ML19274E291
| ML19274E291 | |
| Person / Time | |
|---|---|
| Issue date: | 11/03/1978 |
| From: | Barnes I, Ellershaw L, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19274E279 | List: |
| References | |
| REF-QA-99900259 NUDOCS 7903220198 | |
| Download: ML19274E291 (14) | |
Text
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h VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY C0CilSSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900259/78-02 Program No. 44070 Company:
Combustion Engineering, Inc.
C-E Avery Division Old Dover Road Newington, New Hampshire 03801 Inspection Conducted: October 17-20, 1978 Inspector:
U) WZ
// O 7
[. E. Ellershaw, Contractor Inspector, Vendor oat 6 Inspection Branch kEl tbo
///_+ N I. Barnbs, Cont'ractor Inspector, Vendor
/ Date Inspection Branch
/. /f Approved by:
M
/
D. M. HtInnicutt4 Chief, ComponeatsSection II,
/ Date Vendor Inspection Branch Summary Inspection on October 17-20, 1978 (99900259/78-02)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B Cr.teria, and applicable codes and standards, including: nonconforming material, parts, or components; corrective action; nondestructive examination personnel qualifications; nondestructive examination; welding procedure specifica-tions; joint fitup and welding; welding material control; weld heat treatment; control of forming and action on previous inspection findings.
The inspection involved fifty-two (52) inspector-hours on site by two (2) NRC inspectors.
Results:
In the ten (10) areas inspected ten (10) deviations from commitment and two (2) unresolved items were identified in nine (9) areas.
7 9 0 3 2 2 0 Igg
_2_
Deviations: flonconforming Materia;, Parts, or Components - Subsequent operations were performed on parts that had been determined to be nonconfoming without authorization, which is contrary to Criterion XV of Appendix B to 10 CFR 50 (Enclosure, Item A.); Cnrrective Action -
deviation notices are reviewed, signed and dated by Quality Assurance, to show concurrence, without the cause of the deviation being identified, which is contrary to Criterion XVI of Appendix B to 10 CFR 50 (Enclosure, Item B.); fiondestructive Examination (f DE) Personnel Qualifications -
ASME Code required visual examinations were signed off by noncertified personnel as a result of C-E Avery not addressing visual examination as an flDE discipline, thus not certifying personnel as visual examiners, which is contrary to Criterion IX of Appendix B to 10 CFR 50 (Enclosure, Item C.); flondestructive Examination - it could not be verified that the total sulfur and halogen content of the liquid penetrant in use did not exceed 1% by weight, which is contrary to Criterion IX of Appendix B to 10 CFR 50 (Enclosure, Item D.), and penetrant materials are not being com-pletely removed from parts after examination, as required by Criterion IX of Appendix B to 10 CFR 50 (Enclosure, Item E.); Welding Procdut c S,necifica-tion - Format for certain WPS not in accordance with Criterion IX of le CFR 50, Appendix B, and the variable requirements of ASME,Section IX (Enclosure, Item F.); Joint Fitup and Welding - Perfonnance of production shielded metal arc welding not consistee with the requirements of i
Criterion V of 10 CFR 50, Appendix B, arc applicable WPS (Erclosure, Item G.); Welding Material Control - Qualification of a subr erged arc wire-flux combination not in accordance with Criterion IX o f 10 CFR 50, Appendix B, and the test requirement of ASME Code,Section III (Enclosure, Item H.); Weld Heat Treatment - Overiay cladding procedure qualificatico exceeded with respect to postweld heat ;.reatment without requalificatiot being performed, as required by Criterion IX of 10 CFR 50, Appendix B, and the ASME Code,Section IX (Enclosure, I em I.); Control of Forming
- Procurement of forming services not consistent with Critt rinn IV of 10 CFR 50, Appendix B, and the ASME Code,Section III, relative to forming qualitication (Enclosure, Item J.).
Unresolved Items: Welding Procedure Specifications - Abse me of infoma-tion relative to stainless steel weld cladding operations of SA 508 Class 3 pump casings, in terms of commitment to or compliance witi Regulatory Guide 1.43 (DetailsSection II, B.3.b.); Joint Fitup and 1,31 ding - Absence of formalized requirements relative to assurirg accuracy of meters on automatic welding equipment (DetailsSection II, C.3.b.).
. DETAILS SECTION I (Prepared by L. E. Ellershaw)
A.
Persons Contacted D. C. Almeda, Quality Assurance Engineer R. E. Claar, Manager, Quality Assurance
- 9. Dutton, Supervisor, Production Control N. C. Irvine, Senior Quality Assurance Supervisor and Level III, NDE Examiner L. Lanciano, Supervisor, Material Handling D. Lynch, Foreman, Quality Control G. Roberts, Quality Assurance Engineer B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 78-01): This item dealt with C-E Avery not performing the required, semi-annual magnetic particle examinations of certain plate clamps.
C-E Avery has implemented their committed corrective action i
and all scheduled magnetic particle examinations have been performed.
C.
Nonconforming Materials, Parts, or Components 1.
Objectivas The objectives of this area of the inspection were to verify that C-E Avery ha> implemented the requirements for the control of nonconforming material, parts, or components in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Acccmolishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 22, " Nonconforming Material or Items," Ravision 9.
b.
Review of Administrative Manual Procedure, AM-10-004, Revision 4.
c.
Review of Deviation Notices.
-4 d.
Observation and review of nonconforming parts and associated documentation.
e.
Discussions with cognizant personnel.
3.
Findinas a.
Deviation from Commitment See Enclosure, Item A.
b.
Unresolved Item None.
D.
Corrective Action 1.
Objectives The objectives of this area of the inspection were to verify that C-E Avery had implemented the requirements for identifying the causes of conditions adverse to quality and that corrective action was implemented to prevent recurrence, in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 23, " Corrective Action,"
Revklion 9.
b.
Review of Corrective Action Reports.
c.
Review of Corrective Action Review Team meetings, held to evaluate corrective actions and analyze the trends.
d.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Commitment See Enclosure, Item B.
b.
Unresolved Itera None.
. E.
Mondestructive E:. amination (NDE) Personnel Qualifications 1.
OMcRvn The objectives of this area of the inspection were to verify that C-E Avery had implemented the requirements for the qualifica-tion of NDE personnel in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 15, " Nondestructive Examination,"
Revision 9.
b.
Review of qualification records of Nondestructive Examina-tion (NDE) personnel.
c.
Review of applicable ASME Code requirements and recommended practice, SNT-TC-1A, June 1975 edition, d.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Commitment See Encl 0sure, Item C.
b.
Unresolved Item None.
F.
Objectives The objectives of this area of the inspection were to verify that C-E Avery had implemented the requirements for the centrol of nondestructive examinations (NDE) 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, Section 15, "Mondestructive Examina-tion," Revision 9.
. b.
Review of Liquid Penetrant procedure, NDE-P-048, Revision 1 dated May 15, 1978.
c.
Review of Radiography procedure, NDE-P-040, Revision 3, dated October 20, 1977.
d.
Observation of in-process liquid penetrant examinations.
Observation and review of set-up for in-process radiographic e.
examination.
f.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Commitment (1) See Enclosure, Item D.
(2)
See Enclosure, Item E.
b.
Unreso_lved Item None.
G.
Exit Interview A meeting was held at the conclusion of this inspection on October 20, 1978, with the following management representatives and the Authorized Nuclear Inspector:
R. P. Adams, Manager, Manufacturing D. C. Almeda, Quality Assurance Engineer P. F. Avery, Jr., General Manager S. Avery, Manager, Estimate and Projects C. J. Beck, Project Engineer R. E. Claar, Manager, Quality Assurance R. C. Devoid, Authorized Nuclear Inspector, Hartford Steam Boiler Inspection and Insurance Company H. J. Gee, Manager, Purchasing P. F. Gillis, Weld Engineer N. C. Irvine, Senior Quality Assurance Supervisor and Level III, NDE ~xaminer R. H. Keyes, Manager, Weld Engineering D. F. Packard, Manager, Manufacturing Engineering The scope and findings of this inspection were summarized. Management acknowledged the statements relative to the findings.
. DETAILS SECTION II (Prepared by I. Barnes)
A.
P_ersons Contacted D. Almeda, QA Engineer P. Bryant, Manufacturing Engineer P. Gillis, Welding Engineer R. Keyes, Manager, Welding Engineering J. Mutchler, Plant Engineer A. Peters, QA Engineer B.
Welding Procedure Soecifications 1.
Objectives The objectives of this area of the inspection were to determine whether welding procedure specifications (WPS) used in production welding were prepared, qualified and controlled in accordance with the manufacturer's QA program and applicable ASME Code and regulatory requirements.
2.
fiethod of Accocplishmant The preceding objectives were accomplished by:
Review of QA Manual, Section 14 Revision 9, " Welding."
a.
b.
Review of Procedure, AM-10-007 Revision 02, " Planning and Control of Welding Functions."
Review of detailed welding procedures observed in produc-c.
tion use and applicable to:
(1) Shielded metal arc welding (fabrication and repair after final postweld heat treatment).
(2) Submerged arc welding of safety injection tanks.
(3)
Submerged arc overlay cladding of tanks and pump casings.
d.
Examination of procedure qualification records (PQR) applicable to the detailed welding procedures with respect to the essential variable requirements of the ASME Code,Section IX.
. e.
Examination of the detailed welding procedures with respect to the nonessential variable requirements of the ASME Cod <
Section IX.
f.
Examination of the PQR test data relative to the require-ments of the ASME Code, Sections III and IX, and the customer product design requirements.
3.
Findings a.
Deviation from Commitment The inspector observed during WPS review that not all variables defined by ASME Section IX for the shielded metal arc (SMAW) and submerged arc (SAW) welding processes were listed in Detailed Welding Procedure (DWP) Nos. 111-10-1.1-9 Revision 00 (SMAW) and I-30-1.1-13 Revision 00 (SMAW and SAW).
Examples of omissions common to both procedures were as follows:
Essential Variables - Range of postweld heat treatment and thickness.
Nonessential Variables - Preheat maintenance, method of initial and interpass cleaning, method of back gouging.
It was additionally noted that both procedures permitted a change to a supplementary essential variable, in that:
(1) DWP No. III-10-1.1-9 Revision 00 allowed up to a maximum value of 280 amps with 3/16 inch E 7018 electrodes, whereas the supporting PQR was qualified at a maximum value of 240 amps.
(2) DWP No. I-30-1.1-13 Revision 00 allowed up to a maximum value of 450 amps with 1/8 inch MIL-B4 wire, whereas the supporting PQR was qualit ad at a maximum value of 425 amps.
Similarly, both C as cennitted the use of increased consumable diameters over what were utilized for the supporting PQRs, resulting in further increased amperage ranges relative to qualifications.
(See Enclosure, Item F. ).
b.
Unresolved Item Absence of information relative to compliance with or commitment to Regulatory Guide 1.43 for stainless steel weld cladding operations performed on SA 508 Class 3 pump casings.
. u
_9 C.
Juint Fitup and Welding 1.
Objectives The objectives of this area of the inspection were to determine if production welding was controlled in accordance with the manufacturer's QA program and applicable ASME Code and regulat ry requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 14 Revision 9, " Welding."
b.
Observation of production shielded metal arc, submerged arc, submerged arc overlay and shielded metal arc repair welding with respect to:
(1) Work being performed in accordance with Manufacturing Process Sheet requirements and instructions.
5 (2) Verification that applicable Detailed Welding Procedures were available at the work stations.
(3) Verification that procedure assignment was in accordance with ASME Code essential variable requirements.
(4) Establishing correct, approved welding materials were in use and welding personnel were complying with parameters required by the applicable welding procedures.
c.
Examination of control measures for use and removal of temporary attachments, d.
Determination of measures used for assuring accurscy of ammeters and voltmeters on automatic welding equipment.
e.
Review of welding personnel qualifications for operations witnessed.
f.
Examination of documentation system utilized for repairs.
3.
Findings a.
Deviation from Commit 7nt
I
. The inspector observed two (2) SMAW welders utilizing DWP No. III-10-1.1-9 Revision 00 on Joint W3 in Job No.
223-090800.
This DWP required amperage ranges of 130-200 and 180-280, respectively, for 5/32 inch and 3/16 inch E 7018 coated electrodes. The actual measured amperage ranges observed in use were 210-220 for one (1) welder using a 5/32 inch electroce and 160-180 for the other, who was using a 3/16 in:h electrode.
Another SMAW operation was observed on Job No. 914-0400-220 with DWP flo. III-45-8.8-5 Revision 01 as the assigned WPS.
This DWP required an amperage range of 90-165 for 5/32 inch E 308-16 coated electrodes.
The actual measured amperage range was observed to be 175-180.
DUP flo. RP-10-3 was observed in use c.; Job No. 158-4802 for the performance of SMAW repairs to P1 safe end after final postweld heat treatment. The ASME Code (NB-4642) and thg DWP both required a maximum interpass temperature of 450 F to be maintained during welding. The welder performing the repairs, however, was not equipped to verify compliance with the interpass requirement.
(See Enclosure, Item G. ).
b.
Unresolved Item
.ietars on automatic welding equipment are presently not included in the C-E Avery calibration orogram. The inspector was informed that the accuracy of such meters was maintained by utilization of the electrical checks made in the welding surveillance program. A procedure, however, has not yet been issued, which defines check requirements relative to method, frequency, master equipment and accuracy.
D.
Welding Material Control 1.
Objectives The objectives of this area of the inspection were to determine if welding material purchase, acceptance, storage and handling was in accordance with the manufacturer's QA program and applicable ASME Cade and regulatory requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 14 Revision 9, " Welding."
I
. b.
Review of Procedure, AM-10-001 Revision 02, "Weldiag Materials Control."
c.
Examination of procurement and certification records for welding consumables observed in production use.
d.
Observation of electrode and flux ovens for identit" control.
e.
Review of temperature control in electrode overs and disbursement and moisture control practices.
f.
Examination of manufacturing records relative to correct identity of welding materials being consumed in fabrication.
3.
Findings a.
Deviation from Commitment The qualification certification for a submerged arc wire
-flux combination (3/16 inch MIL-B4 wire, Heat 4P8632; Linde 124 flux, Lot 3281) did not denote Dreheat and interpass temperatures used for the qualification.
Provisions were available on the certification to complete this required ASME Code information, in that the form included an entry for the applicable weld procedure specification used in the qualification.
In this instance, however, this entry was completed by only the words " Submerged Arc."
(See Enclosure, Item H.).
b.
Unresolved Item None.
c.
Comments C-E Avery has to date not standardized its procurement and qualification requirements for welding materials in the form of specifications.
E.
Weld 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 the manufacturer's QA program and applicable ASME Code and regulatory requirements.
v
. 2.
. [tethod of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual, Section 16 Revision 9, " Heat Treat."
b.
Review of Heat Treat Procedure Nos. HT-P-004 Revision 01 and HT-P-007 Revision 00.
c.
Observation of furnace control instrumentation.
d.
Review of therm.ccouple calibration procedure, QA-I-1005 Revision 01.
e.
Review of furnace calibration procedure, OA-I-1006.
f.
Examination of three (3) heat treat charts and thermocouple lccation records for postweld heat treatment of tanks.
g.
Examination of three (3) heat treat charts for postweld heat treatment of pump casings.
h.
Review of cumulative postweld heat treatment times for Job No.158-1203 (pump casing) relative to qualification times of welding procedures used in fabrication.
3.
_Findinas a.
Deviation from Comn, tment It was established by the inspector that monitoring of accumulated postweld heat treatment time relative to welding materials and procedure qualification times at temperature was not currently being performed by C-E Avery QA staff, as evidenced.y the following:
(1) DWP Nos. WMC-15-6 Revision 01 and WMC 10-7 Revision 01 were used in overlay weld cladding opecationr on Job Mo. 158-1203 and had been qualified with a tea (10) hour time in the postweld heat treatment temperature range.
(2) This time at temperature qualifies up to twelve and one-half (12.5) hours at temperature for production heat treatment when using these DWPs.
(3) The actual accumulated time at temperature was fifteen and one-half (15.5) hours for Job No. 158-1203,
. without detection by QA of the voiding of the proce-dure qualifications.
It was also noted during inspection of this subject area, that Procedure, HT-P-007 Revision 00, was not in strict compliance with ASME Section III rules relative to gliowed temperature gradients. The procedure allowed a 250 F differential between any two (f) points on a pump casing, whereas the Code permits a 250 F differential in any fifteen (15) feet interval of weld length.
Review of heat treat charts, however, showed no gradient problems had occurred as a results of this procedural error.
(See Enclosure, Item I.).
F.
Control of Forming 1.
Objectives The objectives of this area of the inspection were to verify that provisions had been made for the control of forming or bending of pressure retaining materials and that these controls were in accordance with applicable ASME Code and regulatory requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
QA program review and discussion relative to forming of a.
cylinders for tanks.
b.
Sampling of cylinders observed in assembly and review of applicable purchase orders for materials and forming services.
Review of customer specification for tanks relative to c.
rarial property requirements.
3.
Findings a.
Deviation from Commitment Section III of the ASME Code, p... agraph tic-4213, requires performance of procedure qualifications for forming (with certain permitted exemptions) of materials with stipulated fracture toughness properties.
Purchase Order 228-000-4 was placed with a vendor for rolling plate with stipulated fracture toughness properties into cylinders for tank application. The purchase order did not either require
, compliance with NC-4213 or was there any vendor documenta-tion to support qualification of the rolling process for this application.
It was additionally noted that the QA Manual did not specifically address control of forming operations at vendor facilities.
(See Enclosure, Item J.).
b.
Unresolved Items None.
.