ML20006F784
| ML20006F784 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/1989 |
| From: | Baker E, Petrosino J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20006F780 | List: |
| References | |
| REF-QA-99901139 99901139-89-01, 99901139-89-1, IEIN-88-097, IEIN-88-97, NUDOCS 9003010153 | |
| Download: ML20006F784 (8) | |
Text
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ORGANIZATION: GEM 0CO, A DIVISION OF SEQUA ENGINEERED SERVICES
,f HOUMA, LOUISlANA REPORT INSPECTION NO.: -99901139/89-01 RESULTS:
PAGE 2 of 8 A.-
VIOLATIONS:
None.
8.
NONCONFORMANCES:
1.
Contrary to Criterion.IV. " Procurement Document Control," of 10 CFR Part 50 Appendix B:
- a.. GEMOC0 failed to invoke quality requirements to the extent necessary, for material vendors in the fo110 win 9 safety-related purchase orders (PO): GEM 000PO46312(7/18/88) to Jorgensen for Louisiana Power ano Light (LP&L) P0 WP19573, GEM 0C0 PO 45293 l
(4/26/88) to J. W. Tull for LP&L P0 WP19530,) GEM 0C0 P0 43911 (12/19/87) to National Specialty Alloys (NSA for LP&L P0 WP20029, andGEMOCOP048072(1/16/89) to NSA for LP&L P0 WP22873 l
(89-01-01).
i b.
GEM 0C0 failed to assure that its procurement documents to sub-tier material vendors for stainless steel bar specified the relevant ASTM requirements. The stainless steel bar was used to fabricate safety-related valve trim Components. Specifically, GEMOCO P0-l 45293(4/26/88) to J. W. Tull for LP&L P0 WP19530 and GEM 0C0 P0 i
43911(12/14/87) to NSA for LP&L P0 WP20029 (89-01-02).
i 2.
Contrary to Criterion Vill, " Identification and Control of Materials, Parts, and Components," of 10 CFR Part 50 Appendix B, GEM 0C0 failed to assure that its identification and traceability of heat code numbers was explicitly maintained on two of the eight safety-related l
LP&L orders that were reviewed. Specifically, material traceability was not maintained on LP&L P0 WP19573(7/5/88) andLP&LP0WP19530(6/29/88) for seat rings (89-01-03.forplug) assemblies i
C.
UNRESOLVED ITEMS:
None.
4 D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
None. This was the first inspection that has been performed at GEM 0C0 by the NRC.
L-90030f0153 900207 OJf[ *%A l
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0RGANIZATION:- GEMOCO, A DIVISION OF SEQUA ENGINEEREO SERVICES HOUMA, LOUISIANA REPORT INSPECTION-NO. :. - 99901139/E,9-01' RESULTS:
PAGE 3 of C E.-
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Entrance and Exit Meetings The scope of the inspection, as stated above, was discussed with gel 10C0 representatives during the entrance meeting on June 6, 1989.
At the conclusion of the NRC inspection on June 9, 1989, HRC provided its findings to GEMOC0 and discussed its concerns and weaknesses that were observed during the inspection.
2.
10 CFR Part 21 Posting and Procedures The NRC inspector reviewed the GEMOC0 10 CFR Part 21 procedure, i
"QA-10 CFR 21," dated March 21, 1987, and the Part 21 documents that were observed posted at the GEM 0C0 facility. The posted documents included Section 206 of the Energy Reorganization Act of 1974 and a notice which described the regulation as required. The inspectors discussed an ambiguity in the wording of the GEM 0C0 posted notice with the QA manager. As a result of the discussion, he committed to review, revise, and repost the subject notice within 60 days of the completion of this inspection.
3.
Conveying Requirements of the Licensee P0 Requirements:
The inspectors reviewed eight safety-related orders that GEM 0C0 had received from Louisiana Power and Light (LP&L) for valve trim and observed one type of deficiency regarding GEMOCO's inadequately conveying the LP&L P0 requirements to GEM 000's sub-tier vendors for stainless steel bar stock. The following examples illustrate these deficiencies:
a.
A review of the eight LP&L P0 packages revealed that GEM 0C0 failed to convey the relevant QA program requirements to J. W. Tull, Jorgensen, and National Specialty Alloys and also failed to assure that the material was suitable for safety-related use. However, it was noted that Talley, the manufacturer who supplied steel to Jorgensen for LP&L P0 19573, stated that he had an NCA 3800 (ASME) QA program. This is identified as Nonconformance B.I.a. above (89-01-01).
b.
GEMOC0 also failed to identify and specify on its purchase orders the unique requirements for the steel that is to be used for fabrication of safety-related valve-trim parts.
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' ORGANIZATION:' GEMOCO, A DIVISION OF SEQUA-ENGINEERED SERVICES
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HOUMA, LOUISIANA ~
REPORT-INSPECTION NO.: 99901139/89-01 RESULTS:
PAGE 4 of 8
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As.an example, the inspectors identified during a previous inspection at the Masoneilan-Dresser Industry sMD) facilities in' Avon, Massachusetts, that the MD valve-trim part nunbers used the last three digits to specify material.. The method that MD used to identify the valve-trim material from the part nunber is the MD " material code index" (MCI) book.
The MCI book is a proprietary document and specifies, by number, the minimum material requirements (e.g., 316 stainless steel-ASTM 479 minimum). The NRC inspectors observed that GEMOC0 typically procures connercial quality steel (e.g.,304and316)withoutspecifyinganyadditional material requirements or the ASTM specification. This issue is identified as Nonconformance B.1.b above (89-01-02).
4.
Traceability of Material During the tour of this facility, the NRC inspectors observed that GEMOCO was storing all of itr, steel bar stock material-on tiered racks with the heat code numbers prominently displayed.
GEM 000 stated that they have established instructions to their shop personnel.that require the heat code nunters and/or P0
. number that is stamped on the bar stock to be maintained for i
traceability and not be cut off.
Inspection of numerous bar E
stock pieces and lengths of bar stock in the cutting room area indicated that this was being effectively executed by GEM 000 personnel.
It was observed that GEM 0C0 additionally uses a system of " cut slips" to ensure that the material identification is maintained. The cut slip lists the GEM 0C0 shop order number and the cutting room attendant cuts the material according to the instructions on the cut slip. He then documents the P0 and/or i
the heat code nunber on the cut slip which accompanies the material. The cut slip is then subsequently attached to the related shop order package.
During the review of eight safety-related LP&L P0's, the inspec-tors observed that GEM 0C0 did not maintain material traceability as required on two of the eight packages. The Certified Material Test Reports (CMTRs) and sub-tier vendors' P0s and invoices did not adequately identify the heat code number of the material supplied to GEH0CO. This issue is identified as Nonconformance B.2 above (89-01-03).
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_h' LORGANIZATION: GEM 000, A DIVISION OF SEQUA ENGINEERED SERVICES sy HOUMA, LOUISIANA l
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. REPORT INSPECTION NO.:; 99901139/89-01 RESULTS:
PAGE 5-of 8 5.
Valve Trim Identification and Marking Requirements Representatives of the GEM 0C0 quality assurance (QA) and Sales departments were querried regarding the identification'of their valve ~ trim components.
It was stated that GEM 0C0 vibro-etches each valve trim component that it manufactures with " GEM" or " GEM 000" and the associated part numbers. However, GEM 000 stated that there are exceptions to this instruction, specifically:
(1) in cases where the customer's purchase order requirements conflict with the instruction, the customer's requirement will be-met; (2) where etching or other permanent marking is prohibited by the customer or by PO requirement, the item will be identified i
by tagging the part or by outer package marking as practical; i
and (3) in situations where the part is too small or space is not available. The inspector reviewed GEM 0C0 procedure QA-03-007,
" Identification and Marking Requirements," dated May 9.-1989. This l
procedure references section 3.20 of the GEM 0C0 QA manual and was written to address the applicable requirenents of MIL-I-45208 and i
This procedure and discussions with shop personnel indicate that GEM 0C0 is executing its component i
identification controls as required.
The inspector observed a unique note on several of the internal GEM 0C0 Finish Work Order" (FWO) forms which stated "do not etch." These notes appeared to be limited to orders from Capital Westward Systems (CWS) and Process Valve and Equipment Company (PV&E). Consequently, the inspector asked why the GEM 0C0 FWO
' forms contained this note when the customer's P0 did not spec-
)
ifically state this requirement. The inspector was told that CWS and PV&E specifically requested that their parts not be identified with GEMOC0 markings. The inspectors also observed that the majority of the parts that were requested without the etching were Masoneilan-Dresser Industries (MD) valve replacement parts.
Subsequent to this inspection it was also noted that CWS is a 1
current MD sales represent 4tive for the California and Arizona area. CWS supplies MD parts to pelo Verde and San Onofre nuclear plants.
6.
GEM 0C0 Customer's P0 Package Review At the NRC inspectors request, GEM 0C0 provided their complete customer listing. The inspectors reviewed the list and chose several customers to perform a review of the associated P0 packages, including GEM 0C0 internal documents such as FW0s.
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.9 ORGANIZATION: GEM 000, A DIVISION OF SEQUA ENGINEERED SERVICES HOUMA, LOUISIANA REPORT INSPECTION NO.: '99901139/89-01 P,ESULTS:
PAGE 6 of 8 L
The GEMOC0 custoners that were chosen for review included:
i Commonwealth Edison Company; (2) Detroit Edison Company; Florida Power and Light; (4) Florida Power Corporation; Midwest Valve and Su l Company (MV&S); (6) Process Valve and Equipment Company (PV&E)pp(y) Capital Westward Supply Company
- 7 (CWS); and (8) A. A. Hanson Associated, Inc. The objective of the review of customer P0 packages was to identify deviations or inconsistencies in the PO package or shop activities. As discussed in Section E.5, the review identified one type of recurring deviation in the GEMOC0 P0 document packages for Capitel Westward Supply Company and Process Valve and Supply.
The deviation related to a recurring handwritten note on the 1
GEMOCO shop FW0s.
Eight CWS P0 packages and two PV&E P0 packages also contained this note.
For the PV&E orders, these components were actually ordered by MV&S from GEM 000.
The handwritten note observed-on the FW0s required-the deletion of the vibro-etching requirement that would normally be performed by GEM 0CO.
The inspector asked the GEMOCO sales manager if there was a specific
-technical reason why a customer would not want the parts etched.
He stated that he did not know of any technical reason.
The following is a list of customer P0s where the questionable notes were found:
e Customer /P0 Hardware Ordered Notes PV&E88-252(2/22/88) 2-MD 435001-104-567 Plugs "Do not etch" 2-MD 010271-016-686 Diaphragms PV&E 88-702(6/23/88) 4-MD 435001-104-567 Plugs "Do not etch" CWS 8334(10/14/88) 2-MD 310101-000-567 Seat Ring CWS8334(10/14/88) 2-MD 325831-000-163 Plug &
"Do not etch Stem (P&S) parts with GEM 0C0 markings"
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.o-3 ORGANIZATIONt GEM 0CO, A DIVIS10tl 0F SEQUA ENGINEERED SERVICES-HOUMA, LOUISIANA
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REPORT-INSPECTION NO.: 99901139/89-01 RESULTS:
PAGE.7 of 8 t
Customer /PO-Hardware Orderad Notes 1
CWS6942(1/25/88) 2-MD 325819-000-567 P&S 2-MD 310688-000-163 Seat "Do not 2-MD 310303-000-163 Stam etch parts 1
2-MD 310201-000-567 Seat with GEMOC0 2-MD 328951-000-213 Stem mar kings" 2-MD 325819-000-567 Stem 2-MD 310101-000-567 Seat CWS6796(12/7.1/87) 1-Fisher 2F1390-00042 P&S
" Note:
Do not etch parts with GEM 0C0 markings" CWS6782(12/17/87) 3-MD 435001-140-220
" Note:
Do not etch Guide bushings parts with GEMOC0 1
2-MD 435002-104-567 markings" Guide Bushings CWS8207(9/26/88) 10-MD 32581-000-163 P&S "Do not etch GEM 0C0"
- CWS6692(12/1/87) 2-MD 435003-152-567 Guide "Do not etch 1-MD 435003-260-163 Seat Parts" 2-t1D 435003-182-567 Seat CWS6757(12/14/87) 1-MD 326232-000-163 P&S "Do not etch 2-MD 328526-000-163 P85 with GEM 000 markings"
- A GEMOCO order confirmation facsimile, 12/1/87, to Mike Foulds, states"...Do not etch..."
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= ORGANIZATION: GEMOCO, A~ DIVISION'0F SEQUA ENGINEERED SERVICES HOUMA. LOUISIANA, REPORT INSPECTION NO.: 99901139/89-01
. RESULTS:
PAGE 8 of 8 F.
PERSONS, CONTACTED:
GEP.000 Personnel H. F. Millet Senior Vice President, Operations l
D. Autin
- QA Manager-J. Filce
- Inside-Sales Manager
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