ML20204B460
| ML20204B460 | |
| Person / Time | |
|---|---|
| Issue date: | 07/25/1986 |
| From: | Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20204B303 | List: |
| References | |
| REF-QA-99901057 99901057-86-01, 99901057-86-1, NUDOCS 8607300443 | |
| Download: ML20204B460 (7) | |
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ORGANIZATION: GOLDEN GATE FORGE AND FLANGE SOUTH SAN FRANCISCO, CALIFORNIA INSPECTION INSPECTION REPORT DATES: 5/30-6/4/86 ON-SITE HOURS: 62 NO.: 99901057/86-01 e
i CORRESPONDENCE ADDRESS: Golden Gate Forge and Flange ATTN: Mr. Fred Hawley President J. Post Office Box 547 South San Francisco, California 94083 ORGANIZATIONAL CONTACT: Mr. Fred Hawley TELEPHONE NUMBER: (415) 822-3897 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of ferrous and nonferrous forged flanges, i
M%. 7 h 84 ASSIGNED INSPECTOR: .
. Conway, Reacti Inspection Section (RIS) Date OTHERINSPECTOR(S): 0. Gormley, Pro C nation Section APPROVED BY: / MD4 E.W.Merschoff, Chief,RIS,VendorProgramBranch Date INSPECTION BASES AND. SCOPE:
A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21.
B. SCOPE: This inspection was made as a result of the receipt of a 10 CFR Part 21 report from Consolidated Pipe and Valve Supply (CPVS) pertaining to potential defective flanges manufactured by Golden Gate Forge and Flange (GGFF) and furnished by CPVS to the D.C. Cook and Midland nuclear faci-li ties .
PLANT SITE APPLICABILITY: Potential defective flanges - D.C. Cook (50-315/316),
Midland (50-329/330), Rancho Seco (50-312), Beaver Valley (50-334/412), North Anna (50-338/339), Browns Ferry (50-259/260/296), (continued on next page)
!DR 0 FI 99901057 PDR i
ORGANIZATION: GOLDEN GATE FORGE AND FLANGE SOUTH SAN FRANCISCO, CALIFORNIA REPORT INSPECTION RESULTS: PAGE 2 of 7 NO.: 99901057/86-01 PLANT SITE APPLICABILITY: (continued from last page) Shearon Harris (50-400/
401), Nine Mile Point (50-220), Crystal River (50-302), Trojan (50-344), and Brunswick (50-324/325).
A. VIOLATIONS:
- 1. Contrary to Sections 21.6 and 21.21 of 10 CFR Part 21: (86-01-01) a) Copies of 10 CFR Part 21 and Section 206 were not posted in a conspicuous area.
b) Appropriate procedures to evaluate deviations or inform the licensee or purchaser of a deviation did not exist.
- 2. Contrary to Section 21.31 of 10 CFR Part 21, a review of procurement /
documentation packages for nuclear material revealed that customer purchase orders (PO) to GGFF specified 10 CFR Part 21 as an app 11-cable requirement, but GGFF P0s to vendors did not similarly specify that 10 CFR Part 21 would apply. (86-01-02)
B. NONCONFORMANCES:
Contrary to Criteria II and V of Appendix B to 10 CFR Part 50 and Sub-sections NCA-3851/-3862 of Section III of the ASME Code, GGFF manufac-tured and certified ASME Section III, Class 1 flanges without having a documented quality assurance program. (86-01-03)
C. FINDINGS AND COMMENTS:
- 1. Personnel Contacted Fred Hawley, President Gary Fleming, Vice President Nancy Pemberton, Attorney at Law
- 2. Documentation Packages (DP):
The inspectcrs reviewed GGFF customer list and selected 43 customers from a total of 268 for a detailed review of applicable DPs. Out of the 43, DPs were not furnished for seven customers. The inspectors were told that records did not exist for Coffer, Southwest Fabricating and Welding, and Taylor Forge; and the Department of Defense had subpoenaed the records for Amfac Pipe and Supply, Cook Brothers Manufacturing, Cunico, and Riverside.
ORGANIZATION: GOLDEN GATE FORGE AND FLANGE SOUTH SAN FRANCISCO, CALIFORNIA REPORT INSPECTION NO.- 99901057/86-01 RESULTS: PAGE 3 of 7 e
The majority of the orders were for stainless steel flanges which were manufactured from 1979 to the present. The number of DPs were checked against an Accounts Receivable record which was maintained for each customer since 1981. The majority of customer P0s did not specify the requirements of 10 CFR Part 21 and Section III of the ASME Code and did not require GGFF to manufacture the flanges in accordance with an approved QA program. It was later determined in discussions with GGFF management that GGFF does not have a documented QA program or procedures / instructions (see Non-conformance 86-01-03).
The inspectors reviewed approximately 1,840 DPs. A DP consisted of a customer P0, GGFF test report, packing list, shipping record, and invoice. Customers with 100 or more orders included Familian (100),
Capitol Pipe and Steel Products (110), Williams and Company (133),
Newman Flange and Fitting (196), Tube Sales (249), and Allied Supply (392).
A number of customer P0s were missing from the files. These inclu-ded seven from CPVS, four from Newman Flange and Fitting, three from Hawley Forge, two each from Specialty Metals, Consolidated Pipe and Supply, and Guyon Alloys, and one each from Marman-Keystone and
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Western Piping and Equipment.
GGFF test reports certified that the flange (s) was manufactured in accordance with the specification (eg. ASTM or SA 182) identified on the P0 and listed the chemical analysis and mechanical properties.
For the stainless steel flanges, the test report included the follow-ing statement: "The above was forged at 2000 F to 2250 F, reheated to 1900 F to 2050*F and held for approximately 1 hr/in of thickness and water quenched." Based on discussions with GGFF management, it was noted that most of the heat treating, especially the solution annealing of the stainless steel flanges, was conducted in the for-ging furnaces. There was no documented evidence to show that these furnaces were ever surveyed, and the President of GGFF told the NRC inspectors that temperature measurements were estimated visually without the benefit of pyrometers, thermocouples or other measuring devices.
It was also determined that mechanical testing of a flange af ter forging was not performed as required by specification ASTM A 182.
The chemical and mechanical properties noted on GGFF test reports are values taken from certified material test reports (CMTR) from the mill that supplied the steel to GGFF.
ORGANIZATION: GOLDEN GATE FORGE AND FLANGE SOUTH SAN FRANCISCO, CALIFORNIA REPORT INSPECTION RESULTS: PAGE 4 of 7 NO.: 99901057/86-01 Twenty-two of 35 P0s from CPVS imposed 10 CFR Part 21 requirements upon GGFF. Based on other information contained on invoices and shipping records, it was noted that orders from eight other cus-tomers were sent directly to nuclear power plants. These nuclear orders are discussed in item 4 below.
- 3. Physical Inspection:
A physical inspection of the facility centered on activities such as material control, forging, heat treating, machining, and shipping.
When material is received, it is checked against the P0 requirements.
The heat numbers identified on the CMTR from the mill and also stamped on the end of the bar/ billet are verified, and a GGFF heat code number is assigned. The heat code number is used for traceability of the material in the plant. The activities from receiving through ship-ping are performed by one or two people in each operation.
While procedures for material control do not exist, an order is processed through each operation in batch quantities. The heat code number is used to withdraw the material from storage. A pre-numbered job tic.ket accompanies the material through billet cutting, forging, mcchining, and shipping. In addition, the job number and piece numbers are placed on the material whenever possible.
It was noted that three samples of material in storage were pro-perly identified with a traceable heat code, and four samples of material in process were properly identified and accompanied by the appropriate job tickets.
The forging furnaces are natural gas fired with forced air com-bustion. The forging temperatures are visually estimated from the color of the material, and manual adjustments to the furnace rates are made as required. When the material reaches the proper ,
temperature (i.e., color), it is placed on an anvil and forged I with an air operated hamer. The operator (i.e., President of GGFF) holds it in position and directs the forging operations in-cluding the use of punches and forging rings. Another operator (i.e., Vice President of GGFF) operates the hammer assisted by three laborers. The extent of metal reduction performed before i reheating is a function of the need to reheat the material before it has cooled beyond the required forging temperature. The for- 1 gings are cooled with circulating water. When test bars are speci-fically required by the customer, they are cut from the billet material and forged into specimens approximately 1" in diameter.
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o ORGANIZATION: GOLDEN GATE FORGE AND FLANGE SOUTH SAN FRANCISCO, CALIFORNIA REPORT INSPECTION NO.- 99901057/86-01 RESULTS: PAGE 5 of 7 Heat treating is normally limited to a water cuench at the end of forging or a reheat in the forging furnace followed by a water quench. As in the forging operation, the heat treat temperatures are visually estimated. When special properties are desired, Brinell hardness tests are performed at Golden Gate Heat Treating, (GGHT) whose facility is located adjacent to GGFF. Based on the hardness indications, the material is heat treated again or reforged.
When specific heat treating is required by the customer, it is usually subcontracted to GGHT. The forging of two batches of material was witnessed during the inspection.
Additional customer requirements (e.g., nondestructive examination, chemical analysis, and mechanical testing) are subcontracted. Mach-ining of flanges is performed in another building. Dimensions are controlled within the required tolerances with machinist's pocket rules. Special measurements are made with two vernier calipers. It was noted that neither instrument had been calibrated. Flanges are packaged in newspaper, placed in boxes and normally shipped within a day of final machining.
GGFF test reports are normally signed by the shipping foreman. On other occassions a sales / clerical employee or management signs the report. The President stated that the shipping foreman signed the test reports on the basis of his knowledge of ASTM /ASME requirements.
Not withstanding, no one at GGFF was aware of the requirements for a documented 0A program to cover the fabrication of ASME Section III, Class 1 flanges.
- 4. Nuclear Orders:
During a review of approximately 110 DPs relating to orders from Capitol Pipe and Steel (CP&S), it was noted that three orders were shipped to nuclear facilities. On CPAS P0 0-27512-50 dated July 6,1982, GGFF sent five flanges directly to the Rancho Seco nuclear facili ty. The P0 specified "A182 F304 (ANSI B16.5)" and liquid penetrant (PT) examination on each flange. A GGFF test report dated July 27, 1982, did not identify the PT examination. A GGFF memo dated September 30, 1982, and signed by Fred D. Hawley as Quality Control Manager stated, "A liquid penetrating test was per-formed...on July 12, 1982....The piece was found to be acceptable."
The NRC inspector requested to see the PT test report and the qua-lification records of the examiner, but GGFF could not produce a test report or qualification records to verify that PT was ever performed, or that it was performed by a qualified individual.
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. ORGANIZATION: GOLDEN GATE FORGE AND FLANGE SOUTH SAN FRANCISCO, CALIFORNIA REPORT INSPECTION RESULTS: PAGE 6 of 7 NO.- 99901057/86-01 s
CP&S P0 D-26733-65C dated October 12, 1982, was for a pair of 1-1/2 in. 300# flanges, but a material specification was not identified.
The flanges were direct shipped to the Beaver Valley nuclear facility.
A GGFF test report dated October 20, 1982 certified that the material was "A182 F304" from heat code No. A-45. A review of a CMTR from Joslyn Stainless Steels for heat code No. A-45 revealed that the
" physicals" on the test report were identical to ,the mechanical pro-perties on the CMTR which would indicate that tensile tests were not performed after forging as required by ASTM A182. In addition, a time-temperature chart was not made available to the NRC inspec-tor to verify that the austenitic stainless steel was furnished in the heat-treated condition.
GGFF sent 120 flanges to the North Anna nuclear facility on CP&S P0 0-37856-250 dated August 29, 1985. On a test report dated September 3,1985, GGFF certified that the material was "SA182 F316," and the flanges were heat treated. There was no docu-me'nted evidence to verify that the flanges were "... reheated to 1900"F to 2050 F...." as stated in the test report.
CPVS placed approximately 35 orders with GGFF. The majority of orders were for ASTM A182, Grade 304 or 316 stainless steel flanges and required a CMTR. Twenty-two of the orders imposed the require-ments of 10 CFR Part 21 upon GGFF. With the exception of one order, all of the flanges were for the O.C. Cook nuclear facility.
On PO BS-4525-4 dated May 25, 1984, CPVS ordered six-3 in. 1500#
SA182, F316 flanges. Part 21 and Section III, Class 1 of the ASME Code and testing per SA-652 were identified on the P0. The DP contained a CMTR from Joslyn Stainless Steels. Two test reports from Westex indicated that one sample was taken from the forging, and tensile tests and a chemical analysis were performed in June 1984. There was no documented evidence to indicate that a PT exami-nation had been performed in accordance with specification SA-652.
A certificate from GGHT dated May 31, 1984 stated that six flanges were " solution annealed at 1950*F for 1-1/2 hours...." GGFF man-agement was unable to produce a time / temperature chart to verify that the heat treat was undertaken. It was later learned that the President of GGFF is a 30 percent owner of GGHT which is located in the same building as GGFF. The NRC inspectors requested access to the GGHT facility and records but were refused by the President of GGFF and a supervisor from GGHT.
. ORGANIZATION: GOLDEN GATE FORGE AND FLANGE SOUTH SAN FRANCISCO, CALIFORNIA REPORT INSPECTION NO.: 99901057/86-01 RESULTS: PAGE 7 of 7 e
The reviews of the DPs for other cutomers produced similar results.
Post forging mechanical property measurements and nondestructive examination, s:here required by 'A9 specification, were not performed except in a few cases where customers paid for the testing. Solution annealing was by the uncontrolled method described earlier. As noted in Table 1,16 additional orders with these deficiencies were shipped to seven nuclear plants from 1980 through 1985.
TABLE 1 Flanges Shipped Directly to Nuclear Plants Customer Order No Date Qty Material Specification Destination Guyon Alloys A33439-C 6/20/80 37 Carpenter 20 CB-3 to Browns Ferry.
ASTM B 462 A33723-C 12/09/80 6 Alloy 20, ASTM B462 Yellow Creek A46940-C 4/27/81 7 ASTM A182 F304 Shearon Harris A74220 10/19/84 4 ASTM 182 F304 Nine Mile Point A75604 4/09/84 130 ASTM 182 Fil, F22, Nine Mile Point F304, F316 A76051 7/16/84 5 Carpenter 20 CB-3 Nine Mile Point ASTM B462 stabilized annealed 10 ASTM 182 F304 A76008 7/05/84 40 A182 F304 Nine Mile Point -
A74365 12/09/84 12 ASTM A182 F304 Nine Mile Point A74511 12/11/84 12 SA 182 F304 Nine Mile Point Tioga Pipe B18326 2/08/85 18 A 182 F304 Crystal River Familian Northwest 058491 4/08/81* 4 A 182 F304 Trojan 081709 5/26/83* 13 A 182 F304 Trojan 091636 4/04/84* 3 A 182 F304 Trojan Piedmont Hub G42584 7/27/82 26 A 182 F316L Brunswick G44114 10/27/82 11 A 182 F316L Brunswick 18 A 182 F304L Brunswick 2-52207 5/29/85* 100 A 182 F304 Shearon Harris
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