ML19207B904
| ML19207B904 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19207B891 | List: |
| References | |
| REF-QA-99900268 NUDOCS 7909060044 | |
| Download: ML19207B904 (4) | |
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Armco, Incorporated Advanced Material Division Docket No. 99900268/79-01 NOTICF 0F DEVIATION Based on the results of an NRC inspection conducted on February 5-9, 1979, it appears that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
A.
The Armco Advanced Material Division letter dated October 24, 1978, in response to Notice of Deviation, Item B.1, enclosed with the NRC inspection report cover letter dated September 27, 1978, indicated that Procedure No. WP-12 was rewritten to show tack welding may be done with or without filler metal.
Contrary to the above, Procedure WP-12, revised July 13, 1978, did not show that tack welding may be done without filler metal.
B.
The Armco Advanced Material Division letter dated October 24, 1978, in response to Notice of Deviation, Item D.1., enclosed with NRC inspection report cover letter dated September 27, 1978, indicated that Procedure QC-12 would be revised to include the Severn Gage in the calibration program, also any change necessery to the QA Manual will be made. The completion date for these corrective actions was January 1, 1979. AMD indicated preventative action would be provided by performance of internal audits.
Contrary to the above,-Procedure QC-12 and the QA Manual have not been revised to include the Severn Gage nor has this item been audited.
C.
The Armcc Advanced Material Division letter dated October 24, 1978, in response to Notice of Deviation, Item D.3. er. closed with NRC Inspection Report cover letter dated September 27, 1978, indicated that Procedure QC-12 would be revised to delete the requirement that the Foxboro Recorder, Model 40, located on the continuous hydrostatic tester, must have a dated instrument calibration label and a letter of certification on file.
Contrary to the above, Procedure QC-12 has not been revised to delete the labeling and certification requirements for the Foxboro Recorder, Model 40, located on the continuous hydrostatic tester.
D.
Criterion XII of Appendix B to 10 CFR 50 requires that measures be established to assure that measuring and testing devices used in activities affecting quality are properly centrolled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
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. ihe QA Manual paragraphs state in part, "11.1.1 The Laboratory Tech-nician has the responsibility for maintaining an accurate inventory record of all measuring... instruments along with the necessary documentation to show that the required calioration checks have been made...
11.1.1.1 All measuring,... or other test instruments used in the Quality Control System are identified by serial number.
11.1.1.2 serial numbers are either etched on the instrument or ap-plied to a tag which is affixed to the instrument.
11.1.2 Results of equipment calibration and certification are recorded on an 'In-strument Calibration and Certification Checklist'..
11.1.3 Calibration shall be against certified measurement standards which have known relationship to flational Star.dards, where such standards exist."
Contrary to the above, observation of the Argon and Helium welding gas flow meters used to provide the specified percentages mixture of these gases (an essential welding variable) to the I.D. and 0.D.
torches of the automatic GTA welding machines, identified as "6 inch and 8 inch continuous mills", established that the flow meters were not identified by serial number.
Review of Procedure QC-12 "Cali-bration Procedure" and the " Instrument Calibration and Certification Checklist" maintained by the Laboratory Technician, verified that these flowmeters were neither listed in Procedure QC-12 and the checklist ror were there records of calibration.
E.
Criterion IX of Appendix B to 10 CFR 50 requires that measures be established to assure that spe.cial processes, including welding, are controlled and accomplished using qualified procedures in accordance with the code.
The Quality Assurance Manual, paragraph 8.2.1 states, "All welding procedure specifications are developed by the Welding Engineer and are qualified according to Section IX and Section III of the Code."
Contrary to the above, the following conditions were found:
1.
Review of records established that welding was performed in the manufacture of 6" schedule 40, T-304, SA-312, ASME Code Class 2 piping for Mill Order tio. Sil8-5691-1 and tio. Stl8-6044-1 and others usinL GTA Welding Procedure Specification t!o.10, Revi-sion 1 which was not properly requalified in accordance with the ASME Code,Section IX, paragraph QW-201.2.
Revision 1 contained a change in shielding gases from Argon and/or Helium to 10% A-90%He.
This is an essential variable for the GTAW process per ASME Code,Section IX, paragraphs QW-256 and QW-408.2.
The supporting procedure qualification record (PQR) for WPS-10, Revision 1 was a revised PQR rather than a requali-fication.
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2.
Welding was observed being performed on a 6" nominal diameter; Schedule 5, T-304, ASTM A-312 piping using WPS WP-10, Revision 1, and using 100% Argon trailing shielding gas, without the pro-cedure having been amended to include the addition of this nonessential variable as required by ASME Code,Section IX, paragraph QW-282.6.
3.
Welding of T-304, A-312 piping was observed in process on the new 36" automatic GTAW machine using procedure WP-10, Revision 1 with the ID torch in the IG position and the OD torch in the 4G position without the procedure having been amended to show the change in the position of the torches as required for this non-essential variable by ASME-IX paragraph QW-282.6.
F.
Criterion XVII of Appendix B to 10 CFR 50 requires that sufficient records shall be maintained to furnish evidence of activities affec-ting quality.... The records shall also include closely related data such as qualifications of personnel.
The QA Manual paragraph 9.3.4 states in part, with regard to per-sonnel performing nondestructive examinations, "NDE may be performed by an outside testing laboratory provided:
9.3.4.1 The laboratory is on the Approved Vendors List....
9.3.4.3 Training and qual-ification records of operators perfoming the examinations have been approved by the Level III Examiner as stated in paragraph 9.3.2 and these records shal1 be kept in A.M.D. files."
Contrary to the above, the following conditions were observed:
1.
The ARMC0 Houston Works, the subcontractor providing ultra-sonic examination services for examining SA-312, ASME Code, Class 2 piping welds, was not listed on the ARMCO AMD's
" Approved Vendor List".
2.
The training and qualification records for the subcontractor's Level II and III personnel who performed the ultrasonic examina-tion of T-304, SA-312, ASME Code, Class 2 piping; Serial No.
SN8-5694, Heat Nos. 655391, 8644091, and 8644098; Serial No.
SN8-5739, Heat No. 040496; Serial No. SN8-5694, Heat No. 636828, and Serial No. SN8-5900, Heat No. 8644317, were not maintained in the ARMC0 AMD's file.
G.
Criterion XVII of Appendix B to 10 CFR 50 requires that sufficient records be maintained to furnish evidence of activities affecting quality.
The records shall include the results of reviews.
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. The QA Manual paragraph 9.3.6.4 states in part, "Results of NDE are entered on the appropriate form and reviewed by the Quality Assurance Supervisor...."
Contrary to the above, the following ultrasonic test reports for T-304, SA-312 ASME Code, Class 2 piping were not reviewed by the OA supervisor.
1.
UT Report dated September 13, 1978, for 37 random lengths of piping SN8-5739, Heat No. 040496.
2.
UT Report dated September 13, 1978, for 31 random lengths of piping SN8-5694, Heat No. 636828.
3.
UT Report dated September 13, 1978, for 41 random lengths of piping SN8-5900, Heat No. 8644317.
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