ML19282B483
| ML19282B483 | |
| Person / Time | |
|---|---|
| Issue date: | 10/19/1978 |
| From: | Ellershaw L, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19282B443 | List: |
| References | |
| REF-QA-99900282 NUDOCS 7903150051 | |
| Download: ML19282B483 (10) | |
Text
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t VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900282/78-02 Program No. 44070 Company:
ITT Grinnell Corporation Pipe Hanger Division 621 Dana Avenue Warren, Ohio 44481 Inspection Conducted:
September 26-29, 1978 Inspectors:
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@ L. E. Ellershaw, Contractor Inspector
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Vendor Inspection Branch d
Approved by:
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/&/?/~T D. M. Hunnicutt, Chief, Components II
/ Date Vendor Inspection Branch Summary Inspection conducted September 26-29, 1978 (99900282/78-02)
Areas Inspected:
Implementation of 10CFR50 Appendix B Criteria, and ap-plicable codes and standards including: control of nonconformances and corrective action; nondestructive examination process control (magnetic particle); nondestructive examination personnel qualifications; weld heat treatment, and previous inspection findings.
The inspection involved twenty eight (28) inspector hours on site.
Results:
In the five (5) areas inspected, seven (7) deviations from commitment were identified.
Deviation: Nonconformances and Correct.ve Action - segregation and iden-tification on nonconforming material was not maintained, which is contrary to Criterion XV of Appendix B to 10CFR50 (Enclosure, Item A.), corrective action requ'ests were not originated for in-process nonconformances, which is contrary to Criterion XVI of Appendix'B to 10CFR50 (Enclosure, Item B.);
Nondestructive Examination Process Control - a magnetic particle procedure was not in the possession of the NDE examiner or in the QA specification library, adjacent to the magnetic particle area, which is contrary to Criterion 790315006l
_2_
IX of Appendix B to 10CFR50 (Enclosure, Item C), the black light intensity and the bath concentration of the particles had not been determined in accordance with the ASME Code and the magnetic particle examination procedure, which is contrary to Criterion IX of Appendix B to 10CFR50 (Enclosure, Item D); Nondestructive Examination Personnel Qualifications - personnel performing visual examination have not been qualified in accordance with the requirements of the ASME Code and two visual examination specifications do not comply with the appropriate portion of the ASME Code which is contrary to Criterion IX of Appendix B to 10CFR50 (Enclosure, Item E); Previous Inspection Findings (Weld Material Control) - a bundle of approximately 50 welding electrodes, located in a holding oven in a controlled storage area was incorrectly identified which is contrary to Criterion VIII of Appendix B to 10CFR50 (Enclosure, Item F); Previous Inspection Finding (Welding Process Control)
- unauthorized, submerged arc welding was being performed on a shop order in which the drawing allowed shielded metal arc or flux cored arc welding only, which is contrary to Criterion 17 of Appendix B to 10CFR50 (Enclosure, Item G).
i
. DETAILS SECTION (Prepared by L. E. Ellershaw)
A.
Persons Contacted B. Grabowski - NDE level II G. Radu - Manager, Quality Control D. M. Sewell - Division Quality Assurance Manager H. O. Strom - Plant Quality Assurance Manager J. Taylor - Quality Assurance Engineer B. Welsh - Brass Room Attendant i
B.
Action on Previous Inspection Findinas 1.
(Closed) Deviation No. A (Report No. 78-01):
This item dealt with corrective action requests not documenting the cause or the corrective a
- action, i
ITT Grinnell Corporation, Pipe Hanger Division (ITT-PHD) has implemented their committed corrective action, in that a training session was held and a review of corrective action requests revealed that causes and corrective actions were documented.
2.
(Closed) Deviation No. 8 (Report No. 78-01):
This item dealt with welding materials being incorrectly identified and not identified at all.
ITT-PHD has implemented their committed corrective action in that the material was rejected and scrapped, and written instructions were developed.
However, the action taken to preclude recurrence appears to have been inadequate in that a related deviation was identified.
See Enclosure, Item F.
3.
(. Closed) Deviation No. C (Report No. 78-01): This item dealt with certain operations on Welding Travelers and on QC checklists had not been signed off, even though the operations had been performed.
ITT-PHD has implemented their committed corrective action in that the particular operation has been deleted as being not applicable on non-machined material. Additionally, training sessions were held for manufacturing and quality control personnel.
4.
(Closed) Deviation No. D (. Report No. 78-01): This item dealt with missed Authorized Nuclear Inspector hold points.
. ITT-PHD has implemented their committed corrective action in that training sessions were held, and a review of QC Checklists indicated I
that hold points were being complied with.
5.
(Closed) Deviation flo. E (Report No. 78-01): This item dealt with certain parts not being identified with a heat code.
ITT-PHD has implemented their committed corrective action in that the QA Manual was revised to comply with the ASME Code relativa to part identification.
6.
(Closed) Unresolved Item fio B.10. (Report No. 78-01): This dealt with the QA Manual not addressing measures being extended to the performance of a subcontractor's corrective action program.
ITT-PHD has implemented their committed corrective action in that the QA Manual now addresses this ASME Code requirement.
C.
Control of Nanconformances and Corrective Action 1.
Objective The objective of this area of the inspection was to verify that ITT-PHD had implemented the requirements for the control of non-conformances and corrective action in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Review of QA Manual Sections QCH-10.1 "Nonconfomities",
Revision 1, and QCH-10.2 " Corrective Action," Revision 1.
b.
Review of Procedure No.12A001, "Nonconformities and Corrective Action Policy," Revision C, dated July 14, 1978.
c.
Review of Procedure No.12A002, "Nonconformances and Corrective Action Syste:n Guidelines," Revision E dated July 28, 1978.
d.
Observation of nonconforming material / parts, located in controlled and locked storage areas.
Review of Purchased Nonconforming Material Reports.
e.
f.
Review of Rejected Material Reports.
j g.
Review of Corrective Action Requests.
i h.
Discussions with cognizant personnel.
3.
Findings a.
Deviations From Commitment f
(1) See Enclosure, Item A.
(2) See Enclosure, Item B.
1 I
b.
Unresolved Item I
None.
D.
Nondestructive Examination Process Control (Magnetic Particle) 1 1.
Objective l
The objective of this area of the inspection was to verify that ITT-PHD had implemented the requirements for the control of non-i destructive examination (magnetic particle) in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objective was accomplished by:
l a.
Review of QA Manual Section QAM-6.2, " Nondestructive Exam-ination - Procedure Qualification," Revision 0, dated February 22, 1978.
b.
Review of QA Manual Section QAM-6.3, " Nondestructive Exam-ination Status," Revision 0, dated February 22, 1978.
c.
Observation of in-process magnetic particle examination (wetmethod).
d.
Discussions with cognizant personnel, e.
Review records of equipment and material being used.
3.
Findings a.
Deviations From Commitment
--- (1) See Enclosure, Item C.
(2) See Enclosure, Item D.
b.
Unresolved Item None.
E.
Nondestructive Examination Personnel Oualifications i
1.
Objective The objective of this area of the inspection was to verify that ITT-PHD had implemented the requirements for the control of qualifying and certifying nondestructive examination (NDE) personnel in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objective was accomplished by:
l a.
Review of QA Manual, Section QAM-6.1, " Nondestructive Exam-ination - Personnel Qualification," Revision 0, dated February 22, 1978.
b.
Review qualification records of NDE persornel.
c.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitment See Enclosure, Item E.
b.
Unresolved Item None.
c.
Comment Section III, Subsection NF, paragraph NF-5520 states in part,
" Personnel performing nondestructive examination shall be qualified in accordance with SNT-TC-1A-1975, except... for visual examination, The Jaeger Number 1 letters shall be used in lieu of the Jaeger Number 2 letters specified in paragraphs
_ 8.2 (a)(1) of 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 examinations 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."
However, ITT Grinnell Corporation, PHD has not considered visual examination to be a nondestructive examination method and has not developed comparable examinations for the practical portion of the visual method.
Additionally, two visual examination specifications (VES):
1-SF-1501 NF 3 and 1-SF-1503 NF0, do not comply with the above, in that paragraph II of each VES, states in part,
" Personnel qualification - all personnel performing examina-tion in accordance with this specification... shall meet the physical vision test requirements of SNT-TC-1A."
The physical vision test requirements of SNT-TC-1A do not comply with ASME Code requirements.
It should be noted i
that ITT does qualify personnel to Jaeger Number 1 letters.
F.
Weld Heat Treatment 1.
Objective The objective of this area of the inspection was to verify that ITT-PHD had implemented the requirements for the control of post weld heat treating (PWHT) in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objective was accomplished by:
a.
Review of QA Manual, Section QCH-8.1, " Heat Treating,"
Revision 1, dated June 15, 1978.
b.
Observation of in-process PWHT being performd on Shop Order 402384-00.
c.
Review calibration records of recorders, furnace and thermo-couples.
d.
Review heat treat charts for heating and cooling rates, and time at temperature.
e.
Discussions with cognizant personnel.
.. _. ~...
. 3.
Findings a.
Deviation From Commitment None b.
Unresolved Item None G.
Previous Inspection Finding (Weld Material Control) 1.
Objective The objective of this area of the inspection was to verify that ITT-PHD had implemented their corrective action commitments as delineated in their response letter to NRC, dated April 13, 1978.
i 2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Review of QA Manual Section QCH-5.1, " Welding Quality Assurance - Material Control," Revision 1, dated June 15, 1978.
I b.
Review of Welding Material Requisition Forms, used for dis-tribution of weld material to the welders and for verification of correct distribution by Quality Control inspectors.
c.
Observation of hot boxes, used for holding weld material that has been issued to welders, at a given work station.
d.
Observation of the drying ovens located in the Brass Room, which is a controlled area from which the weld material is issued to the welders.
e.
Review of weld material certifications for the required chemical and physical properties.
f.
Discussions with cognizant. personnel.
3.
Findings a.
Deviation From Commitment See Enclosure, Item F.
. A similiar finding was identified in Inspection Report No. 78-01.
b.
Unresolved Item None.
H.
Pre 'ious Inspection Finding (Welding Process Control) 1.
Objective The objective of this area of the inspection was to verify that ITT-PHD had implemented their committed corrective actica as delineated in their response letter NRC, dated April 13, 1978.
2.
Method of Accomolishment The preceding objective was accomplished by:
a.
Review of QA Manual Section QCH-5.4, Revision 1, dated June 15, 1978.
b.
Observation of in-process welding being performed on Shoo Order 21135700 and a review of the associated documentation.
c.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitment See Enclosure, Item G.
b.
Unresolved Item None.
I.
Exit Interview A meeting was held at the conclusion of this inspection on September 29, 1978, with the following management and Authorized Inspection Agency representatives:
D. A. Dorsey - Authorized Nuclear Inspector, The Hartford Steam Boiler Inspection and Insurance Company (HSB).
R. R. Gallatin - Authorized Nuclear Inspector (HSB)
M. A. Grosso - Acting Division General Manager D. M. Sewell - Division QA Manager
~ H. O. Strom - Plant QA Manager The scope and findings of this inspection were summarized.
Management acknowledged the statements relative to the findings.
.