ML19261D984
| ML19261D984 | |
| Person / Time | |
|---|---|
| Issue date: | 01/04/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19261D976 | List: |
| References | |
| REF-QA-99900066 99900066-78-3, NUDOCS 7906290711 | |
| Download: ML19261D984 (3) | |
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Texas Pipe Bending Company Docket lio. 99900066/78-03
?!0TICE OF DEVIATI0il Based on the results of an NRC inspection conducted on December 11-15, 1978, it appeared that certain of you activities were not conducted in full comoliance with NRC requirements as indicated below:
A.
The Texas Pipe Bending Company (TPB) corrective action response letter of May 23, 1978, states with respect to Item C of Inspection Report No. 78-01, "Our QA Manual references a Training Procedure.
This procedure has been revised to require responsible individuals to provide a writter response within two weeks, after they become aware of a finding that involves a deviation from commitment."
Contrary to the above, the training procedure was not revised to require a written response from responsible individuals within two weeks after they become aware of a finding that involves a deviation from commitment.
B.
Criterion XIII of Appendix B to 10 CFR 50 states in part, " Measures shall be established to control the handling, storage... and preservation of material and equipment in accordance with work and inspection instructions to prevent damage or deterioration...."
Section 4 of the QA Manual, paragraph 4.9, subparagraph 2., states in part, " Handling,... storage,... shall be accomplished in l
accordance with approved procedures as applicable...."
Contrary to the above, handling and storage were not accomplished in accordance with applicable approved procedures, in that appropriate procedures had not been developed as of the date of this inspection.
l (See DetailsSection I, B.4.).
This is a repeat deviation, first identified in Inspection Report No. 78-01.
i Criterion II of Appendix B to 10 CFR 50 states in part, "... The C.
program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained..."
Paragraph V. B. in procedure, TIP-1 Revision 0, states in part, "The Department Manager shall conduct the following training of personnel reporting to him:
1.
Training classes shall be conducted on... QA Manual revisions not later that 30 days after the training session covered in
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. IV above..." Paragraph V.c. states, "It is the respo
< ili ty of the department manager to maintain minutes of each trc Wg class. The minutes shall include as a minimum the subjet.; covered, personnel attending, and dates."
Contrary to the above, minutes were not maintained by the department manager for the pipe mill to indicate training sessions had been conducted relative to Revision 3 of the QA Manual.
It should be noted that the primary purpose of this revision was to incorporate the pipe mill activities into the QA program.
D.
Criterion IX of Appen^
to 10 CFR 50 states in part, "Mcasures shall be established ;.;sure that spe;;ial processes, including welding,
... are controlled e accomplished... using qualified procedures l
in accordance with c,.,.licable codes..."
Section 5 of the QA Manual, paragraph 5.5.2, subparagraph 1, states in part, " Unacceptable defects in weld metal shall be repaired by a qualified weld repair procedure..."
Contrary to the above, shielded metal arc weld repairs were made to Job No. M1048-N, Item No. 2, without specification of or evidence of use of a qualified weld repair procedure.
(See DetafisSection I, C.3.a.).
E.
Criterion VII of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents...."
Section 3 of the QA Manual, paragraph 3.7, subparagraph 2, states, "Upon receipt, all MTR's are forwarded to Quality Ass.orance for checking."
Subparagraph 3 states, " Quality Assurance compares the MTR with the Purchase Order specification and if satisfactory, stamps " Reviewed for Purchase Order Compliance."
Contrary to the above, an MTR (Material Test Report) for a fitting (Heat No. 128AN, S/N MT-159), which was observed by the inspector installed in an ASME Section III Class 1 3ssembly, was stamped " Reviewed for Purchase Order Compliance," although th data on the MTR indicated that wet magnetic particle examination of the fitting had not been performed in accordance with the Purchase Orde.c specification.
(See DetailsSection I, D.3.a.).
F.
Criterion V of Appendix B to CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the cire,umstances and shall be accomplished in accordance with these instructions, procedures, or drawings... "
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. Paragraph T-262.2 of Article 2, ASME,Section V, states in part,
"... where inaccessibility prevents hand placing the penetrameter on the source side, a film side penetrameter shall be placed on the film side of the joint...."
Texas Pipe Bending Company Radiographic Pre edure RT-2, paragraph 3
B.3, states in part, "A penetrameter shall ae placed on the side of the material nearest the radiation source whenever practical...."
Contrary to the above, Job Nos. M1048-N-1, M1048-N-2 and M1048-N-3 were radiographed using a single wall technique and a film side penetrameter, when the source side of the material being examined was readily accessible for hand pla. ament of a source side penetrameter. A similar deviation was identified in both Inspection Report No. 76-03 and 77-01 (See Detail Section II, Item B.3.a.).
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1 21;7 337 Il
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