ML19261B473
| ML19261B473 | |
| Person / Time | |
|---|---|
| Issue date: | 08/24/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19261B464 | List: |
| References | |
| REF-QA-99900205 99900205-78-1, NUDOCS 7902230155 | |
| Download: ML19261B473 (2) | |
Text
Process Equipment Company, Inc.
Docket fio.
99900205/78-01 NOTICE OF DEVIATION Based on the results of an flRC inspection conducted on. gust 1-4, 1978, it appeared that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
A.
Criterion XVI of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that conditions adverse to quality
... and nonconformances are promptly identified and corrected The identification of the significant condition..., the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
In addition to the above, ASME Code,Section III, Subarticle NCA-4134.16, Part (c), states, "The requirements shall also extend to the perforiance of the subcontractor's corrective action measures."
Contrary to the above, the Process Equipment Company, Inc. (PEC0)
Quality Assurance Manual does not address the requirements being extended to the perforrance of a subcontractor's corrective action measures.
B.
Criterion VIII of Appendix B to 10 CFR 50 states in part, " Measures shall be established for the identification and control of materials, parts, and components,....
These measures shall assure that identification is maintained by heat number, part number, serial number, or other appropriate means, either on the item or on records trace-able to the item..
ASME Code,Section III, Subsection NB, NC, ND and NE, paragraph 4435 states in part, " Temporary or minor permanent attachments... may be noncertified material and may be welded to the pressure retaining part... provided... the material is identified and is suitable for welding."
Contrary to the above, unidentified temporary attachments were welded to four (4) pressure retaining parts for encapsulation vessels (Jobs 5918A, 59188, 5918C and 5891).
C.
Criterion VIII of Appendix B to 10 CFR 50 states in part, " Measures shall be established for the identification and control of materials These identification and control measures shall be designed to prevent the use of incorrect or defective material, parts, and components."
7902230/67 QA Manual Section VII, paragraph 7.1.4 states in part, " Welding materials will be stored, according to classification, in locked, storage areas.
Welding material will remain in their sealed containers until use is required.... Welding electrodes once removed from their sealed containers will be transferred to holding ovens which are located in a locked and controlled area....
The identifi-cation of welding materials must be maintained by heat and/or lot number at all times." This is accomplished in the storage area holding ovens by designating the type electrode and heat number on the ovens.
Contrary to the above:
1.
The identification of weld materiais was not maintained, in t..u oven number 11 indicated Types 7018, 8018, 308 and 308L electrodes only, and a 1/8 inch type 309 electrode was found mixed in with the 1/8 inch type 308 electrodes.
Oven number 12 indicated Type 7018 electrodes only, and five (5) 1/8 inch type 8018 electrodes were found mixed in with approxi-mately thirty-five (35),1/8 inch type 7018 electrodes.
2.
Welding electrodes removed from their sealed containers were r,ot transferred to holding ovens in that the locked storage cabiaet marked " Nuclear," contained two (2), open, nearly full, fif ty pound containers of Type 9018 electrodes:
1/8 inch, heat number 07LO41 and 5/32 inch, heat number 492L4871.
D.
Criterion IX of Appendix B to 10 CFR 50 states in part, "P.easures shall be established to assure that special processes, ilcluding welding,... are controlled and acccrhplished by qualiiied personnel QA Manual Section VII, paragraph 7.1.3. states in r, art, " Renewal of a welder or welding operators performance qualifications shall be required when a welder or welding operator has r.at used a specific process for a period of three months or more.... The Quality Control Manager shall be responsible for reviewing w'iich welders / welding operators require requalification.
The method of review will be by the Quality Control Manager maintaining a daily log of all welders and the app-licable processes which they use in orde.c to maintain an active 90-day certification for the welders to the evplicable processes which they used."
Contrary to the above, even thoagh a daily log of all welders is main-tained by the QC Manager, many cf the applicable processes recorded in the log as being used by the we'.ders are incorrect, thus the use of this log to maintain an active 90-day certification is nullified.