ML20238C857
| ML20238C857 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1987 |
| From: | Conway J, Stone J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20238C811 | List: |
| References | |
| REF-QA-99900886 NUDOCS 8709100415 | |
| Download: ML20238C857 (10) | |
Text
1 l ORGANIZATION: POSI-SEAL INTERNATIONAL NORTH STONINGTON, CONNECTICUT REPORT INSPECTION (NSPECTION l NO.: 99900886/87-01 DATE: 07/06-10/87 )N-SITE HOURS- M CORRESPONDENCE ADDRESS: Posi-Seal International, Inc. -
ATTN: Mr. Peter E. Arnold ,
I General Manager Route 49 and U.S. 95 North Stonington, Connecticut 06359 ORGANIZATIONAL CONTACT: Robert D. Barry, Manager of Quality TELEPHONE NUMBER: (203) 599-1140 NUCLEAR INDUSTRY ACTIVITY: Manufacture butterfly valves.
ASSIGNED INSPECTOR: 16\ . bW%
J.F . Conway, Program Development and Reactive
[ Zl-8'l Date
'T- 1 G nspection Section (PDRjlS)
OTHER INSPECTOR (S): C. Abbate. PDRIS APPROVED BY: w& ,
/hf> D/ 7 a
J. Stone / Chief,PDRIS,'VendorInspectionBranch
- j INSPECTION BASES AND SCOPE: )
J A. BASES: 10 CFR Part 50, Appendix B and 10 CFR Part 21. !
I B. SCOPE: This inspection was made as a result of an allegation pertaining to the removal of hold tags from nuclear valves by a production manager.
PLANT SITE APPLICABILITY: Palo Verde Units 1, 2, 3 (50-528, 529 and 530).
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l 8709100415 870909 PDR GA999 EPfVPOSIB 99900806 PDR; L _ _ _____ _
i ORGANIZATION: POSI-SEAL INTERNATION/.L NORTH STONINGTON, CONNECTICUT REPORT ' INSPECTION NO.- 99900RR6/87-01 RESULTS: PAGF 7 nf in A. VIOLATIONS: - - . -
Contrary to Section 21.31 of 10 CFR Part 21, a review of documentation packages (DP) and purchase orders (PO) for butterfly valves fabricated under Section III of the ASME Code, revealed that while 10 CFR Part 21 was imposed on Posi-Seal International (PSI), PSI did not specify that 10 CFR Part 21 requirements would apply on P0s H9657 (September 27, 1983),
J0446 (November 4, 1983), and J8593 (January 29, 1985) to ABC0 Welding and Industrial Supply Company; 12261 (April 1, 1987) to Adironadack Steel Castings; G7646 and 7647 (January 15, 1962), K0988 (June 18, 1965) and 11448 (February 19, 1987) to Congdon and Carpenter Company; 13035 (May 26, 1987) and 13076 (May 28, 1987) to Empire Steel Castings; K2060 (July 29, 1985) to Hy-Temp; 12215 (March 31, 1987) to Jessop Steel; G7459 (January 6 1982) to Lebanon Steci Foundry; 13097 (May 29, 1987) to HQS; 12605 (April 24, 1987) to Pre::ure Vessel-Nuclear Steels; 11449 (February 19, 1987) to Quaker Alloy; ard 12208 (March 30, 1987) to Texas Bolt.
l (87-01-01) l B. NONCONFORMANCES:
- 1. Contrary to Criterion IX of Appendix B to 10 CFR Part 50 and
. _ _ . Sections 12.30 and 12.40 of the Quality Assurance Program Manual (QAPM), it was noted that three NDE procedures - Nos. 13S-HAR-UT-29, 23.A.200-1986, and 23.A.031-1986 - used by Magnaflux/MQS Inspection in February 1984 and June 1987 were not reviewed by PSI.
(87-01-02)
- 2. Contrary to Criterion IX of Appendix B to 10 CFR Part 50, Section 12.40C of the QAPM, and Section 9.6.1 of SNT-TC-1A> it was noted that PSI did not have the qualification records ror four individuals from Magnaflux/MQS Inspection who bsa performed NDE in February 1984, February 1986, and June 1987. (87-01-03) -
- 3. Contrary to subsection NCA-4134.4 of Section III s. the ASME Code and Criterion IV of Appendix B to 10 CFR Part 50, a review of P0s I
revealed that quality requirements were not passed on to vendors l for the following P0s: 11656 and 11659 (March 2, 1907) to Airmotive Calibration Corporation; 3689 (April 24, 1979), 3735 (June 4, 1979) and 4857 (July 30, 1979) to Cambridge Plating; and 3692 (April 27, 1979) to Fountain Plating. (87-01-04)
- 4. Contrary to subsecticn NCA-4134.5 of Section III of the ASME Code and Criterion V of Appendix B to 10 CFR Part 50, written instructions or procedures did not exist for the use of " hold tags" on nuclear components. (87-01-05)
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ORGANIZATION: POSI-SEAL INTERNATIONAL NORTH STONINGTON, CONNECTICUT REPORT ' INSPECTION NO.- 99900AA6/87-01 RESULTS: PAGF 3 nf 10 C. UNRESOLVED ITEMS:
During the inspection, it was noted that 4-24" motor operated butterfly valves were returned to PSI from the Palo Verde nuclear site. The valves were returned in 1985 because of deterioration of the electroless nickel plating on the valve discs. A meeting was held on June 25, 1985 with Combustion Engineering (CE) personnel pertaining to this problem.
PSI was unable to furnish documentation of the meeting and the cause for the corrosive attack of the nickel plating. Accordingly, this item will remain unresolved until it is discussed with CE and Bechtel during a future NRC inspection of their facilities.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
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None. This was the first inspection at this facility.
E. OTHER FINDINGS AND COMMENTS:
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- 1. Allegation In April 1987, the Region I office of the NRC was notified of an allegation perteining to the removal of hold tags from nuclear ly- valves in order to get the valves shipped.
l The use of hold tags and other manufacturing controls were reviewed during the inspection. Section 9.30 of PSI's QAPM states that travelers are the official status indicators for nuclear components and all other tags, etc. are used for visual aid only. The traveler is the control mechanism for fabrica-tion in that the next operation on the traveler cannot be performed until the previous operation has been signed off by the QC inspector. All operations must be signed by QC. ,
Hold tags are used on nuclear components as a visuti aid to warn personnel that work is not to be performed on that component until the hold is released. Hold tags are placed on components which do not meet acceptance criteria. The tags have two parts. One part is put on the component as a visual aid while the other part is kept by QC until the problem is dispositioned. After dispositioning both parts of the tag are destroyed.
In addition to the travelers, QC sign-offs, and hold tags, PSI QA personnel perform a final review of the traveler and inspection reports before a computer hold on the component is released. This is done in order to assure that al) operations on the traveler have been performed. Until QA completes its
ORGANIZATION: POSI-SEAL INTERNATIONAL
- NORTH STONINGTON, CONNECTICUT REPORT ' INSPECTION NO.- 99900886/87-01 RESULTS: PAGE 4 nf 10 review and releases the computer hold, a bill of lading or shipping papers cannot be printed; and the valve cannot be shipped.
The inspectors were unable to determine if hold tags were removed from nuclear valves or components. However, due to the additional controls PSI has implemented, a valve could not be shipped unless all holds have been officially released by QA or QC. Subsequently, the allegation could not be substantiated.
The NRC inspector reviewed Section 12 of the QAPM, six NDE procedures, and the qualification records for nine NDE personnel.
Procedure QCS-001 " Qualification and Certification of Nonde-structive Examination Personnel" documents PSI's qualification /-
certification program. A June 1985 letter from PSI's Manager of Quality to Fisher Controls (FC) appointed two individuals from FC as Level III examiners for PSI. FC's written practice, procedure No. FMP 2J1 "American Society for Nondestructive Testing Personnel Qualification and Certification" was stamped QA approved and signed by PSI's Manager of Quality.
It was noted that Magnaflux/MQS Inspection performed ultrasonic (UT) radiographic (RT), and liquid penetrant (PT) testing for PSI. MQS personnel E. Toper performed PT and R. Boswell performed RT in June 1987 on components for Palo Verde (reference job ho.39620). UT was perfurmed in February 1984 by D. Trott on stems for Beaver Valley (reference job No. 30611). For Clinton (reference job No. 36190), R. Thompson performed RT on discs in February 1986. PSI did not have copies of the qualification records for the four examiners identified above (see Noncon-formance 87-01-03). A review of three procedures from HQS and -
used for the NDE testing indicated that PSI did not review and approve the procedures (see Nonconformance 87-01-02). The l procedures were No. 135-HAR-UT-29 " Ultrasonic to ASME Section III" dated February 22, 1979; No. 23.A.200-1986 " Penetrant Examination Fluorescent Dye General Requirements" dated October 27, 1986; and No. 23.A.031-1986 " Penetrant Examination" dated January 21, 1987.
In general, the type of information found in the record files for the seven NDE personnel (five - Level II PT and two-Level I PT) from PSI included educational background, resumes, certificates of training completed, record of qualification,
- certification statements,
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. J ORGAN!ZATI0th POSI-SEAL INTERNAT10NAL
. NORTH STONINGTON, CONNECTICUT
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1 REPORT ' INSPECTION l NO.- 99900886/87-01 RESULTS: PAGE 5 of 10 J examinations (general, specific, practical) and eye exams. ,
The qualification records appeared to satisfy the regy.irements of SNT-TC-1A. A review of the NDE procedures at the PT work station indicated that the current procedures were in the manual.
- 3. Calibration of Measuring and Test Equipment (M&TE)
The NRC inspector reviewed Section 16 of the QAPM, standard instructions, calibration schedule cards, and certifications for reference standards used by service vendors to calibrate M&TE.
An observation of H&TE at various work stations was also per-formed to assure that M&TE are properly identified, controlled and calibrated at specified intervals. The M&TE selected for review include the following: a thermometer, two ampmeters, two voltmeters, five verniers, 10 micrometers, 15 pressure gages, two gage block sets, and a deadweight tuter.
All the M&TE was in current calibration and a sticker showing the calibration due date was attached to each item. Airmotive Calibration Corporation was the vendor that calibrated the two gage block sets and the weights for the deadweight tester. The pressure gages are calibrated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to testing
_ and after each test or series of tests not to exceed two weeks.
5 It was verified that the pressure gages used on testing of nuclear valves had been calibrated prior to and after each test (four in 1986 and three in 1987). The ampmeter and voltmeter on the two " Miller syncrowave 500" welding machines were checked, and all four instruments were in current calibration.
- 4. Training Training records for four years were reviewed. The records consisted of a training folder which included a general _
training matrix, specific training matrices for each department !
of PSI, and training course attendance sheets. The records ant training were in accordance with Section 18 of the QAPM. The ,
general matrix identified positions in PSI and the sections of the QAPM to which employees were to be trained. The specific departmental matrices identified individuals and the sections of the QAPM to which the individual was trained. The attendance records identified the section of the QAPM that was being covered by the training, the date, the instructor and the employees who attended the training. Employees were trained to
. their specific section(s) of the QAPM each time a new revision I of the manual was issued.
'Jr temmu
L ORGAN!ZATION: POSI-SEAL INTERNATIONAL
. . NORTH STONINGTON, C0hNECTICUT
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REPORT -
INSPECTION l NO.- 99900886/87-01 RESULTS: PAGE 6 of 10
- 5. Manufacturing Cortrols _
I During the inspection, manufacturing controls were reviewed by 1 observing the work being performed in the shop and by a documentation / procedure review. Areas examined included shop travelers, material identification and traceability, in-process and final inspection, and inspection personnel qualifications.
In-process and completed travelers for nuclear work were reviewed. The travelers identify the operations to be executed, QA/QC inspections, and maintain material identity and trace-ability. The travelers which were reviewed were complete and in accordance with QAPM Section 8, " Material Control and
- Traceability" and Section 9, " Shop Travelers for Manufacturing Assembly and Testing." The inspections had been performed when required by qualified QC personnel. As outlined in QCS-008,
" Certification of Inspection and Test Personnel," dated L
November 3, 1986, the inspectors were identified on Certifi-cation Record, individual certification records were present and it was verified that the QC stamps used on the travelers corresponded to qualified inspectors.
lY During the review it was noted that hold tags are used on both ,
nuclear and non-nuclear work. A description of how the hold tags were used was given by PSI personnel, but in examining the hold tags it was noted that a hard copy of a hold tag was in the possession of QC, not the soft copy as stated. Although secticn 14.5.0 of the standard Quality Program describes the use of hold tags on non-nuclear work, written instruction or procedure did not exist for the use of hold tags on nuclear work (see Nonconformance 87-01-05).
- 6. Welding The NRC inspector reviewed Section 10.0 of the QAPM pertaining to welding procedure specifications (WPS), procedure qualifi-cation records (PQR), welding material control and welder qualifications. The Welding Engineer is responsible for pre-paring WPSs and certifying the results of tests / examinations on PQRs. A distribution list for each WPS is maintained by the Welding Engineer who currently is also the Supervisor of Engineering. In the weld area which consists of two welding booths, book No. 6 containing WPSs was reviewed, and eight WPSs were compared with master copies retained by the Welding i
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ORGANIZATION: POSI-SEAL INTERNATIONAL NORTH STONINGTON, CONNECTICUT REPORT ' INSPECTION NO . - 99900RR6/87-01 ,JESULTS: ,
PAGE 7 of 10 Engineer to assure that current procedures were at the. work station. WPSs in book No. 2 (QA Supervisor) and book No.1 (Manager of Quality) were also reviewed. The reviewed WPSs in all three books were in agreement with the master copy. The eight WPSs along with supporting PQRs included the following:
No. 1-01-1 " Manual Shielded Metal Arc Welding," Revision 0; No.
1-01-1-SR, " Manual Shielded Metal Arc Welding of P-No. 1 Carbon Steel," Revision 0; No.1-04-NUC " Manual Gas Tungsten Arc Welding of P-No. 1 Carbon Steel," Revision 4; No. 1CV 04-1
" Manual Gas Tungsten Arc Welding of Impact Tested P-No. 1 Grade 1 and 2 Carbon Steel," Revision 2; No. 5F71-04-6 " Manual Gas Tungsten Arc Hard-Facing Weld Metal Overlay of P-No. 5 Base Metal," Revision 0; No. 8-01/04-01 " Manual Shielded Metal Arc / Gas Tungsten Arc Welding of P-No. 8 Stainless Steel,"
Revision 2; No. 8-04-1-SA " Manual Gas Tungsten Arc Welding of P-No. 8 Stainless Steel," Revision 0; and No. 8CV-03-01
" Automatic Submerged Arc Welding of P-No. 8 Group No. 1 Stainless Steel." Welding on nuclear valves was not being performed during the inspection.
The welder qualification test (WQT) records for four welders
!-- were reviewed. It was noted that the four welders had been l '
qualified to four WPSs (i.e., 1-04-NUC, E01R10, 8-04-1 and ;
E08R10) which were used on past nuclear orders. The certifi-cation of the WQTs indicated that the welds had satisfactorily passed a guided-bend, tensile, and/or charpy impact tests in accordance with Section IX of the ASME Code. Testing of )
coupons was conducted by Bridgeport Testing or Dirats Testing q Laboratory. l l
In the weld material storage area, low hydrogen covered elect-rodes were stored in a padlocked oven which was operating at -
250*F. A metal cabinet which was also secured with a lock i contained the stainless steel weld material. The QC Technician j is responsible for storing and issuing welding materials. i Control of material is maintained by heat / lot numbers. The I welding gases were stored in an area specifically designated )
for such storage. l l
The weld history log, which is maintained by the Welding Engineer, was reviewed for the time period 1983 to the present.
The log is updated on a monthly basis and shows the-dates that one of three welders performed welding to four processes (i.e, GTAU, SMAW, SAW and GMAW). A review of the nuclear weld material list (NWML) in the welding material storage area l
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ORGANIZATION: POSI-SEAL INTERNATIONAL
. , NORTH STONINGTON, CONNECTICUT l
l REPORT -INSPECTION NO.: 99900886/87-01 RESULTS: PAGE 8 of 10 identified 11 reference Nos. (i.e., nuclear jobs currently in house) in which the weld material was purchased on tAree P0s.
A review of the NWML in the possession of the Welding Engineer agreed with the reference Nos. and heat Nos. on the listing posted in the weld material storage area.
- 7. Procurement The inspectors examined the procurement process at PSI. This included a review of Section 7 of the QAPM Quality Control Standard (QCS) 015, " Quality Assurance Approved Vendor List; Vendor Survey, Audit, Evaluation," specifications and P0s from PSI customers, documentation packages, the PSI Approved Vendor List (AVL) and P0s to vendors on the AVL.
P0s to material suppliers / manufacturers, calibration vendors, NDE vendor, plating vendors and heat treating vendors were reviewed to assure that applicable technical and QA program requirements were included or referenced in the P0s. The requirements of 10 CFR Part 21 were imposed on vendors in two cases. These two P0s were for limit switches. The P0s which did not invoke the requirements of 10 CFR Part 21 include three P0s for weld wire - 00593, J0446 and H9657; twelve P0s to l 5 material suppliers / manufacturers - K0988, G7459, G7646, G7647, 11448, 11449, 12208, 12215, 12261, 12605, 13035, and 13076; one P0 for heat treating - K2060; and one PO for NDE Services -
13097 (see Violation 87-01-01).
Additionally, the requirement that a QA Program be specified in procurement documents was not included in six P0s to two plating vendors and one calibration vendor. These P0s include 3669, 3692, 3735 and 4851 to plating vendors, and 11658 and 11659 for calibration services (see Nonconformance 87-01-04). .
- 8. Documentation Packages (DP)
Sixteen DPs for Section III, Class 2 and 3 butterfly valves were reviewed. Depending on the customer, the DP consisted of the following documents: QA Records Validation signed by the Manager of Quality, Document Index, Assembly Drawing, Material Traceability List, Certified Material Test Reports (CilTR),
Certificate of Compliance (C of C), weld history (i.e., casting repair), wall thickness measurement reports, PT and.RT reports, cleaning report, final test reports, and an ASME Code Data Report. The Assembly Drawing details individual parts by s
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ORGANIZATION: POSI-SEAL INTERNATIONAL l - NORTH STONINGTON, CONNECTICUT REPORT ' INSPECTION HO.! 99900RR6/87-01 RESULTS: PAGF 9 nf in number and contains general notes (e.g., stamping ard heat treat requirements), QA notes (NDE and welding procedures), and required nuclear procedures (body, disc and seat tests; cicaning; painting, and packaging). The CMTRs were for the body, disc, gasket retainer plate, gasket retainer bolts, weld ;'
material, stems and disc pins. PSI's CMTR certifies that all tests and operations performed by PSI or their subcontractors for the body, disc, gasket retaining and retainer bolts, welding filler metal, and leak-off pipe are in compliance with the requirements of Section II, III and IX of the ASME Code.
In addition, the valve stems and disc pins were procured and manufactured in accordance with a QA program which meets the requirements of Appendix B to 10 CFR Part 50. The CMTR is signed by the Manager of Quality.
The 16 nuclear customers designated by a PSI reference No. and l year include the following: 27813 ('81) Toledo Edison / Davis Besse, 28988 ('82) UE&C/Seabrooke, 30611 ('83) Westinghouse /
8eaver Valley, 32436 ('83) Cleveland Electric Illuminating /
Perry, 34838 ('84) Gibbs & Hill /Susquehanna, 35685 ('85)
Carolina Power & Light /H. B. Robinson, 35910 ('85) TVA/
, _ . Sequoyah, 36190 ('85) Illinois Pner/Clinton, 38216 ('86) Duke Power / Catawba, 38605 ('86) TVA/ Watts Bar, 39838 ('86) Illinois Power /Clinton, 39620 ('86) Bechtel/Palo Verde, 39156 ('86)
UE&C/Seabrook, 40599 ('87) Duke Power /McGuire, 40846 ('87) Duke Power / Catawba, and 40933 ('87) Illinois Power /Clinton.
- 9. Audits The NRC inspectors reviewed the internal audits for 1986 and part of 1987. The 19 criteria outlined in PSI's QAPM were covered in the audits. Each audit included an audit plan, audit checklist, and audit report. Audit findings were documented in Corrective Action Reports (CAR), and deficiencies were corrected in a timely manner. The audits which were reviewed were performed in accordance with the criteria outlined in Section 17 of the PSI QAPM.
Ten external audits were reviewed during the inspection. The l
auditing of vendors is perforraed using both Section 17 of the QAPM and Quality Control Standard (QCS) 015, " Quality Assurance Approved Vendor List; Vendor Survey, Audit, Evaluation," dated l
October 16, 1984. The records which were reviewed included I audit checklists and reports and were complete and demonstrated that PSI is performing vendor audits in accordance
- with their procedures.
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l' ORGANIZATION: POSI-SEAL INTERNATIONAL
!* NORTH STONINGTON, CONNECTICUT REPORT ' INSPECTION tin . - QQQOORA6/A7-01 REStil TS: PAGE 10 of 10
- 10. Plant Tour TheinspectortouredthePSImanufacturingfacilitykvarious times during the inspection in the company of PSI officials.
Items witnessed included receipt inspection, component storage area, weld material storage area, machining, assembly, welding area, testing, final inspection, PT area, c1 caning, painting, and packaging.
F. PERSONNEL CONTACTED:
- M. Shannon, North American Counsel
- K. Gadaree, Accounting Manager
- R. t. Walter, Director of Operations J. Stitel, Manager Nuclear Sales
- R.
- S. J. Baker, Materials Manager
- D. S. Quirk, Applications Engineer
- E. W. Good, Manufacturing Manager
- D. Mashi, PIP Manager
- B. S. Nichols, Quality Assurance Engineer
- F. D. Riccioli, Marketing Manager
- F. Canastar, Manager Human Resources y-' *J. Corey, Manager Engineering
- P. E. Arnold, General Manager
- J. Azzinaro, Director, Marketing and Sales
- E. W. Whitford, Facilities Engineering Supervisor
- R. D. Barry, Manager of Quality J. Jones, Lead Inspector E. Banville, Shipping Clerk N. Place, QC Technician J. Rodgers, Welding Engineer
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- Attended exit meeting.
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