ML19274E290
| ML19274E290 | |
| Person / Time | |
|---|---|
| Issue date: | 11/03/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19274E279 | List: |
| References | |
| REF-QA-99900259 NUDOCS 7903220196 | |
| Download: ML19274E290 (5) | |
Text
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Combustion Engineering, Inc.
C-E Avery Division Docket tio. 99900259/78-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on October 17-20, 1978, it appeared that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
A.
Criterion XV of Appendix B to 10 CFR 50 states in part, " Measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation....
Nonconforming items shall be reviewed and accepted, rejected, repaired, or reworked in accord-ance ith documented procedures."
Administrative Manual Procedure AM-10-004, paragraph 5.1 states in part, "Upon discovery or notification of a nonconforming item, Quality Assurance shall take the following action:
Note DN (Deviation Notice) number on " Hold" tag and Manufacturing Process Sheet (MPS), then attach the " Hold" tag to the nonconforming item which shall be removed from production and, when practical, placed in a designated " Hold" area." Paragraph 5.7 states in part, "DN's dispositioned ' Submit to Customer' shall be retained until the DCR (Deviation from Contract Requirements) has been returned approved or disapproved.
If work may continue without jeopardizing quality, the disposition shall so state.
Quality Assurance shall attach an orange ' Incomplete Operation' tag... (and)... The tag shall be attached to the item and shall remain until customer approval of the DCR is received...."
Contrary to the above:
1.
DN 5528 was written on July 5, 1978, against Job No. 913 0130,
....for discrepant conditions discovered at operation No. 430. A subsequent operation was performed on July 6,1978, without disposition being made until September 12, 1978.
2.
DN 0068 was written on October 16, 1978, against Job No. 226-3513, for discrepant conditions discovered at operation No. 305.
The DN was not referenced on the MPS and a disposition had not been made, yet subsequent operations had been completed and signed off. Additionally, customer approval had not been obtained, and the item was not tagged with an " Incomplete Operation" tag.
B.
Criterion XVI of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that conditions adverse to quality, 79032201
. such as failures, malfunctions, deficiencies, deviations,... and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition...."
QA Manual Section 23, paragraph 3.0, states in part, "When a nonconformance is discovered during in-process inspection, Quality Assurance shall place a ' Hold' tag on the item or material, report the nonconformance on a Deviation Notice (DN), obtain the cause of the deviation, in conjunction with Manufacturing, and forward the DN to Engineering for disposition...."
Administrative Manual Procedure AM-10-004, paragraph 5.5 states in part, " Quality Assurance shall:
Review the Engineering disposition and cause of deviation to determine that quality requirements have been met, then sign and date for concurrence.
Contrary to the above, many DNs are reviewed, signed, and dated by Quality Assurance to show concurrence, without the cause of the deviation being identified; i.e., DN Numbers 0005, 0006, 0009, 0017, 0020, 0022, 0023, 0032, 0046, 0047, and 0049.
C.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including
... nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures...."
QA Manual Section 15, paragraph 2.0 states in part, "It shall be the responsibility of Quality Assurance to train, qualify and certify nondestructive inspectors in accordance with the requirements of the Code and SNT-TC-1A, 1975...."
ASME Code Section V, Article 1, paragraph T-110 states in part, "This Section of the Code contains requirements and methods for nondestructive examination which are Code requirements to the extent they are specifically referenced and required by other Code Sections They include radiographic examination, ultrasonic examination,
... visual examination, and leak testing.
ASME Code Section III, paragraph NB-5521 states in part, "... For nondestructive examination methods not covered by SNT-TC-1A-1975 documents, personnel shall be qualified by the Certificate Holder to comparable levels of competency by subjection to comparable examinations on the particular method involved...."
Contrary to the above, C-E Avery has not addressed the ASME Code requirements for qualification of personnel performing "DE, specifically,
. visual examination. Therefore, there are no certified visual examiners.
. However, certain ASME aection III, Subsection NF work, requiring visual examination, had been performed and signed off by a Quality Control inspector, i.e., operation 20 of Job No. 223-1007, a Motor Support Stand.
D.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including
... nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria and other special requirements."
ASME Code Section V, Article 6, paragraph T-630, states in part,
. "When using penetrant examination methods for nickel base alloys, the penetrant materials shall be analyzed for sulfur content.
The total sulfur content of the residue shall not exceed 1% by weight.
When examining austentic stainless steels.... The total halogen content of the residue shall not exceed 1% by weight."
Contrary to the above, the liquid penetrant is dispensed to the NDE personnel in small, reusable plastic containers, which were observed, in most cases, to be left open. As a result, with the continual refilling and exposure to the machine shop / manufacturing atmosphere, a residue of an unknown substance could be detected in certain con-tainers in which it could not be verified that the total sulfur and halogen content of the liquid penetrant in use did not exceed 1% by weight.
Additionally, it was observed that certain penetrant inspections were being performed using unidentified liquid penetrant.
E.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including
... nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures...."
ASME Code Section III, Subsections NB-NG, Article 5113 states, "Following any nondestructive examination in which examination materials are applied to the piece, the piece shall be thoroughly cleaned in accordance with applicable material or procedure speci fications. "
NDE Procedure NDE-p-048, paragraph 16.0 states in part, " Post Examination Cleaning... Clean the surface examined with a cloth wetted with acetone...."
Contrary to the above, parts are not being thoroughly cleaned in that penetrant material was observed following examination on parts in which penetrant examination had been performed nearly two weeks
. earlier; i.e., Job No. 138-0395 in which final Liquid Penetrant was performed at operation No. 250 on October 8, 1978, and the penetrant was still on the part as of October 19,19'/8.
F.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including welding,... are controlled and accomplished... using qualified procedures in accordance with applicable codes...."
Paragraph QW-201.1 of the ASME Code,Section IX, states in part, "The welding procedure specification (WPS) shall list in detail
... the range of... postweld heat treatment, thickness, and other variables described for each welding process as either essential or nonessential.
(See QW-252 through QW-281)...." Paragraph QW-201.2 states in part with respect to procedure qualification records (PQR), "... A change in any essential variable shall require requalification, to be recorded in another PQR."
Contrary to the above, the inspector observed that certain WPS did not list all applicable nonessential variables contained in QW-252 through QW-281, and permitted changes to a supporting PQR amperage supplementary essential variable.
(See DetailsSection II, B.3.a.).
I G.
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 accordance with these instructions, procedures, or drawings...."
Detailed Welding Procedure (DWP) Nos. III-45-8.8-5, Revision 01 and III-10-1.1-9, Revision 00, which were observed in use, respectively, on Job Nos. 914-0400-220 and 223-090800, stipulated amperage ranges to be used for specific coated electrode sizes.
DWP No. RP-10-3, Revision 00, which was observed in use for repairs after final postweld heat treatment to Job No. 158-4802, required a maximum interpass temperature of 4500F to be maintained during welding.
Contrary to the above:
1.
Welding was observed being performed on Job Nos. 914-0400-220 and 223-090800 with maasured amperage values outside of the ranges required for the specific electrode sizes in use.
2.
The welder performing repairs on Job No. 158-4802 was not equipped to verify compliance with the 4500F maximum interpass tempteIture requirement.
(See DetailsSection II, C.3.a.)
H.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including
. welding,... are controlled and accomplished... in accordance with applicable codes...."
. Paragraph NC-2431.1(c) in the ASME Section III Code (1974 Edition through Sunmer 1975 Addendum) states in part with respect to the general test requirements for weld metel, "The welding of the test coupon shall conform to the applicable Welding Procedure Specification (WPS) for production welding relative to preheat and interpass temperatures...."
Contrary to the above, no records were available, which would allow verification of the preheat and interpass temperatures used for qualification of a certain submerged arc wire and flux combination, that was observed in current Class 2 producticn use.
(See DetailsSection II, D.3.a.)
I.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including welding, heat treating... are controlled and accomplished...
in accordance with applicable codes...."
Paragraph QW-281.2 in the ASME Code,Section IX, requires requalifica-tion of all corrosion-resistant weld metal overlay WPS when the time at postweld heat treating temperature is increased by 25 percent, or more, over the qualified value.
I Contrary to the above, the time at postweld heat treating temperature for Job No. 158-1203 exceeded by more than 25 percent the qualifica-tion times for two (2) overlay WPS used in fabrication, without requalification being performed.
(See DetailsSection II, E.3.a.)
J.
Criterion IV of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that... requirements which are necessary to assure adequate quality are suitably included or ref-erenced in the documents for procurement of material, equipment, and services...."
Paragraph 2.1.1 in Section 9 of the QA Manual states, "The purchase requisition shall delineate material, test, identification and certification criteria, including requirements for submittal c' procedures and notification for source surveillance." Paragraph 2.2 in Section 9 of the QA Manual states, " Quality Assurance shall review the purchase requisitions to assure that ordering data, including quality requirements, is clearly defined, and all required vendor inspections and tests are delineated."
Contrary to the above, Purchase Order No. 228-000-4 was issued to a vendor for rolling of cylinders without delineating or assuring compliance with the forming qualification test requirements of paragraph NC-4213 in the ASME Code,Section III.
(See DetailsSection II, F.3.a.)
.