ML19282B475
| ML19282B475 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19282B443 | List: |
| References | |
| REF-QA-99900282 NUDOCS 7903150044 | |
| Download: ML19282B475 (4) | |
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ITT Grinneii Corporation Pipe Hanger Division Docket No.
99900282/78-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on September 26-29, 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 10CFR50 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. These measures shall include, as appropriate, procedures for identification, documentation, cegregation, disposition...."
QA Manual Section QCH-10.1, paragraph C states in part,... " Red (Reject) tags shall be used on all rejected items.
Items so tagged, shall be segregated until the status has been determined." Paragraph D. states in part, " Form H10.1B, Purchased Nonconforming Materials Report shall be initiated and approved by the Plant Quality Assurance Manager for all Vendor supplied items that do not conform to the applicable requirements...."
t Contrary to the above, segregation and identification was not maintained, in that Purchased Nonconforming Material Report No. 2278C and a red reject tag, each of which stated, three (3), rejected, 2k" diameter studs, were attached to a box containing just one stud. The other two (2) studs were not located during the course of this inspection.
I B.
Criterion XVI of Appendix B to 10CFR50 states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, 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 detennined and corrective action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented...."
QA Manual Section QCH-10.2, paragraph A. states in part, "This procedure defines the systematic method for resolving the causes of nonconformities, identified throrgh various examinations, product measurement operations, and audit findiags.
It also identifies the measures established to correct significant conditions adverse to qual ty in a timely manner so as to prevent repetition thereof.
The methods of documenting these activities, including the identification, cause and corrective action are defined herein." Paragraph B states in part, "The Corrective Action Request shall be originatei by the Plant QA/QC Manager...."
79031500$
_... Paragraph C. states in part, " Corrective Action shall be instituted, and documented by the Plant QA/QC Manager, as applicable, for significant conditions adverse to quality. This applies both to vendor caused nonconformances, as well as in-process nonconfomances."
Contrary to the above, corrective action requests (CARS) which doc-ument the causes, corrective actions, and actions taken to prevent repetition, have not been originated for significant conditions adverse to quality such as in-process nonconformances. A review of the records for 1978 to date, revealed that approximately 1,962 nonconformances have been identified on approximately 1,700 reject material reports with 333 nonconformances identified in the area of material identifica-tion and control, and 226 nonconformances identified in the area of welding, and CARS were not originated.
It was also determined that just eleven (11) CARS have been originated during 1978 to date (CARS 1150 through 1160).
C.
Criterion IX of Appendix B to 10CFR50 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 QAM-6.2, paragraph D. states in part, "All qualified NDE personnel shall have in their possession and'be familiar with the approved NDE procedure before performing any examination."
Contrary to the above, magnetic particle examination (MT) was being performed on Shop Order E-EK-001, Class I Springs, in which the QC check list required the use of MT procedure I-S-1903, Revision 2 and the procedure was neither in the possession of the NDE examiner or in the Specification Library, Station No.1, which is adjacent to the MT area.
D.
Criterion IX of Appendix B to 10CFR50 states, " Measures shall be estab-lished 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."
Magnetic Particle Examination (MT) procedure I-S-1903, Revision 2, paragraph V states in part, " Prior to each examination, oil should be checked with black light to insure that it has minimum amounts of material fluorescence.
Bath strength or concentration of the particles in the bath must be maintained between 0.1 and 0.7 ML by taking a 100 ML portion of the bath into a graduated centrifuge tube or graduate
- and allowing it to settle for thirty minutes.
Prior to this test the circulation of the suspension should be for a minimum of 15 minutes."
ASME Code Section V, Article 7, paragraph T-725.3 states ir part, "If fluoresent particles are used, the examination is to be conducted in a darkened area using filtered ' black light'. The black light intensity at the surface under examination shall be determined at least once every 8 hrs...."
Contrary to the above, magnetic particle examination,was being performed even though the bath concentration had not been determined and the black light intensity had not been determined at least once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
It must be noted that the graduated flask had been broken two days prior to this inspection and a new one was on order.
- However, there was no documented evidence of the above requirements having been performed at any time.
E.
Criterion IX of Appendix B to 10CFR50 states, " Measures shall be estab-lished 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 III, Subsection NF, paragraph NF-5111 states in part,
" Nondestructive examinations shall be conducted in accordance with the examination me+5cds of Section V, except as they may be modified by the requirements of this Article.
... visual examination shall be in accordance with Section V, Article 9."
QA Manual Section QAM-6.2, paragraph C. states in part, "A procedure for a particular examination method shall be written... It shall comply with the appropriate portion of the Code and shall be reviewed by a Level III individual for conformance to the Code."
Contrary to the above, ITT Grinnell Corporation, Pipe Hanger Division, has not considered visual examination to be a nondestructive examina-tion method and has not developed comparable examinations for the visual method.
F.
Criterion '<III of Appendix B to 10CFR50 states in part, " Measures shall oe established for the identification and control of materials, parts, and components.... These measures shall assure that iden-tification of the item is maintained by heat number, part number, serial number, or other appropriate means...."
. QA Manual Section QCH-5.1, paragraph C.2., states in part, " Marking on contaire"s shall include heat, lot or batch number...." Para-graph D.6. states in part, " Materials returned to the Brass Room shall be properly identified.
Returned electrodes, rods and wire shall be banded and tagged with heat or lot number...."
Contrary to the above, a bundle of approximately fifty (50) electrodes were not properly identified, in that the attached metal tag identified the bundle as 1/8" type E8018 electrodes, HT 411B6841, Lot No. 023J 719D while the electrode manufacturer's identification, as printed on the electrodes, read Type 7018 Coh PPP046. A similar finding was identified in Report No. 78-01.
G.
Criterion IX of Appendix B to 10CFR50 states, " Measures shall be estab-lished 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 QCH-5.4, paragraph C. states in part, "All welding materials and operations shall be specified on the Process Sheets.
i The Process Sheets shall be reviewed and approved by the Plant Quality Assurance Manager to verify that all operations specified are in accordance with Product Drawings or Project Sketches, as applicable."
Contrary to the above, observation of in-process welding being performed on Shop Order 21135700 revealed that verification haa not been perfonned, in that the welding operation specified by the Process Sheet was not in accordance with the product drawing requirements.
Submerged Arc Welding (SAW) was being performed as required by the Process Sheet, using Weld Procedure Specification (WPS) 1-02-1-17, dated June 16, 1977, however the required drawing, CH1036 Revision B, dated May 11, 1978, does not allow SAW, but stipulates that WPS 1-01-1 (Shielded Metal Arc Welding) or WPS 1-06-1 (Flux Cored Arc Welding) be used.