ML19263C027
| ML19263C027 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19263C021 | List: |
| References | |
| REF-QA-99900025 99900025-78-2, NUDOCS 7902020074 | |
| Download: ML19263C027 (3) | |
Text
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Southwest Fabricating and Welding Company, Inc.
Docket No.
99900025/78-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on August 21-25, 1978, it appeared that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
A.
Criterion V of Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,... and shall be accomplished in accord-ance with these instructions, procedures, or drawings...."
Paragraph 6.4.3 in Section 6.0 of the QA Manual states in part, "The Quality Control Inspector shall approve the procedure selection, release for welding, and be responsible for weld documentation on the MRS as described in paragraph 5.2.3...." Parc ~aph 5.2.3 in Section 5.0 of the QA Manual states, " Weld documen tion, including procedure used, welder's symbol, and appropriate identification of welding materials shall be verified and entered on the MRS by the assigned Quality Control Inspector."
Contrary to the above, 1.
The procedure used for performing Weld 10, S.0. Q4290, Sheet AC-20-2, was not verified and entered on the MRS by the assigned Quality Control Inspector.
2.
The procedure, welder's symbol and identification of welding materials for Weld 56, S.0. Q4252, Sheet 22, were not verified and entered on the MRS by the assigned Quality Control Inspector.
A similar deviation was previously identified and reported in Inspection Report No. 77-03.
B.
A Southwest Fabricating and Welding Company (SWF) corrective action response letter, dated July 29, 1977, states in part with respect to a deviation pertaining to failure to perform designated in-process liquid penetrant inspections (Inspection Report No. 77-02, Details Section, paragraph D.3.a.(1)), "... A complete investigation was made of the circumstances surrounding this incident.
This revealed that all required penetrant inspections on Welds 3, 4, and 5 had been performed but not properly documented.... The personnnel who were involved in the documentation error were reindoctrinated on June 16, 1977, to prevent a recurrence of this error.
This reindoc-trination included the floor supervision to assure that sufficient time is allowed for the Inspector to complete all operations including documentation."
790202o o7f A SWF corrective action response letter, dated September 21, 1977, additionally states in part, "... Written instructions, ' Quality Assurance Directives' (QAD), are being prepared to formally direct all performing personnel and floor supervision.
These directives will exphasize the mandatory conditions of discipline and provide specific instructions. All the personnel who are directly involved in implementation of the QAD will sign the document to signify understanding and concurrence:
QAD7 will address the general subject of QA Program Discipline.
QADS will specify action to prevent recurrence of the Finding described in D.3.a.(1)...."
Contrary to the above, the inspector observed a further case of apparent improper documentation of in-process liquid penetrant inspections, as evidenced by:
1.
Welds 8 and 9 in S.0. Q4252, Sheet 25, were completed, without either sign-off on the Manufacturing Record Sheet or a nondestructive examination report being available, to signify a required liquid penetrant inspection of the roots had been performed.
2.
SWF Investigation of the incident revealed that the required inspections had been performed, but signed off on the Manufac-turing Record Sheet for S.0. Q4252, Sheet 26, and a nondestructive examination report prepared also for Sheet 26.
It should be noted that the root welds in S.0. Q4252, Sheet 26, had not been made as of the time of the inspection.
C.
Criterion V of Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accord-ance with these instructions, procedures, or drawings...."
Paragraph 6.3.2 in Section 6.0 of the QA Manual state, "All we' ers and welding operators shall be qualified in accordance with r icable requirements of Section III and Section IX."
Paragraph 6.3.4 in Section 6.0 of the QA Manual states in part,
" Quality Assurance shall maintain a list of welders and welding operators, showing processes for which they are qualified....
Current copies of this list shall be furnished to the Welding Foreman and the Quality Control Inspector assigned to the welding area...."
Contrary to the above, the Quality Assurance list of welders and welding operates did not identify process qualifications in
. accordance with Section IX of the ASME Code, as evidenced by the following examples:
1.
A welder sas identified in the list as being qualified to use the gas tungsten arc weld process (GTAW) on stainless steel pipe groove welds of over one (1) to three (3) inch diameter and up to 0.500 inch wall thickness.
The actual ASME Section IX welder performance qualification records showed qualification only up to 0.308 inch wall thickness for this pipe diameter range.
2.
The same welder was identified on the list as being qualified up to one (1) inch wall thickness when using the same process and materials and pipe sizes of three (3) inch and over. The actual ASME Section IX welder performance qualification records showed qualification only up to 0.750 inch wall thickness for this pipe diameter range.
D.
Criterion XV of Appendix B to 10 CFR 50 states in part, "...
Honconforming items shall be reviewed and accepted, rejected, repaired, or reworked in accordance with documented procedures."
Paragraph 10.2.7 in Section 10.0 of the QA Manual states in part, "As each step of the approved disposition is completed to his satisfaction, the assigned Quality Control Inspector will initial and date each step on the RON... Quality Assurance shall sign the RON after all steps in the dispo-ition are completed."
Contrary to the above, Quality Asst ance did not sign RON No. 3301-2 after completion of all steps in the disposition.