ML19257B719
| ML19257B719 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1979 |
| From: | Ellershaw L, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19257B717 | List: |
| References | |
| REF-QA-99900259 99900259-79-2, NUDOCS 8001180199 | |
| Download: ML19257B719 (11) | |
Text
.
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99903259/79-02 Program No. 51300 Company:
Combustion Engineering, Inc.
C-E Avery Division Old Dover Road, Post Office Box 630 Newington, New Hampshire 03801 Inspection Conducted:
Oct 'ber 16-19, 1979
\\
Inspectors:
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/
[ 77 IX E. Ellershaw, Contractor Inspector Datfe ComponentsSection II Vendor Inspection Branch Approved:
2X M'
U/5/77 D. M. Hunnicutt, Chief
' Da t'e ComponentsSection II Vendor Inspection Branch Summary Inspection on October 16-19, (99900259/79-02)
Areas Inspected:
Implementation of 10 CFR 50 Appendix 3 Criteria, and appli-cable codes and standards, including: action on previous inspection findings; allegation regarding compliance with requirements of 10 CFR 21; joint fitup and welding; welding material control; postweld heat treatment; magnetic particle examination. The inspection involved twenty-seven (27) inspector hours on site by one (1) NRC inspector.
Results:
In the six (6) areas inspected, three (3) deviations from commitment were identified. No unresolved items were identified.
Deviations: Joint Fitup and Welding - failure by welders to be equipped to measure interpass temperatures, which is contrary to Criterion V of Appendix B to 10 CFR 50 (Notice of Deviation, Item A.1).
Weld' Material Control - use of welding material which was not qualified fqr the PWHT 1769 f70 110 k B001
2 time at temperature it received in production welding, which is contrary to Criterion V of Appendix B to 10 CFR 50 (Notice of Deviation, Item A.2.),
Postweld Heat Treatment - use of a DWP for production welding which was not qualified for the PWHT time at temperature the material received in pro-duction welding which is contrary to C-E Avery's letters of corrective and pre-
<entive actions and Criterion V of Appendix B to 10 CFR 50 (Notice of Deviation, Item B).
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4 3
DETAILS SECTION (Prepared by L. E. Ellershaw)
A.
Persons Contacted R. P. Adams Manager, Manufacturing D. C. Almeda Supervisor, Quality Systems R. Brillon NDE Engineer S. Conley Supervisor, Weld Surveillance H. J. Gee Manager, Purchasing P. E. Gillis Weld Engineer N. L. Glidden -
Documentation Analyst R. H. Keyes Manager, Weld Engineering R. Reilly Foreman C. E. White Manager, Quality Assurance B.
Action on Previous Inspection Findings 1.
(Closed) Item A.
(Inspection Report No. 79-01):
This item dealt with the format of Detailed Welding Procedures (DWP) not including every essential and nonessential variable as required by paragraphs QW-252 through QW-282 of ASME Code t
Section IX.
C-E Avery has implemented the committed corrective action in that all DWPs have been reviewed and corrected to include all essential and nonessential variables.
2.
(Closed) Item B. (Inspection Report No. 79-01):
This item dealt with an unqualified combination of heat of bare electrodes and lot of submerged arc flux being issued and used by welding operators.
C-E Avery has implemented their committed corrective action in that welding materials observed being issued and used had all been qualified.
3.
(Closed) Item C. (Inspection Report No. 79-01):
This item dealt with production postweld heat treatment (PWHT) time exceeding, by nearly 40 percent, the qualification time of a detailed welding procedure (DWP) used in fabrication,' without re-qualification being performed as required by ASME Code,Section IX.
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4 C-E Avery has implemented their committed corrective action relative to the specific DWPs noted in Inspection Report No. 79-01, in that they were requalified.
Howevcr, a review of additional DWPs and their applicable procedure qualification records, and heat treat charts of reactor coolant pump casings for accumulated time at temperature, revealed another similar deviation. (See Notice of Deviation, Item B.)
4.
(Closed) Item D. (Inspection Report No. 79-01):
This item dealt with certain Engineering Department employees not being placed on distribution for QA Manual revisions.
C-E Avery has implemented their committed corrective action in that all Engineering Department employees are now on the distribution list for revisions.
C.
Allegation Regarding Compliance with Requirements of 10 CFR Part 21
===1.
Background===
An employee of C-E Avery contacted NRC Region I, by telephone on July 18, 1979, and stated that C-E Avery had refused to provide for his examination, copies of Section 206 of the Energy Reorganization Act of 1974, 10 CFR Part 21, and C-E Administrative Manual Procedure, AM-00-013 which is the implementing procedure for the notification requirements of Part 21.
The employee requested copies of Section 206 of the ERA of 1974 and 10 CFR Part 21, which were provided by NRC Region I as enclosures to a letter dated July 19, 1979. The employee was further informed that NRC conducted regular inspections of C-E Avery and this matter would be examined during the next regular inspection.
2.
Method of Accomplishment The NRC inspector contacted the employee on October 17, 1979. The employee reiterated what he stated in his telephone call to NRC Region I.
He expanded further by saying that he had made additional reques'.s to his shift supervisor for the above referenced material, and was refused again. The employee stated that his shift supervisor told him he did not have a need to know.
The NRC inspector asked the employee if divulgence of his identity to the company would create any personal problems. The employee responded by saying he did not care if the company'became aware.
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5 The NRC inspector told him that company management would be made aware and would be requested to respond to his complaint. The inspector further told him he would be briefed on October 18, 1979.
After meeting with the employee, the inspector met with management and discussed the above. Manageme it appeared to be quite concerned and stated that they had no knowledge of anyone's request or a sub-sequent denial of that request for information relative to 10 CFR 21.
Management stated they wanted to talk to the shift supervisor (second shift) to hear his side of the story, and that they would personally provide the employee with a copy of AM-00-013.
The inspector met with management again on October 18, 1979. They stated the shift supervisor indicated he personally would not provide a copy of the requested information, however, the Administrative Manual was located at various foreman stations for the employee to review.
Management indicated that the shift supervisor was probably not aware of the significance of Part 21, in that he was relatively new in that position. They stated that shortly after Part 21 became mandatory, meetings had been held with foremen and supervisors to discuss che requirements of Part 21 and the implementing procedure, AM-00-013.
It was indicated the meetings were not documented, and since that time changes in foremen and shift supervisors have occurred without addi-tional meetings being held. They stated that within the next two (2) weeks, a meeting would be held with all foremen and supervisors to discuss Part 21, to assure that they are aware of the requirements, and that any employee is entitled to this information. They further stated the employee had now received his personal copy of AM-00-013.
After discussions with management, the inspector briefed the employee.
He stated that because Part 21 was a federal regulation, he had the right to obtain it and the implementing procedures and no one should be able to prevent him from doing so.
He further stated he had received his personal copy of AM-00-013, and had no further complaint.
At no time did the employee indicate he was. aware of any defects in materials / components which might create a safety hazard.
3.
Findings The required posting of information relative to 10 CFR 21 and imple-menting procedures had been accomplished in January,1978, as evidenced by the inspector's previous inspection at C-E Avery. The postings are 1769 F74
6 located in numerous locations; i.e., office areas, employees cafe-teria, and throughout the shop areas. Administrative Procedure AM-00-013 is dated January,1978, and was issued at that time. The Administrative Manual is located in a number of locations including several foreman stations. The employee apparently did not go above his shift supervisor with his requests, thus higher management was not made aware.
It appears that personality differences between the employee and his shift supervisor, at that time, may have precipitated this occurrence. The inspector will verify during the next scheduled inspection, that documented eretings have been held with all foremen and supervisors relative to 10 CFR Part 21.
D.
Joint Fitup and Welding 1.
Objectives The objectives of this area of the inspection were to verify that C-E Avery had implemented the requirements for the control of joint fitup and welding in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 14, Revision 10, " Welding."
b.
Review of Administrative Manual Procedure AM-10-007, Revision 03,
" Planning and Control of Welding Functions."
c.
Observation of the following in process welding operations:
(1) Submerged Arc Welding (Strip Cladding) on Job. No. 230-0131.
(2) Submerged Arc Welding on Job. No. 916-0290.
(3) Shielded Metal Arc Welding (SMAW) on Job No. 907-0395-300.
(4) SMAW on Job ho. 13P-040020.
(5) SMAW on Job No. 368-1013-300.
(6) Gas Tungsten Arc Welding on Job No. 915-5169.
9
7 d.
Review of the Welding and Examination Instruction Sheets (WEIS) for each of the above jobs.
f.
Discussion with cognizant personnel.
3.
Findings a.
Deviation from Commitment See Notice of Deviation, Item A.1.
DWP Nos. III-35-8.8-21 and VI-35-8.8-12 were observed in use on Job Nos. 907-0395-300 and 368-1013-300, respectively.
The DWPs required an interpass temperature range of between 60 F and 350 F to be maintained during welding.
The welders performing the welding, however, were not equipped to verify compliance with the interpass temperature requirement.
b.
Unresolved Item None.
E.
Welding Material Control 1.
Objectives" ~
The objectives of this area of the inspection were to verify that C-E Avery had implemented the requirements for the control of welding materials in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Manual Section 14, Revision 10, " Welding."
a.
b.
Review of Administrative Manual Procedure AM-10-001, " Welding Materials Control."
c.
Comparison of issued welding materials as noted on DWPs, to the Welding Material Control List.
d.
Review of Certified Material Test Reports (CMTR) for those welding materials issued, as shown by DWPs.
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a 8
Observation of welding materials located in holding ovens e.
and distribution stations.
f.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Conmitment See Notice of Deviation, Item A.2.
Review of the CMTR for the 1/8" type 7018 electrodes, Heat No.
432C3491, C-E code No. 604, approved by Quality Assurance on October 19, 1978, showed that the test coupon had been postweld heat created for ten (10) hours. DWP No. BMR-10-9 (Base Metal Repairs) was used for Job No. 158-1209 (Reactor Coolent Pump, S/N 9) at operation 10 on April 4 and 5, 1979. A review of the heat treat charts (79-124,79-134. 79-141 and 79-143), all post-weld heat treatments performed after April 4 and 5,1979, showed an accumulated time at temperature of 17k hours, which is 4 3/4 hours in excess of t&_ maximum qualification time of these electrodes.
F.
Postweld Heat Treatment (PWHT) 1.
Objectives The objectives of this area of the inspection were to verify that C-E Avery had implemented the requirements for the control of PWHT in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 16, Revision 10, " Heat Treat."
b.
Review of Procedure HT-P-007, " Post Weld Heat Treatment of System 80 Reactor Coolant Pump Casings."
c.
Review of manufacturing Process Sheets (MPS).
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9 d.
Review of PWHT charts for total time at temperature.
Review of Detailed Welding Procedures (DWP) and their e.
associated Procedure Qualification Records (PQR).
f.
Discussions with cognizant personnel.
g.
Review of Welding and Examination Instruction Sheet (WEIS).
3.
Findings a.
Deviation From Commitment A review of Job No. 158-1209 (Reactor Coolant Pump, Serial No. 9) including the MPSs and WEISS, showed that DWP BMR-10-9 Revision 00, was required to be used for the performance of base metal repairs.
The WEIS, Revision 1, is dated April 4, 1979, and approved by Quality Assurance and Weld Engineering. BMR-10-9 was used for the performance of base metal repairs on April 4 and 5,1979. A re-view of BMR-10-9 revealed a maximum allowable PWHT time at temper-ature of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. A review of the supporting PQR, SMA 1.1-2G-4, verified this in that the PWHT qualification time was ten (10) hours. A further review of all charts of PWHT occurring subse-quent to April 5, 1979, showed that accumulated PWHT time at temp-erature had reached 17k hours, therefore the DWP is not qualified for this application.
This type deviation has been identified now, for three (3) conse-cutive NRC inspections.
It is apparent that preventive measures to preclude recurrence have not been effective.
It should be noted that a review had been started on every DWP qualified for PWHT prior to the conclusion of this inspection.
b.
Unresolved Item None.
G.
Magnetic Particle Examination (MT) 1.
Objectives The objectives of this area of the inspection were to verify that C-E Avery had implemented the requirements for the control of MT in accordance with the QA Manual and applicable NRC and ASME Cod'e requirements.
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a 10 2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Manual Section 15, Revision 10, " Nondestructive a.
Examination."
b.
Review of Procedure, TM-NDE-046, Revision 03.
c.
Observation of MT being performed on Job Nos. 223-00200 and 223-002002, motor support stands.
d.
Review of qualification records of ^he two (2) Level II NDE examiners.
e.
Compare parameters of TM-NDE-046 to the examination activities of the Level II examiners.
f.
Discussion with cognizant personnel.
3.
Findings a.
Deviation from Commitments i
None.
b.
Unresolved Item None.
H.
Exit Interview A meeting was held at the conclusion of this inspection on October 19, 1979, with the following management representatives and Authorized Nuclear Inspectors (ANI):
R. P. Adams Manager, Manufacturing D. C. Almeda Supervisor, Quality Systems P. F. Avery, Jr.-
President R. C. Devoid ANI, Hartford Steam Boiler Inspection and Insurance Co. (HSB)
M. J. Gauntlett Production Superintendant 1769 1.79
11 R. H. Keyes Manager, Weld Engineering L. R. Lansford -
Manager, Operations R. J. Maynord ANI, HSB W. R. Poteet Manager, Quality Assurance, CE-KSB C. E. White Manager, Quality Assurance The scope and findings of this inspection were summarized. The inspector expressed concern over the apparent failure of C-E Avery to implement effective preventive measures to preclude recurrence of Item B, Notice of Deviation. Management acknowledged the statements relative to the findings.
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