ML19269E025
| ML19269E025 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1978 |
| From: | Barnes I, Hunnicutt D, Roberds H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19269E019 | List: |
| References | |
| REF-QA-99900017 99900017-78-2, NUDOCS 7906230068 | |
| Download: ML19269E025 (17) | |
Text
.' -.
r a VEND 0R INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900017/78-02 Program No. 51300 Company:
Dravo Corporation 1115 Gilman Street Marietta, Chio 45750 Inspection Conducted:
November 27-30, 1978 Inspectorsi
$C I ms ' <Q
/l//5/7,i' pm I. Barnes, Contractor Inspector, Vendor
/Date Inspection Branch f
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ef' H. W. rod 6r'ds, Contractor Inspector, Vendor
' Date Inspection Branch
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/
L. E. Ellershaw, Contractor Inspector, Vendor
' Date Inspection Branch Approved by: f_ fd' re-wda<f
/_1//5bf D. M. Hunnicutt, Chief, ComponentsSection II,
/ Datd Vendor Inspection Branch Summary Inspection on November 27-30, 1978 (99900287/78-02)
Areas Inspected:
Implementation of 10 CFR 50, Aopendix B, criteria and applicable codes and standards, including action on previous inspection findings; postweld heat treatment; desigr control; manufacturing process control; nondestructive examination (dye penetrant and magnetic particle);
material identification and control, welding material control; joint fitup and welding; and product acceptance.
The inspection involved seventy-eight (78) inspector-hours on site by three (3) NRC i s2$c 2
1 A
7906230erog
em Results:
In the nine (9) areas inspected, no apparent deviations or unresolved items were identified in five (5) areas; the following were identified in the remaining four (4) areas:
Deviations:
Action on Frevious Inspection Findings - Inclusion of welding variTb'les on Weld Joint Data cards not consistent with corrective action b
commitments (Enclosure, Item A); auditing of production welding relative to recording of travel speed used is not in accordance with Criterion V of 10 CFR 50, Appendix B, and procedure, GWS-6, Revision 2 (Enclosure, Item B).
Postweld Heat Treatment - Acceptance of product without performance of required postweld heat treatment not in accordance with Criterion IX of 10 CFR 50, Appendix B, and the applicable welding procedure specfication (Enclosure, Item C); acceptance of furnace charts not in compliance with written cycle instructions is not consistent with Criterion IX of 10 CFR 50, Appendix B, and Section 9 of the QA Manual (Enclosure, Item D).
Design Control - Failure to control identity of welding materials used in fabrication not consistent with Criterion IX of 10 CFR 50, Appendix B, and Section 9 of the QA Manual (Enclosure, Item E).
Manufacturing Process Control - Process control operations relative to certain drawings, procedure revision utilization and documentation not consistent with Criterion V of 10 CFR 50, Appendix B, NA-4451 of ASME S 'ction III and Sections 3, 6, 9 and 10 of the QA Manual (Enclosure, Item F).
Material Identification and Control - Absence of identification on alignment lugs not consistent with Criterion VIII of 10 CFR 50, Appendix B, and NB, NC, ND-4231.2 of Section III of the ASME Code (Enclosure, Item G).
,Un_ resolved Items: Action on Previous Inspection Findings - Classification
- o. certain fabrication deficiencies as deviations and not nonconformances (DetailsSection I, B.10).
2250 188 s
9
. DETAILS SECTION I (Prepared by I. Barnes)
A.
Persons Contacted
- G. Schwab, Vice President and General Manager
- W. A. Molvie, QA Manager
- E. R. Dysert, Operations Manager
- R. L. Anderson, QA Supervisor R. Abele, Project Engineer L. Dean, Project Engineer P. iiiller, Project Engineer
- R. L. Miller, QA Engineer
- J. Moore, Chief Inspector
- P. P. Norris, Chief Metallurgist
- E. Reno, QA Engineer
- T. Whitacre, QA Engineer
- A. Jozefowicz, Authorized Nuclear Inspector, Hartford Steam Boiler Inspection and Insurance Company.
- Attended exit interview.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Inspection Report No. 78-01, Item A of Enclosure):
Failure to include all variables over which a welder can exercise control on Weld Joint Data cards supplied to welders.
The inspector verified that Dravo Corporation (DC) standard practice welding variables had been incorporated on the back of Weld Joint Data cards and the revised cards were being utilized in fabrication.
During this inspection, however, further instances of incomplete Weld Joint Data cards were observed relative to definition of welding procedure specification (WPS) requirements for purge gas flow rate and permissible wire feed rate in the hot wire gas tungsten arc weld process (GTAW).
The DC standard purge gas flow rate for the machine GTAW process was recorded on the back of the Weld Joint Data card as 5 c.f.h. minimum.
Utilization of this minimum value by the welder and not the required 10-20 c.#.h.
would change an ASME Section IX nonessential variable, which is only permitted by QW-201.1 of ASME Section IX if the change is documented, either in an amendment to the original WPS or in a new WPS.
(See Enclosure, Item A.)
2250 189
.s 2.
(Closed) Deviation (Inspection Report No. 78-01, Item B of Enclosure): General Welding Specification pertaining to tack welding not issued as committed.
The inspector verified that General Welding Specification, GWS-7, had been issued as committed and that an action list system was in effect for monitoring compliance with connitments.
3.
(Closed) Deviation (Inspection Report No. 78-01, Item C of Enclosure): Audit check list of production activities not modified by the committed date.
The inspector verified that the monthly welding audit check list and applicable General Welding Specification, GWS-6, Revision 2, addressed verification of fit-up inspection and that an action list system was in effect for mon? oring compliance with commit-ments.
During this inspection, however, an additional deviation from commitments was identified.
(See Enclosure, Item B.)
4.
(0 pen) Deviation (Inspection Report No. 78-01, Item D of Enclosure): Absence of measures for certain power sources to assure conformance of amperage output with WPS requirements.
This finding will remain open pending receipt and evaluation of an ASME response to the inquiry submitted by DC on this subject.
The inspector verified that meter boxes had been installed as cc::mitted and that a daily surveillance program had been instituted.
5.
(Closed) Deviation (Inspection Report No. 78-01, Item J of Enclosure):
Procedure for the control of vendor audits not written and imposed as conmitted.
The inspector verified that the procedure, GP-4, had been issued and the action list system was in effect for monitoring compliance with coanitments.
6.
(Closed) Deviation (Inspection Repor', i40. 78-01, Item K of Enclosure):
Performance of internal audits not in accordance with QA Manual requirements.
The inspector verified that a schedule had been prepared for internal audits of the QA Program and that outstanding audits had been completed.
The inspector did note an error relative to the DC commitment date of July 20, 1978, in that a required audit of production was not, in fact, performed until August 2 and 3, 1978.
2250 190
. 7.
(Closed) Deviation (Inspection Report No. 78-01, Item L of Enclosure):
Certain internal audits not distributed to the Chief Inspector and Authorized Inspector.
The inspector verified that audit responsibilities had been assigned, standard distribution lists for audit reports established and missing reports sent to required personnel.
8.
(Closed) Deviation (Inspection Report No. 78-01, Item M of Enclosure):
Certain sketches had not received an independent review as required by the QA Manual.
The inspector verified instructions had been issued to Project Supervisors to assure sketches in fabrication and those to be issued, had been checked, initialed, and dated by one other individual in Engineering.
The inspector also sampled sketches currently in fabrication use to verify independent review had been performed.
9.
(Closed) Deviation (Inspection Report No. 78-01, Item N of Enclosure):
Release of certain sketches to fabrication without receipt of prior appro'.al.
As a result of the client response submitted to the NRC by the DC letter of August 7,1978, this item is no longer considered to be a deviation from commitment.
10.
(Closed) Deviation (Inspection Report No. 78-01, Item 0 of Enclosure):
Failure to present certain Nonconformance Reports to the Authorized Inspector (.ANI) for his review.
The inspector performed a sampling of approximately thirty (30)
Nonconformance Reports to verify ANI concurrence.
No further discrepancies were identified relative to submission of Nonconformance Reports.
During this inspection, however, the following unresolved item wr identified:
Sections 3 and 14 of the QA Manual address the subject of devilitions. The text of the QA Manual suggests, but is not totr.lly specific, that a deviation is a planned departure from spr.cified requirements subject to appropriate concurrences, which is generally anticipated in advance of fabrication.
Such actions are not required by the QA Program to be submitted to the ANI
,~
for his concurrence.
The inspector observed. however, certain deviations in the Nonconformance Report / Deviation Request files, 2250 191
... which appeared to be fabrication deficiencies, e.g., heat treat chart not in accordance with requirements, changes in nonessential variables during production welding.
Such items would appear to have warranted classification as nonconformances rather than deviations.
The applicability of the referenced deviations to Section III components was not established during this inspection and will be further reviewed at the next inspection.
11.
(Closed) Deviation (Inspection Report No. 78-01, Item 0 of Enclosure):
Certain Master gages not traceable to flational Standards in that they were removed from the calibration control program.
The inspector ascertained that master gage blocks had been re-classified as Category 1 devices, requiring periodic calibration and that the other referenced devices had been retained as Category 4, requiring initial calibration only.
C.
Postweld Heat Treatment 1.
Objectives The objectives of this area of the inspection were to determine if heat treatment related to welding is specified and performed in accordance with QA Program and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of Section 9 in the QA Manual, Revision 5, " Control a.
of Special Processes."
b.
Examination of three (3) furnace charts relative to compli-ance with heat treat card, customer and ASME Code require-ments.
Review of Standard Shop Procedure, SP-6, Revision 4, " Heat c.
Treat Procedure ASME Section III Classes 1, 2, and 3,1974 Edition through Winter 1975 Addenda."
d.
Evaluation of furnace charts relative to WPS postweld heat treatment qualifications.
2250 192
. 3.
Findings a.
Deviations from Commitment (1)
See Enclosure, Item C.
(2) See Enclosure, Item D.
b.
Unresolved -Items flone.
D.
Design Control 1.
Objectives The objectives of this area of the inspection were to verify that measures were in effect to assure the control of desien and design documents in a manner, consistent with ASME Code and QA Program requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 3 in the QA Manual, Revision 5, " Design Control."
b.
Examination of twenty (20) sketches from three (3) contracts relative to:
(1) Correct revision use in fabrication.
(2)
Independent review and approval of sketches.
(3) Customer submittal and approval requirements.
(4) QA approval.
c.
Examination of project procedures for the referenced contracts relative to customer revision approval.
d.
Verification of correct procedure revision availability in fabrication areas.
c.
Review of system used for sketch preparation from customer drawings.
2250 193
. 3.
Findings a.
Deviation from Commitment During inspection of this area, a deviation relating to welding material control was identified.
See Enclosure, Item E.
b.
Unresolved Items None.
E.
Exit Interview An exit interview was held on Nover.ber 30, 1978, with the management representatives and Authorized Insocction Agency representative denoted in paragraph A above. The inspectars summarized the scope and findings of the inspection.
In addition to the above, the lead inspector expressed individual concerns relative to the permissiveness of certain Dravo welding procedure specifications, although in apparent compli-ance with current ASME Section IX requirements. Management was informed that this item would be discussed with Region IV management.
Management comments were in general co7#ined to clarification of the findings.
3 0 194
_9 DETAILS SECTI0fl II (Prepared by H. W. Roberds)
.A.
Persons Contacted R. L. /nderson, QA Supervisor J. Moore, Chief Inspector K. Welch, NDE, Level II M. Sprague, NDE, Level II B.
A_c_tions on Previous Inspections Findings 1.
(Closed) Deviation (Inspection Report flo. 78-01, Item E of Enclosure):
The committed corrective action with respect to a QA Manual revision had not been accomplished by the specified date.
The inspector verified that the QA Manual had been revised and approved by the AIA on April 25, 1978.
2.
(Closed) Deviation (Inspection Report No. 78-01, Item F of Enclosure):
The committed corrective action with respect to a QA Manual revision to include a requirement for the recording of the procedures and revision letters on the specific back-up shop documents had not been accomplished by the specified date.
The inspector verified that the QA Manual had been revised to include the requirement for recording the procedure and ap-plicable revision on specific back-up shop documents. A review of fifty (50) inspection reports did not reveal a similar discrepancy.
3.
(Closed) Deviation (. Inspection Report flo. 78-01, Item G of Enclosure):
The comitted corrective action with respect to the development and implementation of a new procedure ES-DOC-3 had not been accomplished by the specified date.
The inspector verified that the procedure ES-DOC-3 had been developed and implemented on April 10, 1978.
4.
(Closed) Deviation (Inspection Report flo. 78-01, Item H of Enclosure):
It could not be verified that the total sulfur and halogen content of bulk penetrant materials in open containers did not exceed the 1% by weight requirement of Section V of the ASME Code.
2250 195
... The inspector verified, by observation of three (3) inspection stations, that penetrant materials are maintained in closed containers and are identified to lot and batch number for traceability.
(5)
(Closed) Deviation (. Inspection Report No. 78-01, Item I of Enclosure):
Procedure used for examination of Level III nondestructive examination personnel not described in the Dravo written practice.
The inspector verified that a written procedure, STD-SP-103 dated May 4,1978, has been developed which defines the practice for qualification and certification of Level III nondestructive examination personnel.
(6)
(Closed) Deviation (Inspection Report No. 78-01, Item P of Enclosure): Materials with discrepant CMTR's were not identified with a red tag or trouble tag.
The inspector verified that Section 14 of the QA Manual had been revised to define documentation deficiencies and the safeguards to prevent the shipment of components with uncleared CMTR's.
C.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that the QA Program is consistent with Regulatory and Code requirements relative to:
a.
Manufacturing is performed under a controlled system.
b.
Certain processes are accomplished by qualified personnel using approved procedures.
c.
Completion of specific operations are documented as requi red.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 3, 6, 9 and 10 of the QA Manual.
b.
Review of ten (10) sketches.
2250 M6
. c.
Observation of work in progrcss.
d.
Interviews with cognizant personnel.
3.
Findings a.
Deviation from Commitment Criterion V of Appendix B to 10 CFR 50 states in part,
" Activities affecting quality shall be prescribed by doc-umented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Contrary to the above, certain activities affecting quality were not performed in accordance with QA Manual requirements, as evide'1ced by:
(1) Section 3 of the QA Manual, paragraph 4.2 states, "To insure accuracy the sketches shall be checked, initialled and dated by one other individual in Engineering prior to issuance."
The inspector noted, however, that accuracy of sketches was not assured by checking, in that the weld joint identification on sketches E 3099-160 and E 3099-76, which were used for recording inspection results, did not correlate with the weld joint identification or, applicable sub-assembly sketches used for performance and documentation of welds.
(2) Section 6 of the QA Manual, paragraph 3.2.4.1 states,
" Transmittal of all revised procedures and project addenda will be accompanied by a revised FPI incor-porating the revisions."
The inspector noted that the revised procedure did not accompany a revised FPI incorporating ASME-III4tP, Revision 7 for project 3035, in that the procedure maintained in the up-to date file of standard proce-dures was ASME-III-MP, Revision 5.
(3) Section 9 of the QA Manual, paragraph 4.3.4 states,
" Verification of the completion and acceptance of the test shall be noted on the sketch in the appropriate boxes by the initials of the inspector and the date of app aval."
2250 197
. The inspector noted that the verification of completion and acceptance of a magnetic particle test was not noted an sketch E 3035-224 by the initials of the inspector and the date of approval for welds B and C, although an inspection report had been completed.
(4) Section 10 of the QA Manual, paragraph 3.4.1 states, "Each nondestructive examination procedure to be used including revisions shall be entered either on the NDE inspection records or the sketch."
The inspector noted that each nondestructivt: examination procedure to be used, including revisions, was not entered either on the inspection records or the sketch, in that the inspection reports could not be located at the time of the review of sketch E 3133-101 and the procedure and revision was not listed on the sketch for a penetrant examination conducted on November 22, 1978.
b.
Unresolved Items None.
D.
Nondestructive Examination (Dye Penetrant and Magnetic Particle) 1.
0_bjectives 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 perfvrmed 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 9 and 10 of the QA Manual.
b.
Review of Nuclear Magnetic Particle Test Procedure per ASME Section V, ASME-III-MP.
2250 198
,.. c.
Review of fluclear Dye Penetrant Test Procedure Color Contrast Method using Solvent Removable Penetrant, ASME-III-DP.
d.
Review of six (6) flDE personnel qualification and certifica-tion records.
c.
Review of fif ty (50) PT and MT Inspection reports.
f.
Review of eight (8) sketches.
g.
Observation of work in progress (Dye Penetrant).
h.
Interviews with cognizant personnel.
3.
Findings In this area of the inspection, no deviations from commitments or unresolved items were identified.
2250 199
..., DETAILS SECTION III (Prepared by L. E. Ellershaw)
A.
Persons Contacted _
D. Barrows, Receiving Department Supervisor R. Cline, Weld Foreman R. Davis, Weld Engineer R. Kemp, Weld Foreman R. Miller, Quality Assurance Engineer J. Pribisko, Weld Engineer T.'J. Whitacre, Quality Assurance Engineer C. Wilhelm, Quality Assurance Engineer B.
Material Identification and Control 1.
Objectives The objectives of this area of the inspection were to verify that Dravo Corporation (DC) had implemented the requirements for the identification and control of material in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual dated September 28, 1978, Section 8,
" Identification and Control of Material, Parts and Components."
b.
Verification of nuclear stock carbon and stainless steel fittings and pipe identification by comparing with identifica-tion noted on respective Mill Test Reports.
c.
Verification of fabricated fittings and pipe identification by comparing with identification as noted on the respective sketches.
d.
Observation of alignment lugs used during tack welding of carbon and stainless steel material.
e.
Discussions with cognizant personnel.
2250 200
- 3.
Findings a.
Deviation from Commitment See Enclosure, Item G.
Discussions with cognizant personnel revealed that the alignment lug geometry (as cut by Dravo Corporation) is the indicator of the lug identification and as such, shows its compatability to the component material to which it is welded. The discussions further disclosed that the lug geometry, used as an indicator, is not addressed in the QA Manual or in implementing procedures.
However, there is no appropriate description either on the lugs or on records traceable to the lugs.
b.
Unresolved Item None.
C.
Welding Material Control 1.
Objectives The objectives of this area of the inspection were to verify that DC had implemented the requirements for the control of welding materials in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishmen The preceding objectives were accomplished by:
a.
Review of QA Manual dated September 27, 1978, Section 7,
" Control of Purchased Material Items and Services."
b.
Review of QA Manual dated September 27, 1978, Section 9,
" Control of Special Processes."
c.
Observation of welding material storage in the stockroom.
d.
Observation of electrodes stored in locked holding ovens.
e.
Verification of identification of electrodes in welders hot boxes by comparison with Weld Joint Data Forms.
2250 20t
...... f.
Verification of Impact Test requirements and ferrite content by review of weld materials tally sheet and certified material test reports.
9 Verification of require testing for each bare wire and flux combination by review of certified material test reports.
h.
Discussions with cognizant personnel.
3.
Findings In this area of the inspection, no deviations from commitments or unresolved items were identified.
D.
Joint Fitup and Welding 1.
Objectives The objectives of this area of the inspection were to verify that DC had implemented the requirements for the control of joint fitup and welding in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual dated September 27, 1978, Section 9,
" Control of Special Processes."
b.
Observation of in-process Shielded Metal Arc Welding and Gas Tungsten Arc Welding.
c.
Observation of fitup and tack welding operations.
d.
Review of Weld Joint Data Forms to verify that the weld procedure specification to be used were listed and that the identity of weld materials were documented.
e.
Discussions with cognizant personnel.
3.
Findings In this area of the inspection, no deviations from commitments or unresolved items were identified.
2250 202
2.,'. E.
Product Acceptance 1.
Objectives The objectives of this area of the inspection were to verify that DC had implemented the requirements for product acceptance through receiving inspection in accoradance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual dated September 27, 1978, Section 7,
" Control of Purchased Material, Items and Services."
b.
Observation of receiving inspection operations.
c.
Observation of Contract and Nuclear Stock material in their respective storage areas.
d.
Verification of material identification traceable through receiving inspection tally sheets and material test reports.
Verification of the use of approved vendors by comparing e.
purchase orders to the approved vendor list.
f.
Verification that accepted material met purchase order requirements.
g.
Discussions with cognizant personnel.
3.
Findings In this area of the inspection, no deviations from commitments or unresolved items were identified.
2250 203