ML20215C718

Partially Deleted Insp Rept 99900840/85-01 on 850401-15 (Ref 10CFR2.790).Nonconformances Noted:Failure to Document Audits of Subtier Suppliers & Inadequate Review of Matl Certifications

ML20215C718
Person / Time
Issue date:	06/28/1985
From:	Baker E, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20215C699	List: ML20215C695 ML20215C710 ML20215C718
References
REF-QA-99900840 NUDOCS 8610100417
Download: ML20215C718 (12)

Text

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ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION INSPECTION NO.: 99900840/85-01 DATE(S): 4/1-5/85 ON-SITE HOURS: 76 CORRESPONDENCE ADDRESS: Cardinal Industrial Products Corporation ATTN: Mr. D. Fielder President 3873 W. Oguendo Road Las Vegas, Nevada 89118 ORGANIZATIONAL CONTACT: Mr. Michael J. Donovan, Chairman TELEPHONE NUMBER:

PRINCIPAL PRODUCT: Fasteners.

NUCLEAR INDUSTRY ACTIVITY: Approximately 75% of Cardinal Industrial Products Corporation's (CIPC) sales are to the nuclear industry.

ASSIGNED INSPECTOR:

E. T. 6,Mer, Reactive Inspection Section (RIS)

~h7h Dhte OTHER INSPECTOR (S): T. F. Burns, Brookhaven National Laboratory APPROVED BY: # (-

E. W. Merschoff ief, RIS, Vendor Program Branch Date INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR 21, 10 CFR 50 Appendix B, NCA-3800.

B. SCOPE: This inspection was made to review the implementation of CIPC's corrective action plan and determine the extent to which previously identified hardware deficiencies apply to material supplied to Diablo Canyon Nuclear Plant.

PLANT SITE APPLICABILITY: Diablo Canyon (50-275/323); River Bend (50-458);

Clinton Nuclear Power Station (50-461/462).

8610100417 850726 PDR QA999 EMVCA P 99900804 ,

10 CFR 2.790 INFORMATION HAS BEEB DELETED

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO_- QQQOOR40/RS-01 RESULTS: PAGE 2 of 12 A. INSPECTION ISSUES:

1. Is CIPC effectively implementing the Action Plan reviewed and approved by the NRC?

2. Do documentation packages for material supplied to Diablo Canyon exhibit the same deficiencies (e.g., failure to perform NDE, purchases from unapproved sources, insufficient physica t testing, loss of traceability) observed in documentation packages for material shipped to other plants?

B. INSPECTION FINDINGS:

The following findings were made during the inspection of the CIPC facility in Las Vegas, Nevada.

1. Followup item on corrective action resulting from Inspection Report Nos. 99900840/83-01 and 84-01.

a. Sumary of Issue The CIPC " Action Plan" submitted to the NRC for review and approval, committed to performing revalidation surveys on all suppliers, reviewing all Certified Material Test Reports (CMTRs) for material exceeding 1" diameter, reverifying material chemical and mechanical properties on a sampling basis for material 1" diameter and less, formalizing agency agreements and commitments to pass CIPC's quality requirements down through the procurement chain, and hiring a monitor to supervise and control operations affecting material properties.

j b. Inspection Findings l

l (1) For the revalidation audits performed by a third party, Hartford Steam Boiler Inspection Company (HSBIC), the audit l results were sent to CIPC and CIPC did not send the noncon-i formances to the subtier supplier nor did CIPC request corrective action by the subtier supplier. In addition, CIPC failed to note that companies supplying calibration services to subtier suppliers had not been audited.

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10 CFR 2.790 INFORMATION HAS BEEN DELETED i

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO.- 99900840/85-01 RESULTS: PAGE 3 of 12 (2) The checklist CIPC was using to review material certifi-cation packages was inadequate in that the CIPC review did not identify the following nonconformances; lack of or insufficient magnetic particle testing, insufficient number of tensile tests, and purchases from unapproved sources.

(3) In qualifying a new supplier, facility, CIPC failed to document the audit.

A nonconformance was issued on each of these three findings.

2. Investigation of allegations expressed in 2.206 petition from the Government Accountability Project concerning Diablo Canyon and CIPC.

a. Sunnary of Issues The allegations investigated during the inspection at CIPC included the weldability of A-307B bolts welded as studs to the containment liner, the quality of the PG&E vendor approval system, and the extent to which previously identified problems, e.g., purchases from unapproved sources, failure to perform NDE and destructive tests, and loss of traceability applied to material supplied to Diablo Canyon.

b. Inspection Findings (1) The inspectors reviewed the certified material test reports for nine heats of A-307b bolts supplied to Diablo Canyon between February 1980 and October 1982. All heats were found to be readily weldable.

(2) The first audit of CIPC by PG&E was concucted in December 1984, after NRC Information Notice IN 84-52 was published.

Prior to that time, PG&E placed CIPC on their Approved Vendor List (AVL) based on audits performed by their subcontractors, Pullman Power Products and Bechtel. The inspection report issued by PG&E was reviewed, and while two problems with material supplied under one purchase were detected, PG&E auditors failed to detect insufficient magnetic particle testing and tensile tests on some addi-tional material in the same order. In addition, nonconform-ances involving material supplied on other PG&E orders went undetected (use of unapproved sources and loss of traceability).

10 CFR 2.790 INFORMATION HAS BEEN DELETED

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NA . QQQnnAdn/A9.01 RESULTS- PAGE 4 of 12 (3) In reviewing material supplied under seven PG&E purchase orders and 85 Pullman Power purchase orders, materials for two of the PG&E orders and 15 of the Pullman Power orders were found to have problems similar to those described in IN 84-52, loss of traceability, lack of or insufficient NDE, and insufficient tensile tests.

Since previous nonconformances already address these deficiencies and CIPC has initiated corrective action covering these discrepancies, and PG&E was made aware of the discrepancies during the exit interview, no new nonconformances were issued. CIPC committed to informing other affected licensees as required by their Part 21 procedures.

C. SUPPLEMENTARY INFORMATION:

1. Review of Corrective Action Plan Implementation

a. The inspectors reviewed four revalidation surveys performed by HSBIC for CIPC and two followup audits performed by CIPC. The HSBIC July 31, 1984, and August 1, 1984, of the the October 1984 followup audits of these facilities by CIPC, the HSBIC August 7, 1984, audit of and the HSBIC August 3, 1984, audit of were reviewed by the inspectors. Seven significant nonconformances were identified in these reports. However, contrary to CIPC's QAM, CIPC did not send the subcontractors copies of the nonconformances nor did they request that the subtier suppliers perform any corrective action.

During the review of CIPC's followup audit reports a note on one of the reports stated that had been audited and found acceptable and should be placed on CIPC's AVL. However, there was no completed checklist or audit report documenting the audit. Otherwise the followup audit reports appeared adequate.

b. The inspectors reviewed the checklist developed and used by CIPC in reviewing CMTRs for material exceeding 1" diameter.

The checklist did not require the reviewer to go back to the original P.O. to establish whether the customer initiated any supplemental requirement such as NDE, the checklist did not require the reviewer to consult the product specification to 10 CFR 2.790 INFORMATION HAS BEEN DELETED

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO

• 44QnnR40/85-01 RESULTS: PAGE 5 of 12 assure that the proper number of samples were examined by NDE, the checklist did not require the reviewer to consult the heat treat record or the product specification to assure that the proper number of tensile tests were performed, the checklist did not require the reviewer to establish that traceability existed back to the material manufacturer's CMTR, nor did the checklist require the reviewer to establish that the material was purchased from an approved source.

The inspectors reviewed several P.O.s which had already been reviewed by CIPC personnel to determine if the checklist inadequacies affected the review. A discrepancy was discovered where the number of samples selected for magnetic particle examination did not comply with the AQL of 0.25 as specified in ASTM A490-81. Specifically, material was supplied to Baldwin Associates (Clinton Nuclear Power Station) on CI 31267, Cert.

No. 38789 for 11 - 7 x 3, A490-81 Type 1 bolts (Heat No. 110039) from an eight hundred piece production lot where only fifty pieces had been inspected. In order to fully comply with the standard, it would be necessary to inspect'a minimum of eighty pieces. An additional discrepancy was found in regards to the number of tensile test specimens that were tested from each production lot. ASTM A490 requires (for the Production Lot Method as used by CIPC) that for lots of 801 to 8000 pieces, two tensile specimens be tested. The records examined indicated that only one tensile specimen had been tested from the lot of 816 pieces processed on 10/8/82.

CIPC agreed that the checklist was deficient and committed to reviewing all previously reviewed documentation packages for these deficiencies.

c. Under the material reverification testing program for material 1" diameter and less only a very small number of the material heat / product form combinations had been retested for chemical

t r,1 mechanical properties at the time of the inspection. These l were reviewed to determine that the proper sample size had been tested and that the test results were within specification. No nonconformances were noted,

d. The inspectors reviewed CIPC Standard Practice 8.004, " Agent

' Surveillance" which establishes how CIPC monitors their Trading Agents, as well as reviewed the standard language CIPC uses in formalizing their agreements with their Trading Agents.

Both documents appeared adequate.

10 CFR 2.790 INFORMATI0ri HAS BEEN DELETED t _

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO - QQQOOR40/RS-01 RESULTS: PAGE 6 of 12

2. Review Documentation for Material Supplied to Diablo Canyon

a. An evaluation of weldability was made on a selection of lots of ASTM A-307 fastener material supplied by CIPC for use at the Diablo Canyon nuclear facility. The selection was made from available records covering the period from 1980 to 1982.

The following heats of material were evaluated for the listed Purchase Orders (P.O.s).

Analysis P.O. Date Heat C Mn P S Si 8364 2/15/80 L24813 .17 .38 .021 .018 --

8791 9/4/80 322H380 .19 .42 .017 .045 --

9521 4/28/81 B850587 .16 .37 .030 .019 .01 9520 5/22/81 KA8222 .17 .44 .011 .008 .01 10306 8/9/82 KA8222 .17 .44 .011 .008 .01 5952356 9/7/82 369410 .05 .31 .01 .023 .25 5952356 9/7/82 363233 .04 .33 .015 .024 .230 5952356 9/7/82 367348 .05 .28 .011 .017 .210 5952356 10/26/82 212027 .23 .58 .024 .048 .150 All of the above materials can be classified as . low carbon steels (carbon content of less than 0.25% and an alloy content of less than 1.50%). The above materials would be considered as i

generally weldable without special precautions.

It should be noted that ASTM A-307 does not impose maximum limita-tions on the carbon or manganese content of the material. This places considerable discretion in the hands of the manufacturer with the purchaser presumed to be aware of the effect carbon and manganese content has on the weldability of the material.

The data examined represents an approximate fifteen percent of the total orders made by Pullman Power products from CIPC for use at Diablo Canyon.

b. Because of time constraints the inspectors only reviewed the December 6-7, 1984, and January 1-4, 1985, PG&E audit reports.

Pullman Power Products audit rep'ts were not reviewed.

10 CFR 2.790 INFORMATION HAS BEEN DELETED

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO.- 99900840/85-01 RESULTS: PAGE 7 of 12 The December 6-7, 1984, audit report indicated that PG&E auditors had reviewed P0 4R-66170 and identified that CIPC had not performed sufficient tensile tests on a lot of li" x 6t" A-490 bol ts. The auditors failed to identify that insufficient tensile tests were performed on a lot of li" x 51" A-490 bolts supplied under the same P0 or that insufficient magnetic particle testing was performed on both sizes of bolts.

In addition, on PG&E P0 577706 CIPC supplied ASTM A-194 Grade 4 1-7/8" Heavy Hex Nuts from an unapproved source and lost tracea-bility on the ASTM A-193 B-161-7/8" x 10" studs supplied under the same purchase order.

During the exit interview PG&E personnel stated that the intent of the December 6-7, 1984, audit was twofold; to review a sample of PG&E orders to ascertain whether or not previously identified problems affected material supplied to Diablo Canyon, and to review CIPC's new program to determine whether or not CIPC could be placed back on PG&E's AVL. PG&E was only reviewing a sample of the P0s because CIPC's corrective action program would cover the remainder of the material.

The January 3-4, 1985, audit was performed to review corrective actions required by PG&E as a prerequisite to restoring CIPC to PG&E's AVL. The result of the audit was to reinstate CIPC to the AVL on March 13, 1985.

c. The inspectors reviewed seven PG&E purchase orders and 85 Pullman purchase orders.

(1) On PG&E P0 4R-66170 for 340 11" x 51" and 340 11" x 66" A-490 bolts, CIPC failed to perform sufficient tensile and magnetic particle tests. For production heat treatment l

lots from 801 pieces to 1000 pieces, ASTM A-490 re. quires that two tensile tests be performed. A-490 also requires that the sample size for magnetic particle testing be based i on an acceptable quality level (AQL) of 0.25. The heat treatment lot sizes for both sizes of bolts exceeded 801 pieces and the lot sizes that were magnetic particle tested were 1000 and 500, respectfully. A-490 requires that two tensile tests be performed for the heat treatment lots

for both sizes of bolts and only one had been performed.

The production sample sizes for magnetic particle testing l

l 10 CFR 2.790 INFORMATION HAS BEEN DELETED l

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ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO.- 99900840/85-01 RESULTS- PARF R nf 17 should have been 80 bolts and 50 bolts, respectively, but CIPC only tested 32 bolts ~and 20 bolts, respectively. In addition, one of the 32 bolts failed. A-490 then requires 100% examination of all bolts in the lot. CIPC did not perform any additional testing as a result of the failure.

(2) On PG&E order 577706 for 48 ASTM A'193 B16 1-7/8" x 10" studs and 48 ASTM A-194 Grade 4 1-7/8" Heavy Hex Nuts, CIPC purchased the nuts from an unapproved source and lost traceability on the studs. The nuts were purchased from and were manufactured by in 1977. The first audit of was performed in August 1978 and of in November 1980. This is contrary to paragraph 8-3(b) of the January 23, 1982, revision of CIPC's QAM which is what CIPC certified the material to. According to the shop traveler for the studs, the material for the studs was cut into 10" lengths on 2/29/84, visually inspected on 3/1/84, charpy impact tests performed on 3/8/84, magnetic particle tested as random lengths on 3/13/84 and shipped 3/13/84. Traceability between the material cut to 10" lengths on 2/29/84 and the material magnetic particle tested as random lengths on 3/13/84 could not be established.

(3) A number of purchase orders to CIPC from Pullman Power Products for Diablo Canyon nuclear plant for various quantities of ASTM A-490 alloy steel bolts were issued during the period.1980 to 1982. An examination was made of the documents which covered the items supplied in fulfillment of some of these orders. It was discovered that several orders had been filled by shipping bolting material which had not been magnetic particle tested in accordance with the requirements of ASTM A-490 (para. 11).

These purchase orders are as follows:

Magnetic P.O. Pcs. CI No. Heat No. Date Particle 8528 25 19439 H1124L 5/8/80 No 8528 19 19439 8878948 5/8/80 No 8523 32 19406 Y31200 4/30/80 No l

8523 10 19406-1 H1124L 5/8/80 No 8523 12 19406 Y51054 4/30/80 No 10 CFR 2.790 INFORMATION HAS BEEN DELETED

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO.- 99900840/85-01 RESULTS: PAGE 9 of 12 Ma9netic P.O. Pcs. CI No. Heat No., Date Particle 8641 24 20166 8878948 6/9/80 No 8695 10 20606 8067977 7/3/80 No 10331 150 25952 N32625 2/15/82 No 5952356 10 27541 L83395 9/28/82 No 5952356 16 27541 L21392 9/28/82 No 11124 10 27738 N12900 10/18/82 No Additional shipments of material were made during this period where the required magnetic particle tests had been performed. It appeared that CIPC personnel had simply overlooked the requirement. CIPC could offer no other explanation for this omission.

(4) During the review of orders placed by Pullman Power Products for the Diablo Canyon nuclear plant and the certified material test reports issued, certain discrepancies regard-ing the origin of this material were discovered. The term

" Truck Orders" refers to " Truck Load" shipments of bolt blanks or finished parts received from subtier suppliers.

This type of material and part procurement by CIPC occurred during the period 1979-1981. It is possible that this time frame could be expanded by further investigation. The inability to verify the origin and true identity of the material stems from the fact that all relevant data (heat number, chemical analysis and physical properties) had been transcribed on to certification sheets from Cleveland, Ohio. No original certified material test reports from the material manufacturer were available to confirm this data. For example, one order to Pullman Power Products (7177-7604, 4/6/L) for 4 pcs of 1-3/4"-8UN-2AX8 3/4 A490 Hex Head Machine Bolts was shown as Heat No.

43152 with complete chemical analysis and physical proper-ties including charpy impact results at a specified temperature. However, it was noted that the report from which this data was taken also listed forty three additional heats of material by grade, heat number, chemistry and physical properties.

(5)' The substitution of various grades and/or types of bolting hardware is permitted by the various ASTM standards in those cases where the purchaser has neglected to indicate his need in the purchase requirements. This is a common omission 10 CFR 2.790 INFORMATION HAS BEEN DELETED i

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO.- 99900840/85-01 RESULTS: PAGE 10 of 12 on the part of the buyers of bolting hardware. Virtually all orders emanating from-Pullman Power Products for Diablo Canyon did not specify the type of bolt covered by the standard until about the period beginning 1984.

Consequently, CIPC made substitutions at their facility.

ASTM A-3?.5 permits the manufacturer to substitute-Type 1 or Type 2 material when the buyer neglects to specify type.

A Type 3 is available within this standard but the manu-facturer is not permitted to make this substitution without the consent of the purchaser. Type 1 and 2 bolts are low carbon steels, although the carbon in Type 1 is specified as a minimum with no maximum, and Type 3 is a low alloy material.

During a review of documentation regarding orders placed for ASTM A325 by Pullman Power Products where Type 1 bolts had been specified, it was discovered that a low alloy material (AISI 4140 composition) had been supplied.

This material did not fall into any of the classes of ASTM A-325 and, there was no evidence that the purchaser had agreed to the change. The specific orders examined were:

P.O. C_I_ Item Quantity Heat No. Ship. Date 1)7177-10331 25952 7/8 - 9x21 20 2-0500 2/4/82 2)7177-10331 25952 3/4 - 10x2-3/4 -

2-3200 2/4/82

3) 7177-7387 12195 1-3/4 - 8x1' 4" 2 6752 2/23/79 l

For these three different items the following material l analyses were provided:

C Mn P S Si Ni Cv Mo Cu

1) .40 .79 .011 .025 .23 .12 .85 .166 .25 2 .42 .81 .019 .033 .24 .16 .94 .227 .25 3 .45 .97 .016 .019 .23 .16 1.02 .21 .12 The above material analysis is within the specified range for AISI 4140 - a low alloy material. The physical proper-ties (tensile, yield, elcngation and reduction in area) for this material will differ considerably from low carbon steel even in the annealed condition. In some applications, it 10 CFR 2.790 INFORMATION HAS BEEN DELETED

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ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION  !

LAS VEGAS, NEVADA  ;

l REPORT INSPECTION NO - QQQ00R40/RB-01 RESULTS: PAGE 11 of 12 would be desirable from the end users point of view to know that the material supplied was of a much higher strength level. Also, there could be certain applications or environments where the end user should be aware of the substantial difference in chemical analysis and physical properties. PG&E was not informed of any substitutions and therefore could not review the' application of the material.

D. PERSONS CONTACTED:

CIPC M. J. Donovan, Chairman D. Fielder, President T. Graham N. Henderson, QA Manager L. Mydzowski, Admin. Manager PG&E D. Aaron R. F. Locke B. Norton S. Skidmore M. Tresler CYGNA D. Smedley NRC Region V R. T. Dodds E. DOCUMENTS EXAMINED:

Pacific Gas & Electric Documentation Packages P0 T521791 dated 2/11/83 P0 4R-66170 P0 577705 dated 1/30/84 P0 4R67175 dated 5/11/84 P0 593976 dated 3/11/84 P0 594705 PO 057152 10 CFR 2.790 INFORMATION HAS BEEN DELETED

ORGANIZATION: CARDINAL INDUSTRIAL PRODUCTS CORPORATION LAS VEGAS, NEVADA REPORT INSPECTION NO.- 99900840/85-01 RESULTS: PAGE 12 of 12 PG&E Audit Report for Audits performed December 6-7, 1984 and January 3-4, 1985.

Stone and Webster Documentation Packages (River Bend)

P0 12210-28638 dated 4/20/84 P0 12210-27906 dated 3/12/84 CIPC Standard Practices 8.004 " Agent Surveillance" CIPC Followup Audits dated 12/14/84 Hartford Steam Boiler Inspection Company Audits of CIPC Subcontractors performed 7/31-8/1/85,8/7/84,8/3/84.

I 10 CFR 2.790 INFORMATION HAS BEEN DELETED l

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