ML19276E676
| ML19276E676 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/1979 |
| From: | Mcneill W, Sutton T, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19276E670 | List: |
| References | |
| REF-QA-99900003 NUDOCS 7903200166 | |
| Download: ML19276E676 (13) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900003/79-01 Program No.
51500 Company:
General Electric Company Wilmington Manufacturing Department Box 780 Wilmington, North Carolina 28401 Inspection Conducted: January 8-12, 1979 Inspectors:
- /
[$
///f W. M. McNeill', C6ntractor Inspector, Vendor
' Dhte Inspection Branch i
L0 2
SS W. Sutton, Contractor Inspector, Vendor
/Ddte Inspection Branch Approved b W jff '
M//79 D. E. Whitesell, Chief, ComponentsSection I, Datd Vendor Inspection Branch Summary Inspection on January 8-12, 1979 (99900003/79-01)
Areas Inspected:
Implementation of the Topical Report including enrichment and impurity controls, moisture and hydrogen controls; radiographic examination; welding procedure specifications; and action on previous inspection findings. The inspection involved sixty (60) inspector hours on site by two (2) NRC inspectors.
Results:
In the five (5) areas inspected, no apparent deviations or unresolved items were identified in one (1) area:
the following seven (7) deviations and three (3) unresolved items were identified in remaining four (4) areas.
79032000
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Deviations: Action on Previous Inspection Findings - the specification was inadequate in showing compliance to ANSI N45.2.2 and Regulatory Guide 1.38 as required by Table 2-1 of the Topical Report (See Enclosure, Item A);
Enrichment and Inpurity Controls - the Analytical Laboratory Control Instruction was not fully implemented in the areas of the use of procedures, control of activities affecting analytical measurements, calibration of measurement devices and sufficient records to furnish doumentary evidence to assure the quality of measurements as required by Section 2 of the Topical Report (See Enclosure, Item B); Enrichment and Impurity Controls - on several occasions the NBL97 control charts exceed alarm limits yet there was no documentation of these occurrences as required by Section 5 of the Topical Report and COI-002 (See Enclosure, Item C); Radiographic Examination - revision instructions for controlled documentation was not being implemented as required by Section 5 of the Topical Report and 10.4.4 of the ASME QA Manual (See Enclosure, Item D);
Welding Procedure Specifications - hardfacing was being performed with a procedure which had not been requalified as required by Section 9 of the Topical Report (See Enclosure, Item E); Welding Procedure Specification welders were not maintaining D.W.I. requirements as required by Section 9 of the Topical Report and 9.3 of the ASME QA Manual (See Enclosure, Item F);
Welding Procedure Specifications a ct.rrent design drawing was not being maintained as required by Section 5 of the Topical Report and 6.2 of the ASME Manual (See Enclosure, Item G).
Unresolved Items: Radiographic Examination (DetailsSection II, para-graph B.3.b).
Welding Procedure Specifications (DetailsSection II, paragraph C.3.b.(1) and (2)).
. DETAILS SECTION I (Prepared by W. M. McNeill)
A.
Persons Contacted J. E. Bataunis, Foreman
- C. W. Doyle, Manager, Quality Audits & Customer Service J. A. Farencak, QC Planner
- J. B. Hawkins, Manager, Welding and Special Processes
- R. E. Lennon, QA Engineer
- J. H. Liberman, QA Engineer
!J. E. Miller, Manager, Equipment Quality Programs R. I. Parnell, Chemet Lab Engineer
- E. A. Schaefer, Chemet Lab Engineer
- L. A. Sheely, Manager, Fuel Quality
- D. Starr, Manager, Equipment Quality K. Toussaint, QC Planner
- R. C. Van Duyne, Manager, Engineer Process Equipment Control
- T. P. Winslow, Manager, Chemet Lab A. J. Zeits, Chemet Lab Engineer
- E. L. Sherrill, Authorized Inspector, State of North Carolina iB. L. Whitley, Director (AIA), State of North Carolina
- Denotes those attending the Exit Interview.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report 78-02): Measures did not assure items were packaged in accordance with the Packaging Data Sheets. All the inspection instructions have been revised to incorporate the Packaging Data Sheets and the Packaging Data Sheets have been distributed to the work stations. Training classes have been held on the new procedures and the Packaging Data Sheet require-ments.
2.
(Closed) Deviation (Report 78-02): Some instructions were not properly reviewed prior to release.
The Quality Control Inspection Instruction 001 has been revised to incorporate the requirements of the Packing Data Sheet.
Training has been held to restate the objectives of the review process.
3.
(Closed) Deviation (Report 78-02): Some vendors were not on the Survey Approved Vendor List.
The vendors in question have been surveyed. A review of all current purchase orders have been performed to assure that all vendors are approved.
. 4.
(Closed) Unresolved Item (Report 78-02). Confusion existed on how ANSI N45.2.2 requirements were to be handled.
Deviation General Electric has issued Process Specification, P50YP107, Revision 1, to enforct. compliance with Regulatory Guide 1.38 and ANSI N45.2.2.
The General Electric Wilmington position is that P50YP107 is to be enforced on a "best effort" basis.
As a result, documentation was not obtain of wraps, tapes, and desiccants which would prove such were in compliance with P50YP107, ANSI N45.2.2 or Regulatory Guide 1.38.
The exceptior.s identified in the Topical Report to N45.2.2 and Regulatory Guide 1.38 do not identify enforcement on a "best effort" basis.
This item is closed as an unresolved item but is now a deviation.
(See Enclosure, Item A).
C.
Enrichment and Impurity Controls 1.
Objectives The objectives of the inspection were to verify that:
a.
Material flow procedures and practices cover manufacturing operations for all inputs of material in any form from UF6 to completed pellets.
b.
Enriched material is controlled, inspected and checked at each stage during manufacturing and processing to prevent enrichment mixup or contamination.
c.
Sufficient final enrichment checks and chemical analyses are made on pellets or rods to detect any significant enrichment deviations or contamination and to give as- "ance that the pellets and rods meet specifications ant contractural requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of the Topical Report, BWR Quality Assurance Program Description, NEDO-11209-04A. Sections 5,10,11 and 14 and Wilmington Manufacturing Department Quality Assurance Program, NEDE-20586, Revision 5, Sections 6.5, 6.10, 6.11 and 6.14 which established the general requirements for enrichment and impurity controls.
b.
Review of the following Practice and Procedure (P/P),
Quality Assurance Section Administrative Routine (QASAR),
Station Control Plans (SCP), Chemet Lab Calibration and Cperation Instructions (C0I) and the Chemical, Metallurgical, and Spectrochemical Manual (CM & S) which established the specific requirements of enrichment and impurity controls:
Scale and Blance Program, P/P 70-25, Revision 3, Chem Lab Scale Calibration, QASAR 320-70.5, Revision 1, Detemination of Carbon and Sulfur by Leco Analyze, SCP-201, Revision 0, W/0 U by Gama Spectometry, SCP-401, Revision 6, 235 Uranium Metal Impurities, SCP-501, Revision 4, Balance Calibration Procedure Chemet Lab, COI-001-1, Revision 1, Chemet Laboratories Control Ctarting, COI-002-7, Revision 0, Detemination of Chloride by Turbidity, CM&S-1.2.3.3, Revision 1, Detemination of Carbon and Sulfur by Using the Leco CS44, CM&S-1.2.3.13, Revision 0, Detemination of Fluoride in UO /Gd 023 Pellets by 7
Pyrohydrolysis and Titration, CM&S-I.Z.6.2, Revision 3, Detemination of Nitrogen in Metallic and Uranium Dioxide Samples, CM&S-1.2.14.1, Revision 2, Detemination of Uranium and Oxygen to Uranium Atomic Ratio in Uranium Dioxide Powders and Pellets, CM&S-1.2.15.1, Revision 6, Emission Spectrographic Analysis of Uranium for Impurities, Ci&S-3.1.21.2, Revision 1, Detemination of Weight Percent U235 in an Acid Media by Gama Spectrometry, CM&S-5.2.9.5, Revision 4.
, c.
Inspection of the Chemet Lab, the equipment, testing inprocess logs, and other records at the work stations used for the above CM&S procedures in order to verify that the above procedures were implemented.
3.
Findings a.
Deviations See Enclosure, Items B and C.
b.
Unresolved Items None.
c.
Comments (1) NEBG 70-21 was not fully implemented in several areas.
For example, the CM&S Marual has several sections devoted to such subjects as training, calibration, and general requirements. Many of the applicable procedures of these sections are not fully implemented nor issued to the wcrk stations.
Examples of these are pH meter calibration, total gas release calibration, volumetric calibration and measurement.
Fluoride measuremer is were made by absorbtion after pyrohydrolysis of fluorine in a buffer solution and an ion-selective electrode response. All of which means the rate of flow during pyrohydrolysis is critical for accurate measurement. The CM&S procedure specifies a particular flow rate.
However, the instrumentation used to measure and control air flow was not relatable to the procedure requirement.
A program cf calibration of scales used in analytical measurements had been established in the P/P, QASAR, and COI procedures. The CM&S Manual established that calibration shall be over the full range of the instrumentation. The calibration being performed was not over the full range of tne instrumentation.
Uranium - 235 measurements were by gamma spectrometry.
Because of a filtering effect of sample tube's material, each tube must be selected individually.
Records of the acceptance of the individual sample tubes and the acceptance criteria where not on file for all sample tubes.
. (2) The problem identified with the fiBL-97 control charts had a number of moderating conditions. The statistical control chart limits were set tight and the procedure for analysis needed refinement to remove a source of measurement error.
But there was no identification of the control charts as to be excluded from the procedure on reporting out of limit conditions.
In addition to exceeded alarm limits, this same problem was observed on exceeded control limits.
D.
Moisture and Hydrocen Controls 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Moisture and hydrogen control measures are sufficient to give assurance that internal hydriding failures will not occur in service (i.e.
meets specifications and contractual requi rements),
b.
The moisture and hyarogen control and inspection tech-niques are qualified.
2.
-Method of Accomolishment The preceding objectives were accomplished by:
Review of the Topical Report, BWR Quality Assurance a.
Program Description, fiEDO-11209-04A, Sections 5,10,11 and 14 and Wilmington Manufacturing Department Quality Assurance Program,fiEDE-20586, Revision 5, Sections 6.5, 6.10, 6.11 and 6.14, which established the general require-ments for moisture and hydrogen controls.
b.
Review of the following Practice and Procedure (P/P) and Quality Assurance Section Administrative Routine (QASAR) and the Chemical, Metallurgical, and Spectrochemical Manual (CM&S) which established the specific requiremen's of moisture and hydrogen controls:
Scale and Balance Program, P/P 70-25, Revision 3.
Chem Lab Scale Calibration, QASAR 320-70.5, Revision 1.
Total Gas Released from Uranium 0xide by Hot Vacuum Extraction, CM&S-1.2.7.1, Revision 2.
. Determination of Hydrogen in U02 Pellets by Inert Gas Fusion, CM&S-1.2.8.4, Revision 5.
c.
Inspection of the Chemet Lab, the aquipment, testing inprocess, logs and other records at the work stations used for the above CM&S procedures in order to verify that the above procedures were implemented.
3.
Findings a.
Deviations None.
b.
Unresolved Items None.
c.
Con. ents None.
E.
Exit Interview The inspectors met with management representatives (denoted in paragraph A) at the conclusion of the inspection on January 12, 1979.
The inspectors summarized the scope and findings of the inspection.
The management representatives had no comment in response to each item Cscussed by the inspectors.
8 a
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DETAILS SECTION II (Prepared by J. W. Sutton)
A.
Persons Contacted D. Adams, Process Control Engineer (Level III, X-Ray)
C. W. Doyle, Manager, Quality Audits and Customer Service R. T. Dopki, Manager, Document Control Center E. Devane, Foreman, Welding L. W. Emory, Manufacturing Engineer, Welding W. Hodges, Foreman, X-Ray J. H. Liberman, QA Engineer R. E. Lennon, QA Engineer J. Lasure, Process Control Engineer, Welding E. A. Lion, Purchased Materials, (Weld Materials)
D. Ratliff, Ibnager, Quality Control Engineering Equipment J. E. Stoudenmire, Quality Verification and Release Supervisor R. C. Van Duyne, Manager, Engineer Process and Equipment Control E. L. Sherrill, Authorized Inspector, State of North Carolina B. L. Whitley, Director (AIA), State of North Carolina B.
Radiograohic Examination 1.
Objectives Tne objectives of this area of the inspection were to verify that:
a.
Radiographic examination procedures used by the manu-facturer meet the applicable ASME Code, regulatory and contract requirements, b.
Radiographic examination is being conducted by properly qualified personnel, in accordance with the above procedures and the manufacturers overall QA plan.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of General Electric Topical Report, NED011209-04A, March 1978, Section 9.
b.
Review of the ASME QA Manual, Section 10.4, Nondestructive Examination.
_la_
c.
Review of QC Examination Instruction, 652, Revision 5, titled, Radiography Control Rod Drive Housing.
d.
Review of Quality Inspection Standards (QIS) 109, Revision 2, issued June 24, 1974, titled, Radiographic Film Interpretation of Welds. QIS 243, Revision 0, issued May 15, 1978, tititd, use and Care of Densitometers and Densitometers (X-Ray)
Step Tablats.
e.
Review of the X-Ray Production Log.
f.
Review of design drawing 105D5424G004, Revision 4.
g.
Review of Qua.lity Inspection Standards, number 100.3, Revision ', titled, Inspection and Test.
h.
Discussions with cognizant perscnnel to verify that they are knowledgeable in areas reviewed.
3.
Findinas Due to time limitations, the entire area of Radiographic Examination could not be reviewed or examined.
1his area will be reviewed during a subsequent inspection. The following was identified as a result of this inspection.
a.
Deviations.
See Enclosure, Item D.
b.
Unresched Items The number of reviews per weld required by Section 4.1 of QC Examination Instruction 652, Revision 6, was not consistent with Section 4.2. G.E. will revise this procedure to correct this problem.
_ eldina Procedure Soecifications C.
W 1.
Obj ect.i.c The objective of this area of the inspection was to verify that the Welding Procedure Specifications (WSP) used by a manufacturer in production welding are being prepared, qualified and controlled in accordance with the manufacturer's QA Program and applic.lle ASME Code requirements.
. 2.
Method of Accomolic ment The preceding objective was accomplished by:
a.
Review of General Electric Topical Report, NEDO 11209-04A, March 1978, Section 9.
b.
Review of the ASME QA Manual, Sections, 6.4.3, Welming Material Control, 6.2, Maintenance and Distribution of Drawings, 9.3, Control of Welding.
c.
Wilmington Manufacturing Department List of Current ASFi Code designated components / parts.
d.
Observation of welding activities at three (3) welding stations.
e.
Review of Shop Travelers and drawings Nos.105D6131G047, Revision 4, 105D5424G002, Revision 4, and 137C5058, Revision 3.
f.
Review of Operational Planning Sheets 001 and 002 for drawing No. 137C5057 P001.
g.
Review of Process Engineering Instruction, 2.34, Revision 6, titled, Control of Welding Rod and Wire.
h.
Review of QASAR 320-90.1, Revision 1, Surveillance System for Control of Welding Rod, Wire and Flux and QASAR 320-90.2, Welding and Hardfacing Process Surveillance System.
i.
Examination of welding instructions and witnessed welding operations for D.W.I No. 251 and 0.W.I 261.
j.
Reviewing the current Weld Performance Schedule and the system used to maintain welders qualifications.
Review of qualification records for elders Nos. 13585, 19574, 16727, 16751, and 13607.
k.
Review of certification data for welding materials, Chromenar
- 2V51; Sandvick #4V17; GE 846 #2V52; and Colmonoy, #233.
1.
Review of welding specification P50YP104, Revision 0, issued December 15, 1967., titled, Hard Surfacing of Iron and Nickel Base Alloys with Colmonoy No. 5.
m.
Examination of weld material storage areas and review of welding materials approval and release system.
Review of Weld Material Control Log.
. Review of the calibt ation status of meters on welding n.
equipment utilized for operations witnessed.
Discussions with cognizant personnel to verify that they o.
are knowledgeable in areas reviewed.
3.
Findings a.
Deviations See Enclosures, I'. ems E, F, and G.
b.
Unresolved Items (1) During the inspectors review of Stop Work Notice No.1678, issued on January 10, 1979, it was noted that the fann did not require QA/QC sign off of the completed corrective action. The inspector was informed that the Stop Work Notice is used as a general form and is used regardless if a quality problem does or does not exist.
Procedure 80-34, Revision 6, does not definitely define that QA/QC sign off is requirement for a quality problem.
GE trdicated that the matter will be reviewed.
(2) During the review of design drawing 137C5058, Revision 3, for the Control Rod Guide Tube Base Casting, the subject of ASME Code boundries was discussed. The inspector orginially wal informed by GE that the casting was a Code item, including the hard surfacing operation.
Review by GE Design Personnel indicated that the casting Code boundry had been defined excluding the hard surface areas.
In January 11, 1979, an internal memo from GE design personnel to Wilmington Manufacturing Department it was stated that, "the concept of defining Code boundries internal to an integral casting was specifically addressed and agreed to by the code committee during the original writing of ASME Section NG."
The AIA also had a question regarding this problem they intend to pursue the matter with the Code Committee and relay their findings to GE Wilmington Manufacturing Department.
In addition, on this same part it was noted that the requirements of ASME Code, Section NG 1122, Internal Structures, paragraph (c) requires, "that the Certificate Holder shall certify that the construction of internal structures is such as not to adversely affect the integrity of the core support structure".
Design engineering is in San Jose, and fabrication is at
,... available to show that this requirement was satisfied.
The inspector was informed that designation as to which facility should sign the certification form was under discussion.
This problem is also being researched by the AIA and their findings will be discussed with GE.
c.
Coments During the inspectors examination of the hard surfacing of the Control Rod Guide Tube Base Casting as described on Design drawings 137C5057 and 137C5058 it was brought to the attention of the GE that the hard surfacing was being applied without a properly requalified procedure.
The inspector was informed that all parameters of the hard surfacing was contained in the Method Sheets 001 and 002 for this operation. The Method Sheets do contain the hard surfacing requirements but they are viewed as a "how to do" type document. GE had qualified the procedure for the colmonoy stainless fuse weld w-1 on September 24, 1971, with a oxygen-acetylene flow rate of 18 and 15 lbs.,
respectively.
The oxygen flow rate has been changed in the process being used to 22 lbs. This is consided a major char.ge to the procedure.
There was no evidence that a ryqualification test had been conducted after the above cnange.
In addition, other parameters such as type of equipment and tip size had been changed since the orginal qualification.
As a result of the inspectors inquiry, as to the qualification of the operation, GE issued a Stop Work tiotice io.1678 on January 10, 1979. The notice indicated that, "the present method of colmonoy spray has not been qualified as a weld procedure." All work was terminated.