ML19260C285
| ML19260C285 | |
| Person / Time | |
|---|---|
| Issue date: | 03/28/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19260C234 | List: |
| References | |
| REF-QA-99900019 99900019-79-1, NUDOCS 7912260150 | |
| Download: ML19260C285 (2) | |
Text
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ITT Grinnell Industrial Piping, Incorporated Docket No. 99900019/79-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on February 26 -
March 1,1979, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
A.
Criterion III of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis... are correctly translated into specifications, drawings, procedures, and instructions...."
Paragraph 3.3 in Gibbs & Hill, Inc., Specification No. 2323-MS-43A, Revision 3, states in part, "The fabrication,... and testing require-ments included in this specification shall be in accordance with...
' Control of the Use of Sensitized Stainless Steel'...."
Paragraph C.2. in Regulatory Guide 1.44 states, " Material from which components and systems are to be fabricated should be solution heat treated to produce a non-sensitized condition in the material." Para-graph C.5. states in part, " Material subjected to sensitizing tempera-tures in the range of 800 to 15000F during heat treating or processing other than welding, subsequent to solution annealing... should be retested to demonstrate that it is not susceptible to intergranular attack...."
This applies to hot bending of austinitic stainless steel made to a radius of five, or greater, pipe diameters as well as to the hot bending to a radius of less than five pipe diameters.
Contrary to the above, the inspector ascertained relative to seventy-four (74) austenitic stainless steel hot bends (subjected to a tem-perature range of 800 to 15000F during cooling from the bending temperature range), in the process of manufacture and incorporation into assemblies for Contract No. 7124 (Comanche Peak), that:
Job Specification JS-136-10, common to Gibbs & Hill specification number 2323-MS-43A, did not require either solution annealing heat treatmcat, or intergranular corrosion testing to be performed on austenitic stainless steel hot bends nede to a radius of five (5) or greater pipe diameters.
Moreover, concerning the above paragraph, the Operations Records (manufacturing process sheets) for the affected assemblies did not provide instructions for either a solution annealing heat treatment of the hot bends, or, an intergranular corrosion test to be performed.
(See Details 'ection, paragraph B.2.)
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. B.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including
... heat treating... are controlled and accomplished... using qualified procedures in accordance with applicable codes, standards, specifications...
Paragraph C.2. in Section QCN-8.1, Revision 2, of the QA Manual states, " Heating rates, holding times and temperatures and cooling rates, etc. shall be controlled in accordance with applicable ITT Grinnell Industrial Piping, Incorporated Standard Specifications."
Contrary to the above, postweld heat treatment was performed on Cor. tract No. 7082, Register No. SB-80-3X, using heating and cooling rates that were not in accordance with the applicable ITT Grinnell Industrial Piping, Inc. specification (See Details Section, C.3.a.(1)).
C.
Criterion V of Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, pro-cedures, or drawings,... and shall be accomplished in accordance with these instructions, procedures, or drawings...."
Paragraph VI.B. in bending procecure specification, BF-K-111-2, applicable to Contract No. 7124, states, "The ovality of each bend shall be measured in three or more locations and recorded on the operations record."
Contrary to the above, the inspector observed that bends had been perfonned on Contract No. 7124, Register Nos. PZ-CTR-35-147X, PZ-CTR-25-154X and PZ-CTR-21-138X, without recording ovality measure-ments on the applicable operations records.
D.
Criterion VII of Appendix B to 10 CFR 50 states in part, " Measures shall be establihsed to assure that purchased material, equipment, and services, whether purchased directly or through contractars and subcontractors, conform to the procurement documents...."
Note 3 in the General Notes for Customer Specification 7220-M-481, Revision 12, states, " Class ELB-Impact test pipe, fittings and associated welding filler metal at 300F in accordance with Nuclear Power Plant Components Code, Article NB 2300, and I;C 2300." Article NB 2300 permits only one Charpy-V notch retest.
Contrary to the above, more than one impact test was performed on 18 inch Schedule 80 SA-106 Grade B pipe, Heat No. N32762 (utilized in fabrication of Contract No. 7093, Register No. MR-04-15AX), which was not in accordance with the permissible retest provisions of Sub-Article NB-2350 in the ASME Section III Code (See Details Section, C.3.a(3)).
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