ML19259D646
| ML19259D646 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19259D643 | List: |
| References | |
| REF-QA-99900259 99900259-79-1, NUDOCS 7910250220 | |
| Download: ML19259D646 (3) | |
Text
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Combustion Engineering, Inc.
C. E. Avery Division Docket No. 99900259/79-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on June 25-29, 1979, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
A.
C-E Avery's letter of corrective action dated December 7, 1978, states in part, "... The format of the Detailed Welding Procedure (Form No. 252) is presently being reviewed for revision to include every essential and nonessential variable required by paragraphs QW-252 through QW-282 of Section IX.
The revisions (format) to released DWPs will be completed by the first quarter of 1979.
The DWP form will be revised i,eriodically to include any changes neces-sitated by addenda to Section IX...."
Contrary to the above, revisions to all released DRPs have not been completed in that there are approximately fifty (50) DWPs that have yet to be revised.
They are identified by the following alpha designations: WMC, HS, BMR, WMB, IW, and RP.
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 with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
ASME Code Section III, NB, NC, and ND-4125, states, "All welding and brazing material shall meet the requirements of NB-2400. "
NB, NC, and ND-2420 states in part, "The required tests shall be conducted... for each combination of heat of bare electrodes and lot of submerged are flux.
QA Manual Section 14.0, paragraph 2. 4, states in part,
. Issue welding material to weld Engineering for the testing required by the ASME Code and contract.
Upon receipt of satisfactory test results, Weld Engineering shall add the material to the ' Welding Material Control Lists' (WMCL). " The WMCL is used by General Services and Manufacturing to assure that only qualified welding materials are issued to welders / welding operators.
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2-Contrary to the above, unqualified welding materials were listed on the WMCL and were being used in a submerged are welding (weld metal cladding) operation on Job No. 2270141, Safety Injection Tanks.
There were no test reports to show that the combination of wire, Type ER 304L, heat number 40609, and flux, Type CE 700, lot number JCJH, had been tested and qualified.
It was ascertained that certain testing had been performed; however, all required testing had not been accomplished.
C.
C-E Avery's letter of corrective action dated December 7,1978, states in part, " Detailed Welding Procedures Numbers W3C-15-6, Revision 01, and WMC-10-7, Revision 01, have been requalified and upgraded to forty (40) hours time at temperature. All other welding procedures, related to postweld heat treatment, have been reviewed and are in compliance Contrary to the above, all other welding procedures related to post-weld heat treatment (PWHT) had not been reviewed and were not in compliance.
Detailed Welding Procedure Number WMC-10-5, Revision 00, was quali-fled for PWHT at eighteen (18) hours at temperature, as shown by PQRs SMA-8.3-WMC-lG-1, and -2G-1.
This tLae at temperature qualifies up to twenty-two. and one-half (22 1/2) hours at temperature' for production heat treatment when using this DWP.
Reactor Coolant Pump Casing S/N 7 for Job 158 had welding performed on it using DWP WMC-10-5, which is a shielded metal are welding process for veld metal cladding.
A review of heat treat chart numbers78-079, 78-091,78-099, and 78-105, all applicable to S/N 7, revealed accumulated PWHT time at temperature of twenty-nine and one-half (29 1/2) hours.
This exceeds the maximum allowable time by seven (7) hours.
(See Details Section, paragraph B.10.)
D.
Criterion II of Appendix B to 10 CFR 50 states in part, ".
The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
Manuf acturing Engineering Procedure ENG-P-022, revision 02, paragraph 3.2, states in part, " Continuing training of Engineering Personnel.
All Engineering Department employees shall be on distribution lists for documents pertaining to revision of the Quality Assurance Program and shall acknowledge review of the documents by initialing and dating the distribution lists.
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3 Contrary to the above, Engineering Department est,loyees were not placed on distribution for QA Manual revisions 9 and 10, dated July 24, 1978, and April 13, 1979, respectively, until the week of June 25, 1979, and as a result, all of the employees had not initialed and dated the distribution list to show acknowledgment.
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