ML20206J327
| ML20206J327 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1986 |
| From: | Conway J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20206J281 | List: |
| References | |
| REF-QA-99901055 99901055-86-01, 99901055-86-1, NUDOCS 8606270100 | |
| Download: ML20206J327 (20) | |
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ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION INSPECTION NO.- 99901055/86-01 DATE- 5/12 16/R6 ON-SITC 90tlRS- 40 CORRESPONDENCE ADDRESS: WFI Nuclear Products, Inc.
ATTN: Mr. R. W. Ryan President 4407 Haygood Houston, Texas 77022 ORGANIZATIONAL CONTACT: Mr. G. W. Gross, QA Manager TELEPHONE NUMBER: (713) 695-3633 NUCLEAR INDUSTRY ACTIVITY: Pipe flanges and fittings
/ /
ASSIGNED INSPECTOR: , k LI\M((L ~N-S(
J.)T.Conway, React- e Inspection Section (RIS) Date
)
E. Yachimiak, RIS
\
OTHERINSPECTOR(S):
L. Vaughan, Program Coordination Section APPROVED BY: M [~)Y'h E. W. Merschoff, Chief, RISf Vendor Program Branch Date INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21 S. SCOPE: This inspection was made as a result of the receipt of:
(1) an allegation pertaining to the improper heat treating of stainless steel flanges and falsifying heat treatment charts, and (2) a 10 CFR Part 21 report from WFI on nonconformance reports.
PLANT SITE APPLICABILITY: Not identified.
I 8606270100 860625 PDR GA999 ENVWFINP 99901055 PDR
T ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 2 of 12 A. VIOLATIONS:
- 1. Contrary to Section 21.31 of 10 CFR Part 21, a review of f purchase orders (PO) for nondestructive examination (NDE),
NCA 3800 material, and calibration services revealed that 10 CFR Part 21 requirements were not imposed on the following P0s: N-1239 and N-1245 to Gulf Coast Machine and N-1249 to Guyon Alloy for NCA-3800 material; N-1183 and N-1180 to DLH Qualitech for NDE; and N-1273 and N-1171 to Grady M. Cook,.
N-1177 and N-1163 to Baker Electronics, N-1169 to Texas Micronet/ Gulf Coast Calibration, N-1300 to Technology Calibration, N-1181 to Combustion Services, and N-1174 to Advanced Inspection for calibration services. (86-01-01)
B. NONCONFORMANCES:
- 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Sections 4.2.3 and 7.3.2 of the Nuclear Quality Assurance Manual (NQAM), and Subsection NCA-3864.2 of the ASME Code, it was noted that the QA Manager had written two NDE Pro-cedures (i.e., UT-2-84, " Ultrasonic Examination for Forged Material" and LP-1-84, " Visible Dye Liquid Penetrant Exa-mination Procedure") in September 1984, but there was no documented evidence that the individual was qualified to be a Level III Examiner. (86-01-02)
- 2. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 7.2.1 of the NQAM, Section 8.7.5 of Procedure No.
AD-3, and Section 9.6.1 of SNT-TC-1A, the qualification records of WFI's Level III Examiner did not contain a statement that the individual met the training requirements of Procedure No. AD-3. (86-01-03)
- 3. Contary to Criterion V of Appendix B to 10 CFR Part 50 and Section 4.1 of Procedure No. WFI-22, a non-calibrated protractor / scale (S/N S2) was used to measure the linear dimensions of a fitting supplied on P0 No. N-2473.
(86-01-04)
- 4. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 9.2.8 of the NQAM, the digital temperature display (S/N 99689) for the Charpy impact test bath was two months late in its calibration schedule. In addition, two certi-fications of calibration were missing from the files for J' May 8 and August 8, 1985. (86-01-05)
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ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 3 of 12
- 5. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 9.2.7 of the NQAM, WFI did not have a procedure for the calibration of thermocouples used in the heat treat furnaces. (86-01-06)
- 6. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Section 11.4.1 of the NQAM, and Subsection NCA-3867.4(a) of the ASME Code, it was noted: (86-01-07)
- a. WFI CMTR did not agree with Southwestern Laboratory reports on a number of chemical elements for heat codes 305 BN, 209 BN, 219 BN and 976 AN on nuclear orders N-2516, c2437, -2298 and -2476, respectively.
- b. Heat treat statement on CMTR did not agree with time / temperature chart dated Feburary 13, 1986 for heat code 222 BN on nuclear orders N-2376 and N-2496,
- c. Supporting documentation (i.e. test report and time /-
temperature chart) to substantiate the mechanical properties and heat treat statement on the CMTR dated May 9, 1986 for heat code 134 BN on nuclear order N-2641 was missing.
- d. On nuclear order N-2231, for item 1 (heat code 270 BN),
a time / temperature chart did not exist to substantiate the heat treat statement on the CMTR dated October 31, 1985; and for item 2 (heat code 226 BN), a test report did not exist to substantiate the mechanical properties and the heat treat statement did not agree with the time / temperature chart dated October 10, 1985.
- 7. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 8.2.3, 8.2.6, 8.4.2, and 8.4.4 of the NQAM, during a review of 39 NDRs, three Nuclear Travelers and the NOR log book, it was noted: (86-01-08)
- a. Nuclear Traveler Nos. N-2602, N-2435, and N-2555 did not identify the NOR number for the nonconformance generated.
ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 4 of 12
- b. NDR Nos. 0038 and 0039 were dispositioned by a Material Review Board consisting only of the President, QA Manager, !
and Vice President of Technical Services.
- c. Documented evidence was missing to show that the QA Manager had verified corrective action was initiated for NDR Nos. 0001 through 001S.
- d. Documented evidence was missing to show that an annual sunnary of all NDRs was reviewed by management.
- 8. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 12.2.1, 12.2.4, and 12.2.6 of the NQAM during a review of 13 internal audit reports conducted from January 1981 to January 1986 it was noted: (86-01-09)
- a. Documented evidence was missing for audits conducted between December 1983 and December 1985. For those audits conducted from January 1981 to November 1983, QC procedures AD-1 through AD-5 were not included in the audit,
- b. The following audits were conducted without any evidence of the audit reports being reviewed by management other than the manager of the department that was audited:
Department Audited Date Sales 11/83 and 1/82 Engineering 11/83 and 1/81 Production 11/83 and 1/82 Purchasing 11/83, 1/82, and 1/81 QA 4/83, 1/82, and 6/81
- c. There was no documented evidence of follow-up action to verify that corrective action was implemented for the following audits:
Department Audited Date QA 6/22/81 and 4/19/83 Sales 1/26/82
ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 5 of 12
- 9. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Sections 3.2.1, 3.2.2, 3.2.5 and 3.3.1 of the NQAM, during a review of four Approved Vendor Lists (AVL) issued from November 1983 to April 1986, 15 vendor audit reports, and four P0s, it was noted: (86-01-10)
- a. Twelve P0s(N-1273, -1171, -1181. -1177, -1163, -1298,
-1204. -1209, -1261, -1295, -1175, and -1249) were placed with vendors who were not on the AVL, and documented evidence of an audit or survey was missing,
- b. A distribution list was missing for AVLs issued by the QA Department.
- c. Thermo-Temp Instruments was listed on the AVL dated April 1986, but the last audit was in January 1985,
- 10. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and P0s N-1209, N-1204, N-1168, and N-1160, there was no documented evidence presented to the inspector to verify that any WFI personnel witr.essed the forging activities at K.0. For e and Laclede for the material on these four P0s. (86-01-11 C. UNRESOLVED ITEMS:
None.
D. OTHER FINDINGS OR COMMENTS:
- 1. Allegation In April 1986, the NRC Region IV office received a phone call alleging that WFI had improperly heat treated numerous stainless steel flanges in January 1986 by placing them in the uncalibrated forging furnace instead of the calibrated heat treat furnace. In addition, it was alleged that heat treatment records were being falsified.
The inspector reviewed 40 time / temperature charts for nuclear flanges on 22 orders in 1985 and 1986. With the exception of three orders, the information on the charts agreed with the heat treat statement in the CMTRs (see Nonconformance 86-01-07). For order N-2505, a notation "SA
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ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 6 of 12 105N 270 BN" was added with a different pen to the chart at a later date than the rest of the information contained on the chart. This addition is not significant to the rest of the data. Based upon the review of applicable QA records, discussions with WFI management pertaining to the heat treating of flanges and a physical inspection of the heat treat area, the allegations could not be substantiated.
- 2. NDE A tour of the NDE testing area indicated WFI performs magnetic particle (MT) and liquid penetrant (PT) examinations with WFI owned equipment. The MT equipment consists of a portable unit, Model M-500 (S/N 781505). A sticker on the unit indicated that it was calibrated in December 1985 by Hocker, Inc. A certifi-cate from Hocker, dated December 10, 1985, indicated that the test equipment was traceable to NBS.
The stationary unit, Type No. ARQ-54S (S/N 52556), was calibrated by Baker Electronic Services on September 4, 1985. A review of the certification from Baker Electronic verified that the unic was certified to meet the requirements of ASTM E 109. A magneti-zing current graph was attached to the certification. A state-ment on the certification indicated that instrumentation used by Baker was traceable to NBS.
An ultraviolet meter is used to check the black lite on the magnaflux unit. The "Blak-ray Ultraviolet Meter", (S/N 33260), was calibrated by ARDR0X in January 1986. A certificate from ARDR0X stated that the test equipment used to calibrate the instrument was traceable to NBS and conformed to Mil-STD-45662. A radiometer, (S/N 20710),
used prior to the ultraviolet meter was last calibrated in November 1984.
The chemicals used for PT examination were purchased from Hocker, Inc. who in turn purchased the material from ARDROX.
Three Certificate of Compliances from ARDR0X, all dated April 10, 1986, indicated that the 985-P12 Penetrant (Batch No. 10384), 904A Developer (Batch No. 9534), and 9PR12 Emul-cifier (Batch No. 10126) meet or exceed the requirements in Article 6 of Section V of the ASME Code and Mil-I-25135c, Amendment III. The above batch numbers corresponded to numbers on containers in the PT testing area.
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ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED (
HOUSTON, TEXAS j REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 7 of 12 A review of NDE procedures for ultrasonic (UT), MT and PT exami-nations indicated that a UT and PT procedure were written by the previous QA manager at WFI. There were no certification records for this individual who worked at WFI from 1983 to January 1986 (See Nonconformance 86-01-02). Currently, NDE is performed by an It was noted the Level III performed outside Level III examiner.
MT in March 1986 (order N 2476), and UT and PT in January 1986 (orders N 21364 and N 2291). With the exception of a missing state-ment pertaining to completion of training, the certification records of the Level III appear to satisfy the requirements of SNT-TC-1A (see Nonconformance 86-01-03).
The Level III examiner uses his own equipment for UT. WFI did not have any records pertaining to the qualification of the UT equipment.
After being contacted by WFI, the Level III produced a " Statement of Instrument Performance Test" for instrument UFO-S (S/N 0002).
The inspector reviewed the document and noted that a statement was missing to certify that the UT equipment was tested to meet the requirements of ASTM E317.
- 3. Documentation Packages (DP)
The inspector reviewed the Nuclear Sales Log which is a record of nuclear customers and includes items ordered and shipping dates.
WFI had approximately 325 nuclear orders in 1984, 450 in 1985, and 250 through May 9, 1986. Their domestic nuclear business is approximately 20 percent of sales.
Approximately, 22 ops (17 in 1986 and 5 in 1985) for nuclear orders were reviewed. The orders were for Section III/ Class 2 or 3 flanges and fittings, and all the customer P0s imposed the requirements of 10 CFR Part 21. A DP consisted of a customer P0, specification, invoice, shipping record, certified material test reports (CMTR),
traveler, drawing, and final inspection report.
WFI was issued a Quality System Certificate (Materials) by ASME in December 1983 as a material manufacturer of ferrous and nonferrous seamless tubular products and wrought products. WFI upgrades stock material in accordance with subparagraph NCA-3867.4(e) of the ASME Code. WFI assigns a heat code number for each specific item on a nuclear order. Southwestern Laboratories performs the chemical analysis and mechanical testing for each heat code. With the excep-tion of eight nuclear orders (see Nonconformance 86-01-07),the information contained in WFI CMTRs agreed with the heat treat charts and laboratory reports.
ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION N0.- 99901055/86-01 RESULTS: PAGE 8 of 12 It was noted that the inspection report (Form TS-1) was not signed or dated for five items on nuclear orders N-2639 (heat code 270 BN),
N-2412 (176 BN), N-2496 (272 BN), N-2551 (307 BN), and N-2476 (221 BN).
- 4. Control of Measuring and Test Equipment (M&TE)
A review of WFI's M&TE program was performed and found to meet the requirements of the quality control procedures, NQAM, and applicable NRC requirements, with the exception of three nonconformances.
Procedures to insure quality were available for the calibration of measuring equipment. Eleven measuring tools were selected for review and found to be properly labeled with calibration stickers as being calibrated per Procedure No.WFI-22.
During a review of inspection reports and calibration records, it was noted that a noncalibrated protractor / scale (S/N S2) was used to measure a dimension on a fitting supplied on P0 N-2473 (see Nonconformance 86-01-04).
In reviewing the calibration of test equipment, all equipment was found to meet the imposed requirements, except the temperature measuring device for the Charpy test specimen bath (see Nonconfor-mance 86-01-05). It was noted that the Charpy impact tester was calibrated every 12 months per ASTM E23 by Tech Cal Inc. from September 1982 through November 1985. The Tinius Olsen tensile tester is also calibrated on an annual basis by either Tech Cal Inc.
or Pacific Scientific. Calibration has been performed since June 20, 1980 and documented with certifications.
WFIs two heat treat furnaces are required to be surveyed to MIL-H-6875F at least every twelve months. A review of records since May 1984 indicates this has been done by Combustion Services Inc.
Calibration of temperature instrumentation for these furnaces has been performed at least every six months by Thermo-Temp Instruments Inc. Records from June 1984 pertaining to this equipment were reviewed. Documentation was not made available to the NRC inspector to verify that the thermocouples used in the heat treat furnaces were calibrated (see Nonconformance 86-01-06).
ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 9 of 12
> 5. Engineering Design Control A review of WFI's Engineering Department was conducted covering the areas of component design, code / standard requirements, design control procedures, and component testing. Each of these areas appeared to have been satisfactorily implemented by WFI engineering personnel, meeting requirements contained in NCA-3800, Appendix B to 10 CFR 50, or WFI's NQAM.
ASME/ ANSI requirements related to the design of WFI branch connection fittings consist of ASME Sections I, III - Division 1, and VIII -
Divisions 1 & 2; ANSI /ASME B31.1, B31.3, B31.4, and B31.8; and ANSI B16.5, B16.9, B16.11 and B16.25.
The requirements contained in the above documents have been met by a combination of physical testing and analytical calculations.
Using the concept of " replacement area," WFI engineers have used ASME/ ANSI equations and applied them to their unique integrally reinforced branch connection fitting design. To meet the above listed requirements, a series of ANSI B16.9 burst tests have been performed which prove thJ adequacy of WFI's design. These tests have been performed with an Authorized Nuclear Inspector's in-volvement. In addition, numerous Mark 1 fatigue tests have been performed establishing the Stress Intensification Factor equations for the various WFI branch connection fittings.
WFI has a standard line of ASME/ ANSI qualified fittings. However, if a specialty component is to be manufactured, WFI engineering personnel will utilize procedures which insure the adequacy of the modified fitting to the applicable Code requirements. In reviewing a case where these procedures were used, full compliance to Code requirements for the modified specialty fitting was established.
- 6. 10 CFR Part 21 The NRC inspector reviewed applicable sections of the NQAM, Proce-dure No. AD-4 " Reporting of Defects and Noncompliance in Compliance with 10 CFR 21," dated February 1,1986, and 39 P0s issued for cali-bration services and NCA-3800 material. Noted below are the thirteen P0s out of the 39 P0s reviewed that did not impose 10 CFR Part 21 requirements (see Violation 86-01-01).
ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION RESULTS: PAGE 10 of 12 NO.- 99901055/86-01 P0 N0 Vendor Item / Service N-1239/-1245 Gulf Coast Machine NCA-3800 Material NDE N-1183/-1180- DLH Qualitech N-1273/-1171 Grady M. Cook Calibration Services N-1177/-1163 Baker Electronics Calibration Services N-1249 Guyon Alloy NCA-3800 Material N-1169 Texas Micronet/ Gulf Coast Cal. Calibration Services N-1300 Technology Calibration Calibration Services N-1181 Combustion Services Calibration Services N-1174 Advanced Inspection Calibration Services Copies of 10 CFR Part 21, Section 206 of the Energy Reorgan;zation Act of 1974, and Procedure No. AD-4 were posted in conspicuous locations throughout the shop and office areas. It was noted that Procedure No. AD-4 only addressed the requirements for reporting of defects by WFI employees and not by external sources such as customers and licensees.
- 7. Nonconformance and Corrective Action The NRC inspector reviewed applicable sections of the NQAM, 39 NORs, a Nonconformance Log Book, and three Nuclear Travelers to verify that nonconformance and corrective action activities were being performed as required.
It was noted that three Nuclear Travelers (Nos. N-2602, N-2435 and N-2555) did not identify the NOR number for which a NOR was gene-rated. During the review of NDRs issued from September 20, 1985 to April 4,1986, NDR Nos, 0038 and 0039 were dispositioned and signed by a Material Review Board (MRB) consisting of the President, QA Manager, and Vice President of Technical Services. The NQAM calls for the MRB to consist of the QA Manager, Engineering Manager, Purchasing Manager and Production Manager. There was no documented evidence available that corrective action was initiated and completed for NDR Nos. 0001 through 0015 and that an annual summary of all NORs issued was being reviewed by management (see Nonconformance 86-01-08).
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ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION NO.- 99901055/86-01 RESULTS: PAGE 11 of 12
- 8. Internal Audits The NRC inspector reviewed 13 internal audit reports, auditor quali-fications, and one procedure (" Procedure for Performing Internal Audi ts," dated January 14,1986) to verify that internal audits were being performed as required.
Between January 1981, and January 1986, it was noted that only 13 internal audits were conducted. Twelve audits were conducted be-
-tween January 1981 and November 1983. The 12 audit reports were not reviewed by management. Three of the 12 audits (conducted on June 22, 1981, January 26, 1982, and April 19,1983) resulted in nonconformances, of which documented evidence was not available to verify that corrective action was taken. There was no documented evidence of auditing activities between December 1983 to December 1985. The last internal audit was conducted on January 27-29, 1986, by an independent company (Kleckner & Associates). This audit re-vealed 72 discrepancies at WFI. WFI's corrective action response, dated May 12, 1986, to these discrepancies was also reviewed. Both the independent audit and WFI's response were reviewed by management.
However, none of the audit reports covered WFI QC Procedures Nos.
AD-1 through AD-5 (see Nonconformance 86-01-09).
The NRC inspector also reviewed auditor qualification records, which indicated that R. M. Kleckner, and the Vice President and QA Manager of WFI were qualified in accordance with ANSI N45.2.23. It was also noted that auditor qualification records were not available for auditors who performed audits between January 1981 to November 1983.
- 9. Vendor Audits and Procurement The NRC inspector reviewed four AVLs (dated 4/86, 4/85, 8/84, and 11/83),15 vendor audit reports and 41 P0s to verify that procure-ment activities were being performed as required.
It was noted that the 12 P0s listed below were issued to vendors who were not on the AVL. In addition, there was no documented evidence that the vendors were ever audited or surveyed.
ORGANIZATION: WFI NUCLEAR PRODUCTS, INCORPORATED HOUSTON, TEXAS REPORT INSPECTION N0.- 99901055/86-01 RESULTS: PAGE 12 of 12 Date Vendor Item
_P0 N-1273 3/3/86 Grady M. Cook Calibration Services N-1171 3/6/84 Grady M. Cook Calibration Services N-1181 5/17/84 Combustion Services Calibration Services N-1177 4/16/84 Baker Electronics Calibration Services N-1163 1/16/84 Baker Electronics Calibration Services Hockner Inc. Calibratic, Services N-1298 4/7/86 N-1204 6/5/85 K.0. Forge Forging N-1209 7/2/85 K.0. Forge Forging N-1261 2/7/85 K.0. Forge Forging N-1295 4/3/86 K.0. Forge Forging N-1175 4/4/84 Guyon Alloy Stainless Steel N-1249 1/21/86 Guyon Alloy Stainless Steel It was also noted that Thermo-Temp Instruments was listed on the AVL dated April 1986, but they were last audited in January 1985. A QA department distribution list was not available to record AVLs that were issued to WFI personnel. (see Nonconformance 86-01-10)
In addition to the above, four P0s(Nos. N-1209 and N-1204 to K.0.
Forge and N-1168 and N-1160 to Laclede) called for vendor activities to be witnessed by WFI and QA department personnel. However, a re-view of nuclear travelers and nuclear products forms showed no evi-dence of WFI witnessing any activiities performed by these vendors.
(see Nonconformance 86-01-11)
- 10. PERSONS CONTACTED:
- G. W. Gross, QA Manager
- J. Cates, Vice President
- R. W. Ryan, President
- R. P. Borne, Vice President 5 L. Behrenn, Production Hanager G. Stech, Engineering Manager M. Pittman, QC Inspector G. Woods, Consultant B. Hunter, Purchasing Manager A. Schwinn, Accountant J. Zarychta, QC Inspector D. Hale. Level III Examiner
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