ML19248C990

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QA Program Insp Rept 99900100/79-01 on 790326-29. Noncompliance Noted:Failure of Welding Control Procedure to Provide Parameters Necessary for Snaw & GMAW Control & Failure to Maintain Records of Welder Qualification
ML19248C990
Person / Time
Issue date: 04/24/1979
From: Agee J, Hunnicutt D, Oller R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19248C984 List:
References
REF-QA-99900100 99900100-79-1, NUDOCS 7907260158
Download: ML19248C990 (16)


Text

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900100/79-01 Program No. 51400 Company:

Limitorque Corporation 5114 Woodall Road Lynchburg, Virginia 24502 Inspection Conducted: March 26-29,1979 Inspectors hg M

f/ZM77 R. E. Oller, Contractor Inspector, Vendor Date Inspecticn Branch a

bYkg Y 2 Y/77 J. R. Agee. -Ccotractor Inspector, Vendor

Date

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Inspection Branch Approved by:

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8 /77 D. M. Hunnicutt, Chief, ComponentsSection II, Date Vencor Inspection Branch 9

Sumary Inspection on March 26-29, 1979 (99900100/79-01)

Areas Insoected:

Implementation of 10 CFR 50, Appendix B criteria, other NRC requirements, and applicable Codes and standards including: action on previous inspection findings; review of vendor activities; training; welding control consisting of welding procedure specifications, welding material control and welder qualifications; qualification of NDE personnel; control of special processes; design control; and valve actuator staking problem.

The inspection involved fifty (50) inspector-hours on site by two (2) NRC Inspectors.

Results:

In the eight (8) areas inspected, no deviations were identified in seven (7) areas. The following were identified in the remaining area:

Deviations: Welding Control: Subprocedure QCp-12.F, " Welding," did not provide welding parameters necessary to control the SMAW and GMAW processes for floor stand weldin9 and the procedure was not qualified.

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s Records of qualification for the person who perfonned the welding were not maintained.

Unresolved Items:

None.

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. DetailsSection I (Prepared by R. E. Oller)

A.

Persons Contacted

  • H. Beers, Plant Superintendent
  • W. Denkowski, Vice President of Engineering C. Formica, QA Administrator
  • K. Groone, Manufacturing Engineer K. Kurtz, QC Administrator F. McKenzie, Gace Lab Technician
  • T. Mignogna, Vice President and General Manager
  • W. Vignola, QC Manager A. Wilkes, Manager of Special Processes
  • Attended the Exit Meeting.

B.

Action on Previous Inspection Findings (1)

(Closed) Deviation A (Report No. 78-01):

Failure to perfonn the required internal audit of the QC system area K " Calibration System" during the 12 month period prior to June 13, 1978. The inspector found that in accordance with Limitorque's response letter dated July 17, 1978, the above QC system area was audited on August 7, 1978.

Discussions with the auditor established that he was verbally instructed to follow the internal audit procedure QCP-14.

(2)

(Closed) Deviation B (Report No. 78-01): With regard to the report of internal audit conducted on January 9,1978, the audit checklist nonconforming items A.6, E.3, and E.4 were not sub-mitted to the QC Manager, nor were the Audit Deficienc.y Notifications (ADN) issued by the QC Department for these items as required by the QA Manual.

The inspector found that in accordance with Limitorque's response letter dated July 17, 1978, ADNs were issued for items marked " rejected" in the August, 1978, audit report, and the auditor was verbally instructed concerning the requirement in procedure QCP-14 to issue ADNs when applicable.

(3)

(Closed) Deviation. C-1 (Report No. 78-01): With regard to calibration requirements, two (2) hand type "Takette" digital tachemeters were not identified by serial numbers or calibra-tion labels and no calibration records were maintained for

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s these devices. The inspector found that these devices now have serial numbers and calibration labels on them and calibra-tion record cards are being maintained.

(4)

(Closed) Deviation C-2 (Report No. 78-01): With regard to calibration, a protractor No. QC-98 did not have an attached calibration sticker nor was there a calibration record card for this device as required. The inspector found that in accordance with Limitorque's letter dated July 17, 1978, protractor No. QC-98 was replaced with protractor No. 636.

The calibration record card for protractor No. 93 shows it was scrapped. A calibration record card is being maintained for protractor No. 636.

(5)

(Closed) Deviation C-3 (Report No. 78-01): With regard to calibration, a dial / caliper No. QC-780 was not identified in Procedure QCP-7.D calibration interval list. The inspector found that this device is now listed in the revised calibration procedure QCP-7.0 with an assigned calibration frequency of every six (6) months.

(6)

(Closed) Deviation C-4 (Report No. 78-01): With regard to calibration, optical comparator No. QC-716 was not identified in Procedure QCP-7.0 calibration interval list, nor was there an outside calibration service certificate of calibration showing traceability of the referenced standard to the National Bureau of Standards, as required by the QC Manual.

The inspector found that although this device is still not listed in revised procedure QCP-7.D. it was added to a draft copy during the inspection.

It has been calibrated and there is a certificate of calibration available.

(7)

(Closed) Deviation C-5 (Report No. 78-01): With regard to calibration, the record was not maintained current for a volt-meter, No. QC-710, located on the motor test bench. The attached calibration sticker showed a calibration date of April 1978, while the record card showed a calibration date of August 1977.

The inspector found that this device was taken out of service and scrapped on February 8,1979. This action was recorded on the records.

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. C.

Review of Vendor's Activities 1.

Objective

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The objective of this area of the inspection was to assess the vendor's activities and their impact on future NRC inspections.

2.

Method of Accomplishment The preceding objective was accomplished by:

a.

Review of the QC Manual, Revision a, dated January 15, 1977, and related Quality Control Procedures (QCP).

b.

Discussions with cognizant personnel.

c.

Review of a list of customers to whom Limitorque supplied safety related valve operators during the period of January 1,1978, through March 22, 1979.

3.

Findings a.

Deviations From Connitments None.

b.

Unresolved Items 9

None.

c.

Other Findings (1) The QC Manual, Revision 4, and certain QC procedures, specifically No. QCP-5, are obsolete.

These documents have not been revised to delete references to Limitorque's King of Prussia organization and activities since their relocation to the Lynchburg Plant. Limitorque's management connitted to issue an updated QC Manual by April 30, 1979, and stated that the affected QC procedures would be revised.

This item will be reviewed during a subsequent inspection.

(2)

During the period of January 1,1978, to Parch 22, 1979, Limitorque supplied safety related valve operators to 53 customers consisting of valve manufacturers, electric utility companies, and suppliers or distributors.

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. (3) The current orders for safety related valve operators will extend over several years in decreasing quantities.,

D.

Training 1.

Objectives The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QC Manual and applicable NRC requirements:

a.

A written system-has been established to assure that in-doctrination and training of personnel performing activities affecting quality is implemented in accordance with applicable Codes.

b.

Appropriate written agenda are used.

c.

Records of training sessions agenda and attendance are maintained.

d.

The agenda includes subject matter adequate to provide an understanding of the general and Gatailed aspects of the QC Program, Codes, standards and applicable technical disciplines.

The instructor's are suitably qualified.

e.

2.

Method of Accomolishment The preceding objectives were accomplished by:

a.

Review of the QC Manual Section 1.B, Revision 3, para-graph 1.B.5, concerning training and indoctrination.

b.

Review of Limitorque's " Quality Control Training Manual."

Review of the records of training for 14 QC inspectors during c.

the period from July 18, 1977, through February 27, 1979.

d.

Discussions with cognizant personnel.

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, 3.

Findings Within this area of the inspection, no deviations or unresolved items were identified..

E.

Welding Contml 1.

The objectives of this area of the inspection were to verify that the following activities were controlled in accordar.ce with the QC Manual and applicable NRC requirements.

a.

A system has been established to assure that welding is controlled in accordance with acceptable practices.

b.

The welding procedures used in production welding are prepared, qualified, and controlled in accordance with the QC Program.

c.

The welding materials purchase, acceptance, storage, issuance, and use are controlled and documented in accordance with detailed procedures.

d.

The welders are qualified in accordance with acceptable practices.

2.

Method of Accomplishment The preceding objectives were accomplished by:

a.

Review of the QC Manual, Section 5.C. "Special processes."

b.

Review of Operating Subprocedure No.12.F, " Welding,"

Revision 1, to determine whether or not the procedure contained adequate welding parameters and was qualified.

c.

Review of welding material procurement invoices No. 20693 and No. 22631 on standing purchase order No. SM-206 for Type 7024 and Type 308 electrodes.

d.

Observation in the weld shop of manual metal are and gas metal arc welding machines and facilities including weld wire and coated rod stored in closed cabinets.

e.

Review of Drawing No. 60-161-0067-3, " Floor Stand," to detemine what type of welding instructions were provided.

f.

Discussions with cognizant personnel.

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Findings a.

Deviations From Corrmitment See Notice of Deviation, Items A and B.

b.

Uaresolved Items None.

F.

Qualification of NDE Personnel 1.

Objectives The objectives of this area of the inspection were to verify that the following items were centrolled in accordance with applicable NRC reguirements:

a.

A written system has been established to assure that measures to control the qualification of personnel performing special processes (otter than welding) has been documented.

b.

The above system.tas been implemented such that the subject personnel are properly qualified in accordance with NRC and the manufacturer's requirements.

2.

Method of Accomolishment The preceding objectives were accomplished by:

a.

Review of the QC Manual, Subsection 8.C, " Nondestructive Examination."

b.

Review of ASNT Recommended Practice No. SNT-TC-1A (June, 1975 Edition).

c.

Review of records of qualification, certification, and eye examination for six (6) dye penetrant examination technicians.

d.

Review of records of QC classes and NDE qualificaticns for four (4) dye penetrant examination technicians.

e.

Review of operating procedure No. QCP-11, Revision 6,

" Nondestructive Testing Procedures."

f.

Discussions with cognizant personnel.

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9 3.

Findings Within this area of the inspection, no deviations or unresolved items were identified.

G.

Control of Special Processes 1.

Objectives The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QC Manual and applicable NRC requirements:

a.

A system has been established to assure that the special precesses of 'arburizing and induction hardening of worm shafts and g'ars are performed in accordance with written procedures which are prepared and approved in accordance with the QC Program, b.

The personnel performing these processes are qualified.

c.

The equipment and materials used are controlled and/or calibrated when required.

d.

The results are documented and reviewed for acceptability as required.

2.

Method of Accomplishment The preceding objectives were accomplished by:

a.

Review of the QC Manual, Section 5, " Manufacturing Process Control. "

b.

Review of the following operating QCP Subprocedures:

No. 12.A, " Heat Treating" No. 12.B. " Metallurgical Test Specimen" No.12.C, " Carbon Determination" No. 12.0, " Records" No. 12.E, " Induction Hardening" c.

Observation of the carburizing furnace facilities and calibration status of the thermocouples, recorders, and entrollers.

d.

Review of the C.I. Hayes', " Operating Instruction Manual,"

for the carburizing equipment.

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e.

Observation of the induction hardening equipment and calibration status of the meters, f.

Review of the " Operating, Installation and Maintenance Instruction" manual by Lindburgh Engineering for the induction hardening equipment.

g.

Review of the induction harcaning log book for parts.

h.

Review of production records for carburizing consisting o a it st Specimen Report, a Microhardness Test Report, and a Carbon Determination Report.

i.

Observation of the use of the Knoop Microhardness iester and the Leca Carbon Determiner a.nd other laboratory equipment.

J.

Revicw of a " Shop Order" card and drawing, controlling the movement of part No. 60-420-0001, " worm shaft gear,"

from the Gear Department to the Heat Treating Department.

k.

Discussions with cognizant personnel.

3.

Finfngs Within this area of the inspection, no deviatisins or unresolved items viere identified.

H.

Exit Interview a.

The inspectors met with manageiiient representative denoted in paragraph A of DetailsSection I at the conclusion of the inspection on March 29, 1979.

2.

The following subjects were discussed:

a.

Areas ins,Neted.

b.

Status of corrective and preventive action for the previous outstanding items.

c.

The deviations identified in this report.

3.

The manufacturer's representatives were requested to formulate their corrective and preventative action responses to the

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g n9 b deviations in accordance with the three (3) conditions identified in the inspection report cover letter.

4.

Management's questions related to clarification of the above items.

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DetailsSection II (Prepared by J. R. Agee)

A.

Persons Contacted

  • W. J. Denkowski, Vice President Engineering
  • C. P. Fonnica, Quality Assurance Administrator, Manager Applications Engineering W. A. Moore, Test Laboratory Supervisor
  • Attended Exit Interview.

B.

Design Control 1.

Objective The objective of this area of the inspection was to review Limitorque activities, functions, and documentation related to the design and manufacture of Class 1E valve actuators for nuclear applications.

2.

Method of Accomolishment The preceding objective was accomplished by:

a.

Discussions with the manager of applications engineering concerning the design and manufacture of valve actuators.

b.

Review of customer contracts and specifications for valve actuators, manufactured to Class 1E criteria, for operation of Class I and II valves in safety related applications,(example: Specification S023-507-5, dated June 1, 1974).

c.

Review of Quality Control Procedures (QCP)-15, Design Control Procedure in which it was determined that several generic models of the valve actuator have been designed, qualification tested, and manufactured to meet the criteria of established codes and standards for Class 1E application.

Qualification test reports reviewed include the following:

(1) Qualification Type Test Report, Limitorque Valve Actuators for PWR Service, tested per IEEE Standards 382-1972, dated Cecember 9, 1975.

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(2) Seismic Qualification, Limitorque Valve Actuators, test per IEEE 344-1975 (test conclusions, dated January 2, 1976).

(3) Limitorque DC Valve Actuators for fluclear Power Station Service Conditions, per IEEE Standards -382,

-323, and -344, dated April 30, 1976.

(4) Nuclear Power Station, Qualification Type Test Report, Limitorque Valve Actuators for BWR Service, dated May 13, 1976.

(5) Qualification Type Test Report, Limitorque Valve Actuators for Class 1E.

d.

Review of QCP-16, Order Entry and Processing Procedure in which it was determined that valve actuators are tailored to the specifications of each customer's purchase order by the order entry applications engineering group. Sizing of the valve actuator and the integral motor are specified to meet customer valve thrust requirements that are translated to the Limitorque Bill of Material, Fonn P-250. This Bill of Material requires minimum dual verification of contents before final approval by applications engineering manager for procurement of materials for manufacture of the specified Class 1E valve actuator.

e.

Review of Limitorque document, SEL, Selection Index for sizing valve actuators for valve thrust requirements.

f.

Review of Limitorque Motor Specification and Motor Curves for use in SFB valve actuators.

g.

Inspection of incoming motors and comparison of motor invoices with Specification RCP 242, Limitorque D/S 21-49-001-1. Witnessed functional tests of incoming motors (for SMB valve actuators) and verified the test curves met the required design functional performance curves.

Verified the tests were conducted in compliance with QCP-9, Test Laboratory Procedure, covering such functional tests as voltage, current, speed, cycle, locked rotor, and high potential which are in compliance with routine tests for induction motors per NEMA Standard MG 1-12, and IEEE Standard 112.

h.

Inspection of production test practices and verified production bench tests were being completed in compliance tQ

)h)

. with QCP-5.C, Test Bench Inspection Procedure. Also, verified the tests results were recorded on assembly inspection reports QC 002/003/006/008.

These test results are nonnally not issued with the QA package but are available to the customer along with other certifications, upon request.

3.

Findings Within this area of the inspection, no deviations or unresolved items were identified.

C.

Valve Actuator Staking Problems 1.

Objectives The objectives of this area of the inspection were to:

a.

Review valve actuator designs, b.

Discuss field inspecti'.a findings, identified as staking problems, related to Limitorque valve actuators at four (4) specific nuclear power stations.

c.

Review customer purchase orders for valve actuators.

d.

Review limitorque documentation related to the manufacture and shipment of valve actuators to specific nuclear generating sites.

2.

Method of Accomplishment The preceding objectives were accomplished by:

a.

Review of actuator design and discussions with Limitorque engineering management concerning valve actuator assembly, operation, and staking problems.

b.

Review of the mechanical interface of a valve actuator to a valve stem by the valve stem nut and determining that the valve stem nut provides thrust for movement of the valve stem.

The valve stem nut is retained in position by a lock nut which requires peening or staking to the drive sleeve.

c.

Review of the following thirteen (13) randomly selected Limitorque production orders for valve actuators for 7 9 [',

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nuclear safety related applications which have been manufactured and shipped:

Production Order Value Actuator (1) 3B4563 263142-143C (2) 384760 270280-285 (3) 384760 270042-045 (4) 3B9378 279697-720 (5) 3C1640 288358-359 (6) 3C1710 278635-636 (7) 3C1710 283674-675 (8) 3C3961 288332-339 (9) 3C3961 288338-337 (10) 3C4104 287991 (11) 3C4104 287992 (12) 301472B 291618 (13) 3D1472B 291619 Contract requirements for the above orders required Limitorque to supply the stem nut properly staked in four (4) of the orders while in the remaining nine (9) orders that stem nut was to be shipped to the customer (the valve supplier).

The valve supplier had the responsibility for interfacing the valve stem nut with the valve stem and staking, as required.

Limitorque does not normally sell and ship direc;1y to a nuclear site and therefore does not maintain a cross reference file of a specific product to a specific nuclear site. However, the Limitorque valve actuator produC ion history can be tracted by the order number and/or serial number displayed on the name-plate on the valve actuator housing (Note:

this nameplate is separate from the nameplate on the related valve yoke).

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. Limitorque is amenable to supplying valve actuator production data upon request and receipt of valve actuator order number and/or serial number.

3.

Findinos Within this area of the inspection, no deviations or unresolved items were identified.

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