ML19276E803
| ML19276E803 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19276E793 | List: |
| References | |
| REF-QA-99900286 NUDOCS 7903210118 | |
| Download: ML19276E803 (5) | |
Text
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Gaulin Corocration Cocket No. 999002S6/78-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on October 23-27, 1978, it appeared that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:
^
Criterion X of Appendix B to 10 CFR 50 states in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization oerforming the activity to verify conformance with the documented instructions, procedures, and drawings for acccmplishing the activity.
Such inspection shall be performed by individuals other than those who cerformed the activity being inspected.
QA Manual Section 5, paragraph 5.6.4, states in part, "When an operation listed on a Standard Operation Sheet for Nuclear Material has been completed the machine operator shall notify a Quality Control In-Process Inspector.
The Quality Control In-Process Inspector shall indicate dimensional conformance of said operation by applying his Inspector Stamp and date in the column designated on the Standard Oceration Sheet.
Gaulin Corporation's (GC) response letter to NRC dated Aaril 27, 1978, relative to actions taken to orevent recurrence states in part,
"... A training session has been conducted instructing all Quality Control Inspectors that all operations on a Standard Operation Sheet, that requires inspection; must be stamped and dated before proceeding to the next operation."
Contrary to the above, a review of the Standard Operation Sheet for the Cylinder, P/4 927757, of the Positive Displacement Charging Pumo, S/N 78h001, revealed that the Quality Control In-Process Inspector did not indicate dimensional conformance by applying his Inspector Stamo and date in the designated column for the following inspection operations even though subsequent operations had been completed:
Operations 4, 6, 8, 10, 12, 14 and 16.
A similar deviation was identified in Inspection Report No. 78-01.
(See Details Section, paragraph C.3.).
B.
Criterion X of Appendix B to 10 CFR 50 states in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to 7 9 0 3 2 ] o /! 'd
, verify conformance with the docurrented instructions, procedures, and drawings for accomplishing the activity.
Sucn inspection shall be performed by individuals other than those who performed the activity being inspected...."
QA Manual Section 5, paragraph 5.4.1, states in part, "The Gaulin Quality Control Log Report is used by Quality Control Inspectors to record all inspections performed on Nuclear Materials being processed through tNe shop. The Gaulin Quality Control Log Report defines all required inspections to be performed in sequence with the operations specified on the Standard Operations Sheet.
Contrary to the above, Operation 3 of the Quality Ccntrol Log Report for the Cylinder, P/t4 927757 for Pump S/N 78HC01, consisted of twenty-four (24) required inspections which were to be performed in sequence with the operations specified on the Standard Operations Sheet and only eight (8) had been checked /stamced off by Quality Control Inspectors to indicate verification, and subsequent operations had been completed.
(See Details, Section C.3.).
C.
Criterion IX of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
QA Manual Section 8, paragraph 8.0, states in part, "All Heat Treatment Procedures shall be qualified and perfomed by the Heat Treating Sub-Contractor...."
Heat Treat Procedure GNV-42, Revision 2, states jn part, " Forgings shaji be placed in the heating furnace at a temperature not go exceed 300 F.
Raise the temperature as rapidly as possible to 1925 F plus or c
minus 25 F.
Hold at this temperature for a minimum of one hour and then remove the forgings from the furnace and quench in agitated water.
Heat treatment will be documented by a copy of the original furnace chart showing purchase order... procedure and revision number."
Contrary to the above, a review of the furnace charts showing the heat treatment performed on the suction flunge and the discharge flange for Pump S/N 78H001 revealed:
(1) The temperatures were not raised as rapidly as possible to 1925 F 0
plus or minus 25 F in that the suction flange was held at a 0
temperature of 18C0 F for nearly four and,one half (%) hcurs, and the discharge flange was held at 1800F for nearly two (2) hours before elevation to the required 1925 F.
(2) The procedure used, and its revision number, was not documented on the furnace chart for the suction flange.
D.
Criterion III of Appendix B to 10 CFR 50 states in part, "..
Measures shall be established for the identification and control of design interfaces and for coordination among participating design organizations.
These measures shall include the establishment of procedures among participating design organizations for the review, approval, release, distribution, and revision of documents involving design interfaces..
Design changes, incluaing field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.
QA Manual Section 2, paragraph 2.4, states in part, " Changes to Engineering designs and design documents for whatever reasons required shall be documented and then reviewed, checked, approved and controlled in accordance with full procedural requirements for orignal designs QA Manual Section 3, paragraph 3.2, states in part, "The Specifications Review Committee shall meet to review and compare each Customer's Nuclear Pump Purchase Order and Design Specifications....
The Specifications Review Committee shall review the Customer's Design Specifications to ensure that they are not in conflict with the ASME Code and ensure that all customer requirements over and above the ASME Code are translated into special instructions.
Each member of the Specifications Review Committee shall indicate his acceptance of Nuclear Pump Purchase Order by signing the cover sheet of the Custcmer's Design Specifications...."
Contrary to the above, the Specifications Review Committee did not sign the cover sheets indicating review and approval, of Change Notices 3 and 4 of a Customer Purchase Order, which incorporated Revisions 8 and 11 respectively, to the Customer's Equipment Scecifi-cation.
E.
Criterion IX of Appendix 8 to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestuctive testing, are controlled and acccmplished
_a_
by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requi rements."
QA Manual Section 6, under Purpose states, "This section describes the system utilized to ensure that all nondestructive examinations on materials and parts are conducted by personnel qualified and certified to SNT-TC-1A in accordance with properly certified procedures meetings A.S.M.E. Code requirements."
Paragraph 6.1 states in part, "... The Nondestructive Examination t/ethod of Liquid Penentrant shall be performed by Gaulin Personnel in accordance with the requirements of the A.S.M.E. Code and SNT-TC-1A standards. All other required Nondestructive Examination, including Liquid Penetrant Inspection when practical, shall be subcontracted to a Qualified Nondestructive Examination Company approved by the Manager, Quality Assurance... in accordance with the requirements of the ASME Code and the SNT-TC-1A Standards."
ASME Code Section III, Subsection NF, paragraph NF-5111 states in part, " Nondestructive examinations shall be conducted in accordance with the examination methods of Section V,... visual examination shall be in accordance with Section V, Article 9.
Paragraph NF-5520 states in part, " Personnel performing nondestructive examination shall be qualified in accordance with SNT-TC-1A-1975....
For nondestructive examination methods not covered by SNT-TC-1A documents, personnel shall be qualified by the Certificate Holder to comparable levels of competency by subjection to comparable examina-tions on the particular method involved....
The practical portion of the qualification shall be performed using the Certificate Holder's procedure on parts representative of the products."
Contrary to the above, a review of a subcontractor's documentation relative to visual examination of welds performed on ASME Code, Subsection NF, Class II Component Supports, revealed that the subcontractor had not qualified the visual examination personnel in accordance with the ASME Code by subjection to comparable examinations, both written and practical.
See Detail Section, paragraph F.3 for additional details.
F.
Criterion IX of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that special processes, including welding, heat treating, and 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 IX, paragraph QW-201.1 states in part, "The welding procedure sr,ecification (WPS) shall list in detail... the range of preheat and postweld heat treatment... and other variables described for each welding process as either essential or nonessential...."
Paragraph QW-201.2 states in part, "The specific facts involved in qualifying a WPS shall be recorded in a form called Procedure Qualifi-cation Record (PQR).
This form shall document the essential variable of the specific welding process or processes... and the test results....
The WPS identification (including date and revision number) shall be listed on the PQR....
A change in any essential variable shall require requalification, to be recorded in another PQR."
Paragraphs QW-253 - Shielded Metal Arc Welding (SMAW), and QW-255 -
Gas t'etal Arc Welding (GMAW), both list postweld heat treatment (PWHT) as an essential variable.
Paragraph QW-407.1 states in part, "A change in the specified postweld heat treatment range requires WPS qualification for each of the following conditions:
(a) Where no postweld heat treatment is used; (b) Where postweld heat treatment is used (which is defined as below the critical range)...."
Contrary to the above, GMAW, SMAW, and postweld heat treatment (PWHT) was performed, by a subcontractor, on two (2) ASME Code Subsection NF, Class 2 component supports (Pump Pedestals), using weld procedure specifications which had not been qualified for PWHT as shown by the procedure qualification records which stated, "Postweld heat treatment -
tione. "
Additionally, the revision number of the GMAN WPS used (WPS-AB, Revision 1), was not listed on the supporting PQR.
See Detail Section, paragraph G.3. for additional details.