ML20151T978
| ML20151T978 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/1986 |
| From: | Merschoff E, Trottier E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20151T963 | List: |
| References | |
| REF-QA-99901039 99901039-85-01, 99901039-85-1, NUDOCS 8602100403 | |
| Download: ML20151T978 (18) | |
Text
1 ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAGO, ILLIN0IS )
REPORT INSPECTION INSPECTION N0.: 99901039/85-01 DATE(S): 09/16-20/85 ON-SITE HOURS: 103 CORRESPONDENCE ADDRESS: Joseph T. Ryerson & Son, Inc.
ATTN: Mr. Edward A. Mullin, Vice President and General Manager, Chicago Plant 16th and Rockwell Street Box 8000-A Chicago, Illinois, 60680 ORGANIZATIONAL CONTACT: Mr. John Bingham, Chicago QA Manager TELEPHONE NUMBER: (312) 762-2121 PRINCIPAL PRODUCT: Steel, aluminum and plastics.
NUCLEAR INDUSTRY ACTIVITY: Less than one percent of current business is raw metal for commercial nuclear application.
ASSIGNED INSPECTOR:
E. H. "rcttier, Reactive Inspection Section (RIS)
[dM Date OTHER INSPECTOR (S): J. C. Harper, RIS T. F. Burns, BN APPROVED BY: . 4 Eb 76 E. W. Merscho Chief, RIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR-Part 21 and 10 CFR Part 50, Appendix B B. SCOPE: This inspection was performed as a result of the 10 CFR Part 21 notification made by Calvert Cliffs Nuclear Power Plant on May 28, 1985.
-The inspection addressed the area of material traceability, as well as the adequacy of J. T. Ryerson's Quality Assurance Program and its implementation in accordance with Appendix B to 10 CFR Part 50.
PLANT SITE APPLICABILITY: Calvert Cliffs Nuclear Power Plant 1/2 (50-317, 318).
8602100403 e60207 "
PLR GA959 EMVJTRYI 99901039 PDR
ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION N0.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 2 of 13 A. Inspection Issues:
On May 28, 1985, Baltimore Gas and Electric Company submitted a 10 CFR Part 21 notification to NRC Region I. The subject of this Part 21 notification was the receipt of incorrect stainless steel for pressurizer spray valve bonnet studs at Calvert Cliffs Nuclear Power Plant, Unit 2.
The incorrect material was ordered through the Philadelphia warehouse of Joseph T. Ryerson & Son, Inc.
On August 8-12, 1985, the Vendor Program Branch of the NRC performed an unannounced inspection of the Joseph T. Ryerson & Son, Inc. warehouse facility in Philadelphia, PA (Inspection Report 99900876/85-01). In addition to two violations and seven items of nonconformance,. the inspectors noted that it is the policy of Joseph T. Ryerson & Son, Inc.
to supply all nuclear-grade material from its central facility in Chicago, Illinois, and that the subject material received by Calvert Cliffs did, in fact, originate from that facility. A review of the Certified Material Test Report submitted by the mill (ARMCO) verified that Joseph T.
Ryerson supplied Heat #656045 (17-4 PH stainless steel) to Calvert Cliffs as ordered. '
This inspection was conducted to determine the circumstances contributing to incorrect steel being received and installed in the reactor coolant systems at Calvert Cliffs Nuclear Power Plant. In addition, the inspectors concentrated on the findings identified during the Philadelphia inspection to determine if similar problems existed at the Chicago facility.
B. Inspection Findings
- 1. Violations:
a) Contrary to Section 21.6 of 10 CFR Part 21, J. T.
Ryerson-Chicago did not meet the posting requirements of 10 CFR Part 21. (85-01-01)
A Severity Level V violation was issued in this area.
b) Contrary to Section 21.31 of 10 CFR Part 21, J. T.
Ryerson-Chicago failed to specify Part 21 as an applicable requirement on numerous work orders associated with " Basic Ccmponents" issued to Charles C. Kawin Testing Company in 1984. (85-01-02)
m ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION N0.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 3 of 13 A Severity Level V violation was issued in this area.
- 2. Nonconformances:
a) Contrary to Criterion VIII of 10 CFR Part 50, Appendix B, sheet steel was purchased and placed into storage without markings that established identification and control of this material. (85-01-03) b) Contrary to Criterion VIII of Appendix B to 10 CFR Part 50 and Joseph T. Ryerson Policy and Procedure 18.400.07, material was in stock without color code, material had been placed in stock with incorrect color code, and material was placed in storage compartments where the color code could not be seen without removal of the material from its stored location. (85-01-04) c) Contrary to Criterion V of Appendix B to 10 CFR Part 50 and Section 5.5 of the QA Manual, the Quality Assurance Coordinator failed to verify special requirements on the Critical Requirement Material Instruction Form for numerous orders placed by the Zack and Bahnson companies. (85-01-05) d) Contrary to Criterion XII of Appendix B to 10 CFR Part 50 and Policy and Procedure 18.220.02, measuring and test equipment was not uniquely identified and was not calibrated in accordance with the prescribed calibration schedule.
Further, no acceptance criteria (allowable deviation) had been established for this equipment. (85-01-06) e) Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 and Section 6.1 of the QA Manuai, seven annual internal audits of at least five Ryerson plants were not performed.
(85-01-07) f) Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 anc Section 6.2 of the QA Manual, deficient areas noted in the Detroit plant internal audit had not been closed out at the time of this inspection (September 20,1985). The Detroit facility cominitted to close out these audit findings by April 29, 1985. (85-01-08)
. ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION NO.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 4 of 13 g) Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 and Section 6.4 of the QA Manual, three lead auditors were qualified without evaluation of their communication skillt, and two lead auditors were qualified without having performed a minimum of five QA audits. Two other lead auditors were qualified without having performed a minimum of
. five QA audits within three years prior to their qualification date. (85-01-09) h) Contrary to Criterion XV of Appendix B to 10 CFR Part 50 and Section 5.3 of the QA Manual, a Discrepancy Report for nonconforming material received from a supplier was not completed. No evidence could be found to substantia.te the actions taken to properly dirposition the discrepancy.
(85-01-10) .
C. Other Findings and Comments
- 1. Identification and Control of Materials Ryerson does not have procedures to mark sheet material adequately, because this product form (three-sixteenths inch thick and less) does not lend itself to edge marking. Thus, sheet material was found unmarked, yet no provision is made for this exclusion in the QA Manual or in the' Policy and Procedure Bulletins. (85-01-03)
Ryerson uses an extensive color coding system to identify materials by type and grade within its storage facilities. Generally, the material is ordered with the color code applied by the mill, and inspection of the color code is made at the time the shipment is received. If the material has not been color coded, or has been incorrectly color coded by the mill, Ryerson personnel affix the required identification before the material is placed in storage.
A comprehensive examination was made of all storage facilities at the Chicago ~ location (including the Plate Plant). Products and product forms examined included the following:
ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION N0.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 5 of 13
- a. Carbon steel bars
- b. Alloy steel bars
- c. Carbon steel plates
- d. Alloy steel plates
- e. Steel tube (and structural steel shapes)
- f. Stainless steel (plate, rod, bar and tube)
- g. Nickel (rod and tube)
- h. Aluminum (plate, sheet, rod, bar, tube and structural shapes)
The implementation of the color code program lacks adequate control, based on the number of instances where materials were found to be either unmarked or marked incorrectly. .Due to conflicting identification methods on some materials, it was not always possible to determine the material identity without more extensive examination, or use of additional test methods.
This conclusion is the result of the following observations:
Plate Material - A random selection of 89 plates was made to determine compliance with the established color code (identification procedure). Of these 89 plates:
49 plates were identified and marked correctly 38 plates were not color coded 2 plates could not be identified with certainty 5 plates (of the above) were stored in the wrong compartment Details and inadequacies of implementation of the identification procedure are presented below:
Material Examined Color Code Storage Location 12 stainless Color coded Stored in correct steel plates correctly location (304,304L,316L) 6 stainless steel No color code Stored in correct plates (including location t
" shorts")
1 ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS
\
l REPORT INSPECTION N0.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 6 of 13 )
Material Examined Color Code Storage Location 37 carbon steel Color coded Stored in correct plates (A36) correctly location 28 carbon steel No color code Stored in correct plates location 1 plate-marked Pink Stored in carbon as "A36" on plate (abrasion steel plate area resistant steel) 4 plates-carbon No color Stored in A285 steel code compartment 1 plate-carbon Marked as Stored in A515' steel A285. compartment Aluminum (all product forms) - The stocks of aluminum naterial were found to be almost entirely unmarked. It is estimated by the inspector that the percentage of this material not marked with the prescribed color code exceeded 90 percent. A representative sample of the product forms examined are listed as follows:
Material Examined Color Code Storagr Location 290 pcs. tube No color code Aluminum storage area 4 bundles-squares No color code Aluminum storage area 177 pcs-angles No color code Aluminum storage area 42 pcs-beams No color code Aluminum storage area 46 pcs-channel flo color code Aluminum storage area 7 stacks-plates No color code Aluminum storage (shorts) area
ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION NO.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 7 of 13 Bar/ Rounds / Tube - A random selection of material types and shapes were made for examination to determine the extent of compliance with color code requirements.
Twenty two bundles (exceeding 25 pieces per bundle) of 321 rounds and 33 tubes were examined with the following results:
196 pieces had no color code 16 bundles had no color code 6 bundles of material requiring a dual color code were incorrectly marked 122 pieces were tagged with identification that differed from the color code applied 36 pieces were correctly color coded and-tagged Details on the bar, rounds and tube shapes examined are listed as follows:
Material Examined Color Co6e Storage Location 2 Bundles One-half Receiving area 1" Round (tagged bundle solid 4140) black, one-Falf bundle solid blue 1 Bundle One-half Receiving area 1" Round (tagged) bundle-solid 4940) black, one-half bundle-solid white
! 28, 1" x 9" bars Marked green Carbon steel bar (tagged A36) (1018,1020) area 36, 1" x 9" bars Marked pink Carbon steel bar (tagged A36) and brown area (A36) l 33, 1" x 9" bars No color code Carbon steel bar
! (taggedA36) area l
. ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAGO, ILLIN0IS REPORT INSPECTION N0.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 8 of 13 Material Examined Color Code. Storage Location 10, 1" x 9" bars Marked blue Carbon steel bar (taggedA36) and white:
(there is no carbon steel material allowed with this code-only 410 stainless 8, 1" x 9" bars Marked blue Carbon steel bar (tagged A36) (1035) area 2 Bundles One-half Carbon steel bar li" round tagged bundle-solid area brown, one-half "Stressproof" '
bundle-solid yellow 6 Bundles (tagged No color code ' Carbon steel bar M1020) area 130, 7/8 x 8" bar No color code Stocked with M1020 (taggedA36) material 1 Bundle One-half Stainless 7/16" round bundle-solid compartment (tagged 203EZ) red, one-half bundle-solid black l 33 tubes No color code Stainless tube l
21 x 18 ga. storage location A269T304 l
52 pcs Marked white Nickel storage 11" round (Ni 800) area B408 15 pcs 1" x 8" bar Marked white Carbon steel bar (taggad A35) (Cor-Ten) area 10 buncles 1" x 4" No color code Carbon steel bar bar area l
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' ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS L REPORT INSPECTION NO.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 9 of 13 It is recognized that a considerable quantity of material is identified both by ink marking and hard (stamp) marking of heat numbers and receiving ticket numbers, in addition to the color code scheme.
Although these steps add to the ability to identify material with certainty, the workman in the shop places his reliance on the color code when selecting material to fill an order. (85-01-04)
- 2. Control of Measuring and Test Equipment Control of measuring and test equipment at Joseph T. Ryerson &
Son, Inc. is governed by Policy and Procedure Bulletin (P.&P.B) 18.220.02. This document establishes the procedure'for testing the accuracy of measuring devices and test instruments at specified time intervals. A review of P.&P.B 18.220.02 revealed that it is thorough and encompasses all those tools-and devices used by Ryerson employees in their daily activities, with two exceptions. The procedure does not establish a specific maximum deviation that is acceptable for continued use of the instrument, and the procedure does not provide for identification of test equipment such that traceability of the calibration status of each piece of equipment is established.
The inspector found a significant failure by Ryerson personnel to comply with the requirements of P.&P.B 18.220.02. This failure to comply was due, in part, to the fact that many persons responsible for using this equipment were not aware of the procedural requirements in regards to the calibration schedule, equipment covered and records retention.
The specific areas examined and the results of that examination are as follows:
QA Department Equipment Device _ Cal. Freq Cal. Not Done Tensile Tester Yearly 1980, 1981 S/N R48071 Master Tape (50') Yearly Not performed since (Lufkin) purchase (1977)
ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION NO.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 10 of 13 Device Cal. Freq Cal. Not Done Wilson Hardness Tester Yearly 1977, 1979, 1980, S/N 1413 1982, 1984 Brinell Tester Yearly 1980, 1981 S/N 75105 Starrett Micrometer Set Yearly 1979 S/N 436 CPSZ North Plant Equipment Device Cal. Freq Cal. Not Done Olsen Ductility Yearly No records available Tester except for 1980 Hardness Tester Yearly 1982-85 S/N ISS430 Hardness Tester Yearly 1982-85 S/N IJR954 Tapelines, Slide Monthly No records available Calipers and Steel Squares Micrometer and Vernier Daily No records available Center Plant Equipment Device Cal. Frequency Cal. Not Done Master Block Set Yearly All years since purchase except 1985 (see note)
Tapelines, Slide Monthly All months prior to Calipers, 1985 (no records Steel Squares available)
Micrometer and Vernier Daily All months prior to Calipers 1984
ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAGO, ILLIN0IS REPORT INSPECTION NO.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 11 of 13 South Plant Equipment Device Cal. Freq. Cal. Not Done Starrett End Measuring No frequency No certificate for Rods (used for caliper stated any period checking)
Tapelines, Slide Monthly No records availble Calipers prior to August 5, Steel Squares 1985 Micrometer and Vernier Daily No records available Calipers prior to August 5, 1985-East Plant (Plate) Equipment Device Cal. Freq. Cal. Not Done Ultrasonic Test Machine Before each test No records for any (2 units) period Ultrasonic Test Machine Yearly No records for any (2 units) calibration except unit S/N 1107/T39, which was calibrated on 11/5/84 West Plant Equipment Device Cal. Freq. Cal. Not Done Tapelines, Slide Monthly No records available Calipers prior to 1985 Micrometer and Vernier Daily No records available Calipers prior to 1985
ORGANIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION NO.: 99901039/8Er-01 RESULTS: 09/16-20/85 PAGE 12 of 13 The master block set in use in the Center Plant was sent to a calibration laboratory on August 26, 1985 for accuracy testing.
This is the only record available for the master block set. The set is estimated to have been in use for five to seven years. The calibration laboratory recommended that 28 blocks of the 75 piece set be replaced due to excessive error. Joseph T. Ryerson & Son, Inc.
replaced two of the most used blocks (one inch and three inch).
Ryerson Policy and Procedure Bulletin 18.220.02 also provides specific instructions regarding the steps to be taken when discrepancies beyond acceptable limits are found at the time of calibration. Those instructions specify removal of the instruments from active use until corrective action is accomplished. . Also, material which has been previously examined with such discrepant instruments shall be reviewed to establish whether the applicable requirements have been met.
During the examination of calibration records, it was discovered that three instruments had been noted by the calibration laboratory as follows: "Above unit was received in a damaged and non-useable condition and could not be calibrated before repair." Those instruments were:
- a. Starrett 3"-4" Outside Micrometer, S/N 236 RL-4
- b. Brown & Sharpe 4"-5" Outside Micrometer, S/N 599-50-19
- c. Starrett Mul-T-Anvil Micrometer, S/N 220 No evaluation or corrective action was indicated as having been taken by Ryerson personnel as a result of this notification.
(85-01-06)
- 3. Control of Nonconforming Material Section 5.3 of the Ryerson QA Manual describes the actions to be taken when nonconforming material is found at the time of receipt inspection. Additional guidance is provided by Ryerson Policy and Procedure Bulletin 12.200.03.
The inspector noted that Receiving Ticket No. 40450 and attendant Discrepancy Report No. 190213 for 27 pieces of
" bent and twisted" steel were not documented as required.
In addition, Receiving Ticket No. 56195 and associated 1
e ORGnNIZATION: JOSEPH T. RYERSON & SON, INC.
CHICAG0, ILLIN0IS REPORT INSPECTION N0.: 99901039/85-01 RESULTS: 09/16-20/85 PAGE 13 of 13 Discrepancy Report No. 196031 failed to document the disposition of nonconforming tubular material received from a supplier. No evidence could be found to establish the action taken to resolve these matters.
In conversations with warehouse employees, the inspector was advised that control of material on shifts other than the day shift is a problem. Inadequate shift instructions and the absence of a clear flow chart to remind second shift workers of the correct steps to process such paperwork were cited as problems.
In the case of Receiving Ticket No. 56195 cited above, the material is believed to have been sold "as is". (85-01-10)
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