ML20203F172
| ML20203F172 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/1986 |
| From: | Merschoff E, Yachimiak E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20203F157 | List: |
| References | |
| REF-QA-99900878 NUDOCS 8607300119 | |
| Download: ML20203F172 (9) | |
Text
.
t ORGANIZATION: PHOENIX STEEL CORPORATION PHOENIXVILLE, PENNSYLVANIA INSPECTION INSPECTION REPORT 15 DATE: 6/9-11/86 ON-SITE HOURS:
I NO.: 99900878/86-01 i
CORRESPONDENCEA$ DRESS: Phoenix Steel Corporation i
Tubular Products Division
- ATTN: Mr. R. Anderson Plant Manager 121 Bridge Street Phoenixville, Pennsylvania 19460 l
ORGANIZATIONAL CONTACT: Ms. T. Brugger, QA Manager j TELEPHONE NUMBER: (800) 872-4378 1
NUCLEAR INDUSTRY ACTIVITY: Seamless Alloy and Carbon Steel Pipe, i
ASSIGNED INSPECTOR:
N 7!df %
E. Yachimiak, Retctive Inspection Section (RIS) " Da te OTHER INSPECTOR (S):
l APPROVED BY: .
- 7 t!ff Date E. Merschoff, Chief, R p Vendor Program Branch INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21, NCA-3800, ASTM-106, 333, 335, and 530.
B. SCOPE: The purpose of this inspection was to verify that corrective action commitments stated in Phoenix Steel Corporation's (PSC) written response (letter from R. L. Brooks, PSC, to G. G. Zech, NRC dated 1/11/85) to the findings of inspection report #99900878/84-01 were adequately implemented.
PLANT SITE APPLICABILITY: Various.
l l
l 8607300119 860728 I PD7 GA999 EMVPHOEN 99-700878 PDR
l . .
l .
\
. \
- j l ORGANIZATION: PH0ENIX STEEL CORPORATION l l PH0ENIXVILLE, PENNSYLVANIA REPORT INSPECTION RESULTS: PAGE 2 of 7 J
NO.: 99900878/86-01 l
l A. VIOLATIONS: .
None.
B. NONCONFORMANCES:
- 1. Contrary to Subparagraph NCA-386R.1, Quality Control Procedure (QCP)
PXTT-1, and QCP PXIN-2, PSC failed to calibrate measuring and test equipment in accordance with established requirements. (86-01-01)
- 2. Contrary to Subparagraph NCA-3869.2 and paragraphs and 13.2 of the Quality Assurance Manual (QAM), PSC failed to document conditions adverse to established quality levels; the cause of such conditions; l and the corrective actions taken on such conditions, including actions i
to prevent future occurrence. (86-01-02)
C. UNRESOLVED ITEMS:
5 None.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (Closed) Violation (84-01, Item A.1):
l Contrary to Section 21.6 of 10 CFR Part 21, PSC failed co post Section 206 of the Energy Reorganization Act of 1974.
l Correct posting of Section 206 of the Energy Reorganization Act was found at conspicuous locations in PSC's administrative office. PSC's Part 21 summary and procedure were also on display.
- 2. (Closed) Violation (84-01, Item A.2):
Contrary to Section 21.21 of 10 CFR Part 21, PSC failed to evaluate or report to their customers seamless pipe which did not meet the J minimum wall thickness requirements.
PSC procedure PXGQC-7, " Notification of Product Deviation for NCA-3800 and 10 CFR 21 Nuclear Product," dated 3/12/85, adequately meets the requirements of Section 21.21 of 10 CFR Part 21. This includes provisions for the evaluation of deviations and for the notification of customers if a deviation occurs.
~.-
ORGANIZATION: PH0ENIX STEEL CORPORATION PH0ENIXVILLE, PENNSYLVANIA REPORT INSPECTION NO.- 99900878/86-01 RESULTS: PAGE 3 of 7
- 3. (Closed) Nonconformance (84-01, Item B.1):
Contrary to Subparagraph NCA-3864.2 and QCP NDT-PQC-1, vision exam-inations for nondestructive test (NDT) personnel were not being .
conducted semi-annually as required. !
I Upon review of the NOT personnel records, it es found that all PSC and contract service employees had been given semi-annual eye exam-inations in accordance with PSC procedure NDT-PQC-1 (see section E.2).
- 4. (Closed) Nonconformance (84-01, Item B.2):
Contrary to Subparagraph NCA-3867.1 and Section 11 of SA-530, PSC's method of inspecting pipe wall thickness does not assure that the minimum wall thickness at any point is not more than 12.5% under the nominal wall thickness specified.
QCP PXGQC-8, revision 3, " Procedure for Special Inspection and Relealse "
of Nuclear Quality Material," dated 4/25/85, assures compliance to both of the above requirements. This is done by performing an in-creased number of thickness measurements with an ultrasonic thickness tester and by increasing the minimum acceptable thickness measurement to 0.020" above the governing minimum specification value to com-pensate for wall thickness variations inherent in the manufacturing process (see section E.3).
- 5. (Closed) Nonconformance (84-01, Item B.3.):
Contrary to Subparagraph NCA-3867.3, PSC's procedures for controlling ,
nonconforming material do not adequately address the marking of non-conforming material or the re-marking of material when reclassified, nor have the procedures for controlling nonconforming material been adequately maintained.
Procedures PXAP-4, revision 1, " Customer Referral Procedure," dated 3/15/85, and PXGQC-4, revision 1, " Disposition of Nonconforming
~ Material, dated 2/22/85, have been revised to adequately address the !
marking, reclassification, and remarking of nonconforming material.
The timely revision of these procedures show that they have been ade-quately maintained (see item E.4).
-r --
w- - - - - , - - - - - . - - - - ,%,. ,- - - ,-
ORGANIZATION: PH0ENIX STEEL CORPORATION PH0ENIXVILLE, PENNSYLVANIA REPORT INSPECTION NO.- 99900878/86-01 RESULTS: PAGE 4 of 7 e
l 6. (Closed) Nonconformance (84-01, Item B.4.):
Contrary to Subparagraph NCA-3868.1, QCP NOT-UT1, QCP PiGQC-1, QCP PXIN-2, and PXTT-1, PSC failed to calibrate measuring ind test equip-ment accordance with established requirements.
' A review of calibration records showed that all mensuring and test f
! equipment had been properly calibrated in accordance with procedures with the exception of the working standards. Nonconformance (86 01 addresses the inadequate calibration of these working standards.
Additionally, Final Inspection / Production Reports have not had con-sistent recording of the completion of caliper gauge calibration.
Nonconformance (86-01-01) also addresses this as a failure to show that calibration has been performed. .
- 7. (Closed) Nonconformance (84-01, Item B.'5.):
b f
l Contrary to Subparagraph NCA-3869.2:and paragraphs 12.2.3 and 13.2
- of the QAM, PSC failed to identify and document conditions adverse to established quality levels; the cause of such conditions; the corrective actions taken on such conditions, including actions to prevent future occurrence. PSC also' failed to inform management of conditions adverse to established quality levels within the required l
time period.
i PSC has corrected most of' the above items by writing and implementing new procedures. " Claims Procedure - Phoenixville," 40.70, dated 12/5/83 has been amendid with a Claims Investigation and Corrective Action Report form which requires that the cause of a claim be deter-mined. The Quality Assurance Manager has stated that procedure 40.70 will be updated te' reflect the use of this new form.
Conditions adverse to quality are reported to management in the form of weekly quality reports during' weekly management staff meetings.
This report c'ontains a defined corrective action statement for each condition dstermined to exist for the previous week's activities.
Monthly quality reports have been prepared on time since January 1985. However, they have not contained the status of QA internal audits and customer audits, or the summary of progress for corrective action assignments. Nonconformance (86-01-02) addresses this area.
l t
l l
ORGANIZATION: PH0ENIX STEEL CORPORATION PH0ENIXVILLE, PENNSYLVANIA REPORT INSPECTION NO.- 99900878/86-01 RESULTS: PAGE 5 of 7 E. INSPECTION FINDINGS AND OTHER COMMENTS:
i
- 1. 10 CFR Part 21' Procedures and Implementation:
l A review of PSC's Part 21 procedures was performed and the procedures were found to be acceptable. The Chief Metallurgist is charged with the responsibility to evaluate material nonconformances for all cases l
where nuclear material is involved. After his investigation has deter-mined the reason for the material deviations, he shall notify the l
Technical Director, in writing, with the details of the problem. The f
Technical Director will evcluate this information and notify the NPC if deemed appropriate.
- 2. NDT Personnel Qualification and Certification:
This activity at PSC is governed by QCP, NDT-PQC-1, "NDT Personnel Quelification and Certification." In this document, PSC had esta-blished a requirement that a vision test be administered to NDT i personnel on an semi-annual schedule. PSC had previously (Nonconfod-mance 99900878/84-01 Item B.1.) failed to meet this requirement.
Upon review of the available records, PSC has provided for semi-annual vision tests for all NDT employees utilized by PSC.
- 3. Nuclear Pipe Wall Thickness Inspections:
PSC's QCP PXGQC-8 outlines the inspection actions required for nuclear quality pipe. This procedure consists of a 100% pipe end thickness check with a micrometer: first, a go-no-go check for the minimum allowable specification value is done, then the actual minimum thick-ness is measured. This is performed on both ends of the pipe.
Additional ultrasonic testing (UT) is performed with a UT thickness tester to find the lightest (thinnest) points at circumferential bands approximately 1/4, 1/2, and 3/4's along the length of the pipe. Acceptance for nuclear quality pipe is that all five actual wall thickness values be a minimum of 0.020" above the minimum governing specification value.
- 4. Nonconforming Material Controls PSC has revised the appropriate sections of PXAP-4 and PXGQC-4 so that proper handling of nonconforming material is assured.
l l
. , _ _ _ _ _ . _ . . . _ . - - - - - _ _ _ _ - - - - - . - -_________.__m_
ORGANIZATION: PH0ENIX STEEL CORPORATION PH0ENIXVILLE, PENNSYLVANIA PEPORT INSPECTION RESULTS: PAGE 6 of 7 NO.- 99900878/86-01
- a. Procedure PXGQC-4 contains all the necessary information to insure chat nonconforming material is properly identified as
" scrap," " rework," " referred," " hold," or " stock."
- b. Procedure PXAP-4 now contains the applicable references to PXGQC-4 so that changing of material status from " hold" to i
another classification can be performed as part of the l
customer referral procedure, PXAP-4.
- 5. Control of Measuring and Test Equipment To insure that proper calibration of final inspection and test equip-ment was being performed, the following instruments were checked for adherence to the calibration schedule in PXGQC-1:
Unit Frequency Calibration On Time l
Sonic 502 (#03146E) bi-annually 3/5/86 yes f' 6/5/86 yes Sonic MK IV (#760710)
Sperry 721(#3176-8) 6/5/86 yes 3/5/86 yes UTM 110 (#7889) " yes Nova 201D (#338) 3/5/86 annusily 4/25/86 yes Biddle 72-310-02 (#48599)
Biddle 72-310-02 (#48598) 10/29/85 yes 3/18/86 yes Fluke 8024B (#2865590)
Transmation 1040(#1014001581SP) 5/27/86 yes monthly 6/6/86 yes Heat Treatment Furnace Gas Fired Temp. Control #1 6/6/86 yes 6/6/86 yes Furnace Balance "
6/6/86 yes Zone #3 Barrel Furnace Calibration of the enlongation gage was no longer being performed at the PSC's Phoenixville site since all tensile tests were performed at PSC's Delaware facility.
Calibration of the working standards, however, was not done in accordance with PXTT-1. Instead of monthly calibrations, annual I
check were being performed.
Nonconformance (86-01-01) addresses this item.
f
- - - - . . , , .r,....
ORGANIZATION: PH0ENIX STEEL CORPORATION PHOENIXVILLE, PENNSYLVANIA REPORT INSPECTION NO.- 99900878/86-01 RESULTS: PAGE 7 of 7 t
The Final Inspection / Production Report contains a space to record the completion of the calibration of the caliper gauge used during an inspection shif t. This space was not consistently filled out on the reports reviewed. The procedure for the recording of this I calibration is stated in QCP PXIN-2.
Nonconformance (86-01-01) addressed this item.
- 6. Corrective Action Measures A review of PSC's corrective action procedures for nonconforming material found that the implementation of the " Claims Investigation and Corrective Action Report" form effectively assured that conditions adverse to quality were identified and reported to appropriate levels of management. The one example reviewed by this inspector showed that a thin wall claim was determined to be an isolated incident caused by the forging operation.
L The Chief Metallurgist's responsibility to review nonconformances from the previous day leads to the issuance of a weekly quality report. This report contains a defined corrective action statement for each condition determined to exist because of related nonconfor-mances.
The monthly quality report, which is supposed to .contain a summary of progress for corrective action assignments for any identified l
conditions, did not contain this and the status of QA internal audits and customer audits (the audits, however, were shown to have been performed).
Nonconformance (86-01-02) addresses this item.
N
y ...
, f. Pthbui45 LunTi4 LIED Com'pany W < F Dates b!f - / ( 86 Docket / Report No. N76089 ,
Inspector Cc[,'!ok L/
Page d of (
NAME(Please Print) . TITLE (Please Print) ORGANIZATION (Please Print)
[y' @cgqqpg $dallb(/ksretanceYI 'Orveyn $ch S}wh(orp.
- s. Sn/chw P/awT %a nia ur
- 3. Rh oaks be M Dee(0*
G, QrlS6)( oreN 9 t iNq Osed e'
- p. % as G le.s Nan 1- ~
g, /?. goc,% C/es ?>e+ b
/14 , & ehev /
t m
l
. . . _ _ . . . _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ , , . _ . - - . - . ~ . . , . . . _ , _ _ . . . _ _ _ . . _ - _ _ . , _
w 's , ,
%g! h ia - : : i
. !St i I I
i !
I i -
S 'E s Oi 'd di, bi ! ;
i ! I e '
a >
% 03 4 m+d ' i i
i E
g .
)
g { '$ ' i ! I i
j ,!
o g! '-6
@ v d i i j ' !
I
,. q q, m s; ' s 2, .
l dWW 0- ' --S ' ,
8$2 om o. & O .5 4I li ,
i i i .
i
% %.! .I t- .n i i
fl'I ' 'th' l 6 l l l 9 v ks .
s*
e 3 r
oY o o sl d g gi - s: a o
5 3 Na Q-ad s g %
lt e
i w N
$ i l[
X "
di u- i ll E!"p o : o g i i
l' W j .S T 2 4- I H
- +@ e 2 4
o d 'q o ' o'e 3 l
i l !
O 9o k Q- b !
t 2
c a s a
n e ;
o o
l l
e m "I e n .
f
$ $ ' -) ,
$ )o u ! A. 9, 41) } %. 5 s s
.i,,,,
~
~
Y ~ O C D -
O \
d q l 9 N
u w T 9Io b- I g g 3 g ,
a b' x e i e .
t 2 :
'o l 4j d =
R S i e.Ly.i$<r mo~t e
2 g ;O 2u c 2 51 F -
ye 4 0 8 ey !w e8 ~p '
{.; :. C CCC#
.l Hz @U 12 c4 g y W e C g ggy
" - ' - - . _ _ _ ,