ML20210E937
| ML20210E937 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/1987 |
| From: | Baker E, Trottier E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20210E907 | List: |
| References | |
| REF-QA-99900015 NUDOCS 8702100402 | |
| Download: ML20210E937 (7) | |
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ORGANIZATION: CAPITOL PIPE & STEEL PRODUCTS, INC.
CONSH0H0CHEN, PENNSYLVANIA i
REPORT INSPECTION INSPECTION NO.: 99900015/86-01 DATE: 10/20-29/86 ON-SITE HOURS: 60 CORRESPONDENCE ADDRESS: Capitol Pipe and Steel Products, Inc.
ATTN: Mr. Clifford J. Demarest Chairman 1029 Conshohochen Road Conshohochen, Pennsylvania 19a28
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ORGANIZATIONAL CONTACT: Mark S. Mathias, Manager, Quality Assurance TELEPHONE NUMBER: (215) 828-8100 NUCLEAR INDUSTRY ACTIVITY: Capitol Pipe and Steel Products, Inc. (Capitol Pipe) supplies piping, flanges, and fittings to nuclear plants. Current activity is replacement and system modifications.
ASSIGNED INSPECTOR: (o fc4 /F E. H. Trottier, Reactive Inspection Section (RIS) Date OTHER INSPECTOR (S): Carl J. Czajkowski, Consultant APPROVED BY: [Mb / -b M E d T. Baker, Ac hief, RIS, Vendor Progran Branch Date INSPECTION BASES AND SCOPE:
A. BASES: Allegation IE-86-A-0026 (RII-86-A-0225), 10 CFR Part 50 Appendix B and 10 CFR Part 21.
B. SCOPE: This inspection was conducted in response to the allegation that Capitol Pipe should have filed a 10 CFR Part 21 notification to the USNRC when material received from one of their (continued on page 2)
PLANT SITE APPLICABILITY: Browns Ferry 1/2/3 (50-259/260/296); Sequoyah 1/2 (50-327/328); Watts Bar 1/2 (50-390/391); Bellefonte 1/2 (40-438/439); E. I.
Hatch 1/2 (50-321/366); and Vogtle 1/2 (50-424/425).
8702100402 870206 PDR GA999 EMVCASPS 99900015 PDR
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- ORGANIZATION: CAPfTOL PIPE & STEEL PRODUCTS, INC.
CONSH0H0CHEN, PENNSYLVANIA REPORT INSPECTION N0.: 99900015/86-01 RESULTS: PAGE 2 of 7 B. SCOPE: (continued) suppliers was found deficient in chemical and mechanical tests. In
) addition, this inspection reviewed the Capitol Pipe quality assurance program with particular emphasis on corrective and preventive measures taken in response to the findings of the previous NRC inspection con-ducted in February, 1983.
A. INSPECTION ISSUES:
In August, 1986 the NRC was notified that Capitol Pipe received fittings ,
that subsequently failed chemical and mechanical tests required by the nuclear utility for whom the material was intended. Further, the alle-gation stated the concern that other nuclear utilities could receive what were thought to be substandard fittings from the same source. The alleger stated the belief that a 10 CFR Part 21 notification should have been sent to the NRC in this matter.
In addition to the allegation summarized above, this inspection sought to review the adecuacy of Capitol Pipe's OA program and verify that corrective and preventive actions have been implemented in response to the findirgs of the previous NRC inspection (February, 1983).
B. INSPECTION FINDINGS:
- 1. Allegation IE-86-A-0026 (RII-86-A-0225). This inspection substan-tiated the allegation. Between March 19, 1985 and June 4, 1986, Capitol Pipe identified fittings produced from seven heats of metal that failed supplemental tests required by the purchaser (the supplemental tests were based on the requirements of ASTM A105).
These seven heats became the subject of six internal nonconformance reports originated by the Capitol Pipe warehouse in Charlotte, North Carolina. After the nonconformance reports were processed, the fittings were placed in the QA hold area of the warehouse. In late May 1986, an internal audit of the Charlotte warehouse found that l
these nonconformances remained cpen, with no apparent action being l
taken to resolve them. More significantly, the internal audit l
found that fittings from one of the nonconforming heats had been shipped to a nuclear customer.
In June 1986, the subtier supplier (Bonney Forge) was notified by Capitol Pipe that fittings from seven heats had failed the required supplemental tests. The notification letter also reouested the l
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ORGANIZATION: CAPIT0L PIPE & STEEL PRODUCTS, INC.
CONSH0H0CHEN, PENNSYLVANIA REFORT INSPECTION RESULTS: FAGE 3 of 7 NO.: 99900015/86-01 supplier " review and evaluate this situation." After a second letter to the supplier, Capitol Pipe received a response stating that the fittings had been tested to the chemical and mechanical standards of I A105 before shipping and not a single failure was noted. Further, the supplier sent copies of the test results and offered to make available additional material test specimens from the heats in question. It was in this letter that the issue of adequate test coupon size was raised. It was the supplier's contention that without sufficient size, test results may not accurately reflect chemical and mechanical properties. Past experience showed that some deviations were caused by overheating during machining, or by improper orientation of undersized samples.
With test coupons of the material available, it was agreed by both Capitol Pipe and their supplier to repeat all chemical and mechanical tests. It was further agreed that the laboratory performing the tests would be different from the original laboratories used by Capitol Pipe and their supplier. The retests were performed in August and September, 1986. All material met the chemical ar.d physical requirements of standard A105 and the associated noncon-formances were closed.
In summary, there were two major items associated with this allegation:
Reluctance by Capitol Pipe to issue a 10 CFR Part 21 for 18 nonths after receiving nonconforming raterial intended for sale to a nuclear utility and ronconforming material shipped to a nuclear utility from a Capitol Pipe QA hold status. While the fact that the material ultimately was found to meet all applicable standards ameliorities the substance of the allegation, significant deficiencies in imple-mentation of the Cepitol Pipe QA program allowed this situation to continue. It should also be noted that full cooperation by the present management of Capitol Pipe in bringing the details to the attention of the NRC, as well as their assistance during this inspection, made complete and satisfactory resolution of this ratter possible.
- 2. Violations There were no violations identified as a result of this inspection.
- 3. Nonconformances In resolving and dispositioning the open nonconfornarce reports that were the subject of Allegation IE-86-A-0026 (RIF-86-A-0225), Capitol Pipe deviated from their Quality System Manual in several instances.
The following nonconformances were identified by the inspector:
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' CAPIT0L PIPE & STEEL PRODUCTS, INC.
ORGANIIATION:
CONSH0H0CHEN, PENNSYLVANIA REPORT INSPECTION N0.: 99900015/86-01 RESULTS: PAGE 4 of 7
- a. Contrary to Section 10.4.2 of the Capitol Pipe QSM, three NCRs signed off as being satisfactorily resolved (dispositioned) did not satisfy retest requirements. In one instance, the material 3 failed a hardness test and should have been satisfactorily retested before dispositioning the NCR. In the other two cases, the governing specification on retesting was not followed.
(86-01-01)
- b. Contrary to Section 6.6.5(d) of the Capitol Pipe QSM, mechanical and chemical testing services performed by an outside laboratory were obtained without advising the laboratory that the reouire-ments of 10 CFR Part 21 applied to the testing. (86-01-02)
- c. Contrary to Section 7.3.2 of the Capitol Pipe QSM, test results that were accepted and used to disposition an NCR ,
did not meet the requirements of the governing material specification. (86-01-03)
- d. Contrary to Section a.8.1 of the Capitol Pipe QSM, chemical analyses required by a purchase order to document the content of material supplied were not performed. (86-01-04)
- e. Contrary to Section 12.a.5 of the Capitol Pipe QSM, findings identified by Capitol Pipe audits of their vendors remained uncorrected for as long as four years. (86-01-05)
C. UNRESOLVED ITEMS:
There were no unresolved items arising from this inspection.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. Inspection 83-01 (February 15-18, 1983)
- a. Violations A and B (Closed): Capitol Pipe had not posted a current copy of 10 CFR Part 21, Section 206 of the Energy Reorganization Act of 1974, Company procedures, or a descrip-tion of the procedures intended to implement the applicable requirements.
The inspector noted that 10 CFR Part 21 and Section 206 of the Energy Reorcanization Act were prominently posted in the general office area of Capitol Pipe. Further, Quality System Procedure (QSP) 20,10 CFR 21, was also poifted at the same location. QSP-20 establishes company requirements for posting
1 ORGANIZATION: CAPIT0L PIPE & STEEL PRODUCTS, INC.
CONSH0H0CHEN, PENNSYLVANIA REPORT INSPECTION NO.: 99900015/86-01 RESULTS: PAGE 5 of 7 the above-referenced documents and provides information on internal processing of potential 10 CFR Part 21 items. In addition, the names and titles of Capitol Pipe officials to be notified when deviations are identified is found in QSP-20.
- b. Nonconformance A (Closed): Capitol Pipe did not properly review vendor documentation to assure conformance to order requirements.
In substantiating this nonconformance, seven instances were cited to illustrate that Capitol Pipe was not performing a satisfactory review of dccuments required by purchase orders.
(Purchase orders typically require that Capitol Pipe pass on material requirements to their supplier, then review and verify that all customer requirements are met prior to shipping the material). The inspector verified the corrective and preventive actions taken to resolved these seven examples, as well as reviewing the steps taken by i Capitol Pipe to correct the obvious administrative weakness.
In general, preventive action taken by Capitol Pipe involves formal, documented training on the requirements of the QSM that, had they been observed, would have avoided this nonconformance. The inspector verified that Capitol Pipe has instituted a training history form (Training Session Record). In addition, the training files of three employees were reviewed. Training classes were documented on nearly a monthly basis since December 1983 with approximately 30 entries noted in each employees file. Specific corrective and preventive measures taken were also reviewed. These included: the " Procedure Submittal Logbook," which h?lps ensure Capitol vendors perform and reference the proper material examination procedure; Standard Note 8 on Capitol Pipe purchase orders that requires "A description of the heat treatment of the material;" end the "P.O. Review Transmittal" form that is now used by Capitol Pipe QA personnel to track and verify that all purchase order require-ments are satisfied and documented.
- c. Nonconformance B (Closed): The inspector verified that the Capitol Pipe vendor in question war in fact audited and approved by Capitol prior to issuance of the purchase order for Class 1 material. The vendor should have appeared on the Capitol Pipe list of Approved Vendors,1ut did not. This was an administrative error that Capitol Pipe intends to
a ORGANIZATION: CAPITOL PIPE & STEEL PRODUCTS, INC.
CONSH0H0CHEN, PENNSYLVANIA REPORT INSPECTION NO.: 99900015/86-01 RESULTS: PAGE 6 of 7 avoid in the future by requiring a documented cross check between the Approved Vendor List and the Capitol Pipe purchase order. This verification is documented as item 4 on the "P.O. Review Transmittal" (see item b. above).
- d. Nonconformance C (Closed): Capitol Pipe reviewed and approved an NDE procedure that did not comply with Section V of the ASME Boiler and Pressure Vessel Code, as required.
The inspector reviewed the Capitol Pipe " Procedure Submittal Logbook," that was instituted to prevent recurrence of this nonconformance. In addition to the name of the customer, the logbook data page has eight other entries to help ensure NDE procedures are reviewed and approved both by Capitol Pipe and their customers. Logbook entries include: Type of procedure, date procedure received, date of submittal to custonct, and the date the procedure was approved and returned to Capitol Pipe,
- e. Nonconformance D (Closed): Capitol Pipe placed a purchase order with an approved vendor at one location, but assembly, marking, inspection and shipment were performed by the same vendor at a location that was not on the Capitol Pipe Approved Vendor List.
The inspector interviewed several Capitol Pipe employees to verify that the stated corrective action was performed. Pre-ventive action consisted of requiring a documented verification of the vendor against the current Capitol Approved Vendor List as item 4 of the Purchase Order Review Transmittal. In addition, the inspector verified that training was conducted (and documented; on the proper review and approval of vendor related paperwork.
- f. Nonconformance E (Closed): Capitol Pipe did not perform a thorough review of their suppliers' quality system programs.
Capitol Pipe performed audits of the companies that were the subject of this finding. These audits included a trip to Japan for an audit of the sub-vender of one of the companies identified, and a seven page audit of the other company identified in the finding. In addition, the inspector verified that all customers who received questionable material from these suppliers were notified and offered replacement material or additional testing of the material. The, inspector verified
a ORGANIZATION: CAPIT0L PIPE & STEEL PRODUCTS, INC.
CONSH0F0CHEN, PENNSYLVANIA REPORT INSPECTION N0.: 99900015/86-01 RESULTS: PAGE 7 of 7 that followup registered letters were also sent to the companies not responding to the original letters. Where necessary, Capitol y
Pipe obtained required material test reports, heat treatment reports and additional examination evidence.
E. OTHER FINDINGS AND COMMENTS:
The inspector noted that management changes at Capitol Pipe, as well as misinterpretation and confusion reoarding additional testing required by the utility, and the applicability of the results of the additional testing, contributed to the delay in issuing a Part 21 notification that became the subject of this allegatien. The affected utilities were eventually notified and the NRC was advised as to all circumstances surrounding the apparently substandard material. Thus, the allegation that substandard material was supplied to a nuclear utility and a 10 CFR Part 21 notice was not made is substantiated. However, this is ameliorated by the fact that the material was, in fact, later proven satisfactory by all applicable mechanical and chemical tests.
It should also be noted that specification ASTM E-30 is required for refereeing results of discrepant chemical testing of the kind required by the nuclear utility that ordered the material. This specification was not initially available at the Capitol Pipe corporate headcuarters, but a copy was obtained for future use by Capitol Fire prior to the completion of this audit.
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