ML20147C659
| ML20147C659 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20147C652 | List: |
| References | |
| REF-QA-99900264 NUDOCS 9702060392 | |
| Download: ML20147C659 (8) | |
Text
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b U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Report No:
99900264/96-01 Organization:
Dragon Valves, Inc.
Norwalk, CA 90650
Contact:
Robert L. Snyder, Quality Assurance Manager (310) 921-6605 Nuclear Industry Manufactures instrumentation, manifold and specialty Activity:
valves Dates:
September 23 - 26, 1996 I
)
Inspectors:
Richard McIntyre, Senior Reactor Engineer, Team Leader Uldis Potapovs, Senior Reactor Engineer Bill Rogers, Reactor Engineer Approved by:
Gregory C. Cwalina, Chief Vendor Inspection Section Special Inspection Branch Division of Inspection and Support Programs i
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i 9702060392 961029 PDR GA999 EMVDRAQ 99900264 PDR
1 INSP.ECTION
SUMMARY
During this inspection, the Nuclear Regulatory Commission (NRC) inspectors reviewed the implementation of selected portions of the Dragon Valves, Inc.,
(Dragon) quality assurance (QA) program, and reviewed activities associated with Dragon's activities in supplying instrumentation, manifold, and specialty valves to NRC licensees in accordance with the NRC licensee purchase order requirements.
The inspection bases were:
Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code cf Fedetal Reaulations (10 CFR Part 50) 10 CFR Part 21, " Reporting of Defects and Noncompliance" l
American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section III During this inspection, two non-cited violations of NRC requirements were identified.
The violations are discussed in Section 3.1 of this report.
During this inspection, four instances whue Dragon failed to conform to NRC requirements imposed on them by NRC licensees were identified.
These nonconformances are discussed in Sections 3.2, 3.3, and 3.4 of this report.
2 STATUS OF PREVIOUS INSPECTION FINDINGS There were no open findings from previous NRC inspections of Dragon.
3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 10 CFR Part 21 Proaram The inspectors reviewed Dragon Procedure 14501, " Procedure for Compliance to 10 CFR 21," Revision A, dated June 14, 1993, and representative documentation to verify implementation.
Procedure 14501 established the responsibilities and actions for the reporting of defects and the informing of deviations in accordance with the requirements of 10 CFR Part 21. The inspectors noted, and discussed with Dragon management, that the definitions of the terms deviation (non-conformance) and defect included in the Procedure 14501 were not in complete agreement with the definitions included in 10 CFR Part 21.
Section 10 CFR 21.21 requires that entities subject to the regulations adopt procedures to evaluate deviations within 60 days of discovery, provide interim reports to the h%C within 60 days of discovery, and inform a director or responsible officer within five working days after the completion of an evaluation which determines that a defect or failure to comply exists.
Procedure 14501 stated that, for items which had been shipped to a customer and subsequently identified to contain a 2
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1 deviation or defect, Dragon would perform an evaluation within forty-eight hours.
Upon completion of the evaluation, Dragon would notify the customer and the NRC of the deviation or defect and the Dragon disposition of the items affected and impact on equipment.
If the evaluation could not be performed within forty-eight hours, the customer would be notified of the deviation and would be requested to provide Dragon the current status of the delivered items.
The inspectors concluded that although Procedure 14501 included requirements in the areas discussed in 10 CFR 21.21, the procedure's requirements did not i
agree with, or include all of, the requirements specified in 10 CFR 21.21.
However, the inspectors reviewed Dragon's 10 CFR Part 21 records f
and concluded that there had not been an occurrence where Dragon's actions were not in accordance with the 10 CFR 21.21 requirements.
The inspectors reviewed Dragons's posting in accordance with the regulations in 10 CFR 21.6.
Dragon had posted 10 CFR Part 21 and Procedure 14501 but had not posted Section 206.
The inspectors provided a copy of Section 206 which Dragon subsequently posted.
The failure to adequately proceduralize the requirements specified in 10 CFR 21.21 and to meet the posting requirements specified in 10 CFR 21.6 constitutes violations of minor significance which are being treated as Non-Cited violations, consistent with Section IV of the NRC Enforcement policy (NUREG-1600).
3.2 Procurement and Utilization of Material for Acolications Which A e Reouired to Meet American Society of Mechanical Enaineers (ASME) Boiler
_a_0d Pressure Vessel Code (Code).Section III reouirements.
Although Dragon's ASME Section III, Division 1 Quality Assurance Manual, Fifth Issue, Revision 0, dated March 6, 1996, (QA manual) contains provisions for upgrading unqualified source material, most of the material used in the manufacture of N-stamped valves supplied by Dragon is purchased from ASME-accredited material organizations or suppliers that have been qualified by Dragon.
Since most Dragon-supplied valves are in the 1/2 to 2-inch size range, much of the material used in their construction can be purchased under the ASME Code Section III, Subsection NCA, Subarticle 3800 (NCA 3800) small parts exclusion or the provisions of ASME Code,Section III, Subsection NX, Subarticle 2610 (NX 2610) which exempt small product categories from most of the NCA 3800 quality requirements.
The application of NX 2610, when utilized, is indicated on Dragon's certificate of compliance.
It was noted that the purchase orders of several utilities specifically prohibited the use of the NX 2610 exclusions and that most of the material in Dragon's stock was purchased to NCA 3800 requirements.
3.2.1 Proaram Controls.
The inspectors reviewed the QA manual, Section 7, " Control of Purchased Items and Service," Fifth Issue, Revision 0, dated March 6, 1996, which describes their practice for purchasing material for applications 3
required to meet ASME Code requirements.
Paragraphs 7.5.1 through 7.5.6 address the upgrading of unqualified source material.
Paragraph 7.5.1 states that material shall be purchased to Section III requirements or upgraded by Dragon as permitted by NCA 3855.5(a)(1) through (a)(4), and outlined in Dragon's Procedure 17375.
Paragraphs 7.5.2 and 7.5.3 require that a certification of the requirements which must be performed during the melting and of the heat analysis be obtained from the manufacturer of the source material, and tha, " Dragon Valves, Inc, shall perform or subcontract all other requirements on each piece of the stock material." Paragraph 7.5.4 requires Dragon to perform a product analysis on each piece of source material.
In response to inspector questions concerning the above, Dragon's QA manager stated that "all other requirements," as referenced in Paragraph 7.5.3 of the QA manual, pertained to the product analysis.
In summary, no mechanical testing was procedurally required to upgrade unqualified source material.
This position is consistent with Dragon's implementing Procedure 17375, Rev. N/C, " Procedure for Procurement and Inspection of Unqualified Source Material." For material used for valves over 3/4 inch nominal pipe size, Section 4, " Material Verification," requires only chemical testing each piece of the source material.
The inspector noted that the text of paragraph NCA 3855.5(a)(3) requires the upgrading organization to perform or subcontract "all other reauirements of the material specification on each piece of unqualified source material." These requirements typically include tensile testing and may also include hardness testing, bend testing, hydrostatic testing, impact testing and other tests.
Failure to establish source material upgrading requirements in accordance with the provisions of NCA 3800 was identified as an example of Nonconformance 99900264/96-01-01.
Dragon's quality assurance manager stated that Dragon had not upgraded any unqualified source material exceeding the NCA 3800 small parts exclusion provisions since the implementation of this procedure, therefore the incorrect requirements contained in that procedure should have no effect on Code compliance of supplied items. A review of a sample of material procurements during this inspection tend: to support this conclusion.
The inspector also noted that paragraph 2.1 of Dragon's Procedure 17375, which is referenced in Section 7 of the QA manual for procurement of unqualified source material, states that material may be purchased from any suppliers on the Unqualified Source Material Approved Vendor List.
However, the basis and use of this list was not discussed in the QA manual and the list had not been corgleted and was not available for review.
The QA manager produced another procedure, identified as 17053, Rev. A, " Procedure for Procurement and Inspection of Unqualified Stock Material" which had the same title and appeared similar to Procedure 17375, but was not referenced in the QA manual.
Procedure 4
17053 did not reference the Unqualified Source Material Approved Vendor List (which was referenced in Procedure 17375), but stated that material may be purchased from any supplier.
Both procedures had been approved on February 29, 1996, and were, apparently, in active status.
Inadequate control of material procurement procedures and failure to prepare the Unqualified Source Material Approved Vendor List were identified as examples of Nonconformance 99900264\\96-01-01 3.2.2 Proaram Imolementation The material certification bases for approximately 15 valve orders from NRC licensees were reviewed to assess the effectiveness of Dragon's QA J
program implementation.
The results of this review are discussed in the following paragraphs:
Nebraska Public Power District Purchase Order (P0) 962080, dated September 03, 1996, for one 3/4 inch, 2500 psi needle valve, part number 500F0511SW-875.
The P0 requested compliance with ASME Code,Section III, Class 2, 1983 edition including summer 1983 addenda, but waived Data Report and stamping requirements.
A Certificate of Compliance (C0C) was to be provided instead.
Review of the supporting documentation showed that the valve disc material (SA 564, Type 630) was purchased from Carpenter Technology in Reading, PA.
Carpenter certification indicated that 492 bars of this material (heat 853543) were shipped to Dragon in 1985.
Although Carpenter was on Dragon's approved vendor list at the time of this procurement, their certification did not contain a quality system program statement identifying the revision and date of the applicable written Quality System Program as required by NCA 3800.
The file did contain a generic letter from Carpenter stating that material supplied by them has been manufactured, processed, and j
distributed in accordance with MIL-I-45208 and Carpenter quality assurance manual revision in effect at the time of manufacture.
i Tennessee Valley Authority (TVA) P0 92NNA-76504 B, dated June 29, 1992, for several valves in accordance with TVA Standard Specification MEB-SS-10.19, "ASME Code Valves - 2 Inches and Smaller for TVA Projects."
Review of supporting documentation for a 1/2 inch, 1500 psi globe valve (Fig. 10617-8) showed that the valve body forgings were supplied by Ajax Forge, which was on Dragon's approved vendor list.
Ajax purchased the starting material, SA 182, Type 316 bar (41 lengths) from ESCO Corp., a distributor, which, in turn, cbtained the material from Altech Special*y Steel Corp.
Neither ESCO or Altech certifications included a quality system program statement.
From the available documentation, it could not be determined whether the distributor and steel manufacturer had been audited by Ajax to assure heat traceability of this material or whether Ajax had 5
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upgraded this material.
Review of the supporting documentation for two additional 1/2 inch valves from the same P0, with bodies provided by the same forge shop, showed that Ajax purchased the starting material from Fry Steel Co. of Santa Fe Springs, CA, which, in turn, obtained it from Atlas Specialty Steel.
Neither Fry nor Atlas certifications included a quality system program statement.
Review of supporting documentation for 1 inch, Type 316 stainless steel tubing used in the manufacture of valves covered by the same P0 showed that Dragon had purchased this material in 1988 from a Los Angeles distributor, Tube Sales.
Tube Sales had obtained this material from Sandvik Steel, Scranton, PA.
Although Sandvik Steel holds an ASME quality systems certificate (QSC), and a copy of the certificate was in the P0 file, this material was apparently purchased as commercial grade tubing since Sandvik's certification did not reference their QSC or contain a quality systems program statement.
Sandvik certification identified the material as cold finished ASME SA 213, Type 316 steel (Heat 477898).
In addition to reporting the heat analysis and tensile test results, the certification indicated that flattening and flaring tests had been i
performed on this material.
The file also contained a letter from Tube Sales certifying that this material was annealed at 1900 j
degrees Fahrenheit and water quenched.
Dragon apparently did not perform additional upgrading on this material.
The inspector noted that, since the Sandvik certification did not reference their QSC or contain a quality systems program statement and since no upgrading was performed, this material did not fully comply with the requirements of NCA 3800.
The inspector also noted that there was no apparent basis for the heat treatment statement provided by Tube Sales.
The program implementation review indicated that the majority of material used by Dragon has been purchased from qualified suppliers or certificate holders and, in most cases, sufficient documentation was available to demonstrate compliance with the applicable requirements.
However, as discussed in the examples above, the inspectors identified several instances where Dragon had not verified supplier qualification.
Inadequate verification of supplier qualification was identified as Nonconformance 99900264/96-01-02 3.3 Procurement and Utilization of Material for Non-Code Acolications Reauirino Comoliance With 10 CFR Part 50. Accendix B Most of the valves supplied for safety-related nuclear applications have been supplied as N-stamped components with procurement and manufacturing activities controlled in accordance with Dragon's ASME QA manual.
In soi=e cases, as discussed in parwaph 3.2.2, licensees have waived the Code stamping requirement.
Under these conditions, the valves are supplied under the same QA program, except that the authorized nuclear inspector is not involved in the manufacturing process, a Code data report is not provided, and the valve is not Code stamped.
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Although Dragon's QA manual does not address manufacture of safety-related (10 CFR Part 50, Appendix B) non-Code valves, they have developed a procedure (No. 16562, " Material and Parts Handling for Customer Defined Safety Related Components and Safety Related Items,"
Rev. A, Dated 11/03/93) which is apparently intended to control such activity.
This procedure identifies the safety-related and non-safety-related component parts and defines the procurement, dedication, and processing requirements for each category. According to this procedure, material for safety-related valve components can be procured in i
acccrdance with Dragon's QA manual or purchased to ASME or ASTM specifications and dedicated.
The prescribed dedication process involves cutting a sample from each size and heat of the material and having chemical analysis performed by a qualified vendor.
Dragon's QA l
manager stated that no valves had been supplied to NRC licensees under this procedure.
Although Procedure 16562 referenced Electric Power Research Institute (EPRI) report NP-5652, " Guideline for the Utilization of Commercial
)
Grade Items in Nuclear Safety-Related Applications," the inspector noted i
that it did not follow the EPRI dedication methodology (identification and verification of critical characteristics).
The procedure also did not assure material traceability or provide a basis for assurance that the prescribed chemical sampling (one sample from each size and heat of material from a non homogeneous product lot) was adequate to provide reasonable assurance that the material complied with the specification requirements.
Failure to establish the basis for chemical sampling was identified as Nonconformance 9990U G4/01-03.
3.4 Corrective Action Proaram and Imolementation The inspectors reviewed the QA manual, Section 16, " Corrective Action,"
Fifth Issue, Revision 0, dated March 6, 1996, and representative documentation to verify implementation.
Section 16 established the responsibilities and actions for addressing conditions adverse to quality.
Section 16 of the QA manual stated that conditions adverse to quality shall be identified promptly and corrected within a documented time period.
For significant conditions adverse to quality, the cause shall be determined and corrective action taken to preclude recurrence.
In addition, identification, cause and corrective actions shall be documented and reported to the President and Manager of the departments involved and follow-up action shall be taken to verify implementation of the corrective action by the QA Manager and documented.
The inspectors discussed a recent occurrence in which a Dr,on Instrument Isolation Manifold had been shipped to the Duane Arnold nuclear power plant with the "line" and " instrument" markings, stamped on the manifold body, reversed.
The situation had been identified in April 1995 by Duane Arnold during the testing of a replacement instrument isolation' assembly.
Licensee documentation indicated that if the isolation assembly had been installed with the manifold reversed, 7
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i the isolating valves would have closed with process pressure below the valve seat instead of above and the equalizing valve would have been i
located on the process side of the manifold instead of the instrument stie. As a result, if the man' fold was isolated to calibrate the a
corresponding instrumentation and the equalizing valve opened, this could have caused a reduction in tne differential pressure between the i
two process lines which could have affected other instrumentation fed by the same lines.
Dragon management recalled the event and the related discussions with Duane Arnold and that, in addition to the mismarked manifold in the 4
assembly, Duane Arnold f.ad located another one in inventory. Dragon had j
instructed Duane Arnold to restamp the manifold and had reviewed the Dragon inventory and discovered additional mismarked manifolds.
Dragon determined that the manufacturing technician who marked the manifolds
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had used the correct drawings but had made an error when applying the markings and the inspector wto performed the final inspection of the j
manifold had failed to find the mismarkings.
t i
Further discussion with Dragon and review of the records. indicated that Dragon had not documented the condition, had not entered the condition i
into the Dragon corrective action program, had not documented any corrective actions, and had not documented any actions to preclude recurrence.
The inspectors concluded that shipping mismarked manifolds to a licensee j
was a significant condition adverse to quality and that Dragon had not l
met the requirements of Section 16 of the Dragon QA manual to determine the cause, take corrective action taken to preclude recurrence, document i
and report these actions to the President and Manager of the departments involved, and to take follow-up action to verify implementation of tho i
corrective action by the QA Manager and document these actions.
Failure i
to perform and document the required actions for a significant condition j
adverse to quality was identified as Nonconformance 99900264/01-04.
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3.5 Jndoctrination and Trainina The inspectors reviewed the QA manual, Section 2, " Program," Fifth Issue, Revision 0, dated March 6, 1996, which described the indoctrination and training requirements for Dragon inspection and test personnel and auditors.
Section 2 addressed job functions such as receiving, in-process, and final inspection; hydrostatic, seat leakage, and functional testing; welding; non-destructive examination; and internal and external vendor audits.
The inspectors reviewed documented training records for various personnel for the job functions described above.
The inspectors also reviewed the training files and qua'ification records for lead auditors, welders, non-destructive examination subcontractors, and the various inspection and test personnel.
The inspectors verified that a training plan and schedule was implemented for the job functions examined and that all training that had been planned and scheduled had been completed 8