ML19263B535
| ML19263B535 | |
| Person / Time | |
|---|---|
| Issue date: | 10/13/1978 |
| From: | Barnes I, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263B527 | List: |
| References | |
| REF-QA-99900021 NUDOCS 7901180362 | |
| Download: ML19263B535 (14) | |
Text
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VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900021/78-02 Program No.
44020 Company:
Pullman Power Products Division of Pullman,. Incorporated Post Office Box 3308, Reach Road Williamsport, Pennsylvania 17701 Inspection Conducted:
September 25-29, 1978 m/IJ/73 Inspectors:
-c o
- 1. Barnes, Contractor Inspactor, Vendor Date Inspection Branch hl mr m. W
/0//3/ ll D. M. Hunnicutt, Chief, ComponentsSection II, Datei Vendor Inspection Branch Approved by:
97/,'l'[y..,a,#
/o//S/78 D. M. Hunnicutt, Chief, ComponentsSection II, Date/
Vendor Inspection Branch Summary Inspection on September 25-29, 1978 (99900021/78-02)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards, including action on previaus inspection findings; manufacturing process control; material identifnation and control;
'and vendor audits. The inspection involved sixty (60) inspector-hours on site by two (2) NRC inspectors.
Results:
In the four (4) areas inspected, no apparent deviations or unresolved items were identified in two (2) areas; the following deviations were identified in the remaining areas:
43803R Deviations:
Action on Previous Inspection Findings - Failure to take committed corrective actions relative to deviation B in IE Report No. 78-01 (Enclosure, Item A).
Manufacturing Process Control - Selection of pipe for use in a bending application not consistent with Criterion IX of 10 CFR 50, Appendix B, and customer specificatica requirements (Enclosure, Item B); use and approval of process sheets not consistent with Criterion V of 10 CFR 50, Appendix B, and QA Manual commitments (Enclosure, Item C.).
P
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. DETAILS SECTION I (Prepared by I. Barnes)
A.
Persons Contacted
- R. F Howard, Vice President
- E.
. Genfin, Director of Quality Assurance
- J. J. Krommenhoek, Acting Plant Manager
- T. Daniels, Plant QA Manager
- J. A. Koch, Jr., Manager - Manufacturing Engineering
- R. I. Boyer, Welding Engineer, Central Staff L. A. Christ, Administrative Assistant J. Johns, Project Engineer V. W. Messner, Code Engineer
- F. J. Richards, Welding Engineer, Williamsport Plant
- R. A. Stryker, QA/QC Supervisor J. R. Weaver, Project Engineer
^H. J. Donlin, Authorized Nuclear Inspection Specialist, Hartford Steam Boiler Inspection and Insurance Company
- R. H. Wertz, Authorized Nuclear Inspector, Hartford Steam Boiler Inspection and Insurance Company
- Attended Exit Meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Inspection Report No. 77-02):
Out-of-calibration tools uecd oy manufacturing personnel may not be identifiable, as evidenced by the observation of a tool being loaned to other personnel by the assigned holder of the tool.
The inspector ascertained that Section XII of the QA Manual, paragraph 5.0, had been revised to require recording of the serial number of the inspection tool used by QC on an Inspec-tion Record, which is maintainea in the traveler package.
The inspector verified by examination of six (6) transfer packages, that inspections were being performed in accordance with present QA Manual commitments and after machining, allowing identifica-tion of machinists gages.
2.
(0 pen) Deviation (Inspection Report No. 78-01):
Use of un-identified temporary attachments, without evidence on the Weld History Record of the identity of the welder, welding procedure or welding materials used to weld the attachments.
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The inspector verified that Pullman Power Products (PPPA) had identified materials in storage for use as temporary attach-ments, with regards to material type.
It was established that written instructions had been issued by the Plant Welding Engineering Department to provide for deter-mination of attachment material suitability and compatibility for welding to a component. A training session was documented for July 13, 1978, with affected supervision and inspectors, which discussed the finding and the requirements for compliance to the applicable Shop Procedure.
It was also noted that two audits had been performed by Plant QA staff on September 7 and 22, 1978, which encompassed control of temporary attachments.
Sampling of traveler packages confirmed that documentation of welding of attachments on the Weld History Record had been initiated.
Implementation of the committed steps to prevent recurrence could not be verified, however, in that:
a.
The welding in-process inspection form used by PPPA did not address temporary attachments, nor could it be clearly ascertained how the in-process inspection format provided for compliance with committed corrective actions.
b.
The QA Manual recognizes and addresses only audits performed by the QA Auditor - Central Staff or his designated represent-ative, and requires performance in accordance with a written procedure. The applicable procedure, XVIII-lW, revision dated July 17, 1978, did not address in the referenced check list, verification of control of temporary attachments.
c.
A procedure describing criteria and frequency of internal audits performed by Plant QA staff was not available.
3.
(0 pen) Deviation (Inspection Report No. 78-01):
Certain produc-tion welding operations were observed being performed that were not in full conformance with the requirements of the relevant welding procedure specification (WPS).
The PPPA corrective action response letter of June 7,1978, comitted the following actions in response to deviation B in Inspection Report No. 78-01:
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. a.
Modification of WPS No. 27-III-8-08-12 to delete an Argon backing purge for Nipple to Pipe type weldments where the root pass is being removed by a drilling operation.
b.
Qualification of WPS No. 27-III-8-0B-12 using an increased amperage and voltage setting (PQR-028).
c.
A training session for the Welding Foreman and Welders, highlighting the deviation with respect to cleaning of weld beads and control of submerged arc welding speed and providing necessary corrective action.
d.
To prevent recurrence, compliance with corrective action to be verified by Quality Control Welding Inspection surveillance and steps to prevent recurrence to be a continual process of inspections and audits.
Contrary to the above, the inspector observed the following with respect to the referenced commitments:
a.
WPS No. 27-III-8-0B-12 had not itself been modified to delete the Argon backing purge, which would be required by QW-201.1 of the ASME Code,Section IX, for a nonessential variable change.
PPPA had actually prepared a blanket instruction sheet, Instruction Sheet #1, which deleted this requirement for all existing jobs in the shop.
b.
PQR-028 was n'ot applicable in terms of ASME Section IX requirements to WPS No. 27-III-8-0B-12, in that it was a carbon steel qualification and not an austenitic stainless steel required by the ASME Code, c.
Verification of a training session for the Welding Foreman and welders could not be made, in that there was no avail-able documentation to confirm a session was held, its date, subject matter or attendance.
d.
The welding in-process inspection form provided to the inspec-tor did not address verification of, either slag removal from weld beads during welding, or, correct travel speed in sub-merged arc welding.
e.
The checklist referenced by audit procedure, XVIII-lW, did not provide for detailed verification of compliance with WPS requirements.
(See Enclosure, Item A.)
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. 4.
(0 pen) Deviation (Inspectica Report No. 78-01):
Failure to fully qualify a certain welding procedure specification with respect to amperage supplementary essential variable require-ments.
Completion of corrective actions relative to this finding was not committed until after this inspection.
A partial review of corrective actions revealed, however, a potential problem in regards to compliance with ASME Section III Code requirements relative to impact testing of welding procedure qualifications.
Code requirements relative to specimen depth location were neither transmitted to nor referenced in the purchase orders sent to the testing laboratory.
Actual locations used by the laboratory were not known as of the laspection.
5.
(0 pen) Deviation (Inspection Report No. 78-01):
Failure to perform a required magnetic particle or liquid penetrant examination of a cavity resulting from weld defect removal to assure complete defect removal.
The inspector verified that the committed Repair Process Sheet had been initiated and the QA Manual (Section IX, paragraph 2.4) revised to address its use.
It was also noted that'a training session had been held on July 17, 1978, with NDE personnel, inspectors and supervision relative to QA requirements for defect removal and weld repair.
Implementation of the committed steps to prevent recurrence could not be verified, however, in that the steps consisted of verifica-tion by Plant Quality Assurance audits (See 2. above).
6.
(0 pen) Deviation (Inspection Report No. 78-01):
Failure to notify the ANI in advance of a hold point established for an operation on a process sheet.
The inspector ascertained that Shop Procedure IX-14W (Process Control) had been revised to reflect requirements to be followed for ANI notification and that a training class had been held.
Implementation of the committed steps to prevent recurrence could not be verified, however, in that the steps consisted of verifica-tion by Plant Quality Assurance audits (See 2. above).
7.
(0 pen) Deviation (Inspection Report No. 78-01): Weld procedure selected for a weld repair was not recorded on the appropriate document in the traveler package.
. The inspector ascertained by review of active traveler packages that repairs were being processed in accordance with corrective action commitments.
It was also noted that the QA Manual had been revised to reflect this commitment.
Implementation of the committed steps to prevent recurrence could not be verified, however, in that the steps consisted of verifica-tion by Plant Quality Assurance audits (See 2. above).
8.
(Closed) Deviation (Inspection Report No. 78-01):
Certain internal activities had not been audited within the required frequency.
The inspector verified that a Central Staff audit covering nine (9) sections of the QA Manual had been performed in the week of April 3,1978, and that a schedule had been issued for a further audit during the week of October 2, 1978.
It was also established that the Plant QA Manager had made provisions for follow-up relative to deviations in schedule or activity commitments.
9.
(Closed) Unresolved Item (Inspection Report No. 78-01): Absence of reference in QA Manual to method of performance and documenta-tion of weld repairs, resulting from weld inspection by NDE methods other than radiography.
The inspector verified that paragraph 2.4 in Section IX of the QA Manual had been revised to reflect the method of performance and documentation of weld repairs by all NDE methods.
C.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that manufacturing processes are controlled in accordance with applicable regulatory, code and contract requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual,Section IV, revision dated July 31, 1978,
" Procurement Document Control," relative to controls applied to material procurement.
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. b.
Review of QA Manual,Section V, revision dated July 31, 1978,
" Instructions, Procedures and Drawings," relative to methods used for preparation, approval and revision of drawings and manufacturing procedures.
c.
Review of QA Manual,Section VII, revision dated July 31, 1978,
" Control of Purchased Material, Equipment and Service," relative to system used for control of materials issue.
d.
Review of QA Manual,Section IX, revision dated July 31, 1978,
" Control of Special Processes," relative to welding, NDE and bending controls.
e.
Review of QA Manual,Section X, revision dated July 31, 1978,
" Manufacturing Control and Inspection," relative to definition of manufacturing control system.
f.
Examination of traveler packages for ten (10) assemblies 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 visual status of components.
(4)
Compliance with specified Authorized Nuclear Inspector hold points.
(5)
Comparison of procedures used against procedures desig-nated as approved.
(6)
Review for performance of required examinations and tests at an applicable manufacturing stage.
g.
Verification that listed procedures had been approved, as required, by the client.
3.
Findings a.
Deviations from Commitments
. (1) Paragraph 5.8.2 in Customer Specification No.10466-M-201B, Revision 9, requires for pipe specified by nominal wall or schedules in sizes 24 inch and smaller, that the final fabrication minimum wall thickness shall be at least 87-1/2 percent of the nominal wall thickness.
Item 1 in Job No. 8252, Sheet F1204, was required by the customer to be 4 inch Schedule 40S SA312 Type 304 material.
The material was procured as such, which permits the pipe to be manufactured with a wall thickness as low as 87-1/2 percent of nominal.
No instructions were provided on the drawing with respect to required minimum actual starting wall thickness, to provide for thinning in fabrication and assure at least 87-1/2 percent of nominal in the final fabrication condition.
(See Enclosure, Item B.)
(2) The inspector was infor: ad that the original process sheet examination requirement for spray nozzle welds in Job No. 8405, Sheets F4853, F4865, and F4875, was magnetic particle inspection in accordance with procedure IX-MT-1, revision dated March 1, 1976. The process sheets were subsequently submitted for revision to change the examina-tion method to liquid penetrant inspection.
In the course of this revision, only the process sheet words were changed, with procedure 1X-MT-1 being left as the applicable procedure. These revised process sheets were approved by QA and the traveler packages reissued. The traveler packages were at the work station where the liquid penetrant inspections were being performed.
It should be noted, that the Inspection Records applicable to the liquid penetrcnt inspections observed being performed, did invoke a procedure which had been approved for use on the contract.
(See Enclosure, Item C.)
b.
Unresolved Items None.
c.
Comments (1) The inspector did observe two (2) process sheets in traveler packages, which did not define applicable manufac-turing procedures to be used.
In both cases, however, the
. issue date of the process sheets preceded the conTaitment date given by PPPA, in response to a previous finding on this subject, at which all process sheets issued would reference applicable procedures to be used.
(2) The inspector also noted one (1) process sheet during the inspection, in which radiographic examination of two (2) welds had been advanced by a QC floor change to an earlier manufacturing sequence than originally specified. This practices is permitted by Section XIV of the QA Manual.
In the change, however, the witness point required by the ANI for the original sequence was not also advanced to the earlier sequence.
D.
Material Identification and Control 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,Section IV, revision dated July 31, 1978, " Procurement Document Control," relative to controls in effect to assure procurement of acceptable materials for issue to manufacturing.
b.
Review of QA Manual,Section VII, revision dated July 31, 1978, " Control of Purchased Material, Equipment and St rvice,"
relative to receiving inspection requirements and cont-ol and upgrading of stock materials for ASME Section III applications.
c.
Review of QA Manual,Section VIII, revision dated July 31, 1978, " Identification and Control of Material, Parts, and Components," for system used by PPPA to control materials in storage and fabrication.
d.
Examination of six (6) assemblies at different stages of fabrication relative to component identification.
e.
Comparison of identity with identity entered in traveler packages.
. f.
Review of purchase orders for referenced components with respect to compliance with procurement system.
g.
Verification that materials were procured from companies contained in the Approved Vendor list.
h.
Review of welding materials in storage area relative to approved material listing.
i.
Examination of electrode ovens for segregation of electrodes in accordance with identity maps.
j.
Examination of submerged arc flux identity in heated storage units at welding stations relative to posted accepted wire /
flux combinations.
k.
Review of Certified Material Test Reports for components in referenced assemblies and ten (10) welding materials to establish acceptance by PPPA and to verify compliance with procurement documents and customer specifications.
3.
Findings Within this area of the inspection, no deviations or unresolved items were identified.
E.
Exit Meeting The inspectors cet with the management and Authorized Inspection Agency representatives denoted in paragraph A. above on September 29, 1978, at the conclusion of the inspection. Ine scope of the inspection and the findings were discussed with management representatives present.
Management comments were related generally to clarification of the findings.
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. DETAILS SECTION II (Prepared by D. M. Hunnicutt)
Vendor Audits 1.
Objectives The objectives of this area of the inspection were to verify that the following were controlled in accordance with the QA Manual and applicable NRC and/or ASME Code requirements:
a.
A written system has been established to assure that Vendor Audits are performed and controlled in accordance with applicable com-mitments to verify compliance with the committed QA program.
b.
Audit results are documented and reviewed by designated personnel, who have responsibility in the area (s) audited.
c.
The audit program is being effectively implemented.
d.
Planned and periodic audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibilities in the areas audited.
e.
Follow-up action, including reaudit of identified deficiencies, is completed where indicated.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the QA Manual, Section No. IV, titled " Procurement Document Control," dated July 31, 1978.
b.
Review of the QA Manual, Section No. XVIII, titled " Audits,"
dated July 31, 1978.
c.
Review of Vendor Quality System Material Manufacturer Audit Checklist Preface Sheet (val-6/78) and attached Pullman Power Products Vendor Quality System Checklist.
d.
Review of Summary / Survey Schedule (V2-3-76) Resurvey for months January 1970 through September 1978.
e.
Review of Pullman Power Products Shop Procedure Manual, Document No. VII-1W, dated May 1, 1975.
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. f.
Review of Statistical Evaluatiori of Defective Material Reports (DMRs) and Nonconformance Reports (flCRs) for third and fourth quarters of 1977 and first and second quarters for 1978.
g.
Review of twenty-seven (27) DMRs out of approximately seventy-five (75) dated from January 10, 1977, through September 18, 1978.
h.
Review of thirty-five (35) NCRs out of approximately one hundred twenty-five (125) dated from June 8, 1976, through September 22,
- 1978, i.
Review of eight (8) Completed Vendor Audit Checklists out of forty-nine (49) performed from January 1,1978, through September 22, 1978.
J.
Review of seven (7) completed Vendor Audit Checklists for ASME Certificate Holders randomly selected from Vendor Audits performed from October 12, 1973, through June 14, 1977.
k.
Review of qualification and training records of one (1) Vendor Auditor.
1.
Discussions with cognizant personnel.
3.
Findings _
a.
Within this area of the inspection, no deviations or unresolved items were identified.
b.
The Vendor Audit Checklist is being completed by checking (v) areas and items inspected. No indication of conditions, reports, manuals, instructions, etc., are entered to facilitate independent review or evaluation of the auditor's findings or what led to the auditor's conclusion that the items met the specified requirements.
c.
The auditor was qualified on the basis of his experience, work assignments, past performance during the past sixteen (16) years and the results of written tests (General and Specific Examinations) in the following areas:
(1) Receiving Inspection, (2) In-Process Inspection, (3) Tool and Gage Inspection, (4) Final Inspection, and (5) Visual Inspection.
- The auditor has received no formal instruction. He is considered currently qualified by Pullman Power Products based on past performance and his continued assignments in Vendor Audit Areas.
d.
In mid-1977 Pullman Power Products stopped performing audits of ASME Certificate Holders. The QA Manual will be revised to clearly state that Certificate Holders are no longer audited on a scheduled basis.
e.
Pullman Power Products is currently setting up a divisional (Central Staff Division) audit system. The initial rough draft for this function has been prepared. The Williamsport divisional office will be responsible for this function when it is implemented within the next several months.
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