ML19254D443
| ML19254D443 | |
| Person / Time | |
|---|---|
| Issue date: | 05/25/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19254D417 | List: |
| References | |
| REF-QA-99900066 99900066-79-1, NUDOCS 7910250534 | |
| Download: ML19254D443 (2) | |
Text
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Texas Pipe Bending Company Docket No. 99910066/79-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on May 7-11, 1979, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
A.
Crite rior.
2f Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be prescribed by doc tmented instructions, procedures, or drawings... and shall be accomplished in accordance with these instruct-ions, procedures, or drawings Paragraph 2.8.1.
- 1) in Section 2 of the QA Manual states in part, with respect to applicable requirements when revisions to a Shop Drawing are necessary, ".
. The assembly shall be placed in a designated ' Hold' area for Nuclear fabrication."
Contrary to the above, Job No. N1789, Sheet 229, wa,s observed in a manu-facturing area and not in a designated ' Hold' area for Nuclear fabricatic although the Shop Drawing had been retrieved for revision by Engineering on January 19, 1979.
B.
Criterion V of Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings..
and shall be accomplished in accordance vith these instruct-k ions, procedures, or drawings.
Paragraph 4.6.3 in Section 4 of the QA Manual states in part, "The Project Engineer or the Manager-Quality Assurance may make the following changes directly on the ' Shop' Drawing:
1)
Co rect discrepancies between two dimensions on the ' Shop" Drawing or correct obvious typographical or transpositional errors.
2)
Change the year built on name plate facsimile to the current year.
3)
Change the revision number of a procedure providing it does not incorporate revised Code requirements.
4)
Add intermediate butt welds.
5)
Purchaser approved material call out Contrary to the above, changes were made by the Project Engineer directly on the drawing for Job No. '.71789, Sheet 438, which pertained to weld thickness measurement and performance of postweld heat treatment.
79102s0 534 1209 295
2
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It was additionally noted that these changes would have been required, by paragraph 2.8.2 of the QA Manual if incorporated by a focmal drawing revision, to have either been submitted to the Authorized Nuclear Ir.spector for reassessment of hold points, or hold points assigned if his review was not obtained.
C.
Criterion V of Appendix B to 10 CFR 50 states in part, " Instructions, procedures, or drawings shall include appropriate quantitative or qual-itative acceptance criteria for determining that important activities have been satifactorily accomplished."
Paragr?rh ND-4333 in the ASME Section III Code states in part, "Postweld heat tt :atment of procedure qualification welds shall conform to the applicable requirements of ND-4600 and Section IX.
The postweld heat treat-ment time at temperature to be at least 80% of the maximum time to be applied to the component weld material...."
Contrary to the above, the procedure qualification weld, P-1-SAW-07, for submerged arc welding procedure specification (WPS) P-1-A-01, Revision 0,
' utilized in manufacture of welded pipe) was not postweld heat treated for sat least 80% of the maximum time to be applied to the component weld material, in that:
1.
The procedure qualification weld was heat treated for one (1) hour at temperature, but was used to qualify WPS P-1-A-01, Revision 0, in an application (Job No. M1112N, Item 2, Piece 1)' necessitating a minimum time of two (2) hours at temperature, if Ugld repairs were required to be performed.
2.
The procedure qualification was used in an application, Job No. M1048N, Items 1, 2, and 3, where component weld material received a postweld heat treatment time at teeperature of one (1) hour thirty-seven (37) minutes.
T209 296
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