ML20211B902
| ML20211B902 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/1987 |
| From: | Baker E, Conway J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20211B812 | List: |
| References | |
| REF-PT21-87, REF-QA-99900816 NUDOCS 8702190595 | |
| Download: ML20211B902 (9) | |
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ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY WILLIAMSTOWN, NEW JERSEY REPORT INSPECTION INSPECTION N0.: 99900816/87-01 DATES: 01/17-14/87 ON-SITE HOURS: 24 CORRESPONDENCE ADDRESS: Vest Jersey Manufacturing Company ATTN: Joseph Walker, Sr.
President Post Office Box W
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Williamstown, New Jersey 08094 ORGANIZATIONAL CONTACT: Joseph Walker, Sr.
TELEPHONE NUMBER:
(609) 629 4776 NUCLEAR INDUSTRY ACTIVITY: Manufactune o# ferrous and nonferrous pipe flanges.
ASSIGNED INSPECTOR:
htLi CRL%
'N'U UapesT.Conway, Pea ive Inspection Section (RIS)
Date OTHER INSPECTOR (S):
APPROVED BY:
M (.
(OD,,
Y'il 4
Ed !ard T. Baker, Acti g ief, RIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 50, Appendix 2 and 10 CFR Part 21.
B.
SCOPE: The purpose of this inspection was to conduct a programmatic evaluation of the implemertation of the CA progrrm in the areas of procurement document control, centrol of purchased material and services, and audits.
PLANT SITE APPLICABILITY: Salem 1/2 (50-272/311) and Hope Creek 1/2 (50-354/355).
$$2'aE9NEhj 99900816
ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY WILLIAMSTOWN, NEW JERSEY REPORT INSPECTION NO.: 99900816/87-01 RESULTS:
PAGE 2 of E A.
VIOLATIONS:
Contrary to Sectico 21.31 of 10 CFR Part 21. a review of documentation
)
packages for Section III nuclear flanges revealed that while 10 CFR Part 21 was imposed on West Jersey Manufacturing (WJM) by their customers, WJM did not specify that 10 CFR Part 21 requirements would apply on Purchase Orders (P0) 5366, a911, 5322, 4900, and 5359 to Ramball Test Laboratory; 5628 and 5326 to Donnvan Heat Treating; and 4968 to Pan Am Forge & Tube.
B.
NONCONFORMANCES:
1.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Sections 1.1 and 4.1.2 of the Nuclear Quality Assurance Progran Manual (NOAPM), and Subsection NCA-3865 3 of Section III of the ASME Code, a Quality System Program was ont invoked on P0s 5366, a911, 5322, 4900, and 5359 to Ramball Test Laboratory for analytical testing of nuclear material; 5628 and 5326 to Donovan Heat Treatino for heat treating of nuclear material; and 4968 to Pan Am Ferge for nuclear forgings.
(87-01-02) 2.
Contrary to Criterinn V of Appendix B to 10 CFR Part 50 and i
Sections 4.2.1 and 7.3 of the NQAPM, P0s were placed with Donovan Heat Treating in December 1986 (5628) and November 1985 (5326) and Dallas Force (DF) in December 1983 (4353), but neither company was on the Aporoved Vendor List (AVL) when the order was placed; and documented eviderce was missing to verify that DF had been audited.
(87-01-03) 3.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, Sections 4.4.5.1 and 17.6 of the NOAPM, and Subsection NCA-3867.4 of Section III of the ASME Code, it was noted on nine nuclear orders that data on WJM and DF and Pan Am Ferge & Tube CMTRs differed for:
(87-01-04)
(a) Mechanical propertier Material Customer (P0)
CMTR Date Feat Code i
WJM E
l McJunkin (02-55717) 10-30-85 01-31-84 CND l
l l
ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY WILLIAMSTOWN, NEW JEPSEY REPORT INSPECTION N0.:
99900816/87-01 RESULTS:
PAGE 3 of 8 Material Customer (P0)
CMTR Date
- Heat Code
}
WJM OF, Capitol Pipe & Steel (D-39751) 11-25-85 02-22-84 C0P (D-36670) 12-14-84 02-22-84 C0P Pullman Power Products (1074-67-160) & (1074-68-161) 02-21-86 02-22-84 C0P (b) Heat treatment data Material Customer (P0)
Ch!TR Date Heat Code WJM OF Metal Bellows (7203) 05-03-85 11-30-83 CMP Caruso (4125) 10-17-84 02-29-84 C0Z (1872) 05-13-86*
05-23-86 1800/
1887 Capitol Pipe & Steel (D-38855) 10-07-85 02-29-84 COX (0-39373) 10-18-85 02-29-84 4148
- Pan Am Forge & Tube C.
UNRESOLVED ITEMS:
None.
D.
STATils 0F PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Nonconforrance 83-01-01:
It could not be deronstrated that only vendors cr the AVL had been used for nuclear work prior to September 1982 since superseded AVLs are discarded and not maintained for a period of 3 years.
WM corrective action commitments made in a letter dated June 28, 1983 were reviewed.
Revised 0AI's 7.0 " Procurement Control" and 17.0 " Quality Assurance Records" dated March 1983 indicated that
ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY WILLIAMSTOWN, NEW JERSEY REPORT INSPECTION NO.: 99900816/87-01 RESULTS:
PAGE 4 of S superceded a revised AVLs must be maintained for three years in the QA records file. A record of training indicated that nine employees were instructed on retention of records on March 30, 1983.
)
A file containing AVLs for 1983, 1984, and 1985 was also reviewed.
2.
(Closed) Nonconformance 83-01-02: WJM furnished four Class 1, 10" 150# FF blind flanges to Chicago Tube & Iron Company with direct shipment to Northern States Power Company's Prarie Island Nuclear Plant, and they were not examined by the required ultrasonic or radiographic methods.
The inspector reviewed a letter from Chicago Tube and Iron to WJM dated March 17, 1983 which stated that Northern States Power had waived the ultrasenic or radiographic reouirements as the four flanges were intended for use in an ANSI B31.1 application.
3.
(Closed) Nonconformance 83-01-03:
Numerous instances were identified in which WJM accepted vendor's nondestructive examination (NDE) reports which did not identify the procedure used nor the revision even though WJM P0sspecifically stated that procedure numbers must be on the reports.
The inspector reviewed a letter from WJM to Magnaflux Quality Services dated June 10, 1983 which indicated that WJM will not accept any NDE reports without the proper information completed.
4 (Closed) Nonconformance 83-01-04: Heat treatment statements on WJM CMTRs differed from heat treat data on forging manufacturer's CMTds.
The inspector reviewed revised QAI 8.0 " Receiving Inspection and Paterial Control" which irdicated tFat the QA Administrater would assure that heat treat records on CMTRS are in accordance with the Code and P0 requirements. A record of training indicated that nine employees were instructed on the revised CAI P.O.
i l
5.
(Closed) Nonconformance 83-01-05: Wi1M could rot be aware of the necessity to perform a reouired review to determine if all applicable dimensional requirements had been met, in that requirements were not placed on their calibration vendor to identify equipment which was found to be out of calibratior, i
ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY WILLIAMST0WN, NEW JERSEY REPORT INSPECTION NO.: 99900816/87-01 RESULTS:
PAGE 5 of 8 The inspector reviewed revised QAI 12.0 " Control of Measuring Equipment" dated June 1983 which indicated that the QA Engineer has control of the calibration program. A WJM internal memo showed I
that a representative from WJM met with Gage Laboratory to revise the certificate of calibration to reflect out of calibration equipment. Copies of new calibration records were reviewed.
E.
OTHER FINDINGS AND COMMENTS:
1.
WJM WJM, currently located in Williamstown, New Jersey is a manufacturer of ferrens and nonferrous pipe flanges. WJM fills nuclear orders by purchasing rough forgings from approved material manufacturers and performing final machining on the item. The product is final inspected, packaged and shipped to the customer. Any heat treating or testing (e.g., analytical, mechanical, NDE) activities which may be required are contracted to service vendors. Weld repair is not permitted on any nuclear orders. WJM had a cuality System Certificate (Materials) No. 385 which was not renewed following its expiretion in November 1985. Dcmestic nuclear work in 1986 was approximately 10 percent of the total sales. The inspector was told by the President that the company is persently moving all machining equipment to a Cherry Hill, New Jersey location and will continue the same operations under the name cf Piping Supplies (PS).
PS is planning to apply for a QSC (Materials) within a year. According to the President, since June 1, 1986, nuclear orders to WJM have been filled by PS or suppliert (e.g., Capitol Pipe & Steel, Louis Canuso).
2.
Procurement Document Control Thirty-nine P0s to seven material manufacturers and seven P0s to two vendors for testing and heat treating were reviewed to assure that applicable technical and QA progran requirenents were included or referenced in the P0s. With the exception of two P0s to Colonial Machine and one P0 to Liberty Forge for SA-182 material, the 36 remaining material PCs were for carbon steel forgings (SA-105) to DF (22), Taylor Forge (two), Gulf Coast Machine & Supply (four),
Colonial Machine (three), Pan Am Forge & Tube (PAFT) (four), and PS(one). These P0s were placed from 1982 through 1986.
The seven P0s for services went to Ramball Test Laboratory (five) for analytical testing and Donovan Heat Treating (two) in 1985 and 1986.
All 39 P0s were stamped " NUCLEAR;" and had appropriate signoffs,
O ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY WILLIAMSTOWN, NEW JERSEY REPORT INSPECTION NO.: 99900816/87-01 RESULTS:
PAGE 6 of 8 a "No Weld Repair" statement, and technical requirements (e.g.,
Section III, Class 2 or 3 for the forgings). With the exception of eight P0s, the other 31 P0s contained statements invoking the 3
requirements for:
(a) 10 CFR Part 21; and (b) material / services to be provided in accordance with a OSC or a QA program approved by WJM.
P0s 5366 (01-17-P6), 4911 (02-12-86), 5322 (10-15-85), 4900 (02-28-86), end 5359 (01-03-86) to Ramball Test Laboratory; 5628 (12-03-86) and 5326 (11-04-85) to Donovan Heat Treating; and 4968 (05-08-86) to PAFT did not impose the requirements of 10 CFP Part 21 or a QA program upon the vendor.
(See Violation 87-01-01 and Nonconformance 87-01-02).
3.
Documentation Packages (DP)
The inspector reviewed 59 DPs and 59 P0s from 12 custerers for Section III, Class 2 ar.d 3 flanges. The 59 P0s(three in 1984, and 28 in both 1985 and 1986) from Heat & Power Corporation (one),
Power Piping (one), Liberty Equirrent & Supply (two), Guyon Alloys (two), McJunkin (two), Capitol Pipe & Steel (CPES) (17), Louis Canuso (15), Metal Bellows (eight), Joseph Oat Corporation (one),
AlG Engineering (three), Public Service Electric & Gas (five),
and Pullnan Power Products (two) referenced technical specifications (SA-105 or SA-182), 10 CFR Part 21, 10 CFR Part 50, and Section III of the ASPE Code. The DP consisted of a material supplier /
manufacturer CMTR, Receiving Inspection Report, Drawing, Travel Form, QA/In-process Inspection Sheet, Material Final Inspection Form, Shipping Inspection Report f. CA Document Checklist, WP CMTR, Packing List, and Inynice. The Drawing, Travel Form, and three inspection reports were stamped " NUCLEAR."
The CMTRs from the material suppliers / manufacturers certified that the forgings ret the requirements of Section III of the ASPE Code and were produced under a QA prenram which was approved by WJM. The inspector was told by the President that WJM transfers data (chemical, rechanical, heat treat, etc.) from a vendor's CMTR on to a WJM CMTR which is sent to the customer. CMTRs from material suppliers / manufacturers were not sent to the custoner.
It was noted on nine nuclear orders that certain data on WJM CMTRs were different from informatien contained on naterial manufacture's CMTPs.
In all cases but one (PAFT), the manufacturer was DF.
Cn a McJunkin P0 02-55717 (09-09-85) the rechanical property
ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY WILLIAMST0WN, NEW JERSEY REPORT INSPECTION N0.: 99900816/87-01 RESULTS:
PAGE 7 of 8 values (i.e., tensile and yield strengths and reduction in area) on WJM CMTR (10-30-85) were different from the values on DF CMTR (01-31-84) for A105 material with heat code "CND."
The tensile 3
and yeild strengths, reduction in area, and elengation values for
" COP" material on DF CMTR (02-22-84) did not agree with values on WJM CMTRs dated 12-14-84 and 11-25-85 for P0s D-36670 (12-12-84) and D-39751 (11-18-85), respectively from CP&S.
A similar situation existed for P0s 1074-67-160 (02-17-86) and 1074-68-161 (02-21-86) from Pullman Power Products. The DF certification was dated 02-22-84, and the WJM certification for the material identified as
" COP" was 02-21-86.
On P0 7203 (05-01-85) from Metal Bellows, the WJM certification (05-03-85) stated that material identified as " CMP" was " Normalized at 1600 F per inch cf thk."
Hoyever, there was no heat treatment statement on the DF certification (11-30-83) for " CMP" material, and there was no documented eviderce that WJM had the forgings heat treated. A DF CMTR (02-29-84) indicated that "C0Z" material was " normalized at 1700 F,"
but the WJM CMTR (10-17-84) stated that the meterial was " normalized at 1650 F."
These forgings were purchased by Louis Canuso on P0 4125 (10-24-86).
For CP&S P0 D-38855(10-03-85), WJM certified (10-07-85) that "C0X" material was " Normalized at 1600 F for one hour per inch of thickness being tested." The DF CMTR (02-29-84) did not contain a heat treatment statement, and there was no documented evidence that WJM had the forgings heat treated. A similar situation existed on CP&S P0 D-39373 wher WJM certified (10-18-85) that "4148" material was " Normalized for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 1650 F," but a heat treatment statement was not on the DF CMTR (02-29-84).
On Louis Canuso P0 1872 (04-10-86), the Pan Am Forge and Tube CMTR (05-13-86) only specified " ASTM A105 Forgincs" for two itens identified with "1800 and 1887" heat codes, but the WJM CMTR(05-23-86) contained a heat treatment statement and certified that the two items ret "ASME SA105 Section III, Class 2" and that "Part 21 and 10 CFR Part 50 applies." There was no documertation to support these statements.
(See Noncerformance 87-01-04).
It was also noted that CMTRs from vendors were missing for two orders from Louis Canoso (2010 dated 04-22-86 and 2234 dated 05-09-86) and one order (11785 dated 01-17-86) frem A&G Engineering.
o O
ORGANIZATION: WEST JERSEY MANUFACTURING COMPANY
^
WILLIAMST0WN, NEW JERSEY REPORT INSPECTION NO.:
99900816/87-01 RESULTS:
PAGE 8 of 8 4.
Audits The inspector reviewed applicable sections of the NQAPM, AVLs,
)
external audits, and auditor qualifications to assure that materials and services were obtained from approved vendors who had been audited by qualified WJM persennel. A review of AVLs from 1983 thru 1985 and nuclear orders placed during this time frame indicated that P0s 5326 and 5628 were placed with Donovan Heat Treating in November 1985 and December 1986, respectively; and P0 4353 was pieced with DF in December 1983, but neither company was on the AVL (See Nonconfornarce 87-01-03).
A review of external audits from 1983 through 1986 indicated that six individuals performed audits of vendors.
Eighteen audits were documented on a Quality Sugvey Report which contained a check-list addressing the 18 criteria of Appendix B to 10 CFR Part 50. The audits were conducted on eight material manufacturers (Forgital-Italy, Liberty Forge, Gulfalloy, Rotek, Colonial Machine, PAFT, Gulf Coast Machine, and PS), and five service vendors (Magnaflux, Bristol Steel Treating, Donovan Steel Treating, Ramball Test Laboratory, and Gage Laboratories).
It was noted that nuclear orders were placed with DF in December 1983 and January 1984, but documented evidence was not available to shew that DF was audited by WJM.
A review of training files for the six auditors revealed a certification memo signed by the President for five auditors.
The memo stated that the individual was qualified "to perform audit surveys on behalf of West Jersey Manufacturing Company in accordance with N45.2.12 (1977)... based on his experience in the industry, education, and training classes." However, documentation did not exist to reflect the education, experience, and training to assure that each individual was qualified to conduct audits.
The President conducted three audits, but his file did rot even contain a certification memo.
F.
PERSONS CONTACTED:
- Joseph Walker - President Joseph Walker, Jr. - 0A Manager Susan Cervino - QA Administrator.
- Attended exit meeting.
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