ML20212P813
| ML20212P813 | |
| Person / Time | |
|---|---|
| Issue date: | 08/25/1986 |
| From: | Harper J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20212P693 | List: |
| References | |
| REF-PT21-86, REF-QA-99900362 NUDOCS 8609030296 | |
| Download: ML20212P813 (11) | |
Text
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ORGANIZATION: UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION INSPECTION NO.-
99900362/86-01 DATES: 6/2-6/86 ON-SITE HOURS: 36 CORRESPONDENCE ADDRESS: Unistrut Corporation ATTN: Mr. Timothy B. Conduit Senior Vice President 35005 Michigan Avenue West Wayne, Michigan 48184 ORGANIZATIONAL CONTACT: Bruce McClure, Material Superintendent TF1FPHnNF NilMRFR-(11 0 7?1 anan NUCLEAR INDUSTRY ACTIVITY: Manufacture of fasteners and channels.
ASSIGNED INSPECTOR:
QMu fd/fn J. C. Huper, Reat:tiveIInspection Section (RIS)
Date OTHER INSPECTOR (S):
8'!ts FC APPROVED BY:
IS, Vendor Program Branc.S Date E. W. Merschoff, Chie INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR Part 21 and 10 CFR Part 50 Appendix B.
B.
SCOPE:
The inspection was made as a result of 10 CFR Part 50.55 (e) reports from Byron and Braidwood of defective spot welds on P1004A Unistrut material used in the fabrication of cable tray and conduit
)
hangers.
In addition, the implementation of the Unistrut QA program j
was evaluated.
PLANT SITE APPLICABILITY:
Braidwood 50-456, 50-457; Byron 50-454, 50 455; Ydtts Bar 50-390, 50-391; Comanche Peak 50-445, 50-446.
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ORGANIZATION: UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION NO.-
99900362/86-01 RESULTS:
PAGE 2 of 9
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A.
VIOLATIONS:
1.
Contrary to Section 21.6 of 10 CFR Part 21, the Unistrut Corporation did not post the requirements of 10 CFR Part 21, Section 206 or a Part 21 procedure.
(86-01-01) 2.
Contrary to Section 21.21 of 10 CFR Part 21, the Unistrut Part 21 procedure, (" Processing of Reportable Events") does not adequately describe or identify time limits for notification of a known defect to the Commission.
(86-01-02) 3.
Contrary to Section 21.31 of 10 CFR Part 21, the Unistrut Corporation failed to impose 10 CFR Part 21 on purchase orders to vendors of calibration, material suppliers (mechanical properties and chemical certification) and suppliers of heat treating services.
(86-01-03)
B.
NONCONFORMANCES:
1.
Contrary to criterion V of Appendix B to 10 CFR Part 50 and paragraph 2.0 of the QA procedure 20-01-003 Revision 2, 48 f t of red ticketed rejected material # HTHR075A00 was not separated from usable material and placed in the MRB designated area.
(86-01-04) 2.
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section XIX paragraph 19.6 of the QA manual, external audits were not perform on at least eight vendors of calibration, heat treating and material suppliers in the years between 1984-1986.
(86-01-05) m l
3.
Co'ntrary to paragraph 19.3 various internal audits scheduled in 1986, 1985, and 1984 were not completed and/or done according to schedule.
Furthermore, implementation of corrective actions were not being completed in a timely fashion.
(86-01-06) 4.
Contrary to criterion V of Appendix B to 10 CFR Part 50,Section III of QA procedure 20-01-031, and Section 8 of ASNT SNT-TC-1A, there were no records of annual eye examinations for a Level II and a Level III NDE inspector. Two Level II NDE inspectors and one Level III MDE inspector had no record of having an annual review of certification, the former in 1985 and the latter never.
(86-01-07) 5.
Contrary to Criterion V of Appendix B to 10 CFR Part 50. and Section III of the 0A procedure 20-01-024 Revision 2, documentation did not exist to show that a new inspector was given his first four weeks
ORGANIZATION:
UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION NO.-
99900362/86-01 RESULTS:
PAGE 3 of 9
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written progress report. The personnel qualifications files for two inspectors were incomplete and nonexistent for one inspector.
(86-01-08) 6.
Contrary to Criterion V of Appendix B to 10 CFR Part 50, CA procedure 20-01-030, ASNT SNT-TC-1A Section 2, four lead auditors had no evi-dence of having their audit communication skills signed and dated on their record of lead auditor qualifications.
Four lead auditors had no record of audit training. Two lead auditors had no objective evidence of audit participation.
(86-01-09)
C.
UNRESOLVED ITEMS:
None.
D.
STATUS OF PREVIOUS INSPECTION FIDNINGS:
None.
E.
OTHER FINDINGS OR COMMENTS:
1.
Inspection Issues The VPB inspection of the Unistrut Corporation was made as a result of 10 CFR Part 50.55(e) reports from Commonwealth Edison's Braidwood Unit 2 (March 6,1986) and Byron Unit 2 (March 12,1986) which reported defective resistance welds for cable tray hanger ma.teri al.
The suspect material, P1004A, consised of two single P1000 channels spaced back-to-back and joined by two side plates with four rows of spot welds at three inches on center.
The defective resistance welded material was identified at Braidwood Unit 2, during the installation 'of cable trays in containment by the electrical contractor G. K. Newberg. The cable tray hangers were prefabricated by Systems Control Corporation (SCC) using the P1004A Unistrut material, t
Unistrut made a visit to the Braidwood site and confirmed that the P1004A material in question was their product.
Commonwealth Edison reviewed the control numbers of the discrepant material and concluded that the majority of the material was manufactured in late 1978 or
d ORGANIZATION: UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION NO.-
99900362/86-01 RESULTS:
PAGE 4 of 9 in early 1979.
It was concluded that 580 feet of rejected P1004A material was inadvertently shipped to SCC by Unistrut and used for cable tray hangers for the Byron /Braidwood project, and primarily used at Breidwood Unit 2.
During April 1978, the Pennsylvania Power and Light Company issued a 10 CFR Part 50.55(e) regarding inadequate spot welding of Unistrut material used in field fabricated supports for safety related electrical raceways, HVAC ducts and instrumentation panels.
As a result, the NRC. performed an audit on Unistrut in March 1979.
According to the NRC inspector that performed this audit, " Prior to the detection of failed spot welds at the job site, the Unistrut material had been purchased as standard off-the-shelf items, with no formal Quality Assurance /QC program involved. Testing was performed by QC on a random basis, however, this was very limited in scope....It was also determined that monitoring of weld machines and welding operators was virtually non-existent...The assessment of the failed spot welds brought about the creation of a formal Quality Control (QC) program, with definitive procedures for welding, testing, and calibration of welding equipment...."
The Unistrut Corporation provided the inspector with a draft of a report dealing with the circumstances surrounding the defective P1004A material supplied to the Byron and Braidwood project. Ba-sically the report identified late 1978 and/or early 1979 as being the time frame in which the material was originally welded. The material was rejected and scheduled for rework. Unistrut concluded th,at a partial rework (rewelding) of at least some of the material was initiated at that time, but before the rework was completed and a QC inspection performed, the material was inadvertently shipped to a customer. During a Commonwealth Edison walk down of the P1004A mateiral at Braidwood and Byron Units 1 & 2, discrepant resistant welds were noted. As a result of the Unistrut investi-i gation, it was concluded that control numbers with the prefix 7 were not of concern since the frequency rate of failed welds for these control numbers were extremely low and inherent for the l
l process.
Unistrut contends that the discrepant naterial was produced in the late 1978 and early 1979. At that time Unistrut P1004A was being produced on three different resistant welding machines, the single heat spot welder #356, the multihead spot welder #6901, and single i
head spot welder #6940. Machines #6901 and #6940 were new equipment
ORGANIZATION: UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION NO.-
99900362/86-01 RESULTS:
PAGE 5 of 9 acquired in 1978 and 1979. Unistrut believes that during the prove-out stage for these new machines, some rejected material may have been produced. Unistrut contends that a partial rework (re-welding) cf at least some of the material was initiated. However, before the rework was completed, 580 ft of discrepant material was in-advertently shipped to Commonwealth Edison.
The NRC inspector concludes that technical problems existed with resistance welding machines and techniques at Unistrut at.the time that the subject material was being welded. These problems were due to the new spot welding machines #6901 and #6940 being in the prove-out stage. Unistrut's QC recogni:ed the defective resistance welds in P1004A control numbers 8N-7791, 8N-7792, 8E-7806, 8E-7828, 8E-7829, and 8N-7830 and rejected the material.
During reworking (re welding) to upgrade the rejected material, a break down in the quality program occurred. This may have been attributed to the fact that the formal QA program had just been implemented (around mid 1978) prior to the welding of the subject material. Therefore, it is conceivable that during the rework the material may have been inadvertently shipped prior to the completion and final QC acceptance by personnel unknowledgeable about quality procedures. The material that was resistance welded during this time frame is probably suspect. However, Unistrut, identified only three shipments of P1004A material that were made to SCC during that time frame (1978-1981).
From these qua~ity records, Unistrut was able to show that only one lot of 580 feet of rejected material could not be accounted for.
It was reported by Unistrut that at th'e time in question, the red tag from the 580 feet of rejected material was located in the plant but the material was missing.
This appears to be an isolated instance.
2.
10 CFR Part 21 From examination of the document' packages it was determined that Part 21 was imposed on P0s to Unistrut by their Nuclear customers, Baldwin Associates, Bechtel, and Brown and Root. The requirements of Part 21 were not imposed on the contractors employed to fill these nuclear orders by Unistrut. The following vendors of calibra-tion services were issued P0s by Unistrut:
Detroit Testing Machine Co. (Tensile Machine Calibration), A. A. Jansson (Gage Block Calibra-Co. LTD (Gage Block Calibration)ge Block Calibration), Mitutoyo tion), Dearborn Gage Company (Ga These P0s did not specify Part 21
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ORGANIZATION: UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION N0.-
99900362/86-01 RESULTS:
PAGE 6 of 9 as a'pplicable to their calibration vendors. Likewise, P0s issued to material suppliers, Stateline Steel (P0-85781/6/84 - P0-09389, 9/17/84 with certification of mechanical and chemical properties) and Triad Metal (P0-P05523 5/15/81 - P0-P08588, 9/25/84) did not specify Part 21 as an applicable requirement and the Unistrut P0-0899 May 17, 1984 to General Fasteners for heat treated studs ASTM A193-83 B7 (Certification of mechanical and chemical properties were supplied),
did not specify Part 21 as an applicable procurement document (See Violation 86-01-03)
The Unistrut Part 21 procedure " Processing of Reportable Events" was reviewed.
It was determined that the procedure did not make provisions for a timely oral (two days) or written (5 days) response following the the receipt of information regarding a reportable item.
(See Violation 86-01-02).
3.
Nonconforming Material The NRC inspector evaluated Unistrut's control of defective material.
Defective materials were tagged with a hard red copy of a rejection ticket and put into areas designated as MRB designated areas.
The NRC inspector noted that 48 ft of material #HTHR075A00 had a hard red rejection ticket attached, however, it was not separated frcm the usable material.
(86-01-04) According to Unistrut there was not enough space in the MRB designated area to store the 48 f t of material, as a result it was not in the MRB designated area.
4.
Calibration of Measurine and Test Equipment The NRC inspector checked the up-to-date calibration of measuring and test equipment against the Unistrut procedure 20-01-026 Rev. 2 which described calibration frequencies. The Tensile Machine Model NST, Serial #1007 had current calibration traceable to NBS 737.04/231572.
Micrometer gage block Set Serial #743612 had current calibration traceable to NBS 738/230272-83,-the Hardness Tester Serial #6718 had a current certificate of calibration traceable to NBS. One micrometer, 715 and three Calipers (#16, #18, #19) from the floor area were checked for current calibration against the calibration index.
All of the instruments checked were found to have current up-to-date calibration.
ORGANIZATION: UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION NO.-
99900362/86-01 RESULTS:
PAGE 7 of 9 5.
Audits Internal Audits Internal audit records were examined for the years 1983-86. These audits were performed according to an authorized audit check list and in accordance with the Internal Audit procedure 20-01-027. However, there were problems found with Unistrut's ability to maintain their established audit schedule.
In May,1984 internal audits were scheduled for sections X, XI, and XII of the QA Manual. The scheduled May 1984 audit was not performed until July 1984. The internal audit scheduled for August 1984 of QA Manual sections XIII, XIV, and XV, was not performed until October of that year.
In March 1985, OA Manual sections II, VIII, and IX were to bc audited, however no audit was performed. QA Manual sections X, XI, and XII were to be audited in June 1985, however no audit was performed. QA Manua~1 sections XIII, XIV, and XV were to be audited in September 1985 and section XIX in December 1985, again no audits were performed.
The internal audit performed an January 7,1986 of the QA Manual, identified some deficient areas in Sections III, VIII and XVII. As of the time of the inspection, imp 15 mentation of corrective action had not been taken. Unistrut has committed to implementing corrective action of deficient areas of their audited program within 30 days of the internal audit report. Audits of QA Manual sections IV, V, VI, and VII were scheduled during the month of April 1986. However, as of the date of the inspection, the April 1986 audit had not been initiated.
(See 86-01-05 and 86-01-06)
External Audits External Audits were to be performed according to the Unistrut proce-dure 20-01-007 and performed on an annual basis (net to exceed a 12 month period by more than 30 days). Procedure 20-01-007 describes the responsibility of the Purchasing Department in 1ccating suppliers of materials, the QA Manaaer's responsibility in source inspections, and requirements for companies being placed and remaining on the Approved VendorList(AVL).
It was noted by the NRC inspector that Unistrut has a provision in procedure 20-01-007 that states, in part, "...In the event the material, equipment on services required are nuclear related and would amount to or exceed ten thousand ($10,000.00) annual volume of business, the manager of Quality Assurance, will arrange for and conduct a source inspection ard audit prior to the issuance of a 1
m-
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o ORGANIZATION: UNISTRUT CORP 0:'ATION WAYNE, MICHIGAN REPORT INSPECTION NO.-
99900362/86-01 RESULTS:
PAGE 8 of 9 purchase order...."
The philosophy of this provision is nat in accordance with the requirements of procurement outlined in ASME section III and/or 10 CFR 50 Appendix B.
The Quality Assurance of Nuclear Safety related products by source inspection is to be independent of cost considerations.
The AVL for 1979-86 was reviewed and found to contain vendors used by Unistiut to fill their nuclear safety related orders. However, several vendors were on the AVL without benefit of an audit by Unistrut. The following companies were not audited during 1985 and 1986:
A. A. Jansson, General Fasteners, Detroit Testing Machine Company, Rouge Steel Company, Traid Metals, Stateline Steel Company and United Testing Systems. The following companies were not audited during 1984:
A. A. Jansson, Rouge Steel Company, National Testing and Research Laboratory.
(See Nonconformance 86-01-05) 6.
Training / Qualification Training /Quaiification records were reviewed for nine quality inspec-tors (QC and NDE) and eleven welders. Two level II inspectors (in 1985) and one level III NDE (PT) inspector had no record of having an annual evaluation by a certifying authority. The level III inspec-tor had signed off as being the certifying authority for the lower level inspector. However, records indicate that the Level III inspector had never been subjected to an evaluation by a certifying au thori ty. There was no objective evidence of ar annual eye examina-tion for one level II and one level III NDE inspector as required by section 8 of ASNT SNT-TC-1A.
(See nonconformance 86-01-07). All ut'her NDE inspectors were recertified on a three year basis as a result of continuing satisfactory performance and continuing compliance with Part 8 and 9 of ASNT-TC-IA.
Unistrut requires new employees involved in Quality Assurance /0uality Control to be trained according to training procedure 20-01-024 Rev 2.
As part of this requirement each employee must spend the first four weeks of their employment in an on the job training program. The QA manager or the supervisor of QA is to review and document, on a weekly basis, the employee's progress during the first four weeks. Once the new employee's 90 day probationary and training period is completed satisfactorily, they will be removed from the probationary classifi-ca tion. A file of personnel qualifications will be maintained with specific information regarding proper certification of qualifications, levels of capabilities and records of past performance, history, and
ORGANIZATION: UNISTRUT CORPORATION WAYNE, MICHIGAN REPORT INSPECTION N0,-
99900362/86-01 RESULTS:
PAGE 9 of 9 evaluations every two years or as required. Upon review of the Unistrut training records, it was determined that a number of personnel qualification files were incomplete. For example, one inspector had no record of having a file of personnel qualifications.
Two inspectors had files of personnel qualifications however they were incompleted and not up-to-date. One inspector had no record of ever having a written progress report during the first four weeks of employnent by the QA manager or the supervisor of OC.
(Sec Noncon-formance 86-01-08)
Unistrut procedure 20-01-030, Lead Auditor Qualifications, states that the lead auditor shall have qualifications similar or consistent with N45.2.23. N45.2.23 has specific requirements for completion and docu-mentation of competence in the area of communication skills, training, and auditor participation. The NRC inspector reviewed the records of four lead auditors. Of these auditors four had no documented evidence of competence in communication skills.
Four lead auditors had no objec~tive evidence of ever taking an audit training course. Two lead auditors had no objective evidence of fulfilling their audit partici-pation requirement.
(See Nonconformance 86-01-09)
Eleven welder qualificatiens were reviewed for welders since 1978. Of the welder qualifications examined, all were qualified according to AWS D1.1, GMAW in the 3G position.
In addition, the welders were all trained and indoctrinated on the Unistrut Quality program.
F.
PERSONS CONTACTED:
Timothy Condit Manufactured Products Unistrut
- Bruce McClure Senior Vice President Unistrut Materials Superintendent Unistrut
- Atte:1ded Exit Meeting
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