ML19259B370
| ML19259B370 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/1978 |
| From: | Barnes I, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19259B365 | List: |
| References | |
| REF-QA-99900348 99900348-78-1, NUDOCS 7902090064 | |
| Download: ML19259B370 (11) | |
Text
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VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900348/78-01 Program No.
44070 Company:
NPS Industries, Inc.
10420 Metric Boulevard Austin, Texas 78758 Inspection Conducted: September 11-13, 1978 Inspectors:
8e
/o/s/7T I. Barnes, Contractor Inspector, Vendor Date Inspection Branch Approved by:
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D. M. Hunnicutt, Chief, ComponentsSection II, Date Vendor Inspection Branch Summary Inspection on September 11-13, 1978 (99900348/78-01)
Areas Inspected:
Initial Management Meeting and implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards, including QA program review; manufacturing process control and nonconformances and corrective action.
The inspection involved twenty (20) inspector-hours on site.
Reruits:
In the four (4) areas inspected, no apparent deviations or unresolved items were identified in one (1) area; the following were identified in the remaining areas:
Deviations: QA Program Review - QA Manual not consistent with the require-ments of Criterion IX of 10 CFR 50, Appendix B, and Section IX of the ASME Code relative to welder requalification time requirements (Enclosure, Item A.).
Manufacturing Process Control - Incorrect weld examination technique specified relative to the requirements of Criterion IX of 10 CFR 50, Appendix B, and Subsection NF of the ASME Section III Code (Enclosure, Item B.); improper review of welding material certification at receidr.g inspection 7 9 0 2 0 9 0 0 Co Y
. not in accordance with Criterion VII of 10 CFR 50, Appendix B, and Section 10 of the QA Manual (Enclosure, Item C.); failure to follow amperage requirements of applicable welding procedure specification not in accord-ance with Criterion V of 10 CFR 50, Appendix B (Enclosure, Item D);
failure to use the interpass temperature of the applicable welding procedure specification for production welding, in qualification of a heat of SFA 5.18 E70S-3 wire, not consistent with Criterion IX of 10 CFR 50, Appendix B, and Subsection NF of the ASME Code,Section III (Enclosure, Item E); presence of a canister of Type 309 wire in the controlled storage area, without an identified Material Inventory Control number, not consistent with Criterion VIII of 10 CFR 50, Appendia, B, and Work Procedure Nos. 9.1.1, Revision 0, and 9.1.2, Revision 0 (Enclosure, Item F. ).
Nonconformances and Corrective Action - Failure to follow nonconformance system for two (2) nonconformance reports, not consistent with Criterion XV of 10 CFR 50, Appendix B, and Work Procedure Nos.15.0.1, Revision 0, and 15.0.2, Revision 0 (Enclosure, Item G. ).
Unresolved Items: Absence of documentation at the Austin facility to allow verification that a required review of Owner's Design Specifications had been made, with respect to determination of impact test requirements for component supports and issue of applicable welding criteria.
. DETAILS SECTION A.
Persons Contacted
- L.
Hovi, Vice President
- R. C. O'Neill, Plant Manager
- D. G. Harbison, Corporate Manager of QA
- G. M. Hemphill, Plant QA Manager
- Attended both Initial Management Metting and Exit Meeting.
B.
Initial Management Meeting 1.
Objectives The objectives of this meeting were to accomplish the following:
a.
To meet with the NPS Industries, Inc. (NPS) ccmpany manage-ment and those rersons responsible for administration of the NPS Austin QA program and establish channels of communication.
b.
To determine the extent of company involvement in the commercial nuclear business.
c.
To explain the NRC direct inspection program including Licensee Contractor Vendor Inspection Program (LCVIP) organization, Vendor Inspection Branch (VIB) inspection methods and documentation.
d.
To describe the NRC evaluation of the ASME inspection system.
2.
Method of Accomplishment The preceding objectives were accomplished by a meeting on September 11, 1978, with the attendees noted above. The following is a sunnary of the subject matter covered:
a.
The VIB organization was described and its relationship to NRC Region IV and other components of the Office of Inspection and Enforcement.
b.
The LCVIP was described including the reasons for its establishment, its objectives, and implementation methods and criteria used.
. c.
The conduct of VIB inspections was described and how our inspections are documented including the report, responses to reports, how proprietary information is handled, the Public Document Room, and the White Book.
d.
The purpose, scope, and status of the NRC's two year program for evaluation of the ASME inspection system as an acceptable independent third party was discussed.
e.
The company contribution to the nuclear industry was discussed, including current and projected manufacturing activity, status of ASME Certificates of Authorization and third party inspection arrangements.
3.
Findings a.
NPS has recently moved their Austin manufacturing facility to a new location in Austin.
b.
The inspector was informed that the Austin plant has contracts for component supports for three (3) nuclear plant sites and anticipates a sigrificant increase in level of manufacturing activity within the next year.
c.
NPS has a contract with Hartford Steam Boiler Inspection and Insurance Co. to act as their Authorized Inspection Agency and is presently served on an itinerant basis by an Authorized Nuclear Inspector.
C.
0A Program Review 1.
Obj ectives The objectives or this area of the inspection were to verify that a documented QA program had been prapared, which was consistent with regulatory and ASME Code quality and technical requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by review of the QA manual and supporting working procedures to verify the following:
a.
Thc QA Manual contained a management policy statement endorsiag the QA program and vesting responsiblity and organizational freedom to QA management to permit maintenance and implementation of tne program.
, b.
The QA program addressed the criteria contained in Appendix B to 10 CFR 50 and NCA-4000 of the ASME Code,Section III.
c.
The QA program described in sufficient detail the systems, procedures and controls used to provide for conformance with Section III of the ASME Code.
d.
The QA program defined management and staff responsibilities with respect to performance of program functions.
3.
Findin,gs a.
Deviation frcm Commitment See Enclosure, Item A.
b.
Unresolved Items Paragraph 9.1.3 in the QA Manual requires review by the Project Engineer of Owner's Design Specifications to ascertain whether any supports are required to be impact tested.
Welding criteria are then required to be issued to assure tnat purchased welding materials and all welding performed are in compliance with Code requirements including fracture toughness.
At the time of this inspection, no documentation was available at NPS-Austin to allow determination of either if these reviews had been made, or, if any component supports had stipulated fracture toughness properties. Welding criteria had not been issued by the Project Engineer as of the inspection.
In the absence of this infonnation, procurement practices in regards to base material require-ments could also not be inspected.
The inspector was infonned that the responsibility for this function was assigned to the NPS home offi:e in Secaucus, New Jersey. This item will be further revicwed during future inspections of Secaucus and Austir.
c.
Comments It was noted during the QA Manual review, that the organi-zation chart did not reflect a Corporate Manager of Quality Assurance. The inspector was infonned by management that this was part of a recent organizational change and was shown a copy of a letter notifying ASME of the scope of changes.
. D.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that manufacturing pitcesses are controlled in accordance with applicable regulatory, code and contract requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Mariual, Section 4.0, Revision 2,
" Procurement and Procurement Document Control. "
b.
Review of QA Manual, Section 9.1, Revision 1, " Welding."
c.
Review of QA Manual, Section 9.2, Revision 1, "Qualifi-cation of Welders."
d.
Review of QA Manual, Section 9.3, Revision 0, " Nondestructive Exami nation. "
e.
Review of QA Manual, Section 10.0, Revision 2, " Inspection Control."
f.
Review of QA Manual, Section 14.0, Revision 1, " Inspection and Test Status."
g.
Review of work procedures applicable to referenced QA Manual sections, h.
Examination of drawings and process control sheets for four (4) assemblies relative to:
(1)
Definition of manufacturing procedures used to perform scheduled manufacturing operations.
(2) Verification that completed manufacturing operations had been signed off.
(3) Ascertaining that manufacturing records were consistent with observed visual status of components.
(4)
Compliance with any specified Authorized Nuclear Inspector hold poir.ts.
. (5) Comparison of procedures used against procedures designated as approved.
i.
Yerification that listed procedures had been approved, as required, by the client.
j.
Observation of two (2) gas metal arc welding operations relative to welding procedure specification requirements.
k.
Review of welding personnel qualifications relative to welding operations perfomed.
1.
Examination of welding materials storage area and review of materials issue system.
3.
Findings a.
Deviations from Commitment (1) See Enclosure, Item B.
(2) See Enclosure, Item C.
(3) See Enclosure, Item D.
(4) The purchase order (P.O.) applicable to the referenced 0.045 inch SFA 5.18 E705-3 wire, P.D. 7-A-1336, made no reference to the additional test requirements imposed by Sub-Article NF-2400 of the ASME Code. Testing was required only in accordance with SFA 5.18 E70S-3 wit's results based on actual deposited weld metal; and the material was furnished to this requirement. This specification requires welding of the test cou;on to oe performed using an interpass temperature range of 300 + 250F, whereas the applicable NPS welding procedure specifications perm";ted a 4000F maxinum interpass temperature.
It was additionally noted that the QA Manual does not clearly address procurement and control of welding materials with respect to Section III requirements.
Paragraph 91.4.b) requires procurement of welding materials to Code SFA specifications.
Paragraph 9.1. 3.a),
however, stipulates that the Project Engineer is respon-sible for preparing and issuing welding criteria to assure that purchased welding materials comply with Code requirements.
The term, " Code" is defined in the NPS QA Manual Glossary asSection III, Division 1,
. of the ASME Boiler and Pressure Vessel Code.
Similarly, Paragraph 9.1.3.d) stipulates that the Quality Control Supervisor is responsible for weld metal tests as required by the Code. No procedure was present, however, in the Work Procedure Manual, which addressed testing of welding materials to NF-2400 requirements, nor was any Project Engineer welding criteria made available.
(See Enclosure, Item E.)
(5) The NPS quality system requires assignment of a Material Inventory Control (M.I.C.) number after acceptance of incoming material has been made, and is used to identify all accepted materials to a Certified Material Test Report or Certificate of Compliance. After assignment of a M.I.C. number the material is entered into inventory by the Material Techniciar and can be requisitioned for fabrication.
If the receiving system has been followed, welding material cannot enter inventory (controlled storage room) without assignment of a M.I.C. number.
During examination of the welding materials controlled storage area, the inspector made the following additional 3bservations:
(a) A small bundle of unidentified copper coated wire was present in the room.
(b) A spool of partially used weld wire had been returned to the storage area and not replaced in a plastic bag and resealed as is required by paragraph 9.1.4.d) of the QA Manual.
Examina-tion of unopened cartons containing spools of weld wire, revealed that the spools were not originally packaged in plastic.
This would appear contrary to the QA Manual, which states in part in paragraph 9.1.4.d), "... Damaged cartons shall be opened to verify their plastic seals are intact and resealed if required...." (See Enclosure, Item F. )
b.
Unresolved Items None.
, E.
Nonconfomances and Corrective Action 1.
Objectives The objectives of this area of the inspection were to verify that a system for control of nonconfomances and for assuring effective corrective actions has been established and implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 15.0, Revision 1, " Nonconforming Material or Items."
b.
Review of QA Manual, Section 16.0, Revision 0, " Corrective Action.
c.
Review of Work Frocedure No.15.0.1, Revision 0, " Nonconforming Material or Items."
d.
Review of Work Procedure No.15.0.2, Revision 0, " Disposition of Rejected Material or Items."
e.
Review of Work Procedure No. 16.0.1, Revision 0, " Corrective Action.
~
f.
Examination of Nonconfomance Report Log.
g.
Examination of two (2) current Nonconformance Reports with respect to:
(1)
Identification of item and description of nonconformance.
(2)
Identification of reporting party and personnel responsible for resolution.
(3) Disposition of nonconformances in accordance with program commitments.
(4) Evidence of management participation in nonconformance report and corrective action review.
(5) Analysis of nonconformances and detemination of required corrective action.
(6) Assigned responsibilities are carried out in an effective manner.
. h.
Location of nonconforming items referenced in g. above and examination of shop floor handline, practices relative to QA program commitments.
3.
Findings a.
Deviation from Comitment Work Procedure No.15.0.1.,>ermits and defines four (4) types of disposition of reported nonconfonnances i.e. Use-as-is, repair, rework and reject.
Paragraph 3.1 in Work Procedure No.15.0.2. requires material or items dispositioned as " reject" by the Project Engineer to be tagged with a Reject Tag and moved to a segregatec' reject storage area to anit an ultimate disposition.
Paragraph 3.2 requires Quality Control to verify the item has been moved to the reject area, and so note on the "close-out" portion of the NCR.
Paragraph 3.3 requires a review of rejected items to determine their ultimate disposition.
Paragraph 3.5 permits four (4) types of ultimate disposition i.e. scrap (material or items shall be eliminated from the system), returned to vendor, returned to inventory, and non-code use.
Paragraph 3.4 requires preparation of a work instruction after review of the material or item, indicating the ultimate disposition of the rejected material or item.
Paragraph 3.6 requires attactment of the work instructions to the NCR and Quality Control verification of the ccmpleted ac ti on.
Contrary to 'he above, the inspector observed the following with re::pect to Nonconfonnance Report (NCR) Nos. 021 and 022:
(1) The recomended disposition by the Production Engineer was scrap, which is not one of the four (4) types pennitted by Work Procedure No.15.0.1.
(2) The Engineering Review section of the NCRs was blank, other than it had been initialled and dated,
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