ML20210H065

Insp Rept 99901060/86-01 on 860623-27.Violation Noted: Failure to Impose Part 21 on sub-tier Vendors.Nonconformance Noted:Welding Control & Failure to Administer Exams for Distinguishing Colors

ML20210H065
Person / Time
Issue date:	09/09/1986
From:	Harper J, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20210H040	List: ML20210H038 ML20210H046 ML20210H058 ML20210H065
References
REF-QA-99901060 99901060-86-01, 99901060-86-1, NUDOCS 8609260055
Download: ML20210H065 (13)

Text

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CRGANIZATI0t': ITT HENZE MOBILE, ALABAMA INSPECTI0t: INSPECTION REPORT t:0.: 99901060/66-01 DATES: June 23-27, 1986 ON-SITE HOURS: 40 CORRESPONDENCE ADDRESS: ITT Henze ATTN: Mr. Mike Grosso, Vice President and General Manager 2970 Cottage Hill Road Mobile, Alabama 36606 ORGANIZATIONAL CONTACT: Jack Cawoon, Jr.

TELEPHONE NUMBER: (205) 476-7183 NUCLEAR INDUSTRY ACTIVITY: Valve Testing and Repair.

-o) 76$

ASSIGNED INSPECTOR:

J. C. Hhper, Reactivd Inspection Section (RIS) /vate OTHER INSPECTOR (S): None.

APPROVED BY:

9 (f E. W. Merschoff, Chief S, Vendor Program Branch Date INSPECTION BASES AND SCOPE:

A. BASES: 10 CFR Part 21 and 10 CFR Part 50 Appendix B.

B. SCOPE: The inspection evaluated the ITT Henze OA program and implementa-tion. Specifically, the inspection addressed Henze's involvement in the reported main steam safety valves with high lif t set points at North Anna Unit 2.

PLANT SITE APPLICABILITY: North Anna 50-338, 50-339; Perry 50.-440, 50-441.

8609260055 860924 PDR GA999 ENVITTH7 99901060 POR

ORGANIZATION: ITT HENZE MOBILE, ALABAMA PEPORT INSPECIION NO.: 99901060/86-01 RESULTS: PAGE 2 of 9 A. VIOLATIONS:

1. Contrary to Section 21.21 of 10 CFR Part 21, ITT Henze failed to have a procedure pursuant to 10 CFR Part 21. (86-01-01)

2. Contrary to Section 21.31 of 10 CFR Part 21, ITT Henze has never imposed the requirements of 10 CFR Part 21 on applicable subtier vendors. (86-01-02)

P. HONCONFORMANCES:

1. Contrary to Criterion IX of Appendix B to 10 CFR Part 50 and Proc.e-dure SP-TNG-2-1, Revision 0 of the ITT Henze QA System Procedure, the Welder Qualification Test performed on February 27, 1984 by stamp no. FB was not witnessed by a QC representative. (86-01-03)

2. Contrary to Criterion IX of Appendix B to 10 CFR Part 50 and Proce-dure ITTHS-NDT-2 of the ITT Henze QA System Procedure, Henze did not administer examinations for distinguishing and differentiating con-trast between colors for their NDE inspectors. (86-01-04)

3. Contrary to Criterion XIII of Appendix E to 10 CFR Part 50 and NCA-4134.13 of Section III from the ASME Code, Henze failed to have written procedures or instructions regarding the storage and handling of welding materials intended for use in Nuclear safety related service. (86-01-05)

4. Contrary to Criterion VII of Appendix B to 10 CFR Part 50 and Section II of the Henze Quality Assurance Manual QAM-40, Henze failed to have procedures to control the changes made to the Oualtiy Assurance Manual, QAM-40. (86-01-06)

5. Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 and Proce-dure ITTHS-QAV-3, Revision 0 of the Quality Assurance System Proce-dures, no internal audit was performed on the ITT Henze Nuclear Service Branch in 1984. No review of the February 1985 internal audit was performed by the Nuclear Services Branch Manager. And the followup and response to a February 1985 internal audit did not occur until late June 1985. (86-01-07)

8. Contrary to Criterion VII of Appendix B to 10 CFR Part 50 and Section NR-1210.17 of the Henze QAM-30, the following companies were employed by Henze and were on the QVL without being subjected to a source evaluation: Mobile Instrument Company in 1986; Welding Engineering l

ORGANIZATION: ITT HENZE MOBILE, ALABAMA REPORT INSPECTION N0.: 99901060/86-01 RESULTS: PAGE 3 of 9 Supply in 1986; Nondestructive Technical Services in 1986; Nobert Plating Company in 1986; and the Earle Jorgensen Company in 1984, 1985, and 1986. (86-01-08)

C. UNRESOLVED ITEMS:

None.

D. STATUS OF PREVIOUS INSPECTION FINDINGS:

None.

E. OTHER FINDINGS AND COMMENTS:

1. North Anna Main Steam Safety Relief Valves The NRC Vendor Program Branch inspection at ITT Henze was initiated in response to a VEPC0, North Anna Power Station Unit 2 (Licensee Event Report) LER 86-001-00 dated March 21, 1986. On February 21, 1986, eight of fif teen Unit 2 MSRVs failed to lif t durina testing.

The unit was in Fode 3 (Hot Standby) and the licensee was performing periodic testing of the MSRVs in accordance with Section XI of the ASME Boiler and Pressure Vessel Code. The test was conducted using a pneumatic assist test device in addition to the pressure in the main steam lines. The pneumatic assist test device was used in accordance with instructions supplied by the valve manufacturer, Crosby Valve and Gage Company. Following a series of tests (refer to NRC Region II Inspection Report Nos. 50-338/86-15 and 50-339/86-15 for details on the sequence of testing) which determined that there were an excessive r; umber of inoperable valves, the licensee elected to retest the velves utilizing a steam pressure system. Wyle Laboratories wan cdntracted to perform the testing and refurbishment of the valves. ~

At Wyle Laboratories, testing was repeated on each valve until three successful successive test results were obtained. Nine of the ten valves needed adjustment, since the valves were out of their setpoint ranges on the high side. The remaining valve was found to be acceptable. Subsequently, VEPC0 sent the remaining five valves to Wyle Laboratories for retesting. Three of those five valves were also set on the high side. All fifteen MSRVs were reset to their proper ranges, refurbished, leak tested, and returned to the licensee for reinstallation. In addition, Wyle Laboratories found that 12 of IE guide ring setpoints varied from +135 to +48 notches and nozzle ring setpoints varied from -21 to -3. The valve manufacturer Crosby l

ORGANIZATION: ITT HENZE MOBILE, ALABAMA REPORT INSPECTION NO.: 99901060/86-01 RESULTS: PAGE 4 of 9 Valve and Gage Co. recommends that guide rings are to be set at +150 notches and the nozzle ring at -20 notches.

Henze North Anna Steam Safety Relief Valve Tests Performed by ITT Fenze j During September 1984, the licensee contracted the services of ITT Henze to perform valve testing, utilizing the steam pressure method.

Testing and repairs were performed and completed in September and October of 1984. It was reported by Henze that of the fif teen valves, two were within the setpoint range. The other valves all failed on the low side and were reset by Henze to within the proper setpoint range. Henze increased setpoints on the valves from 24 to 119 psig. The guide and nozzle ring setpoints were all set by Henze to the manufacture specifications of +150 and -20, respectively.

During this inspection, Safety-Relief Valve Reports for the 15 subject valves and the Gauge Calibration Certification used in testing the valves were examined. Review of the Safety-Relief Valve Reports indicated that a VEPC0 representative had witnessed each test. The Safety-Relief Valve Report provides data on the condition as received, work performed as well as a Pretest Report (pressure), test medium and set pressure. According to Henze, 13 out of 15 valves-received from VEPC0 were not within ASME Code tolerance. The safety valves listed below were pre-tested, repaired, and set in the Henze Norfolk plant under the guidance of the Nuclear Branch and VEPC0 QC Rep.

Repaired Set As Found Leaked Reset at Valve # Pressure (psi) (pretest (psi) at (psi) (psi) 201-C 1085 1093 150 1085 202-A 1095 640 150 1095 203-B 1110 1086 175 1110 204-C 1120 1071 N/A 1120 205-A 1135 1112 100 1135 201-A 1085 1046 N/A 1085 202-B 1095 1060 175 1095 203-C 1110 1073 N/A 1110 204-A 1120 1056 150 1120 205-B 1135 1020 200 1135 201-B 1085 1036 100 1085 202-C 1095 1041 350 1095 203-A 1110 1046 100 1110 204-B 1120 1022 200 1120 205-C 1135 1135 1016 1135

ORGANIZATION: ITT HENZE MOBILE, ALABAMA FEPORT INSPECTION h0.- 99901060/86-01 RESULTS: PAGE 5 cf 9 The valve guide and nozzle rings for the valves listed below were all inspected and set to mar,ufacture specifications of +150 notches and -20 notches respectively.

As Found As Reset to Valve # NR GR NR GR 205A -4 +132 -20 150 205C -14 +157 -20 150 204A -3 +148 -20 150 204C -20 +48 -20 150 203B -20 +50 -20 150 202C -16 +145 -20 150 201A -20 +175 -20 150 ITT Henze has detailed test criteria for testing main steam safety valves. Among some of the written practices are: calibration of service gauges and instrumentation prior to test (pressure gauges are to be calibrated within a tolerance of 2 1/4 of 1%); three consecutive tests shall be completed satisfactorily according to the stamped set pressure of each valve; repairs are to be authorized by the vendor; the vendor shall witness each valve test to verify that the setpoint acceptance criteria are met.

The Heise gauge used for testing (model number 710-A, SN S-7-5158) was calibrated and supplied by the Henze Nuclear Branch, used in Norfolk for testing and then returned to the Nuclear Branch for a postfield service calibration check.

The Heise model 710-A, serial number S-7-5158 was calibrated on 5/26/84, 10/9/84 and 11/11/84, traceable to NBS test P7239. There were no adjustments necessary when comparing the initial and adjusted measured values to nominal values. The unit had an accuracy better than 1/4 of li. Instrument Lontrol Service performed the calibration, and a certificate of calibratien was submitted for each calibration l performed.

From.the records reviewed at ITT Henze, it appeared that:

1) The Heise gauge used in testing of the MSRVs was calibrated and found to be within the rated accuracy of : 1/4% before and after the testing.

2) All valves were repaired / reset at the original set pressure as witnessed by a VEPC0 representative.

ORGANIZATION: ITT HENZE MO6ILE, ALABAMA REPORT INSPECTION RESULTS: PAGE 6 of 9 NO.: 99901060/86-01

3) Guide and nozzle ring guides were preset to manufacturers speci-fications of +150 notches and -20 notches respectively.

In general, the valves were repaired and set in accordance with the ITT Henze Service Quality Control Procedures ITTHS-VR-2 and ITTHS-PT-1, which confcrms to ASME requirements.

10 CFR Part 21 The ITT Henze shop area was inspected for the posting of Section 206 of the Energy Reorganization Act of 1974, a Part 21 procedure and a Part 21 notice. The Part 21 notice was posted, however, Section 206 and a Part 21 procedure were not. ITT Henze confirmed not having a Part 21 procedure (see violation 86-01-01). From examination of the document packages-it was determined that Part 21 was imposed on ITT Henze by their nuclear customers. At the time of the inspection, Henze did not impose the requirements of Part 21 on contractors employed to fill their nuclear orders.

For exarole, 10 CFR Part 21 was imposed on ITT Penze by CEI, P0 Q-4992-66. To fill the CEI order, ITT Fenze contracted and obtained the sersices of Cabot P0 #110224,1/2/85; Nobert Plating Company P0 #110461; 5/13/85, and ND Technical Services P0 #03062, 11/28/84. ITT Henze did not impose the requirements of 10 CFR Part 21 on any of these contractors (see violation (86-01-02).

Quality Assurance Records Upon review of the ITT Henze QA Manual, there was confusion regarding revision updates. Review of the context of the QA Manual revealed that revisions denoted by a symbolic notation in the left margin of the text. However, those revision changes or symbols were not clearly described on the cover page or in a directive explaining the use of the QA Manual. No instructions were given on how manual revision changes are identified. The cover page of the QA Manual was documented as Revision 2, however, some parts of text of the manual were docu-mented with unidentified symbols (Revision 3). Since the QA manual had no directive to inform the reader of updated revisions, references to a prior revision may be misleading. Furthermore, this lack of control of the QA manual revisions may lead to outdated manual revisions being inadvertently used in the field as well as in the field effices. (see nonconformance 86-01-05)

s CPGANIZATION: ITT HENZE MOBILE, ALABAMA ,

REPORT INSPECTION NO.: 99901060/86-01 RESULTS: PAGE 7 of 9 i

Special Processes i

Welder qualifications and welding specifications were evaluated. ;All of the welder cualifications were satisfactory with the exception,cf Welder FB. Welder FB qualified according to WPS No. 21, Rev. 0,3 ' ,

Laboratory-Test Number-2906, conducted by Ncndestructive Technical J

Services. This test was invalid since there was no objective evidence on the WQR that the test was witnessed ny an ITT Henze '

Quality Control Representative (see nonconformance E6-01-03).

The NRC inspector evaluated the welding and welding material storage and handling area. The welding storage area was locked, clean and ,

orderly. However, there were no written procedures or instructions-to control the storage and handling of welding materials intended fur use in Nuclear safety related service (see nonconformance 86-01-O')). ,

Since there was no procedure, there were loose welding electrodes laying around the welding machine, no guidelines for distributing welding materials and no temperature range limits established for handling low hydrogen coated electrodes. There were two welding -

rod ovens, one was locked in the control room and the other was on the shop floor by the welding machine. It is obvious that the overJ in the lock area was for nuclear welding electrodes. However, the use of the oven on the floor was not obvious since it was not marked as " Nuclear" or "Non Nuclear."

No written procedure or instructions addressed the meth3d of welding rod identification within a rod oven, or a storaje teTioerature range for low hydrogen coated electrodes, or identification ~of the rod ovens as " Nuclear" or "Non Nuclear." At the time of the insMction the E7018 low hydrogen coated electrodes were being stored at 250 F; A temperature of 250 F is the minimum desirable temperature that these electrodes should be stored, in order to ensure minimum moisture absorption.

Eight NDE inspectors qualification records were examined, seven Level II and one Level III. All of the qualification records examined were satisfactory according to ASME, SNT-TC-1A and ITT Henze require-ments with the exception of the requirenent for an annual eye examin-ation. Testing for the capability of distinguishing and differen-tiating contrast between colors was not policy at Henze and therefore was not implemented for Henze NDE inspectors on an annual basis (see nonconformance 86-01-04).

1 ORGANIZATION: ITT HENZE g P0 BILE, ALABAMA A fi 3 PEPORT INSPECTION RESULTS: PAGE F of 9

,i NO.: 99901060/86-01 r

Audits

!q Internal Audits Internal audit records were reviewed for the years 1983-86 for audit completeness ano quality. All audits were performed by qualified personnel not directly responsible for the work performed. These audits were performed according to the ITT Henze Quality Assurance

- , System Procedure ITT HS-0AV-3, Rev. O, NR-1210-17, Rev. O.and Quality However, there

' Assurance Manual-40 Baseline Manual Section XVII-AUD.

were a few problems in the implementation of these procedures. There w6s no evidence that a 1984 internal audit was ever performed (see nonconformance 86-01-07). The nuclear service branch manager was contnitted to reviewing internal audits by signature approval. ho such signature approval was found on a February 13-15, 1985 internal audit of ITT Henze's 0A system (see nonconformance 86-01-07). Section

(

?4

) XVII-AUD of the ITT Fenze QAM-40 and ITTHS-CAV-3 does not specify a time frame for corrective action of an internal audit finding. How-ever, Section XVII-AUD does require an immediate resolution to internal s audit deficiencies.

!* Corrective action for the findings of the internal audit of February 13-15, 1985 was not responded to until June 26, 1985. From review of the internal audit the NRC inspector noted that a 30 day i response was requested by the auditor performing the internal audit (see nonconformance 86-01-07). Therefore, it can be concluded that the required immediate resolution referenced in the 0AM-40 should have been submitted within 30 days.

External Audits External audits were to be performed according to ITT Henze QAM-30, Section NR-1210.17 and XVII-AUD QAM-40. It is the policy of ITT Henze to perform annual audits of all subcontractors of special processes prior to updating the Nuclear Service Branch QVL. There were several companies that ITT Henze employed for nuclear power plant work and had placed on the QVL without being subjected to an annual audit by a Henze quality representative. The Mobile Instrument Company supplied Henze with calibration services and was on the Henze QVL in 1986 without being subjected to the scheduled audit for that year.

The Welding Engineering Supply Comp ny, suppliers of welding electrodes in 1986 was on the QVL and was not subjected to the scheduled audit for that year. Nondestructive Technical Services, suppliers of welder

ORGANIZATION: ITT HENZE MOBILE, ALABAMA FEPORT INSPECTION l NO.: 99901060/86-01 RESULTS: PAGE 9 of o <

Qualification Services in 1986 was not subjected to the scheduled audit for that year. Norbert Plating, suppliers of silver plating on seal rings in 1986 was not subjected to the scheduled audit for that year. Finally, the Earle Jorgensen Company, material suppliers was on the QVL and not subjected to the scheduled audit for the years 1984, 1985 and 1986. (See nonconformance 86-01-08.)

F. PERSONS CONTACTED:*

Ti tle Company Name

1. Clint Rose National Nuclear Coordinator ITT Henze

2. Wayne Prokop Nuclear Branch Manager ITT Henze

3. Mike Grosso General Manager ITT Henze

4. Jack Cahoon, Jr. Technical Director and Quality ITT Henze Manager

• Present at the June 27, 1986 Exit Meeting.

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