ML20197E039
| ML20197E039 | |
| Person / Time | |
|---|---|
| Issue date: | 05/06/1986 |
| From: | Harper J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20197D995 | List: |
| References | |
| REF-QA-99900774 NUDOCS 8605150148 | |
| Download: ML20197E039 (19) | |
Text
{{#Wiki_filter:- ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHIO REPORT INSPECTION INSPECTION NO.- 99900774/86-01 DATE: 1/27-31/86 DN-SITE HOURS- 64 CORRESPONDENCE ADDRESS: Airco Filler Metals ATTN: Mr. John H. Stamateris Materials Manager 4437 E. 49th Street Cleveland, Ohio 44125 ORGANIZATIONAL CONTACT: David C. Nenstiel Tetrou0Nr NUMAFD- (710 A41 A70n NUCLEAR INDUSTRY ACTIVITY: Welding Rods. ASSIGNED INSPECTOR: J.
\km mx arper', ~ ReUc4fve Inspection Section (RIS) 5446 Date OTHER INSPECTOR (S): 0. P. Gormley, Special Projects Inspection Section (SPIS)
APPROVED BY: 5[([rc E.W.Merschoff,ChiggRIS,VendorProgramBranch Date INSPECTION BASES AND SCOPE: A. BASES: 10 CFR Part 21 and 10 CFR Part 50, Appendix B. B. SCOPE: This inspection was performed as a result of the 10 CFR Part 21 notification made by the Donald C. Cook Nuclear Power Plant,on- i December 20, 1985. The Part 21 notification reported incomplete flux coating of a significant number of E7018 weld rods. The inspection addressed the adequacy of Airco's quality assurance program and its implementation in accordance with Appendix B to 10 CFR Part 50. PLANT SITE APPLICABILITY: Perry (50-440, 50-441); Yankee Rowe (50-029); Dresden (50-010,50-337,50-249); D.C. Cook (50-315, 50-316); Clinton (50-461, 50-462); Maine Yankee (50-309); Bellefonte (50-438, 50-439). 3605150148 86G313 PDR GA999 EMVAIRC 99900774 PDR
ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHIO REPORT INSPECTION NO.- 99900774/86-01 1 RESULTS: > AGE 2 of 11 A. VIOLATIONS: Contrary to Section 21.31 of 10 CFR Part 21, Airco did not specify Part 21 as an applicable requirement on purchase orders (P0s) issued to vendors of calibration services and the Tensile Testing Co. which supplied machining and stress relieving services to Airco. (85-01-01) A Severity Level V violation was issued in this area. B. NONCONFORMANCES:
- 1) Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 7.2.2 of the QAI Manual and SNT-TC-1A, a radiographic test trainee independently performed radiographic tests on Lot #026C003, Heat
#72181 without being qualified and certified to SNT-TC-1A Level I status. (85-01-02)
- 2) Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 7.2.2 of the QAI Manual and SNT-TC-1A, Section 8.1, at the time of the inspection there was no record or objective evidence of an eye examination for the radiographic test technician qualified to Level III from 1977 to 1983. In addition, the 1986 eye examination was approximately one month past due. (85-01-03)
- 3) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco Quality Assurance Instruction (QAI) Section 2.2.1, qualifi-cation records did not describe in detail the qualifications of the quality department personnel. Additionally, the records do not show correlation between training and qualification of quality personnel, and the required oualifications for the position. (85-01-04)
- 4) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco Quality Systems Manual (QSM) Section 3.2.b, wire mill personnel, press operators, packers and inspection spares perform quality related functions but were not trained and indoctrinated in the Airco quality system. (85-01-05)
- 5) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QSM Section 3.1.3, procedures for wire mill operations were not available at the work stations for wire mill personnel.
(85-01-06)
ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHIO 1 REPORT INSPECTION NO.- 99900774/86-01 RESULTS: PAGE 3 of 11
- 6) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QAI Section 4.2.2, 11 purchase orders for core wire and one purchase order for test specimen machining and stress relieving were not reviewed and approved by the QA Manager as evidenced by ;
his signature. (85-01-08)
- 7) Contrary to Criterion V of Appendix B to 10 CFR 50 and the Airco QSM Section 2.3, the requirements of Appendix B to 10 CFR Part 50 were not imposed on P0s to Airco's vendors that supplied calibration services and test specimen machining and heat treatment. (85-01-09)
- 8) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QAI Section 4.2.1, the QA Manager did not review and approve the calibration procedures used by Brinkman Instruments in 1985 and Brown & Sharpe in 1984. (85-01-10)
- 9) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QAI 8.2.1, the Sartorius analytical balance model #2465 was not calibrated and certified traceable to NBS in 1985. The certificate of calibration and traceability for do Blo:ks (gage block) set serial #2119 dated June 20, 1984 was invalid since the certificate was not signed by an authorized person from the calibration vendor (Brown & Sharpe). (85-01-11)
- 10) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QAI 7.2.2, welders fabricating weld samples used for acceptance testing of nuclear orders #026C007 and #026C008 were not identified by signature on the weld test report. (85-01-12)
- 11) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QAI Section 4.2.1, Brinkman Instruments, suppliers of analytical balance calibration for Airco in 1985 and 1986, were not on the Airco AVL. (85-01-13)
- 12) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QAI 12.2.1, Georgetown Steel was not removed from the Airco AVL when they did not implement corrective action required by a 1984 Airco audit finding. The finding involved a failure to calibrate the Mike Master gage block set SN632. (85-01-14) l l
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ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHIO REPORT INSPECTION NO.- 99900774/86-01 RESULTS: 3 AGE 4 of 11
- 13) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and the Airco QAI manual 14.2.1, the internal audit performed in August 1985 of the quality department was done by an untrained and unqualified auditor. Also, the frequency of audits performed in 1985 did not reflect the audit results found in 1984, since in 1984 a minimum of 26 audit findings were reported. (85-01-15)
- 14) Contrary to Criterion VII of Appendix B to 10 CFR Part 50, quality program audits have never been performed on Airco's vendors of calibration services and test specimen machining and heat treatment vendors. (85-01-16)
E. OTHER FINDINGS OR COMMENTS:
- 1. Inspection Issues The inspection was conducted in response to a report of defective coatings on E7018 weld rod received at D. C. Cook. One report stated that the coating was missing over 180 in circumference and appeared to have been machined or shaved off. A carbon copy of a photomacrograph showed rods with incomplete coating. The extent of the defective coating observed in the poor quality photomacrographs ranged from roughly 1/2" to 12" in length. In the photomacrographs the circumferential extent of the defects appeared to be not more than 60 . The depth of the defects could not be determined from the photomacrographic evidence. The Airco QA Manager never saw the defective rods and had not seen any of the photomacrographs.
It was determined from procurement records that the weld rods supplied to D. C. Cook were from production run 026C003 and was shipped between August and November 1984. These rods were made in June 1984. ' l At that time nuclear weld rods were being produced for the first time at the Cleveland plant, following the closedown of the military / nuclear product lines at the Sparrows Point plant in Baltimore, Maryland. Therefore, the rod was manufactured in Cleveland and samples taken to Sparrows Point plant for evaluation in July 1984 ; since the quality laboratory was not moved to Cleveland until March l 1985. At Sparrows Point the quality laboratory performed tests for chemical and mechanical properties of deposited weld metal to ensure that the requirements of ASME SFA-5.1, Specification for Carbon Steel Covered ARC Welding Electrodes, were met. The records produced during those tests did not reveal any failure to meet the specification. l l l
ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHI0 REPORT INSPECTION NO.- 999007/4/86-01 RESULTS: > AGE 5 of 11 However, the chemical and mechanical tests do not address uniformly or the lack of defects in pre-coating. The same rods could have been damaged after samples were taken for analysis. Concentricity measurements per ASME SFA-5.1 were made in Cleveland during the manufacturi:.g process. No evidence of concentricity defects was noted in the quality records. Formal and informal audits of the Cleveland plant conducted in early 1984 revealed an abnormal number of quality findings in January and May. Corrective action reports after the May audit, and the clcseout of those findings in the November 1984 audit indicated that the quality problems had been addressed to the point where acceptable quality should have been expected during the period when run 026C003 was produced. To summarize, some quality problems did exist during the period when the rods 026C003 and other nuclear weld rods were produced. During this time nuclear weld rod production was being moved from Sparrows Point in Cleveland. Quality records reviewed during the inspection gave no evidence of coating defects as seen in the photomacrographs (as delivered to D. C. Cook). Any technical conclusion by the NRC inspector of the defective coating without the benefit of the rod analysis would be purely speculation.
- 2. 10 CFR Part 21 Quality Assurance instruction 15.2.4 relating to the reporting of defects and failures was reviewed. The, implementation of the manual in regard to posting requirements was evaluated and found adequate by inspecting the manufacturing facility and the warehouse facility in Broadway Heights, Ohio.
Interviews were conducted with Airco management and quality personnel to determine their familiarity with the provisions of Part 21. Three of the management personnel contacted were not familiar with the provisions of Part 21. The welding supervisor and the Quality Control Technician were not aware of any written company policy on Part 21. l They both knew to inform the QA Manager when finding a defect that would result in shipping a defective product. Neither was specifi-cally aware of Section 206 or Part 21 procedures as they apply to Airco nuclear orders or its posting locations at Airco.
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ORGANIZATION: AIRCO FILLER METALS CLEVELAND, OHIO REPORT INSPECTION NO.- 99900774/86-01 RESULTS: ' AGE 6 of 11 P0s issued to vendors of calibration services; Honeywell, Timius Olsen, Filing Scale Co., and Brown & Sharpe, did not specify Part 21 as an applicable procurement requirement. Airco contracted cali-bration services for Jo Blocks, welding meters, impact machine, moisture furnace, analytical balances, micrometers, weighing scales, oven temperature controllers, temperature indicator for impact testing, tensile testing elengation gage, and the environmental chamber. In addition, P0s to the Tensile Testing Co., (blanket P0 #497802 dated August 15,1985) did not specify Part 21 as an applicable procurement requirement. The Tensile Testing Co. machined 3/4" tensile bolts and impact specimens as well as performing stress relieving operations. (See Violation 85-01-01)
- 3. Training / Qualification Training records and qualification requirements were examined for some 20 people involved in auditing and welding, as well as quality control and quality service personnel.
Training records for a radiographic test technician revealed that he was a trainee and was not certified to independently perform radiographic tests. The QA manager is the Level III radiographer. He is responsible for the trainee's training and certification as well as supervising him while he performs radiography. Due to the volume of work being performed by the QA Manager, he does not have enough time to accompany this trainee while he takes radiographs. Therefore, the trainee must perform radiographic tests without the benefit of having a Level II or III present. Specifically, this inspection identified radiograph 5 taken on Lot #026C003, Heat #72181, Test No. E391F on June 28, 1984 by this individual without proper supervision (see Nonconformance 85-01-02). Qualifications of the Level III radiographic technician revealed that between the years of 1977-83 objective evidence of an eye examination was nonexistent. The radiographic technician did produce receipts indicating payment to an optometrist during this period. However, there was no record or explanation indicating the nature of the visit or examination (see Nonconformance 85-01-03). At the time of this inspection it was evident that this Level III Technician's 1986 eye examination was approximately one month past due, i
ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHIO REPORT INSPECTION NO.- 99900774/86-01 RESULTS: ) AGE 7 of 11 Wire mill personnel, and packers, all perform quality related functions at Airco. However, these personnel are not trained and indoctrinated in the Airco quality system program. Wire mill personnel are responsible for constant surveillance of their operations. Further-more, they are responsible for assuring that the special nuclear tote cans are completely empty before use and that the dimensional tolerance of the wire is correct. Personnel that pack the electrodes into the special tote cans are the last to see each individual electrode before they are canned and sealed for shipment. The packers perform a quality related function from the standpoint of making a visual go/no-go determination of the electrode quality before packing. (See Nonconformance 85-01-06). An internal audit performed during August 1985 at the Cleveland plant was performed by an unqualified auditor. This was the first audit performed following the quality laboratory relocation to Cleveland, Ohio from Baltimore, Maryland. Apparently, since the quality department reports to the QA Manager, the department was
. audited by a person independent of that department, a process engineer. No records of qualifications for that process engineer functioning as an auditor were available during the inspection.
(See Nonconformance 85-01-15) Qualification records available for present members of the quality department were generally inadequate in describing in detail the qualifications of the stated personnel. In addition, the records do not document the training received in relationship to the qualifica-tion required for the position. The qualification form letters state that the individual had successfully completed a three month on-the-job training program and was considered fully qualified to perform all quality related functions within the scope of the Quality Assurance Program. This was observed on the qualification records of both the Chemical Laboratory Technician and the Quality Control Technician (as well as others). Both perform important quality functions. The statement "on-the-job training" was supplemented by a reference to QA training in 1983 on the quality form letters (for the three quality control specialists). Upon review of the 1983 training records it was evident that the three quality control specialists had only received two half-day QA orientation seminars. The records reviewed for some former quality personnel at the Baltimore plant were somewhat more specific in providing a log of jobs worked during the on-the-job training program. However, these records lacked specific correlation
ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHIO REPORT INSPECTION NO.- 99900774/86-01 RESULTS: ) AGE 8 of 11 - between training, education and on the job instruct oni and the pre-determined and/or specific qualifications for the position. While the Airco QAI requires training in all facets of-the positions' requirements as well as documentation (on the record sheet), the record sheet does not give enough detail to objectively identify an individual's qualifications. The present documentation of the record sheet form gives no evidence of specific training or any objective means to audit the stated oualifications (see Nonconformance 85-01-04).
- 4. Audits The inspection evaluated the implementation of the Airco System.
External audits are performed for AVL qualification. Airco performs two types of internal audits. A semi-annual internal audit and a General Manager's annual assessment of the QA program as required by the QAI. The General Manager's annual assessment of the QA program was reviewed and found to be within the intentions of the program. Hcwever, there were problems found with the semi-annual internal audits being performed in 1985. Airco conducted three internal audits of its Cleveland facility in 1984 while the quality laboratory was still in Baltimore. The first audit was an informal audit done on January 24, 1984, which produced ten findings. The second audit performed on November 26, 1984 was formal and produced only one or two findings (while closing out findings from the 5/22/84 audit). In 1985 the Quality System was audited on an annual basis. The audit was performed on August 12, 1985. This is a time delay of nine months since the previous audit. Furthermore, considering the number of items found in the 1984 audits, the frequency of audits in 1985 should have been increased, according to the Airco QAI. (see Nonconformance 85-01-15). It was noted that Airco's policy of approving vendors of calibration services is based on the QA manager reviewing and approving their procedures. Airco contracts calibration services for calibration of the tensile machine, moisture furnace, analytical balances, environ-mental chamber, Jo Blocks, oven temperature controllers and weld meters. The NRC's position on auditing suppliers of calibration services for measuring and test equipment is that Appendix B to 10 CFR Part 50 should be applied to these vendors. Additionally, preaward evaluation and postaward audits are required. Airco has
ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHIO REPORT INSPECTION NO.- 99900774/86-01 RESULTS: ? AGE 9 of 11 failed to conform to this policy by not imposing the requirements of Appendix B to 10 CFR Part 50 on P0s to these vendors as well as by not performing preaward and postaward audits as required (see Viola-tion 85-01-01 and Nonconformances 85-01-09 and 85-01-16). Furthermore, Airco failed to follow its QAI manual when approving vendors that perform calibration services. The QA Manager did not review and approve the procedures of calibration vendors Brinkman Instruments and Brown & Sharpe. In 1985 Brinkman Instruments provided calibration for the Mettle analytical balance model #P10TW. In 1984 Brown and Sharpe provided calibration services for the do Block (gage blocks) set model #2119 (see Nonconformance 85-01-10). It was noted that Airco purchased machining and heat treatment services for their tensile and impact test specimens from the Tensile Test Co., P0
#4-2019-02 (blanket order requisition #489114 in 1985). The heat treatment in this case denotes a stress relieve of tensile and un-notched impact test specimens at 1150 F for 1 hour, furnace cool at 200 F/hr. until below 500 F. Airco did not impose the requirements of Appendix B to 10 CFR Part 50 on P0s to this vendor nor did they impose Part 21. Nor did Airco perform a preaward or postaward audits on The Tensile Test Co. Since dimensional tolerance and the correct stress relieve is essential to determining accurate mechanical and impact test results, it is important that a quality program, as well as, a mechanism of accountability be imposed on vendors of machining and heat treatment. In cases where heat treatment furnaces are faulty or dimensional tolerances are inadvertently missed and the particular problem is not discovered until a later date, a mechanism for notification needs to be present (see Violation 85-01-01 and Noncon-formance 85-01-09 and 85-01-16).
Two audits of Georgetown Steel, 17 months apart revealed that the Mike Master set $N632 used to calibrate micrometers were not traceable to NBS. At the time of this inspection there was no objective evidence available to verify that corrective action had yet been accepted. In spite of this, Georgetown Steel was still on the Approved Vendor's List. P0s #497807 and #497810 had been placed with Georgetown after the second audit which reported at the time that corrective action had not yet been taken (see Nonconformance 85-01-14).
- 5. Calibration of Measuring Test Equipment j The NRC inspector checked the up-to-date calibration of measuring )
and test equipment against the Airco " Calibration Frequency Chart." Welding meters; calibration ruler serial #64167, #92872; measuring
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ORGANIZATION: AIRC0 FILLER METALS CLEVELAND, OHI0 REPORT INSPECTION NO.- 99900774/86-01 RESULTS: PAGE 10 of 11 devices (rulers, tape measures); oven temperature controllers line 6 Toledo 2086 scale; the temperature indicator for impact testing; the moisture furnace (transmation mod 1045, serial 140507); tensile testing elongation gage calibrations were all up-to-date. All the Certificate of Calibrations were traceable to the NBS. Micrometers CM08, AM73 and micrometers CM01, CMD25 and the production micrometers CM020, CMOS were checked and found to have up-to-date calibrations. However, the Jo Block (master blocks) set serial #2119 for blocks no. E1641 size 4, E1156 size .0625", E1375 size .125", E1890 size .250" and E1539 size .500" possessed a Certificate of Calibration that was not signed by the authorized calibration vendor (Brown & Sharpe) and as a result was not traceable to NBS (see Nonconformance 85-01-11). The Sartorius analytical balance model #2462 used for weight measure-ments in rod moisture testing did not have a Certificate of Calibration (see Nonconformance 85-01-10). However, both the Mettler analytical balances serial #376039 and #B29349 had up-to-date calibration and Certificates of Calibration traceable to NBS. I
- 6. Special Process and Procedures A percentage of Nuclear & Military Weld rod is selected during production runs and submitted to the quality laboratory for evaluation. Airco handles military and nuclear rod in the same fashion as far as quality requirements. Welders use the rod and make a simulated weld joint which serves as a test specimen. Weld metal test specimens and chemical analysis specimens are prepared and are used to determine the acceptability of the production run. Each test weld is documented on a weld test report which should be signed by the welder. In the two most recent nuclear production runs #026C007 and #026008, 47% of the weld test i reports were not signed by the welders (see Nonconformance 85-01-12).
When notified of this problem the QA Manager stated that the problem ! had been identified in an earlier ASME inspection. Records were produced to show that recent military runs 100% of the weld test reports were signed by the welders. The NRC inspector witnessed a moisture test in progress. The actual test was evaluated against QAI moisture testing procedure 15.2.12 rev. 3 dated 9/6/85. The test operator was knowledgeable on the procedure. The procedure was well written, and straight forward. Airco has made a minor improvement to this procedure that was not written into the procedure. This step involves a heating cycle.
ORGANIZATION: AIRCO FILLER METALS CLEVELAND, OHIO REPORT INSPECTION NO.- 99900774/86-01 RESULTS: > AGE 11 of 11
- 7. Record Retention Retention of Qualification Records Eight nuclear production runs, cuality documentation packages were reviewed and 23 individuals were selected for an examination of qualifications. All of these individuals were involved with quality related functions such as auditing, radiography, welding, inspection.
Records for six were not available. These six people had been moved to Cleveland when the nuclear weld rod production was transferred there. Airco requires such records to be maintained for a minimum of three years (see Nonconformance 85-01-07). i l
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