ML20237F210
| ML20237F210 | |
| Person / Time | |
|---|---|
| Issue date: | 12/23/1987 |
| From: | Baker E, Cilimberg R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20237F168 | List: |
| References | |
| REF-QA-99900866 NUDOCS 8712290443 | |
| Download: ML20237F210 (8) | |
Text
.. - _ _..
ORGANIZATION: HUB INCORPORATED TUCKER, GEORGIA 1
REPORT INSPECTION
.NSPECTION NO.: 99900866/87-01 DATE: 11/16-20/87
)N-SITE HOURS: 31 CORRESPONDENCE ADDRESS: HUB Incorporated ATTN: Mr. B. H. Camp Chairman of the Board 2146 Flintstone Drive Tucker, Georgia 30084 ORGANIZATIONAL CONTACT: Mr. E.- Thornton, Manager. Quality Assurance
(
TELEPHONE NUMBER:
(404)934-3101 NUCLEAR INDUSTRY ACTIVITY: Approximately 85 percent of the Energy and Process Division of HUB Incorporated sales of pipe, valves, fittings, structural steel and fasteners are made to the connercial nuclear industry.
ASSIGNED INSPECTOR:
/
( W#
h R. L. Cilimberg,'Pr/jjram Development and Reactive Date Inspection SectioM (PDRIS)
OTHER INSPECTOR (S): None A'PPROVED BY:
Odt
/ Date ker, Acting h[gPDRIS,VendorInspection INSPECTION BASE!i AND SCOPE:
A.-
BASES: 10 CFR 21 and 10 CFR 50, Appendix B.
B.
SCOPE: This inspection was made to follow-up an allegation pertaining to marking pipe with incorrect heat numbers and to review corrective action on previous inspection findings.
l PLANT SITE APPLICABILITY: Vogtle 1/2(50-424/425).
l 8712290443 871223' PDR GA999 EPfVHUB 99900866 PDR c
ORGANIZATION: HUB INCORPORATED i.
TUCKER, GEORGIA REPORT INSPECTION NO.: 99900866/87-01 RESULTS:
PAGE 2 of 8 aA.
VIOLATIONS:
None B.
NONCONFORMANCES:
Contrary to Criterion VIII of Appendix B to 10 CFR 50, heat number 60744 and heat number 62879 were marked on the same pipe which results in loss of traceability if the incorrect heat number, 62879, is used to locate records.
(87-01-01)
C.
UNRESOLVED ITEMS:
(0 pen) Unresolved An allegation was received by the NRC which alleged that the alleger saw a warehouseman write a false heat number on a pipe without a heat number.
The false or incorrect heat number was alleged to have been selected at random from a test report and written on the pipe with a Dalo. The NRC inspector partly substantiated the allegation in that an incorrect / false i
heat number, 62879, had been marked on a pipe as determined during the inspection. Although HUB took corrective action on the pipe containing the incorrect heat number the allegation will remain unresolved until HUB has responded to Nonconformance 87-01-01 and the possibility that incorrect heat numbers have been marked on other material in storage at HUB.
Specifically this item will not be closed until HUB has implemented appro-priate corrective action.
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
1.
(Closed) Violation (84-01-01)
Contrary to Section 21.21 of 10 CFR Part 21, HUB procedures did not include an evaluation process. The procedures only covered the particular customer purchase order on which the deficiency was found.
There were no provisions to review material in stock or perform a file search for other customers who might have received the same material.
A review of QCP 16 " Reporting of Defects and Noncompliance (10 CFR Part 21)," Revision 0, dated April 9,1986 determined that this HUB procedure contains an evaluation process which ircludes provisions to review material in stock and notification of customers who might have received defective material.
.~w w
--- -= -
=_
ORGANIZATION: HUB INCORPORATED TUCKER, GEORGIA F
REPORT INSPECTION NO.: 99900866/87-01 RESULTS:
PAGE 3 of 8 2.
(Closed) Violation (84-01-02)
Contrary to Section 21.31 of 10 CFR Part 21, material was furnished by HUB on some purchase orders for which the applicability of 10 CFR l
Part 21 was a specific requirement, without similarly specifying its applicability in the HUB procurement documents for these items.
In
/
addition, neither the Quality Systems Manual (QSM) nor any other procedures require that the Part 21 applicability statement be applied to purchase orders or that anyone review the purchase orders to assure that it is there.
The inspector determined that stamps are being used on nuclear purchase orders (P0) which contain the word " NUCLEAR" and "10 CFR 21 APPLIES."Section IV of the QSM, Revision 9, dated February 13, 1987, requires that P0s be stamped by the QA Manager.
3.
(Cicsed) Nonconformance (84-01-03)
Contrary to Criterion IV Appendix B to 10 CFR 50, NCA-1140(b),
NCA-3867.4.b, and paragraph 5.3.2 of the Quality Systems Manual (QSM),
i HUB is not imposing on their suppliers the requirements imposed on HUB by their customers.
This nonconformance is withdrawn based on discussion with ASME and the change to NCA-3867.6 clarifying the code requirements. HUB is imposing on their suppliers the requirements imposed on HUB by their customers. The date of the Manufacturer's program stated on the Certified Material Test Report (CMTR) together with the Supplier's audit of the Manufacturer's Program is the documentation that the program meets the requirements of NCA-3800 provided the Supplier has performed an adequate audit.
4.
(Closed) Nonconformance (84-01-04)
Contrary to Criterion VII of Appendix B to 10 CFR 50 and Baltimore Gas and Electric (BG&E) purchase specification SP-242, HUB is not assuring that all purchased material meets the procurement requirements.
g HUB assures that purchased material meets the procurement requirements through Section 4.0 of the QSM, Revision 9, that requires that the P0 be issued to an ASME or HUB qualified source. A HUB document certifies that the material supplied was produced under the applicable Quality System Program, date and revision, which was surveyed and qualified by HUB or includes the supplier's Quality System Certificate Number and expiration date.
.. +.
h-
ORGANIZATION: HUB INCORPORATED TUCKER, GEORGIA REPORT INSPECTION NO.: 99900866/87-01 RESULTS:
PAGE 4 of 8 5.
(Closed) Nonconformance (84-01-05)
Contrary to Criterion X of Appendix B to 10 CFR 50, inspectors were required to inspect work which they had performed.
Review of Section 5.0 of the QSM, Revision 9, determined that work I
is performed by operations warehouse personnel end inspected by QA inspection personnel.
6.
(Closed) Nonconformance (84-01-06)
Contrary to Criterion XV of Appendix B to 10 CFR 50, HUB did not have a procedure or criteria for accepting material that was initially dispositioned as nonconforming due to loss of traceability.
In addition, HUB did not have a procedure for handling nonconformance reports (NCRs) received from customers.
Review of Section 9 of the QSM, Revision 9 determined that measures are provided to obtain documentary evidence from the vendor to alleviate questions of material integrity such as loss of traceability.
A procedure for handling NCRs from customers was transmitted by memos to the HUB staff dated August 24, 1984 and January 15, 1987, with an enclosed form AR Revision 1, " CUSTOMER REQUEST FOR ACTION."
7.
(Closed) Nonconformance (84-01-07)
Contrary to Criterion XVI of Appendix B to 10 CFR 50, HUB procedures do not require corrective action for internal nonconformances, only for nonconformances found during audits of suppliers programs.
This n6hconformance was withdrawn in response to HUB's comments on two forms approved by ASME which are used internally. Internal Discrepancy Report Form #111 has a section titled " Corrective Action Taken" and the Nonconformance Report Form #104 has sections titled
" Recommended Disposition" and " Final Disposition," where corrective action is entered.
8.
(Closed)Noncon.
...ance (84-01-08)
Contrary to Criterion XVII of Appendix B to 10 CFR 50 and paragraph f
D. of Quality Control Procedure (QCP) #6, HUB was not maintaining records as required.
-____--____m.
. ~ _ _
.~
ORGANIZATION: HUB INCORPORATED TUCKER, GEORGIA REPORT INSPECTION NO.: 99900866/87-01 RESULTS:
PAGE 5 of 8 i
The NRC inspector determined by review of records that Hub's corrective action was appropriate for the four incidents of ftilure to maintain the required records.
9.
(Closed) Unresolved Items (84-01-01 Through 84-01-06)
(
A review of NCRs written by HUB on material supplied to them with various marEing/ traceability problems resulted in the following unresolved items.
In each of the NCRs listed below traceability had been lost by the time the material had reached HUB. HUB informed the supplier of the marking / traceability problem. In all cases, HUB accepted a letter from the suppliers authorizing HUB to re-mark the l
material as appropriate corrective action and re-marked the material.
No additional substantiating documentation or explanation of how traceability was re-Established was requested or received. HUB has agreed to request additional substantiating documentation from their suppliers. A listing and brief description of the NCRs follows:
URI 84-01-01 NCR #42 25% of 3995' of 2" x H Seamless A106 GrB pipe was received with two different heat numbers stenciled on each piece.
URI 84-01-02 NCR #56 3" SA-106 GR. B pipe, Heat Number on pipe 366195, Heat Number on CMTR 366340.
URI 84-01-03 NCRf62 16 SA 193 GR 87 studs received without any markings or tags.
URI 84-01-04 NCR #94 168' of 3/8" rod and 420' of 1" rod were not marked as a bundle or as individual pieces.
URI 84-01-05 NCR'#96 A quantity of nuts were received which were marked A4. The CMTR was for trace code Y13. The response from the supplier was a new CMTR for trace code A4Y13 and instructions to mark the nuts as such.
URI 84-01-06 NCR #98 One 4" standard 45' Elbow SA234WPB was received with heat code JJ72 while the CMTR was for heat code LL72.
Copies of substantiating documentation and explanations were submitted to the NRC inspector for each of the unresolved items. The inspector reviewed the submitted information and determined that appropriate corrective action had been implemented.
._m___._
- 3 -- -
ORGANIZATION: HUB INCORPORATED TUCKER, GEORGIA REPORT INSPECTION NO.: 99900866/87-01 RESULTS:
PAGE 6 of 8 E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Entrance and Exit Meetings The.NRC staff informed HUB management representatives of the scope of the inspection during the entrance meeting on November 16, 1987, I
and summarized the inspection findings and observations during the exit meeting on November 20, 1987.
2.
Allegation An allegation was received by the NRC which alleged that a ware-houseman had a pipe on a fork lift without a heat ensmber. The alleger stated that he saw the warehouseman pull a test report for a 14 to 16 inch diameter pipe and the test report contained four heat numbers.
The warehouseman was alleged to have selected a heat number at random and wrote the heat number on his hand. The alleger stated that he watched the warehouseman jot the number on the pipe with a ?alo.
This marking of an incorrect heat number on a pipe was alleged to have occurred between April and June of 1987. Between October 1986 and January 1987 the alleger saw the warehouseman write a heat number on a six to eight inch diameter A 106 pipe. This heat number was also written on the hand of the warehouseman. The alleger stated that other. warehousemen knew of similar allegations and that the Hub QA manager was told about one similar allegation which occurred in late 1986.
The alleger had contacted Georgia Power Corporation (GP) prior to reporting the allegation to the NRC and EP recommended that the alleger call the NRC about his concerns. GP discussed the allegation with HUB who employed a consultant to conduct an investigation of the allega' tion. This inspection consisted of a thorough review of the consultants interviews with 21 present and former employees of HUB, including the alleger, warehouseman in question, and the QA Manager.
HUB did not believe that the allegation occurred while GP assumed that the allegation did occur and requested that HUB provide GP with a list of recalls of nuclear materials from HUB by HUB's suppliers.
The recall list did not contain any pipe material so HUB and GP concluded that faulty marking would not have safety significance because HUB purchases all pipe material with the documentation required for nuclear application.
The NRC inspector reviewed HUB's documentation of the allegation including letters, sunnary reports, and transcripts of the interviews
ORGANIZATION: HUB INCORPORATED TUCKER, GEORGIA l
REPORT INSPECTION NO.: 99900866/87-01 RESULTS:
PAGE 7 of 8 of 21 people. This review developed a question as to why HUB manage-ment waited until August 1987 to act on the report to management from the QA Manager of the incident, which occurred in late 1986. The NRC inspector independently assessed whether the allegation was correct and conducted the inventory described in 3 below. The results of that inventory partly substantiated the allegation in that a pipe z
was incorrectly marked, but it is not known if the incorrect heat number was obtained from the QA files.
3.
Pipe Inventory The NRC inspector randomly selected an area of outdoor pipe storage which contained large diameter pipe. HUB inventories outdoor storage every six months and creates a log which provides material location by area number on a diagram and lists the material located in each area. The inspector used the log to determine that area 6 was the randomly selected physical location containing the material to be checked. While checking the identification on each pipe with the information on the log, a 17 foot three inch length of 14 inch diameter, schedule 80, A106C alloy pipe was observed to exhibit two heat numbers 60744 and 62879. Heat number 60744 was stencilled on the pipe while heat number 62879 which was marked with a Dalo is considered to be incorrect because 60744 was on the inventory log and was found later to match the information on the CMTR. A red reject tag was placed on the pipe by the Assistant QA Manager and the pipe was taken to the Nonconforming Material area in accordance with Section IX, " Nonconforming Material Control" of the HUB QAM, Revision 9, dated February 13, 1987.
(Seenonconformance 87-01-01) 4.
Document Review CMTRs,' P0s, and Inspection Reports were reviewed to determine what information was contained in the QA files relative to information marked on pipes which was obtained during the pipe inventory discussed in 3 above. Appropriate information was contained on documents covering 18 pieces of pipe. Heat number 62879, which was incorrectly marked on a 14 inch diameter schedule 80 pipe fabricated from A106C alloy, was found on a CMTR for an 8 inch diameter schedule 80 pipe 5
fabricated from A106B alloy. Heat number 60744 was found on a CMTR for 14 inch diameter, schedule 80 pipe fabricated from A106C alloy, which matches the information marked on the pipe with two heat numbers.
The inspector could not develope any rationale for the incorrect heat number 62879 being marked on the 14 inch diameter pipe.
_,.,,__,_,__,,,,__J
e m a.m...
.._..m...1
..._A
,.C-4 4
ORGANIZATION: HUB INCORPORATED TUCKER, GEORGIA REPORT INSPECTION NO.: 99900866/87-01 RESULTS:
PAGE 8 of 8 F.
PERSONS CONTACTED:
- C. Bell
- R. Berry
- R. Buffington I
B. Camp
- G. Chilson
- D. Cumings
- R. Dunster
- G. Finck
- Keith Kennedy
- Kathy Kennedy L. Page M. Smith
- G. Snyder
- E. Thornton
- K. Thornton
- Attended exit meeting.
(
i
)