ML20140E494

QA Program Insp Rept 99900888/84-01 on 841112-15. Noncompliance & Violation Noted:Section 206 of Energy Reorganization Act Not Posted in Three Areas of Mfg Facility & No Procedures Existed for Matl Testing

ML20140E494
Person / Time
Issue date:	12/21/1984
From:	Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20140E478	List: ML20140E475 ML20140E483 ML20140E488 ML20140E494
References
REF-QA-99900888 NUDOCS 8501110059
Download: ML20140E494 (21)

Text

ORGANIZATION: TEXAS BOLT COMPANY 1 HOUSTON, TEXAS  !

I REPORT INSPECTION INSPECTION NO.: 99900888/84-01 DATE(Sl 11/17-16 /R4 nN_qTTP unnoe. 7n CORRESPONDENCE ADDRESS: Texas Bolt Company ATTN: Mr. W. E. Windt QC/QA Manager Post Office Box 1211 Houston, Texas 77001 ORGANIZATIONAL CONTACT: Mr. W. E. Windt, QC/QA Manager TELEPHONE NUMBEPt (710 9A4 7111 PRINCIPAL PRODUCT: Threaded Fasteners NUCLEAR INDUSTRY ACTIVITY: Approximately 40 per cent of the 1983 production.

ASSIGNED INSPECTOR:

• A'h T. Conway, React Inspection Section (RI4) hkk Date OTHERINSPECTOR(S): L. Burns, Consultant APPROVED BY: / lt -2 s -f4 E. W. Merschof hief, RIS, VPB Date INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21.

B. SCOPE: This inspection was made as a result of the 10 CFR Part 21 report from Public Service of Colorado (PSC) pertaining to cracks in threaded rods for use in reinforcement of safety related masonry block walls at the Fort St. Vrain Nuclear Generating Station.

PLANT SITE APPLICABILITY:

Cracks in threaded rod: 50-267.

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8501110059 850109 PDR GA999 EMVTEXB 99900888 PDR

ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION NO.: 99900888/84-01 RESULTS: PAGE 2 of 10 A. VIOLATIONSI Contrary to Section 21.6 of 10 CFR Part 21, a copy of Section 206 of the Energy Reorganization Act was not posted in three areas of the manufactur-ing facility where 10 CFR Part 21 and Texas Bolt's (TB) Part 21 procedure were posted.

B. NONCONFORMANCES:

1. Contrary to Criterion V of 10 CFR Part 50, Section 1.7 of the Quality System Manual (QSM) and Sections 8.5.3(c), 9.6, 9.6.1, and 9.7.3 of SNT-TC-1A, a review of nondestructive examination (NDE) records revealed the following:

a. Procedure No. TB-NDT-PQC-#1, "NDT-Personnel Qualification and Certification" dated March 2, 1981, did not contain rules covering interrupted service requiring re-examination and re-certification.

b. Records for five NDE personnel (3-Level II and 2-Level III) from TB did not contain a statement indicating comp training in accordance with TB's written procedure ,letion of

, c. Records for two NDE personnel from Industrial Inspection' (II),

who were certified as Level III - liquid penetrant (PT) and Level II - magnetic particle (MT), did not contain a physical examination (s) or copies of the PT and MT examinations.

d. The practical examination for both of TB's Level III - MT examiners (QA/QC Manager and Assistant QA/QC Manager) was incomplete in that a specification or procedure for the performance of a MT examination was not written.

2. Contrary to Criterion V of 10 CFR Part 50, the Policy Statement of the QSM, Subsection NCA-3866.2 of Section III of the ASME Code, and Section 7 of ANSI /ASME N45.2, measures were not in place to identify individuals / organizations responsible for preparing, reviewing, and I appr1 ving the procedures contained in the Procedure Manual.

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3. Contrary to Criterion V of 10 CFR Part 50 and Sections 4.3 and 7.lb of the QSM, a review of purchase orders (P0) to suppliers.and external-L audits conducted by TB revealed that the plating services of Southwestern Plating were utilized in September 1984 on nuclear bolts, and the calibration services of Honeywell Corporation, W. H. Kessler l

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, ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION NO.- 99900888/84-01 RESULTS: PAGE 3 of 10

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Company, and Newport Instrument Company were utilized for quality-related temperature measuring equipment on November, June, and May 1984, respectively, although none of these firms were included on the approved vendors list.

4. Contrary to Criterion V of 10 CFR Part 50 Section 12.1 of the QSM, Subsection NCA-3868.1 of Section III of the ASME Code, and Section 13 of ANSI /ASME N45.2, II calibrated two magnaflux units (S/N 43253 and S/N 81409) but II's Machinery Inspection Report for each unit did not indicate the standards used for calibration,to assure that traceability to national standards was maintained.

5. Contrary to Criterion V of 10 CFR Part 50, Sections 2 and 6 of ANSI /ASME N45.2, and Subsections NCA-3866.4 and NCA-3866.1, it was noted that procedures or instructions did not exist for the following activities:

Heat treating in the Electric Box Furnace (S/N F-10-65)

Material testing such as tensile strength, hardness, and proof loading evaluations. **

Utilization of stamps such as " LAB," " NUCLEAR," and " Material Approved by Met Lab."

6. Contrary to Criterion V of 10 CFR Part 50 and Section 4.2 of the QSM, the Quality System Manager or his designee did not sign a total of 19 internal purchase order forms reviewed during the inspection.

. 7. Contrary to Criterion V of 10 CFR Part 50 and Section 12.5 of the QSM, on November 14, 1984, numerous discrepant gauges including a "no-go" gauge and a micrometer were not placed under lock and key and were not tagged with a "00 NOT USE" tag.

8. Contrary to Criterion V of 10 CFR Part 50 and Section 15.2 of the QSM, TB did not tag and segregate nonconforming material following final visual inspection as evidenced during a plant tour when bolts, nuts, and threaded rods were stored in untagged cartons which were mixed with cartons of acceptable materials pending final product packaging and shipment.

9. Contrary to Criterion V of 10 CFR Part 50 and Section 15.2 of the QSM, three nonconformance reports for 1984 and three nonconformance reports for 1982, constituting the total number of reports for each year, were dispositioned by the Assistant Quality Systems Manager / Laboratory -

Supervisor.

ORGANIZATION:

TEXAS BOLT COMPANY '

HOUSTON, TEXAS REPORT INSPECTION NO.- 99900888/84-01 RESULTS: PAGE 4 of 10

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C. UNRESOLVED ITEMS:

None.

D. OTHER FINDINGS OR COMMENTS:

1. 10 CFR Part 21 Report - Public Service Company of Colorado (PSCC) notified the NRC in a Part 21 report dated July 30, 1984, and a revised report dated September 6, 1984, of defective threaded rod material for use in reinforcement of safety related masonry block walls at the Fort St. Vrain Nuclear Generating Stati6n. The material in question was ordered (P0 No. 5401 dated May 14,1984) from TB as 5/8 inch diameter all threaded rod, purchased under specification ASTM A193, Grade B16. It was noted that PSCC's P0 did not specify that 10 CFR Part 21 should apply or that TB's QA program should meet the applicable requirements of NCA 3800 of Section III of the ASME Code or ANSI N45.2.

All the defective rods came from bar stock (heat lot no. 8087367) purchased from Republic Steel on P0 3868. The inspector reviewed TB's internal P0 177786, traveler and certified material test report (CMTR) which showed that TB had upgraded the stock material by performing tensile tests and a chemical check. A visual examination of the threaded rod by TB failed to detect the longitudinal cracks .

which were identified in 15 of the total 60 rods by PSCC during receipt inspection. The remaining 45 rods were MT examined by PSCC, and an additional rod was rejected by this testing. The 16 defective rods were returned to TB to be scrapped.

TB had II perform (P0 34057 dated June 18,1984) MT examination on five threaded and 45 blank-5/8 inch diameter x 20 ft bars. II's NDE report dated June 20, 1984, indicated that magnaglo inspection was performed and no indications were noted. Accordingly, TB threaded 11 blanks and returned a total of 16 rods to PSCC. PSCC scrapped the entire shipment when five rods of this shipment contained defects similar to the original shipment.

TB has acknowledged that the visual examination was conducted in a poorly lighted area, and the MT examination by II using portable equipment was conducted in TB's Hot-header Department where there was too much light to permit the identification of defects using black light. In August 1984 TB moved their Visual Inspection Department to a natural lighted area for easier detection of small defects by the naked eye, and moved the area-for magnafluxing with a portable unit to another building where most light can be eliminated.

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' ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT .

INSPECTION NO.: 99900888/84-01 RESULTS: ) AGE 5 of 10

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A visual examination by TB of 80 remaining bars noted that approxi-mately 50% contained cracks. TB has scrapped all the 5/8 inch diameter bar from heat lot no. 8087367, and Republic Steel has confirmed the discontinuities in the bar stock and agreed to replace all the 5/8 inch stock from heat lot no. 8087367. TB told the inspector that PSCC was the only nuclear customer who received any product from the 5/8 inch stock on heat no. 8087367.

2. 10 CFR Part 21 Requirements - The posting of Part 21 accompanied by a Part 21 reporting instruction sheet was noted i.n three areas of the manufacturing facility. However, as of November 12, 1934, in no instance was Saction 206 of the Energy Reorganization Act of 1974 posted. The Part 21 reporting instruction sheet was directed to all personnel and provided notice for the immediate relay of .

information concerning quality product defects or noncompliance to the Quality System Manager. The Part 21 reporting instruction sheet was observed to be lacking a procedure control number, revision status, and a signatare block although the posted document had been initialed and dated by the Quality System Manager. The QSM and supporting formal procedures do not include the Part 21 reporting instruction sheet nor other provisions for ensuring Part' 21 compliance.

Violation A.1 was identified in this area of the inspection.

3. NDE - The inspector reviewed TB's procedure for NDE, one MT examin-ation procedure, and the certification records for two Level III-MT and three Level II-MT. It was noted that the practical examination given in 1977 for both Level III examiners did not contain a written specification / procedure but was the practical examination specified in SNT-TC-1A for a Level II examiner. The certification records for the three Level II examiners were in accordance with SNT-TC-1A.

II performed MT examination in June 1984 on threaded rod for.a nuclear facility. II's written practice for NDE, the MT procedure used, and the certification records for the Level II-MT examiner were reviewed.

Nonconformance B.1 was identified'in this area of the inspection.

4. Control of Nonconformances - Nonconformance reports for several years were reviewed. TB does not maintain a nonconformance log but the Assistant Quality Systems Manager / Laboratory Supervision produced three reports for 1984 and three reports for 1982. All of the nonconformance reports lacked clarity and adequate information l

ORGANIZATION:

TEXAS BOLT COMPANY HOUSTON, TEXAS l

REPORT INSPECTION NO.- 99900888/84-01 RESULTS: PAGE 6 of 10

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concerning corrective action, and in every instance the report had not been dispositioned by the Quality Systems Manager. The six documented nonconformances dealt with material hardrers deficiencies identified during laboratory testing, and TB-Quality System Depart-ment personnel indiccted that no other nonconforming conditions had been identified in recent years.

Nonconformance B.9 was identified in this area of the inspection.

5. Procedures - The NRC inspector reviewed TB's Procedure Manual which contained 16 procedures addressing such areas as heat treating, calibration, document control, MT examination, charpy impact i testing, NDE personnel qualifications, audit, plating, cleaning, and inspection. It was noted that the " Record of Revisions" section ,

contained an issue block for each procedure, but the block was not '

signed or dated. Procedure No. TB-DC-#1 " Document Control" listed requirements for a "QC Manual" when in fact it was the " Quality System Manual." Also, there was no identification / control number on Procedure Manuals assigned to a total of five personnel.

Although it was apparent from a review of test results for various customer orders that TB does in fact conduct material integrity evaluations, no formal documented procedures exist for the conduct of these tests other than charpy impact procedure TB-CIP-1. Tensile strength, hardness, and proof loading evaluations are performed in accordance with TB quality control document, TBF-1, " Final Inspection Procedure," which is a generic instruction lacking adequate procedural steps as well as test acceptance criteria.

Furthermore, the Assistant Quality Systems Manager / Laboratory Supervisor indicated-that, at the discretion of the technician conducting a Charpy impact test, use of TB-CPI-1 can be exchanged for uncontrolled Procedure No. 4, " Procedure for Charpy Test,"

dated January 3,1984, and signed by the Quality Systems Manager.

An inspection of production procodures revealed that uncontrolled index cards developed by the plant production superintendent are used as the reference and basis for fulfilling customer order requirements.

For example, Carolina Power and Light PO B-22331 (TB P0171488) required a total of 500, 3/4"-10, SA563-Grade 8 heavy hex nuts, and a review of the production process document package indicated that the "SA563-Grade B" (card system) procedun had been used as the guideline for manufacturing the order. "SA563-Grade B," as with all other (card system) procedures that were reviewed in the presence of the Assistant Quality Systems Manager / Laboratory Supervisor,

l ORGANIZATION:

TEXAS BOLT COMPANY HOUSTON, TEXAS l

REPORT INSPECTION NO.- 99900888/84-01 RESULTS: PAGE 7 of 10

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1acked a document control number, revision number, and signature block. There was no evidence that any of the production procedures had been formally evaluated and properly qualified.

Nonconformances B.2 and B.5 were identified in this area of the inspection.

6. Calibration of Measuring & Test Equipment (M&TE) - The NRC inspector reviewed records for M&TE and certifications for reference standards used by service vendors to calibrate M&TE. An observation of M&TE at various work stations was also performed to assure that M&TE are properly identified controlled and calibrated at specified intervals. The temperature recorders on 15 furnaces (seven spheroidizing, three continuous fed-line, two box-tempered, one electric box and two batch) were calibrated by Honeywell Corporation.

Calibrating stickers denoting the date and the due date for the next calibration were attached to all M&TE. In the MT examination area, two MT units (S/Ns 81409 and 43253) were calibrated by II in September 1984. It was noted that the Machinery Inspection Reports from II did not specify the serial number of the electrical standards used to calibrate the two MT units to assure traceability to national standards.

Calibration status of laboratory test equipment was verified for the following items:

Equipment (S/N) Vendor Calibration Date Charpy Impact Tester (83166) Army Materials & 3/15/84 Mech. Res. Center Tinius-Olsen Universal Tester J.M. Nash Company 7/24/84 (73444-5)

King Brinell Hardness Tester J.M. Nash Company 7/24/84 (YX-59)

Service-Rockwell Hardness Tester J.M. Nash Company 7/20/84 (68002)

Wilson-Rockwell Hardness Tester J.M. Nash Company 7/20/84 (45RBB-5849)

Acco-Rockwell Hardness Tester J.M. Nash Company 7/20/84 (79128)

Newport Digital Pyrometer Honeywell Corp. 11/13/84 (2350263A-96)

Standard Immersion Thermometer W.H. Kessler Co. 6/29/84 (none)

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ORGA.NIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION NO.- 99900888/84-01 RESULTS: ) AGE 8 of 10

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The digital pyrometer was purchased from Newport Instrument Company on May 13, 1983 (P0 10R356) primarily for impact specimen cold-bath temperature measurement as required by TB quality control document, TB-CIP-1, "Charpy Impact Procedure." Calibration of this instrument was performed by Newport Instrument Company on May 16, 1984, and by Honeywell Corporation on November 13, 1984. A standard immersion thermometer used either as an alternate or as a supplement to the digital pyrometer for the Charpy tests was last measurement-qualified by W. H. Kessler Company on June 29, 1984. It was noted from the review of records that Newport Instrument C,ompany, Honeywell Corporation, and W. H. Kessler Company had not been included on the current issue nor on preceeding issues of the approved vendor list.

TB's "1984 Monthly Calibration Log" was utilized to verify recent calibration status for various production gauges, including pitch and outside diameter micrometers as well as ring and plug gauges.

Nonconformances B.3 and B.4 were identified in this area of the inspection. ,,

7. Documentation Packages-(DP) - The NRC inspector reviewed 84 DPs (65 for 1984 and 19 for 1983) for nuclear fasteners. A DP consisted of a customer's P0 and specification, if applicable; TB's internal P0, work order (i.e., traveler), CMTR and/or Certificate of Compliance, CMTRs from material suppliers, and heat treat charts, if applicable.

Following receipt of the customer's P0, TB transcribes quantity and quality specification requirements onto an internal P0 form which is assigned a unique TB number. The intent of the internal P0 form is to provide a manufacturing in-process record as well as a permanent record of the customer order. It was noted that the Quality System Manager or designee neglected to sign the internal P0 form for the following TB numbers:

167563 172614 173810 174731 173644 168802 173437 173859 174774 173742 169315 173450 174047 170792 173760 169614 173557- 174423 174488 In addition, the minimum solution annealing temperature was not specified on TB's CMTRs for austenitic stainless steel fasteners for the following TB numbers:

ll . . _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _

m ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION NO.- 99900888/84-01 RESULTS: PAGE 9 of 10

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176351 167563 178966 180763 173450 178734 175156 179022 173644 175660 180926 169315 175597 175144 Nonconformance B.6 was identified in this area of the inspection.

8. Plant Tour - The NRC inspector toured TB's manufacturing facility at various times during the inspection in the company of TB's personnel. Areas and activities witnessed included storage of incoming material, receipt inspection, heat treatin'g, hot and cold forming, roll threading, machining, MT examination, destructive testing, metallography, final inspection, and packaging.

The inspection revealed that nonconforming material identified during final product visual examination is not tagged and segregated pending packaging for shipment. However, cartons of acceptable bolts, nuts, and threaded rod were properly tagged and accompanied by the work traveler.

It was noted that discrepant gauges were kept in a cardboard box on a shelf in an unlocked room, and although tagged in most instances, none of the tags explicitly stated "D0 NOT USE."

Nonconformances B.7 and B.8 were identified in this area of the inspection.

9. Audits.- Semi-annual internal audit reports from May 1973 to August 1984 covering the areas of " Purchasing," " Production," and " Quality-System" were reviewed. It was noted that the audit checklist forms were very general and limited in scope, and in no instance was any

, significant corrective action specified. TB internal memoranda dated March 22, 1983, and July 15, 1979, qualifying selected management and Quality System Department personnel to perform audits were reviewed, but there was insufficient evidence that all of the individuals had received QA training. In fact, it was observed that the TB Vice President-responsible for performing the majority of internal audits

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[ is not even included on the QA manual controlled distribution list.

In addition, certain internal audit reports revealed that the inspection is sometimes conducted by the same individual approving the findings, such as in the cases given below:

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ORGANIZATION: TEXAS BOLT COMPANY HOUSTON, TEXAS REPORT INSPECTION NO.- 99900888/84-01 RESULTS: l AGE 10 of 10

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Audit Date Audit Area TB-Auditor / Audit Approval 8/6/84 " Production" Quality Systems Manager 2/19/84 " Production" Quality Systems Manager 2/19/84 " Quality System" Vice President External audits conducted by TB on Republic Steel, Carpenter Technology, U. S. Steel, and Colt Industries (including SCC Corporation) for maintaining approved vendor list status were reviewed. As with the internal audit forts, the external audit checklists are inadequate in that survey questions are non-specific and do not promote in-depth inspection. No corrective action requirements were observed to have ever been imposed on the aforementioned suppliers as a result of the audits. .

The audit report of Bechtel Corporation compiled from a May 23, 1984, inspection which cited the failure of TB production personnel to sign the work traveler at various manufacturing process stages was reviewed. It was noted that TB responded promptly to Bechtel and provided suitable evidence of corrective action for the nonconformance. -

10. QA Program - A detailed review of the Quality Systems Manual which documented a QA program description addressing 15 QA sections led to the following observations:

a. The organization chart does not reflect the current management structure.

b. QA responsibilities of each of the elements noted on the organizational chart were not described.

c. Job titles comprising an existing Material Review Board (MRB) were not identified.

d. The duties / responsibilities of the MRB and the procedure for a review of a material' problem were not described.

These observations were not considered as.sufficiently severe deficiencies in the existing QA program or its implementation to be classified nonconformances, but were brought to the attention of appropriate TB management personnel for their evaluation and follewup.

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PAGE l of 2.

INSPECTOR: 6.L, Hums (Es)Q DOCKET NO.: 99100S%3 SCOPE: (*be galt C. .. d '

~ REPORT NO.: %4-04 Pnosuse,nak sa. 21 DOCUMENTS EXAMINED ITEM TYPE OF DOCUMENT '

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