ML20210G078
| ML20210G078 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/1987 |
| From: | Baker E, Conway J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20210F984 | List: |
| References | |
| REF-QA-99901070 99901070-86-01, 99901070-86-1, NUDOCS 8702110218 | |
| Download: ML20210G078 (14) | |
Text
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ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION
- RUSSELLVILLE, ARKANSAS 1 INSPECTION INSPECTION REPORT ON-SITE HOURS: 30 DATE: 11/17-21/86 NO.: 99901070/86-01 CORRESPONDENCE ADDRESS: Ladish Company Industrial Products Division ATTN: Mr. Richard B. Steele Vice President and General Manager 5481 S. Packard Avenue Cudahy, Wisconsin 53110 Mr. William A. McRoberts, Manager Quality Assurance ORGANIZATIONAL CONTACT:
TELEPHONE NUMBER: (501) 964-6227 NUCLEAR INDUSTRY ACTIVITY: Manufacturer of fittings and flanges.
/~d-8/
ASSIGNED INSPECTOR: ((M.Ld-A
\ active Inspection Section (RIS)
Date J ',es T. Conway, OTHER INSPECTOR (S):
T. Tinkle, Consultant
- / "
APPROVED BY: e W N ate Edward T. Baker, Acting Chief, RIS, Vendor Program Branch INSPECTION BASES AND SCOPE:
BASES:
10 CFR Part 50, Appendix B and 10 CFR Part 21.
A.
B. SCOPE: The purpose of this inspection was to conduct a programmatic evaluation of the implementation of the QA prcgram in the areas of training, control of special processes, reporting of defects, control of purchased material, nondestructive examination, control of measuring 4
and test equipment, and audits.
PLANT SITE APPLICABILITY: Not identified. -
8702110210 870202 PDR GA999 EMVLADC PDR 99901070
- r
ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION RUSSELLVILLE. ARKANSAS REPORT INSPECTION N0.: 99901070/86-01 RESULTS: PAGE 2 of 10 A. VIOLATIONS:
Contrary to Section 21.34 of 10 CFR Part 21, a review of documentation packages for Section III nuclear fittings and flanges revealed that while 10 CFR Part 21 was imposed on Ladish Company (LC) by their custcmers, LC did not specify that 10 CFR Part 21 requirements would apply on Purchase Orders (P0) 23613 to Charles C. Kawin; 23467 to Magnaflux; 21613 to Mid-South Calibration; 20240 to Edmunds Manufacturing; 29297 to Starrett; AT-9443, -5875, -8644, and -9381 to United States Steel; and AT-9124
-8987, and -8557 to Armco Tubing. (86-01-01)
B. NONCONFORMANCES:
- 1. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Subsec-tion NCA-3867.4(e) of Section III of the ASME Code, it was noted on 20 orders for Section III fittings, that LC stated on applicable certified material test reports (CMTR) the " Fittings are Nuclear Class X per ASME Section III (year and addenda of the Ccde)," but there was no documented evidence that a chemical analysis and mechanical testing were perfonned on the stock material (pipe purchased to ASTM A106 requirements only) to meet the requirements of the material specification (e.g., SA 105 and SA 234) and the upgradingrequiremer.tsofNCA-3867.4(e). (86-01-02)
- 2. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Subsection NCA-4134.6 of Section III of the ASME Code, and Section 2.3 of Procedure 2AR001, it was noted that: (86-01-C3)
- a. Revision 2 dated May 8, 1985 to Procedure 4AR001 " Acceptance Test Sampling for Starting Raw Material" was not at the bar stock storage area.
- b. Revision 3 dated August 21, 1986 to Procedure 7AR005 " Magnetic I
l Particle Inspection in Accordance with MIL-STD-271E and NTR-1E" I was rot at the magnetic particle inspection station.
- c. Obsolete revisiens to Procedures 6AR001-B, -C, and -F were at the heat treat station in the tubing facility.
l
- 3. Contrary to Criterion V of Appendix 8 to 10 CFR Part 50, Sections 1.3 and 7.1 of Procedure 7AR001, and Section 9.6.1 of SNT-TC-1A, a review of qualification records for nondestructive examination personnel revealed that the records for the Level II examiner did not contain completion of training in a statement indicating satisfactory accordance with Procedure 7AR001. (86-01-04)
ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION RUSSELLVILLE, ARVANSAS REPORT INSPECTION N0.: 99901070/86-01 RESULTS: PAGE 3 of 10
- 4. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Secticn 5 of ANSI N45.2, a QA Program was not invoked en PC 23613 (February 26, 1986) to Charles C. Kawin for mechanical and analytical testing of nuclear material; and P0s 23467 (January 15,1986) to Maanaflux Corporation; 21613 (December 14,1984) to Mid-South Calibration; 20240 (January 18,1984) to Edmunds Manufacturing; and 29297 (September 19,1984) to Starrett, all for calibration services.
(86-01-05)
- 5. Contrary to Criterion V of Appendix B to 10 CFR Part 50, Sections 4.3 and 4.4 of Procedure 3AR002 and Section 18 of ANSI N45.2, it was noted the Fittings Inspection Check List (FICL) for iter.s 1, 4, and 5 on LSO F18848 did not identify the inspector nor the S/N of the gages used for the dimensional inspections; and the FICL for item 1 on LSO R16749A did not record a number of dimensions nor identify the S/N of gages. (86-01-06)
- 6. Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 4.3 of Procedure 3AR002, the recorded dimensional readings on the FICL for item 29 on LSO R18237A indicate inspection readings are net being compared to the Product Design Print in all cases.
(86-01-07)
- 7. Contrary to Criterien V of Appendix B to 10 CFR Part 50, Section 5.1 of Procedure 12AR001 and Section 3.3.3 of Procedure 12AR001M, it was noted that serialized gage block sets being used in the calibration program were not listed in the Master Log of Tool Serial Numbers, and several steel scales under the control of the calibration program were found without calibration stickers.
(86-01-08)
C. UNRESOLVED ITEMS:
None.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
None.
's :
ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODijCTS DIVISION DI'WI I Vil I L ARVANSAS REPORT INSPECTION N0.: 99901070/86-01 RESULTS: PAGE 4 of 10 E. OTHER FINDINGS AND COMMENTS:
- 1. Control of Measuring and Test Equipment (M&TE)
The inspector reviewed Section 12 of the Quality System Manual (QSM) and various procedures relating to the calibration control of M&TE.
The heat treatment area and final inspection area were inspected to review the calibration status of measuring and test instruments and gages found in these areas.
Two unserialized 6" and 12" steel scales were found on the inspection tables in the inspection area. Further review revealed that these scales were personal tools. Ladish procedures neither encourage nor discourage personal M&TE in the plant. However, Section 2.2 of Procedure 12AR001 " Dimensional Tool and Gage Control" does indicate that only Ladish Company owned tools are included in the tool and gage control program and personal measuring tools shall not be used for the final acceptance of products. A number of serialized steel scales with no calibration stickers were found in the inspection area (see Nonconformance 86-01-08). The Master Log of Tool Serial Numbers and the Gage Record Cards were reviewed for these steel scales. The scales (S/N) included 18" (809-18), 18" (811-18), 24" (807-24),24"(813-24),36"(804-36),72"(192).
All the scales were controlled and in current calibration with the exception of the 72" scale (S/N 192) which was an uncontrolled company tool used by the machinists group. The missing calibration stickers on several scales were discussed with the Supervisor of Inspection and the Manager of QA. They stated that the calibration stickers come loose with continued use of the scales. As a result, they have instituted a practice of posting a list indicating cali-bration status of controlled steel scales. They further acknowledged that Procedure 12AR001M needed to be revised to reflect the new practice.
Records for selected gages calibrated by Ladish personnel (Inspectors 80136 and 80082) were reviewed. The gages (S/N) included step gage (301), OD micrometer (601), OD micrometer (602), step gage (306),
dial indicator (102), vernier (403). All the gages were in current calibration. Records for selected gages and instruments calibrated by outside activities were reviewed, and they included gage blocks (88-74P) by Starrett; gage blocks (P8-192C) by Edmunds; granite table (G-835-6) and metal table (179) by Mid-South; U/V meter (16191), and shunt meter (701) by Magnaflux. All the gages were in current calibration. Controlled gages (S/Ns88-74P and 88-192C) were not listed on the Master Log of Tool Serial Numbers.
l
i ORGANIZATION: LADISH COMPANY It'DUSTRIAL PRODUCTS DIVISION QilqRFi l Vil l F . ARl/ANSAS REPORT INSPECTION NO.: 99901070/86-01 RESULTS: PAGE 5 of 10
- 2. 10 CFR Part 21 Compliance The inspector reviewed Procedure 11AR004 " Reporting Requirements Concerning Defects Under Federal Regulation 10 CFR 21" dated November 15, 1985. The breakrooms in the forging shop and the tubing shop were inspected. A copy of 11AR004, 10 CFR 21, and Section 206 of the Energy Reorganization Act were found to be posted in both areas. The Manager of QA stated that potential or actual 10 CFR Part 21 items have not been reported to or by the Arkansas Plant of LC. Thus, other documentation on 10 CFR Part 21 activity was not available for review.
The inspector asked the Manager of QA whether the Arkansas Plant of LC had established requirements for invoking 10 CFR Part 21 on vendors supplying materials and services for nuclear fittings and flanges. He responded that LC buys commercial grade material to produce commercial grade items. These comercial products can be selectively qualified per Procedure 3AR002 to meet ASME Section III requirements when a customer places an order for a nuclear item.
LC considers the process of selective qualification also serves to dedicate the commercial item for nuclear service and, prior to this dedication, 10 CFR Part 21 does not apply.
A number of LC P0s for outside calibration services were reviewed.
The gages and instruments affected by these services are used in the selective qualification of commercial products for nuclear applica-tions. LC did not invoke 10 CFR Part 21 on any of these PCs (see Violation 86-01-01). The P0s included 23467 dated January 15, 1986 to Magnaflux Corporation; 21613 dated Decenber 14, 1984 to Mid-South Calibration Services; 20240 dated January 18, 1984 to Edmunds Manufacturing Company; and 29297 dated September 19, 1984 to Starrett, Weber Gage Division.
LC P0 8421, dated April 18, 1985, to Mills Alloy was reviewed and found to invoke 10 CFR Part 21. The Federal Reculation was not invoked in the original P0, but it was invoked by Revision 1 dated April 30, 1985. In this case, LC was buying material to produce ASME Section III Class 2, 22" standard caps for Capitol Steel on P0 37426-00N (LSO E14025A) dated March 22, 1985.
's :
1 ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION RUSSFItVILLE. ARKANSAS REPORT INSPECTION NO.: 99901070/86-01 RESULTS: PAGE 6 of 10
- 3. Indoctrination / Training of CA Personnel The inspector reviewed Procedure 1AR003 " Training, Qualification, and Requalification of Quality Control Personnel," dated September 11, 1985. The program established by this procedure relies mainly on satisfying training, qualification, and requalification requirements by using on-the-job training. Further, the only requirement for documenting these activities is that a list of skills and abilities are to be placed in the individual's training file as they are developed on the job. The training files for a number of individuals were selectively reviewed. These files contained documentation of on-the-job training. For some individuals, additional information was found in the file such as records of eye exams, letters certifying that the individual understandards a particular procedure or completed some special qualification or training. The training file review consisted of employees 80136, 80438, 80040, and 81121 from the QC-Inspection Department and 80007, 80468, and 80286 from the QC-Metallurgy Department.
The training files for the two individuals who handle order entry and processing for the Arkansas Plant were reviewed. In one case, the individual did not have a training record. In the other case, the training record did not contain any training documentation.
4 0A Audits The inspector reviewed Section 12 " Audits of the Programs" of the QSM and Procedure 4Q027 "Ladish Company Vendor Qualification Program" dated September 3, 1986. The inspection of audits and auditor quali-fications was cursory because the Manager of 0A stated that the official company records were not available. He stated these records are maintained in LC corporate offices in Cudahy, Wisconsin.
The NRC inspector reviewed Procedure 9P900 " Qualification &
Certification of NDE Personnel to Level III" dated February 14, 1986; Procedure 7AR001 " Qualification and Certification of Magnetic Particle Testing Personnel" dated February 21, 1984; and the quali-ficationandcertificationrecordsoftwoNDEpersonnel(one-Level III and one-Level II) to determine that individuals performing magneticparticle(MT)examinationswerequalifiedandcertified
ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION RUSSFIIVilI L ARKAN3AS REPORT INSPECTION N0.: 99901070/86-01 RESULTS: PAGE 7 of 10 to SNT-TC-1A. Procedure 9P900 is a coportate level document as the LC office in Cudahy, Wisconsin is responsible for certifying Level III personnel in the company. Procedure 7AR001 indicated that training and examination were to be in accordance with SNT-TC-1A.
Copies of tests and annual eye examinations were on file for each individual. With the exception of a statement showing satisfactory completion of training in accordance with Procedure 7AR001 for the level II examiner, the qualification records of the two NDE personnel appeared to be in accordance with SNT-TC-1A (see Nonconfermance 86-01-04).
- 6. Procument Document Control Seven P0s to two material manufacturers and five P0s to five vendors for testing and calibration services were reviewed to assure that applicable technical and QA program requirements were included or referenced in the P0s. None of the P0s invoked the requirenents of 10 CFR Part 21 upon the two steel manufacturers (United States Steel and Armco Tubular); the testing vendor (Charles C. Kawin),
or the calibration service vendors (Magnaflux Corporation, Mid-South Calibration Services, Edmunds Manufacturing Company, or Starrett-Weher Gage Division) (see Violation 86-01-01). The P0s to the steel manufacturers specified that pipe was to be supplied to ASTM A106 (i.e.,Section III requirements were not referenced) under a QA program that had been previously approved by LC. In addition, P0s 23467, 21613, 20240, 24297, and 23613 to the service vendors did not invoke requirements for the services to be provided in accord-ance with an approved QA program (see Nonconfornance 86-01-05).
- 7. Docunentation Packages (DP)
The inspector reviewed 20 DPs and 20 P0s from six customers for Section III, Class 1 and 2 fittings and flanges. The 20 P0s(17 in 1986 and 3 in 1985) from Hub (five), Capitol Pipe (four),
Guyon Alloy (four), PBI Industries (two), Joilet Valve (four), and Louis P. Canuso (one) referenced technical specifications, 10 CFR Part 21 and Section III of the ASME Code. The DP consisted of a Manufacturing Order and Plant Reuting (MOPR), Drawing, FICL, CMTR, Heat Records, and Invoices.
ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION RUSSELLVILLE, ARKANSAS REPORT INSPECTION NO.: 99901070/86-01 RESULTS: PAGE P of 10 The M0PR was similar to a " Traveler," and for Section III itens it was blue colored and stamped " Nuclear." The M0PR referenced Section III, Class 1 or 2 and 10 CFR Part 21 and noted that inspection per Procedure 3AR002 for nuclear ouelified be performed.
The visual inspection was a 100% to the dimensions on the drawing with 10% of the results being recorded on the FICL, The inspection was LC's only means of qualifying commercially produced tubular fittings for Section III applications (see Nonconforrance 86-01-02).
The CMTRs from the steel manufacturers (i.e., United States Steel and Armco Tubular) certified that the seamless pipe met the require-rents of ASTM A106 and was produced to a GA Program that had previously been approved by LC. The inspector was told that the CMTRs from the steel manufacturers were not sent to the customer.
The LC CMTR rertified that the finished fitting / flange ret the requirements of ASME SA 234 or SA 105. In addition, the LC CMTR stated that the fitting / flange net Section III requirements, that 10 CFR Part 21 applied, and the material was produced under LC's QA proaran which was audited and approved by the custerer as meeting the requirements of Subsection NCA 3800 of Section III of the ASME Code. It was noted that the chemical prorcrties on the LC CMTRs were identical to those for the starting material (i.e., a product analysis was not made beyond the ladle analysis supplied by the steel manufacturer). Even though the starting material underwent hot working and subseouent heat treating, the rechanical properties on LC CMTRs were identical to those en the steel menufacturer's CMTRs.
Several FICSs contained discrepancies. On the FICS dated September 8, 1986 for item 1 on LSO R16749A (Joilet Valve), it was noted that the perforrance of the final tool verification check was not documented, the space for the inspection retults for Dimensional Cc6 "C" was blank, and the S/Ns of the gages used for the dimensional inspections were not recorded. The S/Ns of the gages used fer the inspet: tion
-eadings for Dimensional Codes "R" and "0" were not documented on the FICS for item 2. FICSs for items 1, 4, and 5 on LSO F18848 (Huh) did not contain inspector's I.D. No.; the inspection procedure used; nor the S/Ns for the master step gage, dial indicator caliper, or the vernier that were used (see Nonconformance P6-01-06).
> a ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION plI99FIIVil1F. ARKANSAS REPORT INSPECTION N0.: 99901070/86-01 RESULTS: PAGE 9 of 10 The FICS dated June 6, 1986 for item 20 on LSO R18237A (Joilet Valve) indicated that the inspection was performed on June 6, 1986 per Procedure 3AR002, Revision 2. A review of the Quality System Procedure and Instruction Index indicates that on this date the current revision was No. 3 which was issued on May 20, 1986. For item 29 on the FICL dated June 10, 1986, it was noted that the print dimensions documented for Dimensional Codes "C" and "E" were both 2". The actual readings recorded for these Dimensional Codes were 4-29/32" and 4-15/16", respectively. An asterisk next to these readings referred to dimensional readings found on a manu-facturing process standard sheet (No. 132). This matter was discussed with the Supervisor of Inspection and the Manager of QA.
They indicated that these actual readings are compared to the standard sheet because the inspector cannot actually measure the dimensions called out in the Product Design Print. They further indicated they intend to revise the procedure to incorporate the use of the standard sheet. (See Nonconformance 86-01-07)
- 8. Document Control While evaluating the manufacturing facility, a number of procedures at various stations were selected to assure that current procedures were at work stations. The procedures and stations are as follows:
4AR001 and 4AR002 (bar stock storage area); 3AR005-D, -E, -F, and
-G (forging furnace); 6AR001, -A thru -J, 6AR002, and 10AR001 (heat treat - 2 locations); 7AR002-SP1, -SP2, and 7AR003 thru 005 (MT inspection); and 3AR002 and 9AR001, -002 (final inspection). After checking these procedures against the master file in the QA depart-ment, it was noted that: Revision 2 dated May 8,1985 to 4AR001 was not at t'ar stock storage; Revision 3 dated August 21, 1986 to 7AR005 was not at MT inspection; and obsolete revisions (i.e., I to 6AR0016, 1 and 2 to 6AR001C, 1 and 2 to 6AR001F) were at heat treat in the tubing facility. (See Nonconformance 86-01-03)
- 9. Plant Tour.
The inspector toured the LC manufacturing facility at various times during the inspection in the company of LC officials. Items witnessed in the forge shop included: bar stock receipt and inspection area, heat treat area, machining, cleaning, and final inspection. In the tubular ship, items witnessed included: pipe storage and inspection cutting operation, induction heating, drawing (e.g., elbows),
forging (e.g., tees, reducers, and caps), heat treating, cleaning, sizing, machining, MT inspection and final inspection.
ORGANIZATION: LADISH COMPANY INDUSTRIAL PRODUCTS DIVISION RUSSELLVILLE, ARKANSAS REPORT INSPECTION N0.: 99901070/86-01 RESULTS: PAGE 10 of 10 F. PERSONS CONTACTED:
- R. Schmidt, Plant Manager
- W. McRoberts, Manager QA
- D. Brown, QC Supervisor of Inspection
- D. Dietz, QC Supervisor of Metallurgy
- D. Bragdon, Manufacturing Panager
- attended exit meeting
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