woldabil.ty. This is oxactly what I told liarold Karnor more than a year ago, to refuto his contention that becauso Tablo I-13.3 listed A-307 as a P-1 material, it in fact was.

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23. Kirsch further states in his February 5, 1985 report that he " examined certified material test reports (CMTR) for the welded A-307 at Diablo Canyon. As this was the first time a CMTR had been mentioned, I called Kirsch on February 15, 1985 to gain more information. In this con-versation, Kirsch stated he had not seen the CMTR's until late 1984. In light of the fact that the manufacturer would not normally be required to have CMTR's for this material, and that the manufacturer was Cardinal Bolt, and that almost a year elapsed since the issue was raised, serious questions arise as to the validity of these reports.
24. When asked to cite purchase orders reviewed, Kirsch stated he "had not written anything down", and that he "could't remember which ones he looked at". .He did state that "several Purchase orders could not be matched to a CMTR". Although this would seem t,o substantiate my con-
  • corns, this was ignored by the staff. Due to the findings of the NRC VPB, there is little objective evidence to be-lieve that Cardinal would have above-board QA for their non-certified items, yet would be in so much trouble over their supposedly certified materials. sc
25. Kirsch could not confirm that the CMTR's he reviewed indicated that the material used to manufacture A-307 bolts was purchased as a P-1 material in accordance with Section IX of the AsME Code. This is the only acceptable conclusion to the acceptability of this material. j l

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i 26. Kirsch also refused to provide me with the CMTR's  !

! so I could review these myself, stating it was "not ger- l maine to the issue that I see these". As he admitted l

that these records weren't " resurrected" from cardinal until late 1984, I cannot accept Inspector Kirsch's con-clusions without some objective evidence to support any  :

of his claims. Had these records been available in early 1984 when I identified this concern, this issue could have been put to bed long ago, in a responsible, forthright (,

manner on the record. j

27. b Had a proper investigation been conducted, Kirsch  ;

would have been asking Cardinal for this information ap-l proximately on's wee.k after I reported it to the NRC, rather f t

than " tipping his hand" to the utility and letting them l in on the fact that the information had been supplied to  !

the NRC. i L

t l 28. In a February, 1984, interview with RV inspector i Gonzalo Hernandez, I was told by Hernandez that, "NRC l

metallurgists had determined that A-307 material was ac- '

captable, but that A-325 was not." As Region V would not i examine a CMTR until it was " resurrected" almost ten months later, I wonder what Hernandez was citing as evidence that I no problem existed. The metallurgists referred to in this i

l conversation were most probably PG&E's. Further attempts  !

throughout March, April, and May to obtain any objective  !

evidence for this conclusion proved futile.  !

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29. NRC Region V staff stated falsely in testimony before the Commission that the use of ASTM A-307 material in weld-ed applications was authorized by a Code Case to the ASME B&PV Code. In fact, no current Code Case is applicable

.o to this material in welded applications.

30. The fact that the NRC Region V staff's position on this matter parretted the original excuse that Pull-man and PG&E offered proves the staff's willingness to accept licensee responses to allegations at face value, with no critical review of the information presented.

In this case, the use of ASTM A-307 material is clearly unacceptable without some objective evidence that this material, as s'upplied to Diablo Canyon, meets the ree.uire-ments for weldable chemical composition. Had this infor-mation, if it existed at the time, been made available, this would not have become the issue it now appears to be.

6 Transcript of " Discussion and vote on Full Power Operations for Diablo Canyon", dated August 2, 1984, test-imony of Bishop, page 53, specifically stating that ASME Code Case N-71 authorized ASTM A-307 as a P-1 material.

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II. FAILURE OF THE DIABLO CANYON ALLEGATION MANAGEMENT PROGRAM ( DCAMP).

The DCAMP system, described in SSER 22 for handling and resolution of allegations submitted to the NRC, failed to operate in an objective manner as described in SSER 22.

A key provision which was not followed was feedback from allegers to confirm the staff's understanding of allega ,

tions. Instead, the RV staff pursued allegations based ,

largely on PG&E responses, and essentially put the bur-den of proof on the alleger to substantiate the concern t

without access to the documentation necessary to do so.

r Furthermore, the staff refused to held timely follow-up interviews by offerring the excuse that it was not "prac-ticable" due to the sheer volume of allegations.

In regard to my allegations, DCAMP was a failure for the following reasons:

31. The RV staff accepted licensee false statements, which '

then became the basis for the staff's conclusions that the allegations were unsubstantiated. This resulted in more allegations, based on the staff's inability to ad-l dress the initial allegations in a responsible manner.

32. The RV staff ignored relevant NRC rules and regula-tions when these had an adverse impact on licensing the plant. These include Appendix B to 10 CFR 50, various NUREG and Regulatory Guide standards, national Codes and standards, and relevant information generated within other

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branches of the NRC.

33. By refusing to hold timely follow-up interviews, the staff was able to mischaracterize allegations, and stall for time while the licensing hearings proceeded. Many allegations appeared with the staff's position identical to the licensee, which required additional affidavits to i clarify issues which, more appropriately, could have been clarified at a follow-up interview.

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34. The staff freely divulged the content of'our confi-dential conversations concerning harassment and intim-idation to the very management individuals who, I believe,

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were orchestrating the process in an attempt to get me off the Diablo Canyon site. By PG&E's own admission at

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r the time, the delays caused by allegations were costing  !

upwards of $16 million per week. The types of deficien- '

cies I was finding as an inspector were serious enough ,

as to have licensing impact. As licensing drew near, '

and particularly after the June ASLAB hearings, the har-assment I was getting became markedly more severe. Exhibit 6 is a decision by the California Unemployment Appeals Board,  !

Case No. VN 24357, concerning Pullman's appeal of my un- i employment insurance claim. This report states, inter alia, "The Department determined that the claimant had quit '

his job because of unsafe working conditions which '

were brought to the employer's attention but insuf-ficient action was taken to correct this matter".  !

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. 1 and ...the claimant had voluntarily quit because of l hazardous working conditions after informing the l employer that a need for corrective action need be taken. The claimant met his reporting respon- i sibility to the employer by making the employer aware of his concern. The Department determined ,

that insufficient action was taken to correct the problem"by the employer. The Department determin- ,

ation and ruling and the presumption was not re-butted by the employer."

35. NRC investigations did not make an effort to pro-tect the confidentiality of the allegers. The effect of +

the investigations was to alert the licensee and sub-contractor who the " problem" individuals were who were

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providing information to the NRC. These individuals, myself included, were then targeted for harassment.- i

'36. The RV staff refused to allow allegers to participate in the decision-making process. The attitude was that once a concern was voiced, no further involvement was necessary. This would be acceptable if the staff were actually investigating these concerns, however the staff and PG&E acted in concert to arrive at the conclusion that i

the vast majority of allegations were unsubstantiated. I believe had the facts been examined, this would not have been the case.

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37. Once PG&E established the Quality Hotline in March, ,

1984, the staff refused to accept new allegations. I was wary of dealing with the Hotline, but did make several al-legations that the NRC refused to listen to available to

! the Hotline. - These concerned concrete drilling practices, l

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harassment over discrepancy reporting priority, and mater-ial storage problems that the subcontractor refused to deal with. The Hotline, as I suspected, was a vehicle for PG&E management to stall issues past any licensing deadline, while management ultimately succeeded in making my life'on site so miserable that I had no choice but re-sign.

38. The bottom line is that the conduct of the staff in-vestigat' ions in' regard to my allegations leaves me with little confidence that they were conducted in an objective, competent manner. In this regard, it is not surprising that the staff conclusions parrotted PG&E in almost every instance.

I have read the preceeding l7 page affidavit, and the information outlined herein is true and accurate to the'best of my knowledge.

Dated: February 22, 1985 / ,

T hJ. O'Neill Subscribed and sworn before me this 2 2nd day. of February, 1985 L t e.,

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F'l/T I SSINS No.: 6835 IN 84-52 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 JUNE 29, 1984 IE INFORMATION NOTICE NO. 84-52: INADEQUATE MATERIAL PROCUREMENT CONTROLS ON THE PART OF LICENSEES AND VENDORS Addressees:

All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP).

Purpose:

This information notice is provided to inform licensees of deficient procure-ment controls and quality assurance (QA) practices on the part of suppliers of nuclear materials and to call attention to possible generic problems in procure-ment activities of licensees. No specific action is required in response to this information notice, but it is expected that recipients will review the information presented for applicability to their facilities.

Discussion:

The Vendor Program Branch (VP8) of the NRC inspects vendors, material manufac-turers, and material suppliers of licensees. One purpose of these inspections

.is to verify that vendors and suppliers of safety-related materials to licensees are complying with the requirements of 10 CFR 21 and Appendix B to 10 CFR 50. These inspections have revealed a large number of quality-related deficiencies on the part of nuclear suppliers such as:

a. Improper certification of stock materials as being fabricated and/or upgraded in accordance with ASME Code requirements.
b. Inadequate inspection of materials received.
c. Failure to ensure satisfactory performance of required mechanical testing and nondestructive examination.
d. Inadequate and/or incomplete survey and audit records.
e. Breakdown of procurement controls with respect to the requirements of 10 CFR 21, Appendix B to 10 CFR 50, and the ASME Code.

Table 1 lists vendors and recent VPB inspection reports where specific dis-crepancies have been identified regarding implementation of the vendors' quality assurance programs. These reports are published quarterly by the NRC in the " Licensee Contractor and Vendor Inspection Status Report," NUREG-0040.

Copies of this document (the White Book) may be obtained at a nominal cost OM%T@UL --

  • IN 84-52 NUCLE June 29, 19E Page 2 of 2 e

from the National Technical Information Service, Springfield, VA 22161.

Correspondence with contractors and vendors relative to the inspection data contained in NUREG-0040 is placed in the NRC Public Document Room, 1212 H St., N.W., Washington, DC 20555. .

Deficiencies also have been identified with respect to licensee procuremen1 and associated QA activities. The licensee is responsible for the quality of purchased nuclear materials and for procurement control of its vendors and suppliers of safety-related material. Deficiencies of this type incluc

a. Inadequate specification of code requirements on purchase orders and other documents.
b. Failure to develop and, monitor an approved vendor list
c. Inadequate inspection of materials and components when received.
d. Inadequate survey and auditing of vendor QA programs.
e. Failure to perform adequate internal audits of the procurement proces
f. Inadequate training of personnel who procure nuclear materials under requirements of 10 CFR 21, Appendix B to 10 CFR 50, and the ASME Code
g. Insufficient management attention to procurement activities.

No written response to this notice is required. If you have any questions regarding this matter, please contact the Regional Administrator of the appropriate NRC regional office or this office.

tdward L,. Jorda , Director Division of Emergency Preparedn ss and Engineering Response l

Office of Inspection and Enforceme Technical Contacts: N. J. Miegel, IE (301) 492-7557 E. W. Merschoff, IE (301) 492-4572 Att.achments:

l 1. Table 1

2. List of Recently Issued IE Information Notices

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Attachment 2 IN 84-52 June 29, 1984 LIST OF RECENTLY ISSUED IE INFORMATION NOTICES Information Date of Notice No. Subject Issue Issued to 84-51 Independent verification 06/26/84 All power reactor facilities holding an OL or CP 84-50 Clarification of Scope of 06/21/84 All power reactor Quality Assurance Programs facilities holding Pursuant to 10 CFR 50 an OL or CP Appendix B 84-49 Intergranular Stress Corro- 0'6/18/84 All power reactor sion Cracking Leading to facilities holding Steam Generator Tube Failure an OL or CP 84-48 Failures of Rockwell Inter- 06/18/84 All power reactor national Globe Valves facilities holding an OL or CP 84-47 Environmental Qualification 06/15/84 All power reactor Tests of Electrical Terminal facilities holding Blocks an OL or CP.

84-46 Circuit Breaker Position 06/13/84 All power reactor Verification facilities holding an OL or CP.

84-45 Reversed Differential 06/11/84 All power reactor Pressure Instrument Sensing facilities holding Lines an OL or CP 84-44 Environmental Qualification 06/08/84 All power reactor Testing of Rockbestos Cables facilities holding an OL or CP 84-43 Storage and Handling of 06/07/84 All medical licensees Ophthalmic Beta Radiation Applicators 84-42 Equipment Availability for 06/05/84 All power reactor Conditions During Outages facilities holding Not Covered by Technical an OL or CP Specifications -

OL = Operating License CP = Construction Permit

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b TABLE 1 i

DEFICIENT PRACTICES IDENTIFIED IN RECENT VP8 INSPECTIONS ISSUES VENDOR INSPECTION REPORT Program for certifying auditors non- Taylor Forge (G&W Mfg. Co.) 99900783/82-01 cxistcnt and/or use of auditors who Lone Star Screw Co. 99900781/84-01 had not been certified per documented quality assurance (QA) procedures Use cf suppliers not on an approved Ametek - Texas Flange Div. 99900884/83-01 v:ndors list and/or failure to Tube-Line Corp

  • perferm vendor audits as required Capitol Pipe & Steel Products Co. 99900015/83-01 by documented QA procedures West Jersey Manufacturing Co. 99900816/83-01 Louis P. Canuso, Inc. 99900818/83-01

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Cardinal Industrial Products Corp. 99900840/83-01 Diversified Threaded Products Co. 99900823/83-01 Lone Star Screw Co. 99900781/84-01 Nondestructive examination (NDE) discrepancies

c. failure to perform NDE in Tube-Line Corp.
  • tccordance with or as re- West Jersey Manufacturing Co. 99900816/83-01 quired by the ASME Code G&W Taylor Forge and/or the customer Stainless Div. 99900347/83-01 Cardinal Industrial Products Corp. 99900840/83-01
b. failure to document the Taylor Forge (G&W Mfg. Co.) 99900783/82-01 identity of persons per- , , , ,

ac n r.

fcrming visual examinations 15 5 c3C

c. f S r l c. failure to have complete Coffer Corp. 99900822/83-01 o l' "jM Knd/or current certification Ametek - Texas Flange Div. 99900884/83-01 "' _,  :',

recards for NDE personnel Tube-Line Corp. *

il ..

Taylor Forge (G&W Mfg. Co. ) 99900783/82-01 ^

)

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. I ISSUES VENDOR ,

INSPECTION REPORf I

Cardinal Industrial Products Corp. 99900840/83-01 Lone Star Screw Co. 99900781/84-01 Diversified Threaded Products Co. 99900823/83-01

d. commercial NDE performed in lieu of Tube-Line Corp.
o. failure to have NDE records, reports, Capitol Pipe & Steel Products Co. 99900015/83-01 and/or material certification Tube-Line Corp. *
f. use of NDE procedures that are Capitol Pipe & Steel Products Co. 99900015/83-01 either not approved in accordance Coffer Corp. 99900822/83-01 -

with documented QA procedures or Tube-Line Corp.

do not meet ASME Code requirements Helt treatment discrepancies c .' failure to perform heat treatments Ametek - Texas Flange Div. 99900884/83-01 ts required by the ASME Code and/or Tube-Line Corp.

  • documented QA procedures Lone Star Screw Co. 99900781/84-01
b. no evidence to support heat treatment Ametek - Texas Flange Div. 99900884/83-01 data stated on CMTRS Coffer Corp. 99900822/83-01 GAW Taylor Forge Stainless Div. 99900347/83-01 Capitol Pipe & Steel Products Co. 99900015/83-01 West Jersey Manufacturing Co. 99900816/83-01 yW3 Tube-Line Corp.
  • y, g , g Cardinal Industrial Products Corp. 99900840/83-01 ,,,,j-ry Lone Star Screw Co. 99900781/84-01 o y> g g

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!?

d ISSUES VENDOR INSPECTION REPORT

c. failure to pass on heat treatment Cardinal Industrial Products Corp. 99900840/83-01 requirements to heat treatment vendors
d. failure to document heat treatment Cardinal Industrial Products Corp. 99900840/83-01 required by the customer, invoked codes, standards and/or specifications Failure to perform and/or document Taylor Forge (G&W Nfg. Co.) 99900783/82-01 rccsiving inspections failure to pass on requirement that Tube-Line Corp.

, natirial be manufactured in accordance Cardinal Industrial Products Corp. 99900840/83-01

, with a QA program meeting ASME Code Lone Star Screw Co. 99900781/84-01 l r:quirements Diversified Threaded Products Co. 99900823/83-01 Failure to specify on purchase orders Cardinal Industrial Products Corp. 99900840/83-01 4

(P0s) that 10 CFR 21 was applicable 0iversified Threaded Products Co. 99900823/83-01 Lone Star Screw Co. 99900781/84-01 Coffer Corp. 99900822/84-01 Failure of the QA department to review Coffer Corp. 99900822/83-01 cnd/or approve P0s Cardinal Industrial Products Corp. 99900840/83-01 Diversified Threaded Products Co. 99900823/83-01 Failure of QA to review and/or approve Coffer Corp. 99900822/83-01 ..

drawings and/or manufacturing shop Diversified Threaded Products Co. 99900823/83-01 2?ETETFi travelers -

% S eg {

'" l $ li: 5I

% ~ "' "s t.

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ISSUES VENDOR INSPECTION' REPORT (

bilura to review suppliers' CMTRs Capitol Pipe & Steel Products Co. 99900815/83-01 i

%/cr acceptance of CMTRs which were Coffer Corp.

st in compliance with P0 or material 99900822/83-01 L. P. Canuso, Inc. 99900818/83-01 becification requirements Cardinal Industrial Products Corp. 99900840/83-01 Diversified Threaded Products Co. 99900823/83-01 occdur s not available at work stations Coffer Corp. 99900822/83-01 '

i bilura to control ASME Section III flanges Coffer Corp. 99900822/83-01 on being mixed in with commercial flanges pilura to establish measures to ensure that Tube-Line Corp.

  • fidingiscontrolledandaccomplishedin Cardinal Industrial Products Corp. 99900840/83-01 tc:rdance with the applicable codes ictrrect attestations of material meeting Tube-Line Corp.
  • ME Code requirements Ametek - Texas Flange Div. 99900884/83-01 Cardinal Industrial Products Corp. 99900840/83-01 Lene Star Screw Co. 99900781/84-01 a of stock materials without properly Ametek - Texas Flange Div. 99900884/83-01 trtifying the material per procedures Capitol Pipe & Steel Products Co. 99900015/83-01 i the ASME Code, standards, and/or Tube-Line Corp.
  • iecifications Cardinal Industrial Products Corp. 99900840/83-01 Lone Star Screw Co. 99900781/84-01 Diversified Threaded Products Co. 99900823/83-01 ac->

iiluro to perform testing required by Cardinal Industrial Products Corp. 99900840/83-01 .$ E " N be customer, invoked codes, standards, Lone Star Screw Co. 99900781/84-01 **$$

}'$ } {

id/sr specifications Diversified Threaded Products Co. 99900823/83-01 P.

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VENDOR INSPECTION REPORT ISSUES Cardinal Industrial Products Corp. 99900840/83-01 Failure to provide original CMTRs as required by NCA-3800 in the ASME Code resulting in transmittal of incorrect and/or inaccurate material data "Information regarding Tube-i.ine is contained in NRC IE Belletin 83-06, dated July 22, 1983. This document was mailed to licensees in July 1983 and is available in the Public Document Room.

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  • *va o * '-' a' M/dAGER, QUALITY A!5 MANCE 01C 201984
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CENERAL CONSTRUCTION

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Prompt Notification of Actions Resulting .

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from Supplier Audit of Cardinal Industrial Products

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December 20, 1984 .

f*,).'$i d.. ..4 .-

MR. J. R. MANNING: 3: ' .

- . N. ' ;- ' . c :U .

, !f..'.'.' y . q.9-ATTENTION: MR. R. LIEBER *

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.. . n .: a.y_ s, q. .

. Quality Assurance Imple=entation Audit 844085 of Cardinal '

Industrial Producte, Las Vegas.. Nevada. December 6-7 '1981

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idcpti'ied significant deficiencias in their past quality

, assurance. Program. Se are providing this.no'tification  ;..;

%1'.-

the issuance of the formal audit report becaus' e the findings.nay 4 .';., ' 5' ' ' ,

have an adverse impact on material s'upplied by Cardinal.

7 , , , . J,' ' ' - >

Cardinal has provided fasteier materials for the Diablo Canyon "

Power P3 ant en the fo)1oving purchase orders: .

. ; .. ..<; .. . .v.. . . .

P.O. 594705 - N.P.O.

. . .. i, '

P.O. 577706 - N.P.O. ...(-

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P.O. 321791 - N.P.O. ', .

'#.0. 593976 - N.P.O. .

P.O. 4R67175 - G.C. '

P.O. 4R66170 - C.C. '

' . c..

P.O. 057152 (Poley) - G.C. .- ,

., . . ; , . f .;J '

The audit  ; t :i; .-;

!dentified.seven deficiencies in Cardinal's quality , j , , ~,, 6.fl. ,-

program, of be significant:

which the following three deficiencies were found to.e . mi; '

i

1. '

The auditors determined that Cardinal did not have sufficient documented evidence to support the l

qualifications of their suppliera of certified materials and processes for the fastener vaaterial furnished to PGandE. j 2.

The auditors identified certifications for the heat treating of taaterials shipped to PCandE that did not '

contain the heat number of the subject material. .

3. The auditors identified materials shipped to PCandE .

that had not received required tensila strength tests. "

1

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e Mr. J. R. Manning -

Dece-ter 20. 19Be These de!!ctencies w:re identical or siellar to the conconformances identificd by the FPC in their recent inspcction '

of Cardinal Industria; Products. ced our audit determined that thess deficiencias de.cerly related ra rhe marer**1m gnpp1*ed te Diablo Canyon. As a result..the quality of the fastener

~.aturials we have received from Cardinsi en the purchase order.=

listed above is indeterminate st this tine.

Cardf9a3 has instituted a 'evad#*

aart".d Lasting a a result of the up.. "yn'U*...,.

' ' "- prostam thicugh third e .

a :ee- t- *nc u e $e esterials su;p'te' to DC " ' , - E ,~ ' t have

.i "

t .a: revalidation prog:n . Cardinal sti;l has ~

'5 C-c same materials ser: :.- pcang.g g., tse , . s. ...

P r e.,. u.T 's es * * "t otha.

c k' a -

a".,ccate and

,n the third party return tes:of a s:Pfle . but s-be PGandE use a av 'e '41" ***d e *c3 to warminal a' fer testing. ,

  • "e ex;e :;?:5.

Te:raz;y t: :btain the rcvalidatier resu;ts frer Cardi tal by 6

"ardinal be Icested Mest.v'ile, we re:: .rtnj ths; the iters supplied ar.d tagged ir 6;plicable requirc ents of your de;a.rta:::rden:e ceta*. preendu:es. with the

s re cest en exte sier.

that yeu reses ch yeur re:: ds and n::1Cy P.; D. S. AS!'n Carcinal. 3020/3190 if there hava bacr. e.:Mer tur:5aser f:c-A:

Cardi al's re:aest ve else cont.:ted a :.alift: 2:::r auf*! cf if we;dir.a;'s ASPE NOA-3S";; que.11:y as>. se:e r grar te deter-tr.e eesid retr. state ther en cur Qualified f ur;11ers List fc!

fe:::e erders. k'e fcund that Cardir.s; Mad taken significant s* ps in recent renths te ir;::ve -heif ;uality r;rcEra 4-d that ef:c: a few re e corrc::ivs actiens +:e ve::fied, they cruld bc -

re;;.statet 3?-L * .

es a qua*ified s';;l'er urf+: 3*a-dard 'Ft-ifiesti"-

N . befetod r . ~ . . r. .

~hta::n(30:*.3490):vr*

cc: R. A. H:tgeed

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PACIFIC OAS.S.ND E LE C T RIC C O M PANY 3: .% W3 -F- DIABLO CANYON PROJECT

  • GENERAL CONSTRUCTION P O Box tir
  • AVILA SEACH. CAUtOAMA 93424 *#805) 595 2324 {

December 21, 1984  !

Mr. P. Stieger Pullman Power Products P.O. Box 367 Diablo Canyon Project Avila Beach, CA 93424 SUB. LECT: Purchase and Control of Cardinal Fasteners

Dear Mr. Stieger:

.- i I

The PGandE Ouality Assurance Department has identified deficiencies in Cardinal l Bolt's quality assurance program which may af f act materials supplied to Diablo i canyon (see attached. letter dated 12/20/84). As a result, all-fasteners in' Class.

One storage supplied by ' Cardinal Bolt, i'ncluding thos'e ~ supplied thr6 ugh a third ,

i party, must be immediately identified utilizing Pullman's discrepancy reporting systems. This will also apply to fasteners purchased prior to this date which have not yet been received.

The PGandE Quality Assurance Department has requested that all Pullman purchases placed with Cardinal be identified by P.O. number and heat numbers to support any research necessary to trace fasteners for possible qualification testing by an independent laboratory.

Pullman is authorized to release these materials for installation, provided a >

system is established that will identify each fastener by size, material type, purchase order, heat and/or lot number, and installed location. In addition, ,

f asteners f rom each heat or lot shall be retained by Pullman for qualification '

testing conducted by others.

/

R. R. Lieber Field Construction Manager R. A. Hob o l G. C. Quality Control Supervisor '

RRL/RAHobgcod:kIh 0736m 000 23174

.__ _ _________. _ _,_ , _.____ _ __ _ _ _ . , _ _ _ _ , , _ . _o -_ _.

&s'p@f '

O.R. No -1 g") Pullman Power Products 5 ,["; [

10 CW' . j pl Code No. 01-10-G-P 8151 er915 NOTU i ATTACHED

- 'g eT X (yes) (30) 2'.,isTOug a . Feel'c Ga. 4 el.ettte SPac. No: 8711 CAft:12/21/84 ocesset. D C**v'" 7'77 see ac.: '~senerea: K 4 .1 / o --

l

scaspa=v traw.  !

CARDINAL INDUSTRIAL PRODUCTS CORP - VENDOR SUPPLIE0 MATERIAL g.atAmarrow op etsemapancy? .

Per PG&E direction, all material in Pullman warchouse which was ,

i manufactured by C4rdinal Industrial Products Corporatic'1 is being placed l I

on Hold.

This reouest is iq,part a result of th.9 following: ,

1. I.E. Information Notice C4-52. l
2. Removal of Cardinal Industrial Produdts Corporation from PG&E's Qualiffeo Suppliers List.

, Adcitional information will be included with this OR when available.

l ese:w. sween oiseesirio=: INDICATE ' APPROVAL SY CIRCLING THE APPROPRIATE

  • REC::te'E.'l0E0 ,

O!SPOSITION*

{ 1) Research the material currently in the Pullman warehouse and i storage areas to determine: -

l A. What was manufactured and supplied by Cardinal Industrial  ;

i Products Corporation. i

- 0, 'What was manufactured by Cardinal Industrial Products l FGF.2 G.C. Corporation but supplied by another vendor.  !

QUALITY CCMTCOL  !

(Example: Purchase Order with A & G who in turn :: ouch- ,

% " 9., - j material manufactured by Cardinal . )

][-

, (Continued - Page 2)

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! EXetANAftCM llP NGCSSSAAYl:

i l CONTROLLED CGPY a r Construct.icn  !

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  • ilt.i ty ?t C N- 3 M.se.r Q.A. F14 3 Aoin. sa a. E sag.a r ag Caet. C cta.r i 3 C e.m.e C .4 ag C P:.se f at t.e 8 i ef'ACM 3487CM t. NGCESSARY

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, 10 CFR 21 f e.a.no.

m. ac.

9l M - Pace 2 s0{

n/1 115) cr0IS NOTO

  • ATTAGED OlSCREPANCY REPORT unif No. II coat wo 01-10-G-P cuerp.sa: pseine cas a e!We spec.no: s711 cars: 12/21/84 penser: 0l**88 Caav*a aos no.: 7177 inspectca: Kinsnel/ Kino RECOMMENDED DISPOSITION: (Continued from Page 1)  !

Place all material manufactured by Cardinal Industrial Products 02 Corporation on Hold. -

L I

3) Prepare a list of all Cardinal manufactured items currently in s stock. The list shall include as a minimum:

A. P.O. number and item number.

l

8. Description of material (type, size, ASTM designation, etc.). i C. Location (warehouse / sea trains, row number, bin number,  !

etc.,ifapplicable). l D. Quantities. ,

E. Heat numbers or Lot numbers. -

l r .

1 4 . Identify all items currently ordered from Cardinal but not '

yet received. Items will be placed on Hold upon receipt.

i

5) Segregate and retain a minimum of four (4) items of each size and heat number for possible future testing. If i Tess than four (4) items are currently in stock, retain all items. .

y Items placed on Hold may be conditionally released under the fo11cwing conditions: ,

A. Items are p  !

identifying,ermanently marking traceable markedto thewith heat'the number heatornumber P.O. or an number / item nun:bar as applicable. (Darmanent marking  !

will be either low stress metal stamping or vibro etching.) ,.su- 3 /,,/,g

8. The specific location where the item (s) are to be installed is' identified. (Such as area, hanger number, system, iso number, flange connection, etc. , as .

applicable.) A record of these locations shall be retained in a separate file. A copy of'this file shall be attached to this OR.

C. Items released and installed are subject to removal if subsequent testing or evaluation determines that the ,

3 material is unacceptable, f

OR, PG8E to disposition. I

s3_d%b kBr,hehn#_ 2 : z~,1 : - rei --- xc. :-s r _e e e m . s c_- w- x Mp .#t N @lN INTEROFFICE CCARESPCNDENCE ,g DATI DECEMBER 21, 1984 to P. STIEGER/P. MOKRY/M. SACC0CCIA

~

ncM H. W. XARNER susJect MATERIAL SUPPLIED BY CARDINAL INDUSTRIAL PRODUCTS CORPORATION Per direction from PG&E, all Cardinal supplied material shall be placed on Hold. Please have the manufa'cturer verified for any bolting material that is requested prior to issue. An inventory and research of our storage areas is being conducted and all Cardinal items are bei1g placed on Hold.

Your assistance in completing this inventory By 12/21/84 will be greatly appreciated. A DR is forthcoming concerning this item.

Harold W. Karner QA/QC Manager HWK: sam I

cc: W. Kimmel C. Neary R. Xing ,

All QA Receiving (days & nights)  !

Warehouse l l

Jim Rowley ,

A. Eck i

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1 c.4M3 INTEROFFICE CCRRESPONDENCE ,4 4 oAre DECEMBER 21, 1984 to ALL WAREHOUSE QA PERSONNEL ncM H. W. KARNER susJECT CARDINAL INVENTORY

1. All Cardinal supplied / manufactured items shall be placed on " Hold." (bbits, nuts, washers, etc.)
2. Class I material shall be the priority items checked.
5. Record ALL pertinent information such as:

A. P.O. number.

B. Item number. .

C. Description (bolt, nut, washer, size, ASTM designation).

D. Location (warehouse / sea train, row number, bin number, etc.).

E. Quantities (if determining the quantity will impede the completion of placing all Cardinal items on Hold by 4:00 p.m.

on Friday 12/21/84, then eliminate the physical count to a later time.)

F. Heat numbers (record actual heat numbers. If recording heat numbers prevents completion of placing items on Hold by -

4:00 p.m. on Friday 12/21/84, then record at a later date.)

4 Place a Hold Tag on the mateilal.

S. Sign and date the form showing the information.

6. After all Cardinal items are on Hold, complete any necessary verification of quantities and heat numbers.

darold W. Karner QA/QC Manager H'lX: sam cc: C. Neary, P. Stieger, P. Mokry l .

Revision 12/27/84 INSTRUCTIONS FOR IMPLEMENTATION OF DISPOSITION OF CR 9173

1. (a) All items ordered from Cardinal in the warehouse or Area 10 have hold tags applied. Any new items received from Cardinal (or another supplier which uses Cardinal supplied material).

shall be hold tagged.

II. (a) All bolts, nuts, and washers in stock, supplied by other vendors must be checked to determine if the material originated at Cardinal. The "Boltina Material Manufacture Verification" form,shall be used.

(b) This form shall be filled out for each item as follows:

(1) The P.O. # of the item shall be entered.

(2) The Item # of the item shall be entered.

(3) The description of the item shall be entered.

(4) The manufacturer's box shall be checked. If "other",

enter the manufacturer's name.

(5) If~the item is marked " Cardinal" (a "C" or "K") check this box and place a hold tag on the item.

(6) If the item bears another manufacturer's stamp, enter the symbol here. This material is acceptable.

(7) If the item is not marked, check this box.

(8) If marking is not required for the item, check this box.

(9) & (10) Will be completed by QA when document reviews are necessary as a result of (7) and (8).

(11) The QA r&ceiving inspector completing the form shall sign and date here.

(c) It is suggested that, as bins are checked, they be marked to indicate they are completed.

II:. (a) For Cardinal material which will be conditionally released for installation, the following forms will be completed:

1

Instructions fcr implementation of dispssition of DR 9173 Page 2- --- - - - - - -

. . .x ,. 11 (b) The 173 Cardinal Material conditional Release" shall be '-

used:ta provide traceability to where the material is installed. ,

The first time an item is requisitioned, a page will be created for the ites. The following infonnation will be entered to j identify the item in question: [

i (1) A description of the item.

(2) The ASTM designation. '

(3) The heat and Lot. f, if known.

(4) If the material does not have a' manufacturer's heat code stamp, a Pullman code letter will be assigned for stamping (see III(c) below). The. code letter is entered here.

(5) The original quantity received.

(6) The quanity now on hand.

(7) The receiving report f.

(8) The P.O. f. ,

(9) The Item f.

Each time the item is issued the following information will be entered:

(10) The contractor the material is issued to.

(11) The quantity issued..

(12) The unit the material will be used in.

~

(13) The building the material will be used in.

(14) The hanger d', rupture restraint f, or Iso i the material is issued tb.

(15) The specific point of usage.

The remainder of the fdnu will be completed upon the receipt of the required test results. A copy of the requisition or G-64 form shall be retained. .

d

knstructions for implementation of disp:sition of DR 9173 i Page 3- ..

3' (c) Allf!a$s'enholdwhicharematerialissuedmust'havetraceable .~ .

i i

heat codes stamped on the item. If there is no manufacturer's heat code on the item, a Pullman code letter will be stamped. '

The "Ca-dinal Material - DR 9173" Code Symbol Loc will be filled out to show what items have Pullman issued code symbols. The log will be filled out as follows:

(1) The Pullman code letter will be entered in this column.

The codes will go "A" to "Z". "C" and "K" will not be used.

(2) The P.O. # is 1.tered in this space. -

l (3) The Item # is entered in this space. '

(4) Heat / lot lot i is entered, if known.

~

i (5) Comments may be added if needed.

When an item is issued a Pullman code letter, the code letter should be marked on the bin card with a highlighter pen.

(d) A separate heat card file wil1 be maintained for all items on hold which are conditionally released. The cards will be duplicates of the regular file cards, except they will indicate the Pullman code letter, if one is issued.

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do not usa tg 10tter CC' cr CARDINAL MATERIAL - OR-9173 ,

Pullman Assigned Code Symbol for Cardinal Material ' ~

Issued _to the Field Cross Referenced to'P.O. # and Item # ..

b .'

Utew. .

P3 .P.O. # ITEM i Ht/ Lot # 'C0teENTS I.D. 7177- If App.

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ej g .-(.-T, Power Product 3 Pulltr

! A so. sdno.n ..........D:st FIELO REQUISITION - PURCNASE ORDER - RECEIVING REPORT sutti

" swirPins AconEss: PULLHAN POWER PRODUCTS "EO -

7'77 12-16-80 D i scoun t itRus suiPP:No itRus 1 of 2 C/0 Pacific Gas & Electric Company I.b ~

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Diablo Canyon Power Plant . Joe cosi cooE:

sunconinAr VsA 7 Miles North of Avila Beach CA 9 % 24 122 NO.

VENDOR:

~ Cardinal uAIL 4 copies or invoicts i 3873 W. Oquendo P.O. Box 367

. Las Vegas Nevada 89118 Avila Beach, CA 93424 t itu ois.

(IfIftH) REU/D. DESCRIPTION '

PRICE TOTAL g cen, g

~

/

A 5 3/4" x 4" Bolts WIth Heavy Hex Nuts 2 03 10 15 B 10 I" x 4 1/2" Bolts With Heavy Hex Nuts

  • 4 14 hl 40 C 12 1 1/4" x 5 1/2" Bolts With Heavy Hex Nuts 8 51 102 12 D 5 I I/2" x 6 I/2" Bolts With Heavy Hex' Huts' 17 20 86 00 E 5 1 3/4" x 7" Bolts With Heavy Hex Nuts. 26 77 133 85

-i.....,

y- ' '

_ E_.

t- ail' Items ASTM A-307 Grade A. UNC Threads c4 .--

t 11.> HOTE: SEE SPECIAL REQUIREMENTS ATTACHED i= Wit i H_C9d *ED T O T A1. PRICE t= iTM 373 52 sifa

~ ~ ~ "

s.E t s.E n roR; REMARKS RECEIVING DEPARTMt sicsmic l.imiter CIsmp Bolt Replacements 365/07 -

Ship 12-24-80

  • l' A T I NilOED: DATE ONDERED DATE PROMISED: I CARRIER:

ASA P I*G(5) 4TTACnED:

12-19-80 , 10 Days ((3d7 /-8[-8/

e e 8738d f COMPLETE PARilAL rHII AH E D (g y : API ' ll

  • P e *  : REPAID: OLLtci:

- .. D. . f i.c. G. . r e.w k .ft- .- -

IMPORTANT: inis oRDtR is sisDJEci TO ALL 0 cout.s i n ous PR :Ni[u ON THE REVERSE sIDt HEREd#.

hE TEHMs AND

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,n. i ie e......... FIELO REQUISITION - PURCHASE ORDER - RECEIVING REPORT s: st *.O. GnTE SHEET "0-SHIPPING ADDIESS: PULLMAN PGlER PRODUCTS

~ ~

C/0 Pacific Gas E Electric Company P: :- NO. F- 7177-9146

___7177 1-15-81 l of I SUBCONTRACT Olablo Canyon Power Plant JOB COST CODE: .

til 5E utA' I E hfAS SHIPPING TERMS No-122 7 Miles North of Avila Beach. CA 93424 WIA VENDOR:

Cardinal Matt 4 COPIES or INvo1CES To:

3873 W. Oquendo . P.O. Box 367 Las Vegas. Nevada 89118 Avila Beach, CA 93424 UNIT DATE OTv ITEM QTY.

s i PRICE TOTAL REC'D. REC REC /D.

DESCRIPTION (EETIER)

Thischangeofpurchaseorderiswrittentomal[ethefollowingchange.

All items to be ASTM A307 GR A or Grade B,UNC Threads. -

All other requirements to remain the same.

= u=w w;m;-y TOTAL PRICE @ ~t-Vf _~lII _d[NPdif~

REMARKS RECEIVING DEPARTMEC zal I I4 L D foR: .

. CARRIER:

t[Ait re t: E D E D : DATE ORDERED: DATE PROMISED:

I IIs t. ( L ) ATTACHED: r ,

COMPLETE PARTIAL f f OLLECT:

REPAID:

PREPARED BY: A N 1

/ E; PufCHASED BY:

') / D efner

~

JECT TO A H lilPORTANT: THIS ORDER IS S

- (.OseDITlONS PRINTED ON THE REVERSE SIDE HEREOF. .

~

.. _ - - . - _.....rm uncT .aDDfAE Dbl ALL I N V_Q_I C Eh ,0 0(10,5 0F LADING, _ _

e. ) uu ttii' vower talouucts

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..so.n.l........ FIELD REQUISITlall - PURCH ASE ORDER - RECEIVINO REPORT M el' ?.O. DATE SHEET

"

  • SHIPPING ADDRESS: PULU!AN POWER PRODUCTS- REO..

7177 12-16--80 c/o Pacific Gas & Electric Company NO. F 7177- 9146 2 of 2 , R. g o siioiET TERMS SHIPPING TERMS Diablo Canyon Power Plant I

. Jos COST CODES SUBCONTRACI 7 Miles

  • North of Avila Beach, CA 93424 122 VIA VENDOR:

Cardinal' .

MAIL 4 COPIES OF INV0lCES TO 3873 W. Oquendo Las Vegas, Nevada 89118 P. O. Box 367 Avila Beach. CA 93424 -

SI'ECIAL REOUIREMEllTS FOR STRUCTURAL BOLTS OR ~ FASTENERS FOR IIANGERS:

. /, .

1111 1 . Supplier shall furnish three copies of a Manufacturer's Certificate of Com -

pliance signed by manufacturer indicating that materials furnished are in cogliance with this Purchase Order, with specifications, or as listed in

. suppliers or manufacturers catalog. , ,  !  : t lin?. Certificate of Complience shall be traceable to our Purchase Order and Item No.

11113 All required documentation shall be sent the day of each shipment to PULU!AN -

PC.JER PRODUCTS, P.O. Box 367, Avilla Beach, CA 93424 Aten: Q.A. Dept. 'In addition, a copy shall accompany each shipment.

11!& Any_nonconformance to the requirements of the Purchase Order will be considered just cuase for return of materials without cost to buyer. '

118 5. Itaterials shall be domestically manufactured. '

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s=-m n- i-  ;,

AMl3 MMi  ?! ;i* i.

?" =Wi3EE C EI: El Ntfoio FOR: REMARKS RECEIVING DEPARTMEt

. SOURCE DOCUllENT REQUIREMENTS oA O tEnto: oATE ORDEREo: DATE PRoMISEps Corp. Appr. Vendor; Hay Use CARRIER 3 Site Appr. Vendor o a c. t S ) ATrAcHEon .

' (All) lianger CLI, G E, Sprinkler i

[ Spec H-10 COMPLETE PARTIAL l rutrAoto ov: AP t DY" PuRCHA B -

8724 Cardox OLLECT:

W .

jREPAID:

I M P O R I'A N T :

  • REctivEn s_ve THis oRotR is su JECT To ALL OF THE TERMS AND ,

cososisoNs PRINTEo ON THE REVERSE SIDE HEREOF. ,

PULLMAN POWER PRODUCTS Q'@h 3 7177

  • AVILA h!EACH. CALIFORNIA 93424. PHONE (805) 595-23

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. PRODUCT E:;GINEERING DEPARTMEMT QUALITY ASSURANCE AND DOCUMENTATION REQUIREMENTS Approved Verified by Req'd by Customer P.P.P. Q.C.

1. Vendor Quality Assurance Program -

ASME Section III l 2. Certified Drawings for Approval i

3. Qualified Procedures for Approval
n. Welding .
b. Weld Repairs
c. Heat Treatment d Ultra s onic
e. Radiograph i
f. Magnetic Particle
g. Liquid Penetrant I
h. Eddy Current .

. I i

4. Documentation
a. Mill Reports ,.
b. Impact Tests
c. Ultrasonic
d. Radiograph
e. Magnetic Particle l- f. Liquid Penetrant ,
g. Eddy Current Results
h. Hydrostatic
i. Partial Data Reports ASME Section .
j. NDT Personnel Qualifications
k. 'hnufactur7r : C o' C / ,

i 5. Marking per P.P.P. Standard

. O AR d M4 L ,

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'7/77 - 914-6

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PREPARED BY JJ [/I,ng DATE OF ISSUE /2 -2 P

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l l'ULillAN V0gyu 9y000~. -

P, Pullm ower Products l .. .

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DIVISION OF TIIE H. U f.l.CC.0 CCC .

A SUBSIDIARY OF VilEEIJJRAIOR-F l .....n ....,.. ..

FIELO REQUISlTION - PURCilASE ORDER - RECEIVING REPORT Jon No. DATE SHEET SHIPPING ADDRESS:

l PULLHAN POWER PRODUCTS REQ..

7177 7/22/81 1 of 2 C/0 Pacific Gas f, Electric Company P.0.-

, __ NO. F-7177-9894 DiscouNr TERus SHIPPING TERMS Diablo Canyon Power Plant Joe Cost CODE: suecot:rR Aci 7 Hiles North of Avila Beach, CA 93424 122 NO.

l VIA VENDOR:

i "^ 4 C "8 CARDINAL ' '"""' ' '

3873 W. Oquendo P.O. Box 367 lac Unnas, ununda RollR Avila Retch. CA 93424 (L T R) R D. DESCRIPTION PRICE TOTAL REC'3. kt *I Ea.

A 2 2" d X 3's" Lg. BUN Stud Bolts T_B _E _ 4" A490 157 20 314 40 n 4 2 " d flyy _ Hex nuts A194-r:r_ 2H *4 95 19 80 C 4 2." d Washers A32G 91 3 64 The bolt shall be tested for notch toughness at + 20 F temperature by charpy V-Notch Imnact test using methnds of ASTM A370. Type A. One

. Test (3 specimens) shall be made for each lot of material _ The minimum average value for each Impact test shall be 10 foot-pounds with no mnre than nne snecimen value halow 30 font-pounds; In no r a <c helnw 2G fnnt-nnnnds- l tems set forth. . .. . . . Charpy @ + 20 F.

- = - = = = 337 R4 m m - w NEEDED FOR: R E M A Ret 9'91 RECEIVING DEPARTMEN1 Unit iI Rupture Restraint 2047-2RT h ,]h,, . [#

DATE NEEDED: DATE ORDERED: DATE PROMISED: CARRIER:

ASAP 7/29/81 2-3 weeks DWG(5) ATTACHED: .

PPIPAHt'D HY: API s /l0 fir ' ' CHA . PREPAID: COLLECf; 3

R. King

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" 'm , RECEIVED BY:

I li4 P O R T A N T : THIS o S S JECT TO ALL OF THE TERMS AND

~

't.' u ta D I T I O N S PRINTED e HE REVERSE SIDE HEREOF.

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,. p gp waPullm yw.w. . r Products e s..no.ie....... .. FIEl.D REQUISITION - PURCHASE ORDER - RECEIVING REPORT J03 f.o. DATE SHEET SHIPPING ADDRESS: PULLMAN POWER PRODUCTS REQ..

NO. F-7177 7/22/81 "

  • 2 of 2 c/o Pacific Cas & Electric Company [i: - 7t77, ggg g, DISCOUNT TERMS SHIPPING TERMS Diablo Canyon Power Plant JoS COST CODE: SUBCONTRACT 7 Miles North of Avila Beach, CA 93424 122 NO.

hiA VENDOR-CARDINAL uAlt 4 COPIES or BNvolCES 10:

3873 W. Oquend La5 Vegas, Nevada 89118 P. O. Box 367 Avila Beach, CA 93424 l

SPECIAL REQUIREMENTS FOR' BOLTS OR FASTENERS FOR RUPTURE RESTRAINTS RB2 Supplier shall furnish three copies of Manufacturer's Test Reports.

RB3. Manufacturers Test Reports shall be traceable to our Purchase Order and Items No.

R B4 All required documentation shall be sent the day of each shiDment to PULLMAN P0;JER PRODUCTS, P.O. Box 367, Avila Beach, CA 93424 Attn: Q.A. Dept. In addition -

a copy shall accompany each shipment.

RSS. Any nonconformance to the requirements of the Purchase Order will be considered just cause for return of materials without cost to buyer.

RB6 . Materials shall be domestically manufactured. .

RB7. Lot number shall be entered on containers and Mill Test Reports. The Heat or Heat Code Number shall be marked or tagged on each bundle.

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isc=re=

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J E E D E D roR:

REMARKS , REcElVING D E P A R T M E tJ T Unit 11 Rupture Restraint DATE t;EEDED: DATE ORDERED: DATE PROMISED:

  • CARRIER:

ASAP 7/29/81 2-3 weeks OnG(5) ATTACHED:

(l f) _

COMPLETE PREPAID:

PARTIAL COLLECT:

PREPARED BY APPR vl t Y: TJ (TRf(C H A S E D  :

S R. King g W T pp S

RECElVED BY:

_ .N [P(00 TT 00 TT - vmos eRDE ,S cus;EcT To ALL or THE TERMS AND __

,q Pullp, Pow r Product 3

n. -

...se is....,.....

FIELD REQUISlil0N - PURCHASE ORDER - RECEIVING REPORT ma No. DaiE sHtET sHIPPINc AooREss:

7177 12-31-80 I of 2 PULLMAN POWER PRODUCTS C/0 Pacific Gas & Electric Company "3 -

p ,

NO. F- 7177-9195 R.R..

DISCOUNI ifRMS SHIPPING TERMS Diablo Canyon Power Plant -

JOB COST coot sunconn.sei VIA 7 Miles North of Avila Beai:h. CA 93424 -

  • VENDOR:

Cardinal Bolt uAlt 4 Copies or INvoici. Im 3873 w. Oquendo '~

Las Vegas. Nevada 89118 P.O. Box 367 Avila Beach CA 93f2fl l _

litu 01Y. UNIT DAl "

(18 81184) 14E0/D. DESCRIPTION PRICE TOTAL n t c .lp. .a .

A 6 1/2" x 6" -

13DNC Bolt ASME-SAI93 GR. 87 7 63 45 78 9 lot B 6 1/2" Type B SS Flat Washer AISI 18-8 3 00 1 QD_ .

NOTE: SEE SPECIAL REQUIREMENTS ATTACHED -. _

.~ ____8e w.s

~

TOTAL PRICE N_ N_ N. N._ 48 78 ~. ,

Ni i DE D FOR: REMARKS  ! RECEIVING D E P A D 15.11 Rebet. llead Vent Restraint (I & II)

DAIF NITDED* DAIE ORDtRED: DATE PROMISED: l CARRIER:

1unediately I-20-84 i Week LMOT hTAM i __.

OnG(5) AllACHED: [# g3 40

[ COMPLETE R E P A,l D :

P A ls i l .* 4 I l'8:

P u t P A la l D le y : Al ' '

PURCHASED BY:

R. 13 nQ

/

J / (L._Renner RECEIVED HY:

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I P. P O R I A N T : iHis ORDER IS SW5JEC L OF THE TERus AND

es t.p l i l O N S PRINTfD ON THE REVERSE SiOE HEREOF.

ij l'ullm,M l'ower l'ioducts p

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i..ne.is.......,.. FIEl.0 REQUlstil0li - PURCHASE ORDER - RECEIYaliG REPORT , ,

8018 f.o . DATE' SHEET SHIPPING ADDRESS: PULLHAN POWER PRODUCTS REo..

NO. F. 7177- 9195 7177 l2-31-80

  • 2 of 2 c/o Pacific Cas & Electric Company h,k:

ni sihtDI ItRus SHIPPING TERMS Diablo Canyon Power Plant .

Joe Cost Coots suocoralidEi~

7 Hiles North of Avila Beach, CA 93424 _,

- 8 "- VENDOR:

MAIL 4 COPIES OF INVOICES l0:

Cardinal Bolt __

P. O. Box 367 3873 9. oquendo Las Vegas, Nevada 89118 Avila Beach. CA 93424 -

SI'ECIAL REQUIREl!EllTS FOR STRifCTURAL BOLTS OR FASTENERS FOR llANGERS: -

lint. Supplier shall furnish three copics of a Manufacturer's Certificate of Com -

pliance signed by manufacturer indicating that materials furnished are in compliance with this Purchase Order, with specifications, or as listed in suppliers or manufacturers catalog.

1102. Certificate of Compliance shall be traceable to our Purchase Order and Item No. '

IIBT.~ All required Ilocumentation shall be sent the day of each shipment to PULI11AN PGi'ER PRODUCTS, P.O. Box 367, Avila Beach, CA 93424 Attn: Q.A. Dept. In _

addition, a copy shall accompany each shipment.

1184 Any_nonconformance to the requirements of the Purchase Order will be considered ___

just cuase for return of materials without cost to buyer. ,

1185. llaterials shall be domestically manufactured. _ _ _

. ' - ~

-r.93. . ,

~' --

Oki$d- _: . .

RECEIVIHG DE R 1 f t t ti

.LEt$iD7 oR: ..,

REMARKS SOURCE DOCUt!Elfr REQUIREMEffrS Corp. Appr. Vendor; Hay Use CARRIER:

. Tit uttoEn: DATE ORDERED: DATE PROMISEDI Site Appr. Vendor _ __

(All) llanger CLI, G,E, Sprinkle rCOMPLETE rE ist ATiACuro: } P A f1 T i t t.

W

/h/ PURCHASED BY:

Spec H-10 8724 Cardox PREPAID: COLLECI:

5 A Y.

  • 5 s' R t' W

. a s s. t. h t o n y :

15 Su Ecr To Att or THE TERMS AND , , _

1 11' 0 R 11111 : Tuls oRo

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9 PRODIfCT ENGINEERING DEPARTMENT QUALITY ASSURANCE AND DOCUMENTATION REQUIREMENTS .

I I Approved Verified by ,

/r Reg'd by Customer

  • P.P.P. Q. C.
1. Vendor Quality Assurance Program - .

ASME Section III .

2 Certified Drawi'ngs for Approval ,

3. Qualified Procedures for Approval .
c. Welding
b. Weld Repairs
c. Heat Treatment  ;
d. Ult ra s onic . .

(

e. Radiograph j
f. Magnetic Particle

. g; Liquid Penetrant , j s

h. Eddy Current .

J'

4. Documentation
c. Mill Reports
b. Impact Tests
c. Ultra sonic .
d. Radiog raph
c. Magnetic Particle
f. Liquid Penetrant
g. Eddy Current Results
h. Hydrostatic
i. Partial Data Reports ASME Section J. NDT.Personnci Qualifications
k. 'hnu Femtt'r m C n
  • C /
5. 1.farking per P.P.P. Standard

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C nduat h t+

  • 7l~ll-9197 .

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ENf?d l h CALIFORNIA UNEMPLOYMENT INSURANCE APPEALS BOARD D^cinion of the Administrative Law Judge

-~

OFFICE OF APPEALS PHONE Van Nuys (919) 901-5119 DATE MAILED: .MOV 2 61984 CASE NO. VN-24357 In the Matter of:

DATE APPEAL FILED:

Timothy O'Neill September 6, 1984 .

(Claimant)

P.O. Box 930 DATE AND PLACE OF HEARING:

Arrcyo Grande, CA 93420 (1) October 4, 1984 (2) november 7, 1984 San Luis Obispo, California SSA NO.: 564-15-0937

  • lot-3YB: 071-09054 PARTIES PRESENT:

ER ACCT: 296-2987 (1) Claimant Employer  !

Pullman Power Products (2) Claimant (Employer-Appellant)

P.O. Box 367 Avila Beach, CA '93424 STATEMEvr OF FACTS Tho cmployer appealed a Department determination and ruling which held th0t the claimant was not disqualified from benefits and the employer's recorve account was subject to charges on the ground that the claimant hcd voluntarily quit his most recent work with good cause.

Tho claimant worked for approximately one year as a quality control -

inep;ctor at a final rate of $21 an hour and last worked on July 24, 1984 ,

whon he quit his job.

l Tho Department determined that the claimant had voluntarily quit his job l.b:couse of unsafe working conditions which were brought to the employer's l Gttention but insufficient action was taken to correct the matter.

At the time of the first hearing the claimant and employer appeared.

Tho claimant had a substantial number of documents whiuch he wished to l hava admitted into the record as exhibits., gince the records were subctantial there was insufficient time for the employer to review those

! d:cuments and only very brief testimony was taken after which the hearing l want into recess for further scheduling.

l

~

l On October 26, 1984 the Van Nuys Office of Appeals mailed a hearing notice l to the claimant and employer to notify them of the hearing to take place

cn W;dnesday, November 7, 1984 at.8
30 a.m. in San Luis Obispo. The l documents from the claimant and employer have not been submitted prior to the hearing. Therefore on November 2, 1984 a notice was sent to

! claimant and employer to produce documents for the hearing no later than

! 9:00 a.m. on November 6,1984. The purpose of the notice was to afford 1

et discovery to the parties of all documents to be in'troduced by the other party prior to the day o'f the hearing. Delivery of documents was made by the claimant. No delivery of documents or notice of intent to do so was received from the employer.

On the day of the hearing, November 7, 1984, the claimant appeared with counsel. The employer did not appear. The record was opened for the purpose of marking the documents made available to the parties prior to tho hearing of October 4, 1984 and the documents which the claimant Cubmitted on November 6, 1984. No testimony was taken and the record was cloccd and the matter being submitted for a decision.

REASONS FOR DECISION Scction 1256 of the California Unemployment Insurance Code provides that cn individual is disqualified for benefits, and sections 1030 and 1032 cf the code provide that the employer's reserve account may be relieved of bsnefit charges, if the claimant left his most recent work voluntarily without good cause. ,

The California Unemployment Insurance Appeals Board held in Precedent D cision P-B-27 that there is good cause for the voluntary leaving of work whoro the facts disclose a real, substantial, and compelling reason of cuch nature as would cauce a reasonable person genuinely desirous of roteining employment to take similar action.

In Precedent Decision P-B-262, the Appeals Board held that under Evidence Cado 664 it is presumed that the department had reached its determination only after a careful investigation of the facts and that its official duty in datermining the claimant's eligibility for benefits had been properly parformed. It concluded that the employer had not met the burden of ovorcoming this presumption of regularity.

In Precedent Decision P-B-298, the claimant was a truck driver. He had machenical difficulties with the truck assigned to him and had made several complaints to his superior without avail.

Tho AppeahcBoard held that the claimant had taken all reasonable steps to remedy the situation and therefore had good cause for leaving work.

In Precedent Decision P-B-126 the Appeals Board held that good cause for lOQving work may be found where the conditions of employment are so onerous oc to constitute a threat to the physical pr mental well-being of an cmployee or where the actions of the supervisor are particularly harsh cnd oppressive.

In the present case the Department determined that the claimant had voluntarily quit because of hazardous conditions after informing the Cmployer that a need for corrective action need be taken. The claimant cot his reporting responsibility to the employer by making the employer aware of his concern. The Department determined that insufficient action was taken tg correct the problem by the employer. The Department determina-tion and ruling and the presumption was not rebutted by the employer.

VM-24357 Th2 cmployer did not inform the trier of fact that he did not intend to appaar at this second hearing. Reasons for the employers failure to cppaar are unknown however adequate notice was given to the employer both

  • in the notice of hearing and the notice to produce documents. Under these circumstances it is concluded that the claimant voluntarily quit his most recent work for circumstances that constitute good cause within the meaning of section 1256 of the code.

DECISION Tha determination and ruling of the Department are affirmed. Benefits cro payable provided the claimant is otherwise eligible. The employer's resorve account is subject to charges.

LEONORA M. STOPOL ,.

Administrative Law Judge FOR APPEAL OR REOPENING RIGHTS, SEE ATTACHED NOTICE.

Ib VN-24357 ,

e s