ML19261D986
| ML19261D986 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1978 |
| From: | Barnes I, Hunnicutt D, Roberds H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19261D976 | List: |
| References | |
| REF-QA-99900066 99900066-78-3, NUDOCS 7906290716 | |
| Download: ML19261D986 (12) | |
Text
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4 U. 9. NUCLEAR REGULATORY COMMI3SION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900066-03 Program No.
51300 Company:
Texas Pipe Bending Company Post Office Box 5188 Houston, Texas 77012 i
Inspection Conducted:
December 11-15, 1978
/2/2 7 /7f Thspectors:
I. Barnes, Contractor Inspector, Vendor Date Inspection Branch
/ 2./2.y/7F
[ II. W. Roberds, Contractor Inspector, Vendor Date Inspection Branch
/2 /29 /7f' Approved by:
p D. M. Hunnicutt, Chief, ComponentsSection II, Date Vendor Inspection Branch Summary j
Insoection December 11-15, 1978 (99900066/78-03) i Areas Insoected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards, including action on previous inspection i
findings; manufacturing process control; material identification and l
control; and nondestructive examination (radiography, liquid penetrant and i
personnel qualifications). The inspection involved forty-eight (48) inspector-hours on site by two (2) NRC inspectors.
Results:
In the four (4) areas inspected, no unresolved items were identified; the following deviations were identified in the four (4) areas:
Deviations: Action on Previous Inspection Findings - Training procedure not revised as committed (Enclosure. Item A); handling and storage not accomplished in accordance with applicable approved procedures as required by Criterion XIII of 10 CFR 50, Appendix B, and Section 4 of the QA Manual (Enclosure, Item B); minutes of training session not maintained as required by Criterion II of 10 CFR 50, Appendix B, and i ocedure TIP-1 Revision 0 (Enclosure, Item C).
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1 Manufacturing Process Control - Shielded metal arc weld repairs made to welded pipe without specification of or evidence of use of a qualified weld repair procedure, as required by Criterion IX of 10 CFR 50, Appendix B and Section 5 of the QA Manual (Enclosure, Item D).
Material Identification and Control - Acceptance of Material Test Report with data showing wet magnetic particle examination was not performed in accordance with applicable procedure, not consistent with Criterion VII of 10 CFR 50, Appendix B, and Section 3 of the QA Manual (Enclosure, Item E).
Hondestructive Examination (Radiography, Liquid Penetrant and Personnel Qualification) - Use of a film side penetrameter when material being examined was readily accessible for hand placement of a source side pentrameter, not in accordance with Criterion V of 10 CFR 50, Appendix B, Section V of the ASME Code and radiographic procedure RT-2 (Enclosure, 8
Item F).
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. DETAILS SECTION I (Prepared by I. Barnes)
A.
Persons Contacted
- B. A. Graham, Exeer M2 Vice Pro ident l
- G. R. Shepherd, VR %ident. Contracts and Procurement
- A. T. Cureton, Vice Pror dent, Nnufacturing
- R. L. Pearson, Vice Predident, Engineering
- W. W. Trujillo, Assistant Manager, Quality As:wrance
- L. W. Hensley, Manc.* *, Power Engineering
- B. V. Kielman, Supe!* f sor, Quality Control
- T. R. Dismukes, Manager, Pipe Mill M. J. Hewlett, Welding Engineer
- R. P. Meineke, Manager, Quality Control
- D. Snider, Foreman, Pipe Mill M. R. Wood, Supervisor, Documentation B.
, Action on Previous Inspection Findings 1.
(Closed) Deviation (Inspection Report No. 78-01, Item A of Enclosure): Approval of WPS for applications with specified notch toughness applications, which permitted increases in amperage above the range qualified by the supporting PQR.
The inspector verified that the committed WPS revision and indoctrination session had been perfonted.
i 2.
(Closed) Deviation (Inspection Report No. 78-01, Item B of Enclosure): Management audits of QA Department performance and program effectiveness not being conducted annually.
4 The inspector verified that the committed QA Manual changes
}
relative to management overview had been performed and implemented.
3.
(Closed) Deviation (Inspection Report No. 70-01, Item C of Enclosure):
Followup action not taken by QA after failure to receive an appropriate corrective action statement for an internal audit finding.
This finding has been closed on the basis that the cited internal audit finding was subsequently resolved by Texas Pipe Bending Company (TPB).
Failure of iPB to perfonn comitted corrective actions is reflected in an additional dev'.ation from commitment.
(Sce Enclosure, Item A).
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. 4.
(Closed) Deviation (Inspection Report No. 78-01, Item D of Enclosure): Control of handling and storage not accomplished in accordance with approved procedures.
This finding has been closed on the basis of TPB QA Manual 3
revision to reflect stated intent.
Further review of this subject, however, in the context of this QA Manual change and contractual and Code requirements, have indicated the following further deviation from commitment.
Paragraph 4.0 in customer specification, 9645-G-QA-1, requires the TPB quality assurance program to cover Criterion XIII of 10 CFR SC, Appendix B.
Both Criterion XIII and NCA-4134.13 in I
Section III of the ASME Code require measures to be established relative to control of handling and storage in accordance with instructions, to prevent damage or deterioration.
Paragraph 4.13 in customer specification, 9645-G-QA-1, also states in part,
" Instructions shall be prepared, distributed, and followed for handling, storing... in order to prevent da:aage, deterioration, i
or loss. Such instructions shall provide all information necessary... for the appropriate... handling,...
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protect,i,on against... corrosion, avoidance of undue stressing Contrary to the above, instructions have not been prepared as part of the TPB quality assurance program relative to the i
control of handling and storage.
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It was additionally noted by the inspector that a total of thirty-two (32) Nonconformance Reports had been generated in 1978 as a result of handling damage at the TPB facility.
(See Enclosure, Item B.).
5.
(Closed) Deviation (Inspection Report No. 78-01. Item E of Enclosure): Control of water for steam cleaning not in accordance with customer specification requirements.
The inspector verified that Revision 20 of the custcmer specification deleted the requirements relative to water to be used for steam cleaning.
6.
(Closed) Deviation (Inspection Report No. 78-01, Item F of Enclosure): Revision number of approved welding procedure not being recorded on shop drawing.
The inspector verified that the committed instructions and training had been given. A sample of twelve (12) current drawings was also taken to assure that procedure revision numbers are now being recorded.
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(Closed) Deviation (Inspection Report No. 78-01, Item G of Enclosure):
Failure to develop and implement comitted formal training program.
This finding has been closed on the basis of the development of a formal training program by TPB. During this inspection, however, a deviation from commitment relative to implementation of the training program was identified.
(See Enclosure, Item C.).
8.'
(Closed) Deviation (Inspection Report No. 78-02, Item A of Enclosure):
Resolution of observed welding material qualification data deficiency not accomplished.
The inspector verified that the relevant information had been submitted to the AE for evaluation.
It was also verified that TPB had made a review of previous corrective action comitments and made inclusions in the internal audit check lists relative to measurement of status.
9.
(Closed) Deviation (Inspection Report No. Ja-02, Item B of Enclosure): Copy of drawing transmittal returned by QC not furnished to the Engineering Clerk.
The inspector verified that the comitted actions relative to review and instruction had been performed.
10.
(Closed) Deviation (_ Inspection Report No. 78-02, Item C of Enclosure):
Control of temporary attachment material not consistent with QA Manual commitments.
The inspector verified that the committed corrective actions had been taken and that present practices were consistent with program commitments.
11.
(Closed) Deviation (Inspection Report No. 78-02, Item D of Enclosure): Maintenance checks of a welding station not performed j
at the required frequency.
The inspector verified that present checks were in accordance with commitments and that the internal audit check list had been modified to include monitoring of this activity.
12.
(Closed) Unresolved Item (Inspection Report No. 78-02, B.10): Absence of documented evidence of Quality Management review of vendoc nonconfonnance files.
The inspector verified that a procedure had been prepared relative to nonconformance report review and that documented evidence of review had been initiated.
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Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that the manufacturing process is controlled in accordance with applicable regulatory, code and contract requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
I 1
a.
Review of QA Manual, Section 4, Revision dated through May 18, i
1978, "In-Process Control."
b.
Examination of Fabrication Control Sheets for four (4) assemblies and Manufacturing Control Sheets for eight (8) items of welded pipe relative to:
(1) Definition of manufacturing procedures used to perform scheduled manufacturing operations.
(2) Verification that completed operations had been signed off.
(3) Ascertaining that manufacturing records were consistent with observed status of components.
(4) Compliance with specified Authorized Nuclear Inspector hold points.
(5) Comparison of procedures used against procedures designated as approved.
(6) Review for performance of required examinations and tests at an applicable manufacturing stage.
c.
Verification that listed procedures had been approved, as required, by the client.
d.
Review of welding personnel qualifications relative to welding operations performed.
e.
Comparison of welding materials used relati, APS t wenents.
f.
Verification that materials used in the assecc'ies had been released in accordance with the QA program.
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. 3.
Findings a.
Deviation from Commitment Operation 10 on the Manufacturing Control Sheet for Job No, M1048-N, Item No. 2, required repair of visual defects j
per kR-1, Revision 0, using E 7018 electrodes, Heat No. NNN 081.
This operation was signed off on October 25, 1978, by the I
welder and QC.
Examination of WR-1, Revision 0, revealed that it was a general procedure for elimination and repair of weld metal defects and not a qualified welding procedure specification (WPS). This procedure required a qualified WPS to be used for perfonaing repairs and a record made of the WPS used.
Such a record was not made on the Manufacturing Control Sheet for the referenced item, nor was any infonnation made available to the inspector relative to what criteria had been provided to the welder for the control of weld repairs.
(See Enclosure, Item D.)
b.
Unresolved Items i
None.
c.
Comments Sections 4 and 5 of the QA Manual were not clarified in Revision 3 of the QA Manual to reflect the different system adopted for control of manufacturing processes and welding in the new pipe mill.
D.
Material Identification and Centrol i
1.
Objectives The objectives of this area of the inspection were to verify that material identification and control during manufacturing were in accordance with applicable regulatory, code and contract requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Revision 3, Section 3, " Procurement and Receiving Inspection."
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. b.
Review of QA Manual Revision 3, Section 4, "In-Process Control."
c.
Examination of five (5) assemblies at different stages of fabrication relative to component identification.
d.
Comparison of identity with identity entered on Shop Drawings.
e.
Review of purchase orders for referenced components with respect to compliance with procurement system.
f.
Verification that materials were procured from companies contained in the Approved Vendors List.
g.
Verification that welding materials used in fabrication of the assemblies were on the approved listing.
h.
Examination of electrode ovens relative to identity segregation.
1.
Review of Certified Material Test Reports for welding materials and components in referenced assemblies relative to acceptance by TPB and to verify compliance with procurement documents.
3.
Findings a.
Deviation from Commitment The Material Test Report for a 10" Schedule 80 X 1" Schedule 160 fitting, which was installed in Job No. N1789, sketch 352 (ASME Section III, Class 1, Main Steam System) showed that a wet magnetic particle examination. had been performed using 2500 ampere-turns and 800 circular amps. The applicable procedure was identified as SWL MT-2-75 Revision 1.
This procedure permitted the use of two (2) formulae for determination of coil ampere-turns, i.e. 35,000 divided by the sum of 2 plus the length-over-diameter (L/D) ratio of the test part, or, 45,000 divided by the L/D ratio if a larger fixed size coil was used.
The L/D ratio for the test part in question was 3/4.
Utilization of this ratio value in both formulae produces ampere-turn values, respectively, of 12,727 and 60,000. Calculation of required amperage is performed by dividing the ampere-turn value by the number of turns in the coil used. This value was not recorded on the Material Test Report, precluding evaluation of the adequacy of the 800 amps used for performing the examination.
(See Enclosure, Item E. ).
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b.
Unresolved Items None.
E.
Exit Meeting The lead inspector met with the management representatives denoted in paragraph A. above on December 15, 1978, at the conclusion of the inspection. The scope of the inspection and the findings were discussed with management representatives present.
Particular emphasis was placed on the finding identified as item B. in the Enclosure of this l
report. Management acknowledged the statements of the inspector j
relative to the inspection findings.
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DETAILS SECTION II (Prepared by H. W. Roberds)
A.
Persons Contacted W. W. Trujillo, Assistant Manager Quality Assurance B. V. Kielman, Supervisor, Quality Control L. W. Hensley, Manager, Power Engineering V.Votaw, Supervisor, Radiography i
B.
Nondestructive Examination (Radiography, Liquid Penetrant and Personnel Qualification) 1.
Objectives t
l The objectives of this area of the inspection were to verify that the QA program is consistent with Regulatory and Code requirements as follows:
a.
Nondestructive examination is performed in accordance with approved procedures.
b.
Nondestructive examination procedures meet the requirements of Section V of the ASME Code.
c.
Test results are interpreted by qualified personnel.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 6 of the QA Manual, Revision 1 of July 11, 1977.
b.
Review of the following procedures:
(1) Liquid Penetrant Examination Procedure, QT-2, Revision 1 of December 22, 1977.
(2) Magnetic Particle Examination Procedure, MP-2 of September 16, 1974.
(3) Radiographic Procedure, RT-2, Revision 1 of May 26, 1976.
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..., c.
Review of NDE Personnel Qualification and Certification records.
d.
Review of fifty-four (54) production radiographs for purchase order P-85988-30N.
e.
Interviews with cognizant personnel.
3.
Findings a.
Deviation from Commitment The TPB corrective action letter dated July 22, 1977, states in response to the NRC letter dated June 22, 1977, "Please refe-to attachment memorandum dated July 19, 1977, which explains the actions taken to prevent recurrence."
i The attached memorandum of July 19, 1977 states the following actions taken to prevent recurrence:
1.
The supervisor of radiography will review the shop drawing of nuclear construction, prior to radiograpi,y, to determine when source side penetrameters are required.
He will advise his m bordinates of the results of his review and advise them when source side penetrameters are required. When the supervisor of radiography is not available to review the shop drawings to determine when source side penetrameters are required, the responsible radiographer shall make this determination. The responsible radiographer's entry of his initials or name on the radiographic report form, in the " technician" block shall designate that he has reviewed the piping sub assembly and the shop drawing and that source side peretrameters have been used "when the material being examined is accessible for hand placement of source s'ide penetrameters."
2.
When the radiographs are evaluated the Level II or Level III examiner shall review the shop drawing and film to determine if source side penetrameters are required and used. The Level II or III signature is in the " interpreted by" entry on the radiographic report form shall designate that source side penetrameters have been used "when the material being examined is accessible for hand placement of source side penetrameters."
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A nonconformance report shall be initiated by the Level II or III examiner when it is determined that a film side penetrameter has been used, when it was possible to use a source side penetrameter. The nonconformance report shall be sumitted to the Manager of Quality Assurance for his disposition in accordance with Section 9 of the Quality Assurance Manual.
4.
The supervisor of documentation shall monitor the shop drawings and the radiographic r6 port for compliance for the use of source side penetrameters.
If it is suspected that a film side penetrameter was used, when it was possi5le to use a source side 'enetrameter, the Manager of Quality Assurance or the Level III examiner shall be l
contacted for resolution.
l Contrary to the above, committed reviews by the supervisor of I
radiography and the Level II or III examiner and monitoring by the supervisor of documentation were not performed on Job No.
M1048-N, Items 1, 2, and 3 in that a film side penetrameter was used without initiation of a Nonconformance Report, when the material being examined was readily accessible for hand placement of a source side penetrameter.
The inspector further observed that the selection of the film side penetrameter used for radiography was not in accardance with Table 1X-3325-1 of ASME Section III,1971 Edition including addenda through Summer 1973, invoked by Purchase Order D-85988-30N.
It should be noted that manufacture of welded pipe is performed l
in accordance with a Manufacturing Control _ Sheet and not the l
shop drawing utilized in pipe fabrication. This Manufacturing Control Sheet fully defines required pipe dimensions.
b.
Unresolved Items None.
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