ML20128K277
| ML20128K277 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1985 |
| From: | Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20128K214 | List: |
| References | |
| REF-QA-99900343 NUDOCS 8507240080 | |
| Download: ML20128K277 (14) | |
Text
(
.0RGANIZATION:
GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION INSPECTION NO.:
99900343/85-01 DATE(S):
5/6-10/85 ON-SITE HOURS:
56 CORRESPONDENCE ADDRESS: Gulfalloy, Inc.
ATTN: Mr. P. R. Dalton President 4730 Darien, Post Office Box 52518 Houston, Texas 77052 ORGANIZATIONAL CONTACT: Mr. G. W. Gross, Manager Quality Assurance TELEPHONE NUMBER:
(713) 672-7451 PRINCIPAL PRODUCT: Pipe, fittings, and flanges NUCLEAR INDUSTRY ACTIVITY: Approximately 17 percent of the 1984 sales.
ASSIGNED INSPECTOR:
[-4-fC
- 5. T. Conway, Rea tve Inspection Section (RIS)
Date v
OTHER INSPECTOR:
E. Trottier, RIS APPROVED BY:
s t!ff' E.W.Merschoffplef,RIS Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix 50 and 10 CFR Part 21.
B.
SCOPE:
The inspection was made as a result of the receipt of an allegation i
pertaining to purchasing commercial grade material and supplying it to a Itcensee as nuclear grade, i
t PLANT SITE APPLICABILITY:
Allegation - St. Lucie-1 (50-335) and Turkey Point 3 & 4 (50 250/251) i
%78$M N !fi^
99900343
. ORGANIZATION:
GULFALLOY, INC.
j HOUSTON, TEXAS REPORT INSPECTION NO.:
99900343/85-01 RESULTS:
PAGE 2 of 12 A.
Nonconformances:
1.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Sections 3.1 and 5.1 of the " Quality Assurance Program Materials Indenti-fication and Verification Manual" (QAM), and subsection NCA-3861(b) of Section III of the ASME Code, a review of documentation packages for 20 nuclear orders from Florida Power & Light (FPL) and 2 nuclear orders from Texas Utilities Generating Company (TUGCo) indicated that material on 11 FPL orders and one TUGCo order was purchased by Gulfalloy from the following suppliers / manufacturers who were either surveyed / audited after the purchase order (PO) was placed or who were never surveyed / audited by Gulfalloy:
Customer Order (date)
Supplier / Manufacturer
~
FP&L Delivery & Work Authorization 39541 (December 6, 1982)
Benko Fitting & Flange (1)
Cardinal Industrial Products (2)
Tube-Line (1) 38624 (March 19, 1982)
Ametek (1)
Tube-Line (1) 39666 (January 3, 1983)
Standard Fittings (1)
Hackey (1)
National Flange & Fittings Benko Fittings & Flange (1) 38625 (March 19, 1982)
Tube-Line (1) 24503C (November 10,1981)
Gulf Supply (3) 26398W (January 25,1983)
Cardinal Industries Products (4) 286608 (September 3, 1981)
Gulf Supply (3) 17461A (April 1, 1982)
All States Steci (1)
Gulf Supply (3) 17328 (February 5, 1982)
All States Steel (1) 17387 (March 3, 1982)
All States Steel (1)
, ORGANIZATION:
GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION NO.:
99900343/85-01 RESULTS:
PAGE 3 of 12 TUGCo P0 CPF 1000 - S Coppenveld Regal Tubing (4)
(1) Never surveyed / audited by Gulfalloy (2) Surveyed / audited 6 months after P0 date (3) Last surveyed / audited in February 1978 (4) Surveyed / audited 1 month after P0 date 2.
Contrary to Criterion V of Appendix 8 to 10 CFR Part 50 and Section 3.3 of the QAM, there was no documented evidence of a Quality System certificate (Material) for Nippon Kokan, Kawasaki Steel Corporation and Nippon Benkan who are ASME certificate holders.
In 1982, these three manufacturers supplied pipe and fittings to Gulfalloy through Benko Fittings & Flange, a sister
~
company of Gulfalloy.
Subsequently, Gulfalloy sent a number of the items to the Turkey Point nuclear facility for orders on PWA 39541 dated December 6, 1982 and DWA 39666 dated January 3, 1983.
3.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 2.5 of the QAM and Subsection NCA-3967.4(c) of the ASME Code, a review of documentation packages for 20 "QL-1" P0s from FP&L revealed that Gulfalloy certified on Material Test Reports (MTR) or Certificate of Conformances (CC) that the requirements of SQADs 1001 and 1002 applied to the purchased items but the manu-facturer's Certified Material Test Report (CMTR) did not document this fact.
The affected nuclear orders with improper certifi-tions are as follows:
DWA/PO No.
_MTR/CC Date 34648 October 26, 1981 39641 February 3 and 17, 1983 January 24, 1983 39541 January 26, 27, and 28, 1983 February 7 and 17, 1983 38617 A April 13 and 20, 1982 38624 8 April 12 and 20, 1982 May 4, 1982
ORGANIZATION:
GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION NO.:
99900343/85-01 RE50LTS:
PAGE 4 of 12 DWA/P0 No. (con't)
MTR/CC Date 39666 March 3, 1983 May 4, 1983 January 31, 1983 38625 May 13, 1982 April 22, 1982 21834S August 11, 1982 21935S August 11, 1982 276395 January 5, 1984
~
17461 A April 20 and 23, 1982 17328 February 10, 1982 17387 April 20, 1982 4.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 5.2.2 of the QAM, and Subsection NCA-3867.4(c) of the ASME Code, it was noted that Gulfalloy PO 22-27-22672 dated July 14, 1984 to Copperweld Regal Tubing (CRT) did not reference the code require-ments identified on TUGCo's P0; and Gulfalloy's MTR dated September 23, 1981 certified that the material met the requirements of "ASME '
Section III, 1974 Edition thru 1974 Winter Addenda, NB-2000 for Class 1 material", but CRT's CMTR dated September 3, 1981 did not document that the material met the code requirements.
B.
UNRESOLVED ITEMS:
None C.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Violation (84-01):
Current copies of 10 CFR Part 21 and Section 206 of the Energy Reorganization Act of 1974 were not posted in a conspicuous place.
Appropriate procedures to evaluate deviations or inform the licensee or purchaser of the deviation did not exist.
4
.~.-..m
l ORGANIZATION:
GULFALLOY, INC.
HOUSTON,--TEXAS REPORT INSPECTION l
NO.:
99900343/85-01 j
RESULTS:
PAGE 5 of 12 Current copies of 10 CFR Part 21 and Section 206 of the Energy Reorganization Act of 1974 were found posted on the main office bulletin board.
Quality Assurance Procedure N-10, " Reporting of Defects and Noncompliance", Revision 0 dated October 13, 1984 was also posted.
A requirement to check for continued posting of a current copy of 10 CFR 21 and Section 206 has been added as Item F, Section 2 of QA Procedure N-4, " Internal Audit."
2.
(Closed) Violation 84-01:
P0s placed with Gulfalloy specified 10 CFR Part 21 as an applicable j
requirement for ASME Code Section III material.
However, in ordering the material from manufacturers, Gulfalloy did not " pass on" 10 CFR Part 21 as a requirement.
The inspector reviewed a random sample of 10 P0s for material to be supplied by G'ilfalloy to nuclear power plants.
The P0s were placed in-late 1983 through 1984.
In each case, Gulfalloy's P0 to their supplier. stated that 10 CFR 21 applied to the material being ordered.
Section 5.8 of Gulfalloy's internal audit procedure also has been revised to assure that 10 CFR 21 is imposed on Gulfalloy's suppliers.
This is verified by a random sampling of applicable P0s.
In addition, Gulfalloy notified all their suppliers (57) by mail on October 10, 1984, that 10 CFR 21 applies to orders that require implementation of their approved Quality Assurance Program.
This letter required a positive response that the company was and continues to be in compliance with 10 CFR Part 21 for such nuclear-related orders.
As of the date of the inspection., 40 replies had been received.
3.
(Closed) Nonconformance (84-01):
A receipt inspection was not performed for 6, 6 in. SA-234 tees.
The customer order file was reviewed to verify that a shipping inspection was performed prior to the parts leaving the Gulfalloy facility.
Gulfalloy also committed to expand their normal sample size when reviewing PO files during the following scheduled internal audit (January, 1985); ensure the QA Manager reviews all nuclear-related P0s prior to close-out; and conduct training on the appli-cable section of the Gulfalloy QA Manual.
The inspector verified that the number of PO files reviewed during the internal audit conducted in January - February 1985, was i
ORGANIZATION: GULFALLOY, INC.
HOUSTON, TEXAS 1
REPORT INSPECTION NO.:
99900343/85-01 RESULTS:
PAGE 6 of 12 doubled over the number reviewed in previous audits.
The inspector also verified that a stamp with QA Manager's signature block is now affixed to all nuclear-related P0s, and that training in the requirements of QA Manual Section 5, Procurement, was conducted on July 26, 1984.
4.
(Closed) Nonconformance (84-01):
Three P0s for nuclear related material did not require a QA program certification statement (supplier's QA program approved by ASME or Gulfalloy).
Gulfalloy reviewed the customer order file for each of these supp-liers.
Two had ASME certificates in effect at the time the orders were placed; the third supplier's QA program had been previously audited and approved by Gulfalloy.
Thus, although it was after the fact, each supplier was shown to be properly qualified to provide -
the subject material.
5.
(Closed) Nonconformance (84-01):
A Nondestructive Examination (NDE) vendor performed NDE services for Gulfalloy in May 1983, without their written practice of training and performance being on file at Gulfalloy.
- Further, there was no evidence that Gulfalloy had approved the NDE vendor's written practice of providing NDE services.
The inspector verified that Gulfalloy has since audited and approved their NDE supplier's program (Service Report Evaluation dated 9-14-84) and that their written practice (QAP 970900-75, Rev. 5 dated July 9, 1982) is presently on file at Gulfalloy.
6.
(Closed) Nonconformance (84-01):
Gulfalloy obtained the services of a pipe coating supplier without L
surveying or auditing the supplier.
Gulfalloy reconstructed the events surrounding the purchase of the pipe coating service and determined that even though the company shared yard space with Gulfalloy, it remained a subcontracted service.
Gulfalloy is thus now fully aware of what constitutes a subcontracted service transaction and the proper administrative control thereof.
All nuclear-related material and subcontracted services P0s are required to be reviewed and approved by the c
Gulfalloy Manager of Quality Assurance.
v
ORGA'NIZATION: GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION NO.: 99900343/85-01 RESULTS:
PAGE 7 of 12 7.
(0 pen) Nonconformance (84-01):
Gulfalloy Power Sales / Purchasing personnel had not received QA Program indoctrination training between 1980 and 1984.
Gulfalloy committed to perform the required training in July and November, 1984. The inspector noted that the training scheduled for July was accomplished on July 26, 1984. The training scheduled for November 1984 was not accomplished as of the date of this inspection.
8.
(0 pen) Nonconformance (84-01):
The cause and corrective action taken to resolve deficiencies noted in audits conducted in January 1982 and January 1984 was not docu-mented. Also, reaudits were not performed in any of the deficient areas noted in the January 1982 audit.
Gulfalloy committed to document the cause of the deficiencies noted in the audits of January 1982 and January 1984. Also, Gulfalloy committed to reaudit the deficient areas. The inspector noted that the root cause of past audit deficiencies has not yet been determined.
It was noted tKat the format of the Gulfalloy Nonconformance Report (ie, the vehicle for tracking and resolving s
such deficiencies) does not specifically identify "cause" as a topic of investigation and resolution.
D.
OTHER FINDINGS OR COMMENTS:
1.
Allegation - In August 1984, the NRC Region II Office of Investi-gation was made aware of an allegation, which pertained to pur-chasing commercial grade material and supplying it to FP&L as nuclear grade.
The NRC inspector reviewed 20 procurement documentation packages for nuclear items ordered by FP&L and sent to the Turkey Point (15) and St Lucie (5) nuclear facilities. Documentation packages consisted of written inquiries; FP&L P0s, specifications, and Special Quality Assurance Documents (SQAD); Gulfalloy P0s and Receiving Inspection Reports; manufacturer's CMTRs plus heat treat charts and nondestruc-tive examination (NDE) reports, where applicable; and Gulfalloy MTRs, CCs, and Delivery Tickets.
ORGANIZATION:
GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION NO.:
99900343/85-01 RESULTS:
PAGE 8 of 12 On March 6, 1981, FP&L issued a blanket PO 38497-39056C which authorized Gulfalloy to furnish nuclear safety reinted items for the Turkey Point nuclear facility.
The P0 referenced SQADs 1001 and 1002.
SQAD 1001 established minimum QA requirements to be satisfied by Gulfalloy, and SQAD 1002 addressed the requirements of P0s requiring compliance to 10 CFR Part 21.
Specific orders were placed on Delivery and Work Authorizations (DWA) in accor-dance with the terms and conditions of the blanket P0.
Each DWA noted that it was a " Nuclear Safety Related Order QL-1" and referenced SQAD 1001 and SQAD 1002.
QL-1 orders for items for St. Lucie were placed on separate P0s which also referenced SQAD 1001 and 1002.
The NRC inspector reviewed the following nuclear orders:
No.
DWA/PO (Date)
Item Manufacturer
~
1 34648 (9-29-81) 3 pipe / fittings /
Damascus Tubu1ar flanges Products Taylor Forge WFI 2
39641 (1-17-83) 8 pipe / fittings Sandvik Custom Alloy Camco Fittings Alloy Stainless Products 3
39541 (12-6-82) 28 pipe / fittings /
flanges /
Quanex fasteners Nippon Kokan Kawasaki Steel Cardinal Indus-trial Products Capitol Manu-facturing Nippon Benkan WFI Tube-line 4
38617A (3-19-82) 9 pipe Quanex U. S. Steel Sandvik 5
79935W (6-29-84) 1 - bar WFI
ORGANIZATION:
GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION NO.:
99900343/85-01 RESULTS:
PAGE 9 of 12
~
No.
DWA/PO (Date)
Item Manufacturer 6
386248 (3-19-82) 9 - fittings Ametex Tube-Line Capitol Manu-facturing 7'
39666 (1-3-83) 10 pipe /
Standard Fittings fittings /
Hackey flanges National Flange &
Fittings Nippon Ber Nippon Kokan Quanex 8
38625 (3-19-82) 25 - fittings /
WFI flanges Tube-Line Capitol Manu-facturing 9
21834S (7-26-82) 1 - caps Custom Alloy 10 21935S (8-2-82) 2 - fittings Camco Fittings 11 22046S (8-18-82) order was cancelled 12 24503C (11-10-81) 19 pipe /
Tube-Line fittings WFI Tube Turns Standard Fittings 13 26112C (12-17-82)
QL-2 order for flexible hose 14 26398W (1-25-83) 2 - fasteners Cardinal Indus-trial Products 15 399140 (11-3-81) 1 - fittings Camco Fittings 16 28660B (9-3-81) 12 pipe /
Sandvik fittings Camco Fittings flanges Taylor Forge ITT Grinnell Hackey 17 27639W (10-15-83) 1 - fasteners Texas Bolt
' ORGA'NIZATION: GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION NO.: 99900343/85-01 RESULTS:
PAGE 10 of 12 No.
DWA/P0 (Date)
Item Manufacturer o
18 17461A (4-1-82) 15 - pipe /
All States Steel shapes 19 17328(2-S-82) 3 - plate All States Steel 20 17387 (3-3-82) 7 - plate /bar/
All States Steel shapes It was noted that items for purchase nos. 4 (partial), 5, 6, 9, 10, and 15 were ordered to Section III/ Class 2 of the ASME Code.
Items on the remaining orders were to the following ASTM specifications:
pipe (A312, 53 and 106); fittings (A182, 234, 403, and 105); flanges (A105 and 181); fasteners (A307, 193, and 194); and shapes (A36).
The Gulfalloy P0s for orders to Section III/ Class 2 specified the ASME Code requirements to manufacturers.
The majority of manufacturers were holders of a Quality System Certificate (Materials) or had been audited by Gulfalloy. However, P0s were placed with Tube-Line (nos. 3, 6, 8 and 12); Cardinal Industrial Products (nos. 3 and 4), Ametex (no. 6), Standard Fittings (nos. 7 and 12), Hackey (nos. 7 and 16) and National Flange
& Fittings (no. 7), and these manufacturers were never audited by Gulfalloy or were audited after the items were ordered (see Nonconformance A.1).
Items manufactured by Nippon Kokan (NK),
Kawasaki Steel (KS), and Nippon Benkan (NB) on order no. 3; Hackey, NB, and NK on order no. 7; ITT Grinnell and Hackey on order no. 16 were ordered thru Gulf Supply and/or Benko Fittings and Flange, two sister companies of Gulfalloy. Gulf Supply and Benko Fittings and Flange have never been audited or surveyed by Gulfalloy. NK, KS, and NB are ASME certificate holders, but Gulfalloy did not have a copy of a Quality System Certificate (Materials) for each company (see Nonconformance A.2).
Although FP&L imposed CFR Part 21 requirements on all the QL-1 orders, Gulfalloy failed to specify Part 21 requirements on their P0s to manufacturers for purchase nos. 1, 2, 3, 4, 6, 7, 8, 9, 12, 15, 16, 17, 18 and 19.
Failure to pass on Part 21 requirements to vendors was identified during a previous inspection conducted on July 16-20, 1984 (see Violation A.2, report no. 99900343/84-01).
With the exception of the CMTRs from Capitol Manufacturing (order no. 3), WFI (no. 5), Custom Alloy (no. 9), Tube Turns (no. 12), and Camco Fittings (no.15), CMTRs from the other manufacturers on all the orders did not certify that 10 CFR Part 21 was required
ORGANIZATION: GULFALLOY, INC.
HOUSTON, TEXAS REPORT INSPECTION NO - 99900343/85-01 RESULTS:
PAGE 11 of 12 during the fabrication of the items. However, for all orders Gulfalloy certified on applicable MTRs or CCs that the items were furnished under the requirements of SQAD 1002 (ie, Part 21) (see Nonconformance A.3).
The improper certification of MTRS and CCs by Gulfalloy should have been detected by FP&L since Gulfalloy trans-mitted a copy of all the CMTRs to the licensee.
Based on the results of examining the documents relating to 20 nuclear orders from FP&L from September 1981, through January 1983, it was noted that the items on order 1, 2, 3, 4 (partial), 7, 8, 12, 14, 16, 17, 18, 19, and 20 were purchased as commercial grade and supplied to FP&L as nuclear grade thus substantiating the allega-tion.
There was no documented evidence that Gulfalloy upgraded any material in accordance with the requirements of Subsection NCA-3867.4(e) of Section III of the ASME Code.
2.
Control of Purchase Material
- The inspector reviewed approximately 52 procurement documentation packages pertaining to nuclear orders from 1975 thru 1985. The customers were TUGCo (4), Baltimore Gas
& Electric (3), Stone & Webster (3), Ebasco (8), Bechtel (31) and Pacific Gas & Electric (3). The review was undertaken to assure that applicable regulatory, technica.1, and QA program requirements are included or referenced in procurement documents, and that nuclear was purchased from approved vendors.
TUGC0 - The 4 orders were from July (see Nonconformance A.4), infor-1981 through March 1982. With the exception of order CPF 1000-S mation certified by Gulfalloy on their MTR or CC agreed with the technical data contained in the manufacturer's CMTR. However, it was noted that Gulfalloy's Pos did not specify the requirements of 10 CFR Part 21.
Baltimore Gas & Electric (BGE? - The 3 orders from BGE from November 1979 thru December 1980 were for Section III/ Class 1 tubing.
Gulfalloy P0s were to Teledyne Columbia (TC), who had been audited by Gulfalloy, for direct shipment to Calvert Cliffs nuclear facility.
Gulfalloy MTRs agreed with TC CMTRS.
Stone & Webster - All the items for the three purchases in May and July 1981 for Riverbend were ordered by Gulfalloy from certificate holders or vendors approved by Gulfalloy.
ORGANIZATION: GULFALLOY, INC.
HOUSTON, TEXAS 1
REPORT INSPECTION NO.-
99900343/85-01 RESULTS:
PAGE 12 of 12 Ebasco - Six orders (October 1981 thru December 1981) were for items for Waterford and 2 orders (April and May 1975) were for St. Lucie No. 1.
Gulfalloy P0s for 2 of the 6 orders for Waterford referenced Part 21. All the material was ordered from approved vendors.
Bechtel - Thirty-one procurement packages for Palo Verde, Hope Creek and Arkansas Nuclear received between 1980 and 1984 were reviewed.
In each case the material was intended for nuclear power plant application with Bechtel acting as agent for the utility. Upon review, it was found that all Gulfalloy suppliers (e.g., Sandvik, Quanex, Capitol Manufacturing, Hawley Forge) were either certificate holders or had been audited and approved by the Gulfalloy QA Department. No irregularities were found with the material requirements of the customers P0 and the material certified by Gulfalloy.
Pacific Gas & Electric - The three orders for Diablo Canyon were placed from September 1984 thru March 1985. All of Gulfalloy's P0s were in order as well as their MTRs and CCs.
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