ML20151Z708

Sanitized Version of Audit on 870224-26 of ASME Class 2 & 3 Valves,Parts & Appurtenances

ML20151Z708
Person / Time
Site:	Dresden
Issue date:	03/05/1987
From:	Mazur E COMMONWEALTH EDISON CO.
To:
Shared Package
ML20151Y498	List: ML20151Y495 ML20151Y535 ML20151Z593 ML20151Z708
References
0861Q, 861Q, G-87-204, NUDOCS 8805050346
Download: ML20151Z708 (10)

Text

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Cheage. Ilknois 60690 0767 COMM0hWEALTH EDISON COMPANY QUALITY ASSURANCE $ q 9-)

AUDIT REPORT G-87-204 C&S Valve Company p[

TYPE AUDIT: Program Audit TO: Mr. M. L. Seshagirl -

PROJECT: Aporoved Bidders List (ABL)

VISIT DATE: 02/24-26/87 REPORT DATE: 03/05/87 SYSTEM: NLA COMPONENT IDENTIFICATION: N/A MATERIAL DESCRIPTION: ASME Class 2 & Class 3 valves. Dar!s a,nd aoourtenances VENDOR: C&S Valve Company LOCATION: Westmont. IL SUBCONTRACTOR: N/A LOCATION: $

CONTACTS: See Attachment "A" P.O. NO. 306901 SPEC. NO. $

Recommended Inspections: As Scheduled Notes: Response is required by March 26, 1987.

Auditcr fhi ht.

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Reviewed Lhl ad:. Date 2 -ti 4 7 cc: Manegtr or w y fS - 8) Olrector of QA (Eng /Constr.)

Project Engineering Mgr. B.E. Harl/D.H. Felz Manager of Sta. Const. Manager of Projects Station Nucl. Eng. Mgr. E.T. Mazur Site Const. Supt. Site Quality Assurance Project Manager Project Engineering Mgr.

Auditee Production Stores Administrator (08610) 88d5050346 080426 PDR ADOCK 05000010-

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. COMMONWEALTH EDISON COMPANY QUALITY ASSURANCE DEPARTMENT AVO!T ArG-87-204

. OF C&S VALVE COMPANY Hestmont, IL '

February 24-26, 1987 '

PURPOSE The purpose of this audit was to verify that C&S Valve 15 effectively implementing their approved Quality Assurance Program so that C&S Valve can be maintained on the Commonwealth Edison Approved Bldders List (ABL).

SCOPE This audit reviewed the activities and documentation associated with the C&S Valve Quality Assurance Program as applicable to NCA-4000 requirements pertaining to construction, fabrication and manufacture of Class 2 and 3 valves, parts and appurtenances.

REFERENCES 10CFR50, Appendix B, all criteria ASME Section !!!, Subsection NCA-4000 C&S Valve Quality Assurance Manual Rev. A dated 04/09/86 CECO Purchase Order #306901 (job completed)

NOTE: CECO P.O. #310782 not accepted by C&S at time of audit.

1 AUDIT TEAM The audit team consisted of the following personnel:

E. T. Hazur - Lead Auditor, Braidwc'od Station AUDIT AGENDA 1

An entrance meeting was held at C&S Valve on the morning of j Tuesday 02/24/87. The exit meeting was held on the afternoon of l Thursday 02/26/87. The audit results and conclusions were discussed l and acknowledged by the auditee at the exit meeting. Persons in I attendance at the entrance and exit meetings as well as other personnel contacted during the audit are listed in Attachment "A".

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, AUDIT #G-87-?O4 Page 2 0F C&S VALVE COMPANY'

SUMMARY

Ouring the course of this audit, one (1) Finding and one (1) Open Item were identified. A brief description of each is given below and ,

a detailed discussion is included in Attachment "B". I l

Findino #1 i

Audit of Document Ccatrol was conducted in August, 1986. I Objective evidence was listed, in many cases, without comment or 1 conclusion. Last item in file was dated October, 1986. The audit was I still open with no documentation of follow-up or further activity.

Open Item #1 Eye exam record for a QC Inspector does not clearly indicate acceptable ability to distinguish colors.

ASSESSMENT Oreantration/0A Program A review of the C&S Valve Company organization chart showed Quality Assurance to be an independent group with direct ties to upper management. The CAR procedure indicates that QA has the authortty to limit or control production activities when quality is affected. This area was found acceptable.

0A Organization .

Qualification records for quality personnel were reviewed and it was found that records for training, expertence, and examinations were acceptably documented and maintained. A current vision test record for one (1) inspector did not adequately indicate acceptable color vision. See Open Item #1. Except for this item, this area was found acceptable.

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AUD2T #G-87-204 Page 3 0F C&S VALVE COMPANY Design Control Reviewed documents for CECO P.O. #306901 (bearing change on our valves) and a job (not for Ceco) for new valves. A preliminary design package is made up by an engineer and reviewed by the Engineering Manager and distributed to QA, QC and Drafting. Any changes are incorporated and a Final Design Package is issued. Any changes after that are made thru an Engineering Change Request (ECR). ECR's are reviewed by Engineering and QA. A cover sheet is added to show revisions. ,

Travelers list sequences (activities) which are signed off by the department performing the a:tivities. Completed travelers are reviewed and accepted by QA and the ANI. This area was found acceptable.

Procurement The Accepted Vendors List (AVL) is issued the first work day of each month. Safety Related (Non-ASME) suppliers are approved by an audit or a survey, the date of which is shown next to the supplier.

Safety Related ASHE vendors are considered acceptable if they have a current Certificate Number (expiration date is listed) per their procedure. Calibratton vendors are approved by an audit or survey and an expiration date is listed. This area was found acceptable.

Document Control The Design Package includes a list of procedures (customer approved as applicable), assembly drawings (customer approved), bill of materials and travelers. For any revision, an ECR is processed.

New documents are issued with a transmittal which requires return of old documents. A review of transmittals to Quality Control, Production Control, Dock and Accounting indicates outdated documents are returned, destroyed and documented the transmittal. This area was found acceptable.

Control of Purchased Material Reviewed receiving records. Items received are placed on hold until accepted. Material is inspected and checked against the

• purchase order. Documentation is checked. Accept tags are attached to items that are acceptable. C&S heat codes are assigned to bar stock. These heat codes are cross referenced with the suppliers heat codes. Receipt Inspection Records were founo acceptable.

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AUDIT #G-87-204 Page 4 0F C&S VALVE COMPANY Identification of Haterials. Parts & Components .

Viewed part and material storage areas. Parts are tagged with job number and/or are stored on shelves identified for spectfic jobs.

A random check of heat codes taken from stored items verified the documentation was retrievable and traceability is maintained. This area was found acceptable.

Control of Special Processes .

Welders qualification records were reviewed and personnel training, testing and certification records were found acceptable.

Welder status and activit/ records were reviewed from April, 1986 thru January, 1987 and found that welder activity was adequately reviewed and the status of welders in each process was properly maintained.

This area was found acceptable.

Inspection Travelers for CECO P.O. #306901 were reviewed and noted that QC inspection points covered the following:

Verify torques

- Hydro test Seat test

- Operation / Performance test Verify as-built dimensions Travelers for each job are made up from generic travelers and rzdified as necessary to meet the requirements of the specific job.

Inspection points are shown on the generic travelers. Qualification of personr.el wts reviewed under QA Organization. This area was found acceptable.

Instructions. Procedures and Orawinas/ Test Control Reviewed test reports and procedures used for hydrostatic, leak, and operational testing on CECO P.O. #306901. Test results were recorded and satisfied the acceptance criteria and was witnessed by QA and the ANI. This area was found acceptable.

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, AUDIT #G-87-204 Page 5 0F Cl,5 VALVE COMPANY.

Control of Measurina and Test Eauipment Vertfled that measuring and test equipment is identified with unique identification numbers and is calibrated at regular intervals.

Calibrations are traceable to National Standards and are in accordance with specified tolerances. This area was found acceptable.

Handling, Storage and Shipping No CECO orders were in process at the time of the audit, however a walk through of the plant and storage areas showed that items are marked and/or tagged and during process are moved on skids. Between sequences (steps), items are stored on shelves marked with the job numbers. Found that items moving through the plant and in storage were being handled with care and being protected from damage.

Housekeeping in plant and storage areas was good. This area was found acceptable.  !

. 1 Inspection. Test and Operattna Status Status is maintained and indicated by the traveler. Inspection points for QC, QA, ANI and Customer are shown on the traveler. The traveler includes required tests with sign-offs. Separate test reports are also completed and signed off. This area was found acceptable.

Nonconformina Ittms When an item is found to be nonconforming, a defIclency report is issued and the item is placed on hold. A hold tag is attached to the item with a copy attached to the deficiency report and a copy goes to Production. Nonconforming items are kept segregated in a hold area.

This area was found acceptable.

Corrective Action A review of thirty (30) deficiency reports indicated that nonconforming conditions are properly documented and dispositioned.

This area was found acceptable.

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i AUDIT #G-87-204 Page 6 i 0F l

. CAS VALVE COMPANY 0A Records h,

b A Record Retainer Checklist is made out for each job which lists .

lifetime records, nonperm nent records with retention time noted and a listing of the documentation package. The records and documents were

>l Ji found to be readily retrievable. This area was found acceptable, f i

Audits -

Vertfled that a schedule exists for the internal Auditing of Departments / Areas of CAS Valve. Auditors are assigned to audit departments or areas from which they are independent. Auditors are qualified in accordance with the requirements of NQA-1. Three (3) audits conducted in 1986 were reviewed. Written checklists were ,

used. In two (2) of the audits, objective evidence was listed I adequately to justify acceptance of the area or finding it deficient; l deficiencies were resolved and the audits closed. One (1) audit, conducted in August, listed objective evidence without comment or reason to justify finding it acceptable or deficient and the audit remains open without apparent follow-up since October. See Finding #1.

EVALUATION The major concern identified in this audit was the lack of documentation to justify conclusions and lack of follow through by the auditar or his supervisor to resolve the deficiencies and close an audit. Overall, CAS Valve is effectively implementing their Quality Assurance Program.

As a result of this audit, it is recomended that C&S Valve be maintained on the Ceco Approved Bidders List.

(08610)

A'J0li #G-87-204 Page 7 0F I

C&S VALVE COMPANY

RESPONSE

A written response is required for Finding #1 by March 26, 1987. ' ' '

As requested, a copy of a properly filled out eye test form will satisfy Open Item #1. Response should be addressed to:

Mr. B. E. Harl Quality Assurance Superintendent  ;

Commonwealth Edison Company , l P.O. Box 767 l Chicago, IL 60690 l with a copy to:

E. T. Hazur i OA Engineer Commonwealth Edison Company

, Braldwood Station RR #1, Box 84 Braceville, IL 60407 The response shall address Corrective Action Taken, Action Taken To Prevent Recurrence and Date When Corrective Action will be I completed. Please forward the previously mentioned eye test form at your earliest convenience.

Thank you for your cooperation during this audit.

(08610)

I i AUDIT #G.87-204 Page 1A 0F

. C&S VALVE COMPANY-ATTACHMENT "A" The entrance meeting was conducted on 02/24/87 and the exit

• meeting on 02/26/87 with the following persons in attendance:

Entrance Meetina Name Position Orcanization E. T. Mazur Lead Auditor CECO QA M. Pankov QA Assistant C&S Valve ,

M. L. Seshagirl QA Manager C&S Valve Exit Meetina l

Name Position Oraantration l

E. T. Mazur Lead Auditor Ceco QA  !

M. Pankov QA Assistant C&S Valve '

M. L. Seshagtrl QA Manager C&S Valve  !

i Other Personnel Contacted l Name Position Organization

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R. Alderman QC Chief Inspector C&S Valve i C. Wolfe QC Inspector C&S Valve

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AVOIT #G-87-204 Page IB

' 0F C&S val.VE COMPANY ATTACHMENT "B" Findtna #1 (Quest!qn 18 & 19_) ,

An audit of the Document Control area remained open after six (6) '

months wtth no apparent follow-up for four (4) months and inadequate identification of deficiencies within the audit.

Discussion 100 k50 Appenatx B, Criterton 16 states in part "Measures shall l

be established to assure that conditions adverse to quality, such as

! .... deftetencies, .... are promptly identified and corrected." Also, Criterion 18 states " Follow-up action ... of deficient areas ...

shall be taken ... " It was noted during the audit that questions were not completely answered in C&S audits to justify finding an area acceptable or deficient. Items were listed for objective evidence without coment. Some questions were noted as deficient without

, cement, other questions had coments indicating a deficient condition l without a statement indicating a deficiency or a reference to another I ouestion that was indicated as defletent. Deficiencies were described on a cover sheet, but references to questions was not complete.

' The audit was contiucted in August,1986 and ine last letter in the file was dated in October 1986. There is nothing to document any l

further activity since October.

Corrective Action Verify that corrective action and action to prevent recurrence is l taken concerning the audtt ttems and documented and close the Document l Control audit.

l Train auditors on completing answers to audit questions and on I responsibillties in following up on audtt deficiencies and verifying I corrective action until the audit is closed.

Ocen Item #1 Reviewing the eye test form for a QC Inspector, noted that the color test appeared to be unsatisfactory. The form was filed and the assumption was the color test was passed satisfactorily. The individual was under the impression his test was acceptable. The form coes not clearly indicate acceptable or unacceptable. A retest that confirms an acceptable passing of the color test will close this item.

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• UNITED STATES -i - -

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NUCLEAR REGULATORY COMMISSION WASHING TON, D. C. 39665

.,3 Novecber 10, 1987

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Docket No. 99901099/87-01 C&S Valve Company ATTN: Mr. Tom Casale President 40 East Chestnut Street Westmont, Illinois 60559 .

Gentlemen:

This letter addresses the inspection of your facility at Westmont, Illinois conducted by Mr. J. C. Harper and Mr. Michael V111 aran of this office on July 21-24, 1987, and the discussions of their findings with M. L. Seshagiri and other members of your staff at the conclusion of the inspection.

The inspection was conducted as a result of an allegation pertaining to inadequate transferring of material heat codes and improper selection and use of material for construction of valve parts. Areas examined during the NRC inspection and our findings are discussed in the enclosed report. This inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspectors.

During the inspection it was found that the implementation of your QA program failed to meet certain NRC requirements. The findings are in the areas of procedural sign offs on nuclear travelers and deficiency reports, and mismarking of a heat code on one bar of material in the nuclear material storage area. The s pecific fieldings and references to the pertinent requirements are identified in 11e enclosures to this letter.

Please provide us within 30 days trom the date of this letter a written statement ,

containing: l (1) a description of steps that have been er will be taken to correct these itees; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed. We will consider extending the response time if you can show good cause for us to do so.

The responses requested by thir. letter are not subject to the clearance proce-dures of the Office of Hanagement and Budget as required by the Paperwork Reduction Act of 1980 PL 96-511.

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C&S Valve Company Noventar 10, 1987 l

i In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the hRC's Public Document Room.

Should you have any questions concerning this inspection, we will 6e pleased to discuss them kith you.

Sincerely, y,;fb */

James C. Stone Acting Chief '

Yendor Inspection Branch Division of Reactor Inspection and Safeguards 1

', Office of Nuclear Reactor Regulation i I

Enclosures:

, 1. Appendix A Notice of Nonconfomance

2. Appendix B-Inspection Report No. 99901099/87-01 cc: Brookhaven National Laboratory ATTH: Michael Yillaran Uptor, Long Island, NY 11973 l I

Phi'sadelphia Electric Company ATTN: S. J. Kowalski 2301 Market Street P. O. Box 8699 Philadelphia, PA 19101 1

Arkansas Power & Light Company ATTN: Mr. T. Gene Campbell Vice President, Nuclear Operations P. O. Box 551 Little Rock, Arkansas 72203 Niagara Mohawk Power Corporation 4 Nine Mile Point Nuclear Station, Unit 2 ATTN: B. J. Hooten l

Executive Director - Nuclear Operations 300 Erie Boulevard West Syracuse, New York 13202 I

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P. APPENDIX A CAS Valve Company ,

Docket No. 99901099/87-01

, NOTICE OF NONCONFORMANCE

! Based on the results of an NRC inspection conducted on July 21-24, 1987, it ,

j appears that certain of your activities were not conducted in accordance l 1 with NRC requirements. l A. Criterion XVII of Appendix B to 10 CFR 50 states, in part "Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: Operating...

inspections, tests, audits, monitoring of work perfomance...."

4 The CAS Valve Company Nuclear Quality Assurance Manual. Revision A, dated April 9,1986, Section 6.4.2 states, in part, "Construction shall

. be performed using the accepted traveler as defined in Section 3.7.1.

Construction activity shall be in accordance with the sequences provided in the travelers and manufacturing personnel shall perfom those specified activities tn the documents referenced on the travelers."

1 Contrary to the above, the material release and verification, uterial i cutting, heat code transfer / verification activities were not documented l and signed off as a separate step for various nuclear travelers in the sequence that these activities were being performed. (87-01-01)

B. Criterion XVII of Appendix B to 10 CFR 50, states, in part: "Sufficient

records shall be maintained to furnish evidence of activities affecting j quality. The records shall include at least the following

...

the results of reviews, inspections, tests, audits, monitoring of work perfomance, and materials analyses.... Inspection and test records

shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted...."

Section 12.5 of the CAS Valve Company Nuclear Quality Assurance Manual.

Revision A, dated April 9,1986, states, in part: "The Deficiency l Report, with any attachments, shall be routed to the Quality Control

! Inspectors for monitoring of resolution implementation, h' hen the resolution has been completed and witnessed by Quality Control, Quality I Control signs off the Deficiency Report and returns it to Quality i Assurance /ANI for sign-off. Quality Assurance /ANI sign-off indicates completion and proper disposition of nonconformance and thus releases

the item for further processing. At this stage. QC shall sign-off i the original sequence of operation, identifying acceptance."

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Contrary to these requirements:

1. Block 6 of the CAS Valve Company Quality Assurance Deficiency Reports (QA DR) number 2738 and 2746 were not properly closed out. In both cases the block was signed and dated, but the acceptance cr rejection of the.' disposition was not indicated.

2. Block 6 of the CAS Valve Company Quality Assurance Deficiency Report (QA DR) number 2743 was not properly signed off. The rejected disposition block was chected but no signature or date was provided. (87-01-02)

C. Criterion VI!! of Ap pendix B to 10 CFR 50, states in part, "Measures Shall be established for tie identification and control of materials, part....  !

These measures shall assure that identification of the item is maintained a by heat number....or other appropriate means..... These identification and control measures shall be designed to prevent the use of incorrect or defective material...and components.

- Section 6.7.3 of the C&S Valve Company Nuclear Quality Assurance Manual, Revision A, dated April 9,1986, states, "If the heat code was inadvertently obliterated QC shall verify through accompanying documentation, that proper heat codes are restamped and this operation shall be identified on the traveler. If unable to identify positively, the item shall be rejected and documented, Contrary to the above, one bar of 5" dia. x 14'10", heat M07238 material, was incorrectly marked as heat code QSB instead of the correct heat code GSB(87-01-03).

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ORGANIZATION: CAS VALVE COMPANY

, WESTNONT, ILLIN0!$

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REPORT lNSPECTIO!J l NSPECTION NO.: 99901099/87-01 ?AfES! 07/21-2a/E7 f N.U Tr unux. zo CORRESPONDENCE ADDRESS: C&S Valve Company 40 East Chestnut Street Westmont, Illinois 60559 ORGANIZATIONAL CONTACT: M. L. Seshagirl, QA Manager  ;

TELEPHONE NUMBER! 319 7AQ-RQnn NUCLEAR IhDUSTRY ACTIVITY: Valve manufacture.

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l ASSIGNED INSPECTOR: b"u 11 >~  ?

J. Cf harper, Prografn Development and Reactive ate Inspection Sectiori (PDRIS)

OTHERINSPECTOR(S): Michael Villaran U

• APPROVED BY: f/

E. T. Baker, Acting Chief. PDRIS, Vendor Inspection Branch Date i

INSPECTION BASES AND SCOPE

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

B. SCOPE: The inspection at C&S Valve was to deterinine the merits of aTligations that there has been inadequate transferring of material heat codes and improper selection and use of materials of construc-tion for valve parts.

PLANT SITE APPLICABILITY: Limerick 1/2(50-352,50-353), Peach Bottom 2/3 (50-277,50-278), Arkansas 1/2(50-313,50-368), Nine Mile Point 2(50-418).

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ORGAN!ZATION: C&S VA1VE COMPANY

. WESTMONT, ILLINDIS REPORT INSPECTION on . ceemirco/pt.ni ptsptTs. 07/21-24/87 DAGF 2 ef 11 A. INSPECTION FJNDINGS:

1. Violations None. l i

2. Nonconfomances

a. Contrary to Criterion XVl! of Appendix B to 10 CFR 50, and the C&S Valve QAM, Revision A. Section 6.4.2, the material release ,

and verification, material cutting, heat code transfer /verifica- ,

' tion activities were not documented and signed-off as a separate step for various nuclear travelers in the sequence that these activities were being perfonned (87-01-01).

b. Contrary to Criterion XIV of Appendix B to 10 CFR Part 50, and the C&S Valve QAM, Revision A. Section 12.5, QA Deficiency Reports numbers 2738, 2746, and 2743 were not properly admini-stratively dispositioned. (87-01-02)

c. Contrary to Criterion Yll! of Appendix B to 10 CFR 50, and the CAS Valve QAM, Revision A. Section 6.7.3, one bar of 5" dia. x 14'10", heat M0723B material, was incorrectly marked as heat codeQSBinsteadofthecorrectheatcodeGSB(87-01-03).

B. UNRESOLVED ITEKS:

None, j C. OTHER FINDINGS AND COMMENTS:

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Background:

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The inspection was conducted as a result of an allegation pertaining  !

to inadequate transferring of material heat codes and improper  !

selection and use of material of construction for valve parts. l 1

On July 31, 1985, the C&S Valve Company was formed by purchasing the assets of Clow Valve Company. In a relative size comparison, Clow Valve operated an average of $1g0 million in annual sales as compared i to $5-6 million in annual sales by the CAS Valve Company. C&S Valve Company retained the Clow technical procedures, occupies the former Clow facilities, and much of the staff is from the origini

company. Records and documentation for Clow supplied corponents are I

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ORGANIZATION: CAS VALVE COMPANY I

WESTMONT, ILLlh013

- I f REPORT INSPECT!DN u- coewco /M.01 RESULTS- 07/21-24/97 P W 3 M 11

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1 still maintained by C&S, and the operating, manufacturing and quality procedures have been carried over by C&$.

4 The C&S QA group QA Inspectors, one ofconsists whom isofinatraining QA Manager,(a QA Assistant, and twoat the tion) and has not yet assumed full responsibilities. At the time of the inspection, a third QA Inspector had been teminated two to 1 three weeks prior to the inspection.

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In the transition from Clow Valve Company C&S was forced to reduce

, their work force by 60-70%. Apparently, the redu:ed workforce. l 1 management / personnel relations and cash flow problems contributed - 3 4

a large percentage of disgruntled employees. An interview with e t

of the QA Inspectors (a Clow and C&S employee for 10 years) was i conducted in order to gain insight into the basis for the allegat

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and the reasons for the relatively large employee turnover. During the interview the QA inspector infomed the ins)ection team that t

some employees, particularly machinists, used tie experience gaited at C&S Valve to step up to better jobs outside of the company.

Several people listed on the company roster are part-timers who art

! brought on and let so, based on workload. Morale was a problem j after the CAS take over. Streamlining of the size of the company led to pertonnel cut backs and cash flow probler.s. Morale improved somewhat after 1987 salary raises were issued. During an informal interview with the shop superintendent, he spoke of one instance where an eeployee was leid off from C&S during personnel cutbacks and then he later contacted CSS threatening to report them to the NRC.

4 The Clow ASME N stamp Certificate of Authorization expired on

] July 1, 1985. No nuclear orders were taken entil April 8, 1986 when the N-stamp was reinstated for CAS.

1 On June 12, 1987 allegations were made against CAS Valve Company by  ;

a former employee to Region !!! of the NRC. The following allegations -

were made to Region !!!:

i j Allegation Item #1 l The alleger was told to sign a "nuclear traveler

• for a valve manu-4 factured at least two years prior to the beginning of his orployment, i He could not, recall any of the details regarding the matter but

, he remembered that it pertained to "attesting to heat co(e transfers."

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ORGANIZATION: CAS VALVE COMPANY WESTMONT, ILLIN0!$ l i  !

REPORT INSPECTION

m. coe m ee/nv.n1 prs 01Ts- 07/21 24/97 i m 4 ef 11 l Allegat.fon Item #2 C&S was "pinching pennies" and using low grade materials. In the sawroom, heat codes were not always being transferred between materials and travelers.

! The alleger was telephoned by the lead inspector on July 22, 1987 at his home in order to obtain details about the allegations. The I alleger could not recall details, however, he provided further I information regarding his original statements.  ;

l' According to the alleger, under instruction from the C&S Valve unage-  !

ment he provided signature approv61 on a nuclear traveler for a i sawcut step for one valve unufactured two years prior to his j employment. He stressed that the traveler was a C&S traveler, j During a training session held on the subject of 10 CFR Part 21, he brought the incident to the attention of the C&S management and management explained that the incident was not a problem.

The alleger went on to say prior to the saw cutting operation that )

he would notify the QC depart >nent to transfer heat codes, however. l at times they would not respond. Therefore, manufacturing personnel I were transferring heat codes on these materials or the heat codes were not being transferred. He could not recall any other details.

The Heat Code is defined by C&S Valve as "C&S's unique identification i number (representedby2,3,or4 digits)andisassignedformill i heat / lot numbers except for weld material where.the manufacturer's heat / lot / batch numbers are used." .

j The alleger was asked for details about his statement rogarding C&S using low grade materials in the valves. He responded by saying that CAS used foreign steel producers to uke valve bodies. In one

! case a valve body contained "holes and rocks within the holes,"

, therefore, they could not be cut by the a chinist because the m ehine tools would break, CAS would subsequently "weld over the holes and send the valve to the nuclear plant" without any mention j of the problem. He could not recall any other details.

The a11eger claimed that he knew of both present and fonner employees willing to attest to the problems with C&S Valve Company that he mentioned. At that point, he was given the lead ins >ector's i hotel telephpne number so that the people mentioned could mate

statements. No additional people contacted the lead inspector

.during this inspection.

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ORGANIZATION: C&S VALVE COMFANY ,

. WESTMONT ILLINDIS REPORT INSPECTION en . oooninoe/R7.nl RESULTS- 07/21-24/87 > AGE 5 ef 13

2. Discusslon Allegation Item #1 could not be substantiated.

The alleger claims that he signed one C&S nuclear traveler for a valve manufactured two years prior to his employment date. His 1 employment start date was August 1986. The typical C&S traveler is ]

light green and contains infonnation regarding traveler number, tab number, QA approval, ANI acceptance, heat code, PO number, material description, part number, drawing number, part description, number

. of piects. In addition, each job function during the mar.ufacture 1 and a hold point were delineated on the traveler (See nonconformance l 87-01-01). According to the C&S QA manual paragraph 6.3.2, "The traveler is the primary construction control document for a part or an item...The traveler is identified with the job num%r, drawing number, and so marked with Nuclear or Q as applicable." Also, paragraph 6.8.1, "QC shall witness and sign-off all traveler sequer.ces identified as QC hold points. In addition, QC may detennine to witness any other operation when a problem is detected or suspected. QC inspection shall include verification of material l prior to release and documents the Heat Code on the traveler...."

In this case, the traveler indicated a sign-off step for saw  :

cutting, and for material release and verification (see Nonconformance 87-01-01). It should be noted that each traveler contains a dark bold job number. The first two d'gits of this number are the year that the valve job was quoted to the customer by C&S. It is common practice that a quote would be placed one or two yr.ars before the connencement of actual valve manufacturing.

According to the C&S QA manual the job number is the governing d.dentification number for all documents throughout design, construction and archiving.

According to the alleger's statements, the valve that he signed-off had to have been manufactured in the 1984 time frame and was a C&S nuclear traveler. C&S Valve Company did not exist in 1984. Prior to July 1985, Clow Valve Company was in existance. Due to the color difference bewteen the Clow and C&S travelers, they are easily distinguishable. Nevertheless, the inspection team examined approximately 600-700 Clow and CAS shop travelers from the years 1984-87. The number of travelers reviewed represents approximately 70% of the total travelers written during that period. Nuclear travelers from 1984-85 were reviewed for evidence of the alleger signing-off on the saw cut step and on the QC verification release

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ORGANIZATION: CSS VALVE COMPANY WESTMONY, ILLINDIS i

f REPORT INSPECTION kn - QQQninCQ/A7 n1 RESULTS; 07R 1-24/87 jAGE6of13 block. - Travelers from August 21, 1986 - February 11, 1987 were examin6d and evaluated for missing heat code verification / material release sign-off on jobs worked by the alleger, end personnel sign-offs inconsistent with their employment dates. Only one case was noted: a date on a saw cutting sequence step was apparently improperly signed-off with a signature dated one year earlier than .

the other sign-offs on travaler 004 for job 86-4774-01Q(see nonconfonnance 87,01-01). This sign-off was noted and corrected by C&S at the time that traveler 004 was being executed. The inspec-tion team reviewed and evaluated 129 nuclear document packages which contained the various nuclear travelers.

- According to the C&S training records the alleger was qualified as a i machinist /welde r. The extent of his sign-off responsibilities were ,

to document the physical act of saw cutting material. According to  !

the C&S QA manual paragraph 6.7.2, "When material is to be divided .

into sections during manufacturing, the manufacturing personnel l shall notify QC to transfer heat codes prior to cutting." Materials i for nuclear jobs are all stored in, a locked and controlled area.

According to the C&S Assembly and Weld Shop Foreman, the QC l Inspectors have sole possession of the keys to the controlled area. l Therefore, prior to any material being delivered to the saw, the QC I inspector had to physically release the material from the controlled area. Once the material was divided into sections, the operator ,

signs-off on the traveler's cutting operation block. The QC inspector was to transfer the heat code and subsequently sign-off the traveler's )

verification / material release opeation block. .There was no '

objective evidence to support that heat codes were r.ot being l transferred proparly. It was noted that th re was no specific procedure to cover the process. However, 'nual paragraph 6.7.2 does give instructions covering the cutt) - d transferring of heat code process which should suffice as a pro ,ure. Furthennore, the traveler for this process does not describe the flow of the operation in exact terms. The traveler usually itemizes the material release and and subsequently the verification saw cuttingstep step(as the first traveler typesign-off step 1). Only on occasion will there be a transfer heat code and verification step on the traveler fo110 wing the saw cutting step (traveler type 2).

If "verification" is meent to describe verification that the proper material has been released from the storage area, then there is no distinct heat code transfer verification step in traveler type 1.

If "verification" is intended to mean both verification that the

. correct material has been released from the storage area and that

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. . I ORGANIZATION: C&S VALVE COMPANY h'ESTMONT, ILLIN0IS REPORT INSPECTION wn . oconinoo/R7.01 RFRU! TS- 07/21-24/R7 9FJ 7 of 11 heat code markings have been properly transferred after s'aw cutting, then the construction sequence listed on traveler type 1 does not conform to the comitments of Section 6.4.2 of the Nuclear Quality ,

Assurance Manual. Section 6.4.2 states, in part, "... construction l activitv shall be in accordance with the sequence provided in the Travelers and Manufacturing personnel shall perfonn those specified activities to the documents referenced on the Travelers." According to CAS "verification that heat codes were transferred was made by a verification step block on the traveler regardless of its physical location on the traveler." Therefore, construction activities in the case of traveler type I were not perfonned in at.cordance with the sequence provided in the travelers. (Seenonconformance 87-01-01.)

In some cases, there were steps on the nuclear traveler involving a saw cutting operation that did not require a heat code documenta-tion, for example cutting parallel key actuators (traveler 0096 &

0138)andglandtubes(traveler 0116 & 0139).

The NRC inspector toured the Nuclear controlled area in order to verify that it was controlled and that heat codes were correctly affixed to the materisis. The storage area was clearly designated as a nuclear material hold area and was locked. Seven randomly picked heat codes were checked against the master file. Materials were marked with heat codes QSB, HC-LBE, HC-VLB, HC-ZOB, BQB, MH, 140 BN. All materials checked in the storage room had proper heat codes with the exception of QSB. It appeared that QSB was written in white marker on 1 bar, 5" dia. x 14' 10", Heat M07238. However, after further checking of the heat code master file it was evident that it should have been marked GSB. Upon careful examination of the stenciled marking on the material the G in GSB was superimposed by a stamped number which made it appear as a Q. The person writing the heat code on the material in white marker (for easy identifica-tion) misread the G for a Q and subsequently marked it as such.

(Seenonconformance 87-01-03.)

Allegation Item #2 could not be substantiated.

An attempt was made to determine whether C&S Valve was "pinching nannies" and using low grade materials or foreign supplied material ln their valve components as stated by the alleger. Deficiency Reports (DR)from 1983 - 1985 were reviewed and all of the Engineering ChangeNotices(ECR)fortheyears 1984 - 1987 were reviewed. In no case was there any evidence that materials of construction were used without the approval of the C&S customer or of the eterial being in compliance with applicable codes and standards. DR 2029, (

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,, ORGANIZATION: C&S VALVE COMPANY

,. WESTMONT, ILLINDIS l

REPORT INSPECTION wn - cooninoc/97.01 RFUM TS* 07/E-74/87 l ' AGE R of 11

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l describes valve body OD undersized at 7 5/16", the drawing called for 7 3/4 OD. The corrective action sent the bodies out for repair i l

by weld buildup. DR 2074 involved 14" aluminum bodies. The bodies failed the liquid penetrant test because of porosity and linett )

indications in the ID bore and flange faces. The bleadout exceeded 1 the 3/16" maximum diameter bleedout for 5/8" and greater wall  ;

thickness. The corrective action was to return the material to the supplier to repair the porosity and linear indication by welding.

DR 2033 and DR 2032 involved a 6" and a 3" dual check valve, respectively, which failed hydrostatic testing. The corrective action was to bond new seat material to the valve bodies, reassemble I and test. DR 2001 involved a casting that failed a liquid penetrant test on the machined surface of the flange face. The corrective action was to scrap the body casting and procure a new casting and remachine. ECRs were required for new travelers.

DR1952 involved valve bearing material. The bearing material specified on the traveler did not match the material on the drawing. i The order was for PO #NMP2-P302X, Nine Mile Point Nuclear Station Unit 2 Niagara Mohawk Power Corporation, Jobs #83-2221-04, 05, 07, l 09, 10, 12, 14, 16, 18, 19, 20, 27, 28, 29, 31, 32, 33. The traveler material was 8505 and Metcar M10 (for 83-2221-28, 29, 31, 32, 33).

The material on the print (design condition) was Teflon and Carbon /

Antimony,MetcarMID(83-2221-28,29,31,32,33). The alternate material was acceptable per TWX from Stone & Webster Engineering Corporation for Nine Mile Point, "The alternate materials per your ref TWX are acceptable in accordance with the requirements of the subject specification." DR 1950 involved the same situation and was dispositioned the same as DR 1952. DR 2947 involved 6" cast dual plate check valve bodies with shrinkage cavaties found at the junction of the machined ID wall and seat surface. The casting was returned to the vendor. DR 1858 and 1954, involved 30" valve body (Job #83-2063-02

1. 82-2739-01-N-02)(N) -02, 03 respectively. The(N) -01) and problem in bothvalve body cases wasmachining (Job excessive porosity. The corrective action was to drill out the

' porosity and plug weld.

ECR fl968 was of interest since it involved a major repair of a valve body. The alleger claimed that on occasion C&S Valve would try to process valve bodies with porosity (holes) that contained rocks. Machining these valve bodies could not be done as a result of numerous pachine tool failures. And the porosity would be weld

. repaired, then subsequently sent to the nuclear plants. ICR #1968 involved DR #2654 from Job Order f83-2462-01 (N) -03, a 12" wafer body valve for IL Power (Baldwin). The body material was purchased

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, ORGANIZATION: C&S VALVE COMPANY WESTMONT, ILLINDIS 1 REPORT INSPECTION wn . cooninco/A7 n1 pretM TS - 07/21-24/87 l

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by C&S from a domestic manufacturer, Jorgensen Steel Company. C&S .

obtain6d approval from IL Power for the weld repair procedure on I the subject valve on June 24, 1985. The DR stated that the material was found unsatisfactory since it failed the radiographic examination due to porosity and slag inclusions. The corrective action recomended by CAS was to reissue a supplement to the original traveler to perform the repairs as required and re-examine by radiography.

Applicable approved procedures were EPS 30-69-825, Revision A; EPS 30-20-103, Revision 0; and EPS 30-49-70, Revision B. The weld repair report stated the repair description as drill oversize holes 3

and plug weld. The parent metal was SA516 grade 70, the weld metal and heat number was E7018-3/16, 431C3231. The cavity size was 5/8" radius in four places. The customer. approved weld nrocedures used in the repair were EPS-30-49-825, Revision A and EFS-30-20-103 Revision O. The customer approved radiographic procedure was EPS 30-49-702, Revision B. The report of radiographic examination was reviewed by the NRC inspector and all four repairs were found acceptable.

The report of ultrasonic testing (UT) of the plug welds stated that the areas were machined smooth and an Aerotech 1/2", 2.25 MHZ, O' transducer was used to scan the repairs. No defects were found.

The test was perfonned by a certified Level II UT inspector on June 21, 1985.

ECR #1942 for Job 84-2993-01 (N) Arkansas Power & Light involved an alternate material, SA240-T3166, substituted by C&S for a clamp ring. The no mal clamp ring material was T316 or T304 stainless steel (SS). C&S used 316L since it was available. This was acceptable by the customer since 316L in most cases offers better corrosion resistant properties with an ultimate tensile strength (UTS) of onl 5000 psi less than 316 or 304. ECR #1911 for Job 84-2948-01 (y) N -02 (N), Arkansas Power & Light involved DR 2610 for a 8" lugged wafer stop valve clamp ring. Again, the same situation occurred and disposition was reached as in ECR #1942. i 1

As a result of two Clow Corporation butterf1 valve failures at l Peach Bottom Atomic Power Station (PBAPS), t e Philadelphia Electric

. Company submitted a Part 21 report to the NRC in 1986. The problem I involved seizing of the valves' shafts and bearings which rendered the valves inoperable after approximately one year of service. The subject valves with carbon bearings were in service at Limerick and

. PBAPS. The M-57 valves were containment isolation valves ~. If an accident occurred during purging (when the valves are open), they maynotclosewithintherequiredtimeperiod(5,6,9secondsper

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ORGANIZATION: C&S VALVE COMPANY WESTMONT, ILLINOIS REPORT INSPECTION wn . coon 1roo/A7.n1 RFSULTS! 07/21-24/87 >AGF 10 of 11

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Tech Spec. Table 3/4.6.3) upon receipt of a containment isolation sig nal'. From review of the Philadelphia Electric Compeny's (PEC)

Metallurgical report, it was concluded that the shaft and bearing seized due to improper material selection which caused pitting strictly from galvanic corrosion and a subsequent build up of corrosion products between the valve shaft and bearing material.

C&S valve had two independent laboratories evaluate the problem.

Packer Engineering Associates perfomed a metallurgical analysis and detemined that seizing was due to pitting which was chloride induced crevice corrosion, The crevice was created by the stainless steel shaft in the carbon bearing. The Packer Engineering report states, in part:

"It should also be noted that g'raphite is more noble than stainless steel. Thus, some galvanic acceleration of any corrosion processes is expected." " ...The subject carbon bearing was found to contain significant amounts of chloride, using two separate test methods (leaching and spectrographic). Neither of the new bearings were found to contain significant quantities of chloride. This indicates that the chloride was probably picked up from service exposure.

Corrosion testing has shown that chloride containing water can pit 17-4 PH stainless steel in a manner similar to that observed on the subject. Further, that crevices composed of subject metal and chloride, containing carbon bearing material, produce corrosion pits in six days wbr exposed ,

to pure (detonized) water.

Patel Engineers (PEA) perfonned a literature search and recomend a material change of the bearing to "bronze, babbit, etc." or change the shaft material to "31655."

It appears from review of the evidence submitted in the PEC and

, the PEA metallurgical reports that the chloride level in the environ-ment experience by the failed valves was the cause of the seizing, since similar valves have been in service at other facilities for several years without reported failure. Yet, C&S decided to change thebearingmaterialtoB505 Alloy 932(bronze)inlieuofMercar M-10 or PTFE or Duralon. Approval for the material selection was granted by the customer. The original M-10 material was specified since it was accepted as an industry standard for bearing material.

' The material selection was based on technical merits as well as the financial advantages of material.

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ORMNIZATION: C&S VALVE COMPANY

' WESTMONT, ILLINOIS e

REPORT INSPECTION wn - econinoo/R7.n1 RFtutTK- 07/21-74/A7

'AGF 11 nf 11 An attempt was made to establish whether C&S Valve used foreign materials to mancfecture valves. All purchase orders (PO) from job orders reviewed were evaluated for foreign manufacturers or material certification from foreign manufacturers. None were found. In addition, the ANI who has been auditi.tg Clow and C&S for at least 11 years was interviewed. He stated that at no time has he ever had any knowledge of CAS using any foreign supplied materials / metals for valves manufactured for nuclear plants.

In sumary, there is no objective evidence to prove that C&S Valve has hedged on quality by inadequate material selection due to financial incentives. .

Training and QA Deficiency reports were reviewed in order to deter-mine if those people named in the allegations were adequately performing their job functions. The 1987 training schedules for personnel in the engineering, receiving, painting and crating, quality control, welding, machining, assembly and testing areas were reviewed. The lists of personnel requiring training and their schedule for training were maintained by the QA Manager in accor-dance with the C&S Valve Company Nuclear Quality Assurance Manual (Revision A), Section 15.4. The areas reviewed were found to be adequate. The training files covered were found to be satisfactory.

A review of all completed QA Deficiency Reports (Exhibit 9, C&S Valve Co. Nuclear Quality Assurance Manual) during the time. r-riod from June 1,1986 to present was performed to verify the effective-ness of this aspect of the C&S QA program. A total of forty-six Deficiency Reports were examined. Three of these, each in a different area of the QA function, were investigated in greater detail:

a. DR 2769, dated June 29, 1987. The QA inspector noted that thread gauges being used on Job 87-5149(N),themanufactureof stop and hinge pin retainers, were past their calibration due dates. The finding was substantiated and all gguges were sent for calibration. All items in the job were checked by the alternate wire gauge method as given in ANSI B2.1 and confonrance was verified. The cause of the deficiency was attributed to a QC oversight in the scheduling and update of calibration lists. Calibration schedules were to be maintained monthly.as a corrective action. The auditor reviewed the C&S

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4. ORGANIZATION: C&S VALVE COMPANY WESTMONT, ILLINOIS REPORT INSPECTION wn - cooni nco m7.n1 __

RFStHTS. 07/21-24/87  ! %GF 17 of 1'4 MITE Control program to verify the corrective action and the effectiveness of the M&TE program in general. The areas reviewed were found to te adequate.

b. DR 2766, dated June 12, 1987. While verifying dimensions of work performed on an 8" valve body under Job 87-5032-01 001, traveler 002-1, the QA inspector noted improperly located holes. The finding was justified, holes were weld repaired, re-drilled, and surface penetrant tested per C&S procedure 30-49-700, Revision E. Cause was attributed to machinist not verifying the dra .ng required dimensions and QA hold points not properly identified on the traveler. Machinists were notified of the error and travelers on a generic basis were corrected to prevent recurrence.

c. DR P'49, dated February 20, 1987. QA inspector noted that ar, incorrect alloy was used in a shipment of plates and bodies for Job 86-4665 under Purchase Order No. TDN-00078. Finding was justified. Alloy 952 was supplied instead of Alloy 954, as stated in the Purchase Order, as a result of an error by the vendor's order correspondent. A Corrective Action Requestion 001-87 was issued to the vender in accordance with C&S procedure 30-49-676 Revision A, to identify the cause and implement appropriate corrective actions.

Measuring and Test Equipment Control. As part of the review of QA Deficiency Report 2769 (Section E.3.2), the CAS Valve Company

, measuring and test equipment controls were investigated.

a. Calibration. Cards. Calibration cards for equipment with calibration frequencies of from one month to two years were reviewed. The records reviewed were found to be in order.

b. Calibration Stickers. A sample of two tools was selected from the calibration lists to verify the effectiveness of the program. Tool number S0179, an NGK 7"-8" 0.D. micrometer, and tool number DC06, a Mitutoyo 0"-6" Dial Caliper, were chosen at random from the calibration list and then located in the plant. Both measuring tools were properly marked with their current calibration stickers.

c. Daily Equipment Log. A daily equipment log is mainnined in accordance with Section 10.3 of the C&S Nuclear Quality Assurance Manual, Revision A, dated April 9, 1986, to provide control and traceability of individual tools and the jobs they

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were used on. The log in use on July 23, 1983, was reviewed, and found to be in order. Two items were selected from the current log and validity of their calibration was verified by the inspectors.

d. M&TE Procedure. The M&TE controls at C&S Valve Company are regulated by the Nuclear Quality Assurance Manual, Revision A, Section 10.3 and procedure 30-49-675, Revision Q dated February 6, 1985 "QC Procedure for Tool and Gage Calibration."

These documents were reviewed and found to be adequate.

3. Part 21 The C&S Valve Part 21 procedure was reviewed and found adequate. All

, necessary documents were posted in clear view for all C&S employees.

4. Plant Tour As part of the plant tour, the inspection team verified adequate nuclear weld rod storage. The nuclear weld rod holding oven temperature was being maintained at 275'F. The temperature readings were logged daily and maintained at 250 - 300'F in accordance with procedures.

D. PERSONS CONTACTED

• H. Seshagiri

• Mary Ann Pankov

• Tom Casale

• Greg LaFrance

• Leon Fordhem Scotty MacGregor Habib Jubran

• Attended the exit meeting.

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