ML20215K211
| ML20215K211 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1987 |
| From: | Harper J, Stone J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20215K187 | List: |
| References | |
| REF-QA-99900836 NUDOCS 8705110116 | |
| Download: ML20215K211 (8) | |
Text
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l ORGANIZATION: ROCKWELL ENGINEERING COMPANY, INCORPORATED !
> BLUE ISLAND, ILLIN0IS j REPORT INSPECTION INSPECTION l NO.: 99900836/87-01 DATES: 02/19/87 ON-SITF H0!!DR- A I CORRESPONDENCE ADDRESS: Rockwell Engineering Company, Incorporated ATTN: Mr. A. J. Rudis, Jr. '
President l l
13500 South Western Avenue Blue Island, Illinois 60406 ORGANIZATIONAL CONTACT: Mr. A. J. Rudis, Jr.
TELEPHONE NUMBER: 312-385-4600 NUCLEAR INDUSTRY ACTIVITY: Material Supplier - Structural Steel Components.
, l ASSIGNED INSPECTOR: f!
J. C.i Harper, Program Development and Reactive Date Inspection Section (PDRIS)
, OTHER INSPECTOR (S):
APPROVED BY: ., [, kJ h i J.[. Stone, Chief,PDRIS,VendorInspectionBranch Datd l INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR 50, Appendix B and 10 CFR Part 21.
B. SCOPE: The inspection was performed to follow up on a November 1986 Virginia Electric and Power Company (VEPCO) Part 21 report concerning laminations in steel columns by Rockwell Engineering (RE) produced to North Anna by for Inland Steel and a new service water supplied spray array system.
PLANT SITE APPLICABILITY: North Anna Power Station Unit Nos. I anci 2.
8705110116 870506 l 00 @
ORGANIZATION: ROCKWELL ENGINEERING COMPANY, INCORPORATED
, BLUE ISLAND ILLIN0IS REPORT INSPECTION Nn - QQQnn99F/A7 01 PFStHTS- PAGE 7 of 6
.A. VIOLATIONS:
- 1. -Contrary to Section 21.21 of 10 CFR Part 21, RE failed to adopt a Part 21 procedure for evaluating and reporting deviations.
(87-01-01)
- 2. Contrary to Section 21.31 of 10 CFR Part 21, RE failed to pass down the requirements of Part 21 to sub-tier vendors involved in fulfilling the VEPC0 P0-ET 16183 for the new service water spray array system supports. (87-01-02)
- 3. Contrary to Section 21.6 of 10 CFR Part 21, RE failed to post copies of Section 206 and a procedure for evaluating and reporting deviations pursuant to Part 21. (87-01-03)
B. NONCONFORMANCES: ,
- 1. Contrary to Criterion IV of Appendix B to 10 CFR Part 50 and the RE 0A Manual, Revision 9, RE did not pass down the requirements of 10 CFR 50, Appendix B to sub-tier vendors involved in fulfilling the VEPCO P0-ET 16183 for the new service water spray array system supports. (87-01-04)
- 2. Contrary to Criterion IX of Appendix B to 10 CFR Part 50 and the RE procedure " Qualification, Training and Testing of Cuality Assurance Inspector," RECO 1900-1, Revision 3, and the recommended practices of SNT-TC-1A, two 0A Inspectors with NDE responsibilities were certified without record of a vision examination. There was no l objective evidence that a recertification examination was taken by one of the two QA Inspectors. (87-01-05)
- 3. Contra'y r to Criterion XV of Appendix B to 10 CFR Part 50 and to the RE OA Manual, Revision 9, at the time of the inspection RE had no procedures to address segregation of nonconforming materials.
(87-01-06)
D. OTHER FINDINGS OR COMMENTS:
n Backaround On November 7,1986, VEPCO notified the NRC that RE had supplied defective ASTM A36-84A wide flange structural members for the new service water spray array system supports. On September 15, 1986, a routine-post weld
ORGANIZATION: ROCKWELL ENGINEERING COMPANY, fHCORPORATED l BLUE ISLAND, ILLIN0IS REPORT INSPECTION Nn
- QQQnnF1R/R7-01 RESULTS: PAGE 3 of 6 QC inspection initially revealed laminations in the web section of a i steel column. RE was the seller of the steel columns to VEPC0 and Inland Steel was the supplier of the steel flange shapes to RE. On October 23, 1986, pre-installation ultrasonic testing (UT) of the steel from suspect ,
heat #17802 revealed several additional defective columns. RE was i notified and an Inland Steel UT-NDE Level II technician visited North l Anna on October 28, 1986 and identified the defect as " pipe type indications." J After review of production records for the defective steel, Inland isolated the pipe condition to heat #17802, ingots #11 and #12. Inland's position was that the excessive pipe in ingots #11 and #12 was probably an indirect result of an abnormality occurring during the pcuring of the ,
ingot. This abnormality was a full' running stopper which essentially affects control over ingot pour height. ;
Conclusions (
An inspection of Inland by the NRC inspector confinned that Inland has l an adequate quality program and procedures in place for ingot processing including pouring heats, rolling ingots, ingot pit soaking, and cropping operations. Inland successfully isolated the pipe condition to heat 17802, ingots ill and #12 by narrowing down the ingot production size, l times, and weight. According to the Inland #17802 Heat Review, there
, was no recognizable cause for pipe on the ingots (i.e., dished top contour, ingot eruptions, boiling, metal loss). It is conceivable ,
that pour height control or top end turbulence may increase the l probability of excessive pipe, however, in this case, the critical !
interface for ingot quality is the cropping operation. Therefore, the origin of the pipe defect is academic since it should have been i eliininated during the cropping operation. The Inland Steel Application l Memo instructed the shearman to " cut out pipe" without mandating a l reduced yield (for the circumstance a normal request). Once the ingot was rolled and sent to the shears for cropping, the shearman was not required to be conservative in shearing the ingot (since he was not required to clear the fish tail of the ingot). In light of these ,
factors, it is probable that the shearman missed some pipe or secondary 1 pipe in the ingot. It is also possible that missed pipe may have been interpreted as segregation. In many cases pipe is not visible on the surface but can only be detected by ultrasonics or radiography.
As part of their correct:ve action, Inland has committed to inquire about end uses on all orders specifying 10 CFR Part 21 (in cases where 10 CFR 50, Appendix B is not specified as in this case), and to supply all l
ORGANIZATION: ROCKWELL ENGINEERING COMPANY, INCORPORATED
, BLUE ISLAND, ILLIN0IS REPORT INSPECTION NO - ononn91F/A7 01 RFSUITS- PAGE 4 of 6 orders specifying NCA 3800, N45.2-77, 10 CFR 50 or 10 CFR 21 as bloom-cast (as a primary steel specification) and ingot-cast bottom-cut-only (as an alternate steel specification). UT inspection will be mandatory only if ordered by the customer or in the specification. In this case, UT inspection may have been the only method of discovering the pipe in the finished product. Bloom-cast and ingot-cast bottom-cut-only will reduce the probability of pipe or secondary pipe from being missed during ingot shearing to almost nil since these production methods are inherently less prone to the pipe defect.
It was determined from the inspection that RE did not specify the requirements of 10 CFR 50, Appendix B on the original purchase order (P0 29191) or the replacement order (RY-88962) but they did impose the requirements of 10 CFR Part 21 on Inland. As a result of not imposing
~
Appendix B on Inland, RE was not effective in communicating the quality requirements of the order. Therefore, Inland could justify filling the RE order in their normal and routine (quality requirements) manner, which at the time was different from their equivalent Appendix B ouality program (from a procedural standpoint). Nevertheless, since Part 21 was imposed on the order, Inland should have been alerted to the possibility that the structurals were to be put into nuclear safety related service. '
10 CFR Part 21 Issues
, \
As part of a plant tour of RE, the NRC inspector, verified that the Part 21 notice was adequately posted, however, neither Section 206 I nor a procedure for Part 21 was posted. (See Violations 87-01-03.) I Upon review of the RE Quality System documentation, it was apparent that a procedure for evaluating and reporting devaitions did not exist. Therefore, at the time of the inspection there was no I formalized method of evaluating potentially reportable Part 21 items or reporting Part 21 items. (See Violation 87-01-01.)
l RE fabricated the W10 x 49 members by using processes such as cutting, I boring, welding and galvanizing before shipping to VEPCO. VEPC0 .
imposed the requirements of 10 CFR Part 21 and 10 CFR 50, Appendix B as part of the original P0 ET-16183 on RE. RE subcontracted the galvanizing to the Empire Galvanizing (P0 29230). RE did not impose Part21orAppendixBonEnpire(seeViolation 87-01-02 and Noncoformance 87-01-04). Empire was on the RE approved vendors list when the members were galvanized. Welding rods, Lot #14832, type E711-1, were used for welding on the job. The rods were purchased from Weld Star (P0 29682),
l l
\
ORGANIZATION: ROCKWELL ENGINEERi.iG COMPANY INCORPORATED BLUE ISLAND, ILLINDIS l REPORT INSPECTION No . 40000916/R7.01 RESULTSt PAGE 5 of 6 Job No. 8624-STK. RE did not impose Part 21 or Appendix B on Weld Star (see Violation 87-01-02 and Nonconformance 87-01-04). Weld Star was on the list of RE approved vendors at the time that the rods were purchased.
In addition, RE purchased beams and columns from the Central Steel and Wire Company via Northwestern Steel and Wire Company (P0 NSW-36583, dated November 5, 1985) to be applied to the VEPC0 order. Northwestern Steel and Wire was on the RE approved vendors list when the order was placed. However, RE did not impose the requirements of Part 21 or Appendix B on its P0 to Northwestern Steel and Wire Company. (See Violation 87-01-02 and Nonconformance 87-01-04.)
Qualification and Training Review of the RE is procedure " Qualification, Training and Testing of
~
Quality Assurance Inspector," RECO 1900-1, Revision 3 revealed that it
- was adequate. The qualifications of two QA inspectors, two welders (#32 and #24) and one QA auditor / certified welding inspector were reviewed.
Both of the QA inspectors were missing annual eye exams for at least one year and one of the QA inspector's certification had expired since there was no objective evidence of a recertification examination on file. (See Nonconformance 87-01-05.) The QA auditor / certified welding inspector's qualifications were well documented and correctly presented.
Welders #24 and #32 welded the structural members for the VEPCO order.
'. They both were correctly qualified according to AWS DI.1 (flat and horizontal positions) and to procedure 500-3, Revision 0, " Welding Procedure Specification for Flux Cored ARC Welding of low Alloy and Carbon Steel Plates, Shapes and Forms." VEPC0 approved the procedure on September 24, 1986.
Plant Tour The NRC inspector inspected the shear work station, the saw work station, the burner area, the receiving inspection area, and the weld storage room. Up-to-date procedures were available at the shear and saw work stations as well as the burner area and receiving inspection area. The weld storage room was clean and all electrodes used for nuclear service had certifications and were properly stored.
Weekly calibration of the RECO 2/2A 25 ft. tape measures were verified by the calibration status sheet.
ORGAN 12ATION: ROCKWELL ENGINEERTNG COMPANY, INCORPORATED BLUE ISLAND, ILLIN0IS REPORT INSPECTION Nn - coonnP1A/A7_n1 REStMTS- PAGE 6 of 6
.E. PERSONS CONTACTED:
A. J. Rudis, Jr., President, Rockwell J. Merich, Plant Superintendent, Rockwell R. A. Ruter, QA Manager, Rockwell 1
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. May 6, 1987 Rockwell Engineering Company,
, Incorporated '
You are also requested to submit a similar written statement for each item which appears in the enclosed Notice of Nonconformance.
! The responses requested by this letter are not subject to the clearance
- ' procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
i j In accordance with 10 CFR 2.790 of the Connission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
l Sincerely, Urf6nalSigned by Blis W. yerschoff i
Ellis W. Merschoff, Acting Chief 1 Vendor Inspection Branch
! Division of Reactor Inspection and Safeguards
- Office of Nuclear Reactor Regulation .
]
Enclosures:
1 1. Appendix A-Notice of Violation j 2. Appendix B-Notice of honconformance 1 3. Appendix C-Inspection Report No. 99900836/87-01 l 4. Appendix D-Inspection Data Sheets (2 pages) ,
1 i
) DISTRIBUTION:
tRIDS Code;;IE:09;
,! VIB Reading i DRIS Reading RStarostecki
! JPartlow l BGrimes
. EMerschoff l JStone g4 JHarper (2)
! LParker (2)
Inland Steel Company I \ !
i 2 0FC :VIB:DRIS :SC/VIB:DRIS :AB IB DRIS: : : :
- JHarper:tt .:....._h,...........__:............:._______.................____....
.....:....__..._h_
NAME :JStone : chaff : : : :
, .....:..............:____ ..__... ,_...j. ....._:.......____......__................___......___
i DATE://m/87 :4 /W87 -
- f/ 5 /87 : : : :
I 1
May 6, 1987
, Rockwell Engineering Company,
- Incorporated -2 You are also requested to submit a similar written statement for each item which appears in the enclosed Notice of Nonconformance.
The responses requested by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, NginalSigned by DIis W Merschoff Ellis.W. Merschoff, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation
Enclosures:
- 1. Appendix A-Notice of Violation
- 2. Appendix B-Notice of honconformance
- 3. Appendix C-Inspection Report No. 99900836/87 01
- 4. Appendix D-Inspection Data Sheets (2 pages)
DISTRIBUTION:
RIDS Code IE:09 VIB Reading DRIS Reading RStarostecki JPartlow BGrimes EMerschoff JStone JHarper(2)
LParker(2)
Inland Steel Company OFC :VIB:DRIS :5C/VIB:DRIS :ABf/VIB DRIS: : : :
.:...... ... y. . . .....:..__ ....___:............:............:......__
.....:.__.......k.
MiE :JHarper:t :JStone /: choff : : : :
...._:..............:..........._{,__..j......:............:........____:............:......__
RATE://2/87 :4 /M/87 : f/ 5 /87 : : : :