ML19289E002
| ML19289E002 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1978 |
| From: | Ellershaw L, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19289D994 | List: |
| References | |
| REF-QA-99900342 NUDOCS 7903210280 | |
| Download: ML19289E002 (11) | |
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U.S. iiUCLEAR REGULATORY COMMISSI0il 0FFICE OF INSPECTION AiiD E'iFORCEMEilT REGI0ff IV Report f4o.
99900342/78-02 Program fio. 51300 Company:
Lakeside Bridge & Steel Company 5300 fl. 33rd Street Milwaukee, Wisconsin 53209 Inspection Conducted:
December 11-15, 1978 Inspector:
ev D M Ai 7[
L'.' E. Ellershaw, Contractor Inspe. tor Da/e
/
Vendor Inspection Branch Approved by:
a~-o
^2 /2 9 /7 l' j ee D. M. Hunnicutt, chief, Components Date Section II, Vendor Inspection Branch Sumary Inspection conducted December 11-15, 1978 (99900342/78-02)
Areas Inspected:
Implementation of 10 CFR 50 Appendix 3 Criteria and applicable codes and standards including:
previous inspection findings; nonconformances and corrective actions; manufacturing process control-,
procedure, document and drawing control, joint fitup and welding; weld heat treatment, and design process management, design verification and design document control.
The inspection involved thirty-four (34) inspector-hours on site.
Results:
In the seven (7) areas inspected, one (1) deviation from cosiitment and one (1) unresolved item were identified.
Deviation:
Previous Inspection Finding (Qualification of Weld Procedure Specifications) - revision numbers and dates of weld prccedure specifica-tions are not listed on the applicable procedure qualification records, as required by Criterion IX of Appendix B to 10 CFR 50 (See Enclosure).
Unresolved Item: Weld Heat Treatment - based upon the wording of post weld heat treatment (PWHT) procedures, there is no definition as to how the beginning and ending of a PWHT holding period is determined.
Consequently, certain sections of large components receiving PHT could exceed the PWHT time allowed by the procedure qualification records (Details Section, paragraph H.3.b.).
7103210940 DETAILS SECTION (Prepared by L. E. Ellershaw)
A.
Persons Contacted W. G. Brock - Contract Administrator R. Diehl - Estimator K. Kernats - Drawing Controller L. Krzyzanowski - Chief Draftsman R. Kubit - Chief Structural Engineer J. H. Mortenson - Quality Assurance Administrator R. T. Rozek - Director, Quality Assurance T. Smith - Production Planner Y. T. Smith - Welding Engineer A. J. Was - Quality Assurance Engineer R. Weber - Cage Attendant B.
Action on Previous Insoection Findings 1.
(Closed) Deviation No. A (Report No. 78-01):
This item dealt with hold tags not being attached to nonconforming parts or their associated paperwork.
Lakeside Bridge & Steel Company (LB&S) has implemented their committed corrective actions in that a clarification to their Quality Assurance Manual was made, and nonconforming parts were identified with a hold tag.
2.
(Closed) Deviation No. B (Report No. 78-01):
This item dealt with the LB&S quality program not addressing corrective action requirements being extended to the performance of a subcontractor's corrective action measures.
LB&S has implemented their comnitted corrective action in that this requirement has been incorporated in the Corrective Action Procedure, number 1.12.
3.
(Closed) Deviation No. C (Report No. 78-01): This item dealt with different types of electrodes being intermingled in an electrode holding oven.
LB&S has implemented their ccanitted corrective action in that a review of their electrode holding ovens revealed that cnly designated electrodes were contained in the holding ovens.
4.
(Closed) Deviation No. D (Report No. 76-01):
This item dealt with LS&S not being able to substantiate a Procedure Qualification Record in that a required heat treat chart was missing.
. LB&S has implemented their comitted corrective action in that the Weld Procedure Specification was requalified with a new Procedure Qualification Record.
However, while verifying the comitted corrective actions, a new deviation from comitment was identified (See paragraph C.3.a.).
5.
(Closed) Deviation ilo. E (Report fio. 78-01): This item dealt with revision numbers of Weld Procedure Specifications and flondestructive Examination precedures not being recorded on the Manufacturing Process Sheets (MPS). LB&S has implemented their comitted corrective action in that a review of numerous, in-process MPSs revealed that revision numbers are being recorded.
6.
(Closed) Unresolved Item (Report f;o. 78-01): This item dealt with the LB&S QA Manual not addressing, or referencing a proce-dure which addresses, a corrective action program.
LB&S has revised their QA Manual (revision 3), and developed and implemented a procedure " Corrective Action Procedure", ilo.1.12, which does address the requirements oi' a corrective action program.
C.
Previous Inspection Findinos (Qualification of Weld Procedure Soecifi-cations) 1.
Objectives The objectives of this area of the inspection were to verify that LB&S had implemented their conmitted corrective action, including actions to prevent recurrence, as delineated in their response letter to fiRC, dated August 22, 1978.
2.
Method of Accomplishment The preceding objective was acccmplished by:
a.
Review of QA Manual Section 10.0 " Welding", revision 3 dated October 25, 1978.
b.
Review of Weld Procedure Specifications (WPS) and their applicable Procedure Qualification Records (PQR) for inclusion of essential, supplementary essential, and nonessential vari-ables.
c.
Review of the applicable postueld heat treat charts.
d.
Discussions with cognizant personnel.
. 3.
Findings a.
Deviation from Commitment See Enclosure b.
Unresolved Item None.
D.
Nonconformances and Corrective Action 1.
Objectives The objectives of this area of the inspection were to verify that LB&S had implemented the requirements for the control of noncon-formances and corrective action in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
Review of QA Manual Section 9.0, "Nonconformance and a.
Corrective Action," revision 3 dated October 25, 1978.
b.
Review of thirteen Nonconformance Reports (NCR); of which seven were closed and six were open.
Observation of the nonconforming parts which were indicated c.
as still being open, for application of hold tags and verification that NCR n0mbers were referenced on the Manu-facturing Process Sheets.
d.
Verification of the review and approval cycles of the dispo-sition noted on those NCRs which had been closed.
Review of Corrective Action Procedure No.1.12, revision 3.
e.
f.
Review of Corrective Action Requests (CAR) to assure that the cause of the adverse condition is identified, and that the actions taken to preclude repetition are documented.
g.
Discussions with cognizant personnel.
. 3.
Findings a.
Deviation from Commitment None.
b.
Unresolved Item None.
E.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that LB&S had implemented the requirements for the control of manufac-turing processes 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 7.0, " Control of Fabrication,"
revision 2 dated October 25, 1978.
b.
Observation of in-process parts and a review of their respec-tive Manufacturing Process Sheets (MPS) and fabrication drawings.
c.
Verification of procedures being used by referencing MPSs and fabrication drawings.
d.
Review of Procedure No. 1.15, " Manufacturing Process Sheet Procedure," revision 0.
e.
Verification that required in-process and inspection opera-tions had been signed off on the MPS prior to moving on to subsequent operations.
f.
Discussions with cognizant personnel.
3.
Findinas a.
Deviation from Commitment None.
- b.
Unresolved Item None.
F.
Procedure, Document and Drawina Control 1.
Objectives The objectives of this area of the inspection were to verify that LB&S had implemented the requirements for the control of procedures, documents and drawings in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Manual Section 4.0, " Control of Engineering a.
Procedures and Instructions," revision 3 dated October 25, 1978.
b.
Review of QA Manual Section 5.0, " Control of Fabrication Drawings," revision 3 dated October 25, 1978.
Review of issued procedures and drawings for required review c.
and approvals.
d.
Review of the distribution and recall lists and records to assure that obsolete drawings and procedures had been recalled.
Comparison of procedures and drawings being used fer in-e.
process operations to the Engineering Procedure and Summary List and the Drawing Summary List, respectively, both of which delineate the correct revisions to be used for in-process operations.
f.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Commitment None.
b.
Unresolved Item None.
. G.
Joint Fituo and Welding 1.
Objectives The objectives of this area of the inspection were to verify that LB&S had implemented the requirements for the control of joint fitup and welding 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 10.0, " Welding," revision 3 dated October 25, 1978.
b.
Observation of in-process, Shielded Metal Arc Welding (SMAW) and Gas Metal Arc Welding (GMAW) processes.
c.
Verification that correct Weld Procedure Specifications (UPS),
as delineated by the Manufacturing Process Sheet and fabri-cation drawings, were being used.
d.
Verification that the stated parameters of the WPS were being adhered to by the welders.
e.
Verification of welding material distribution and documenta-tion.
f.
Observation and verification of inspection requirements during fitup.
g.
Discussions with cognizant personnel.
3.
Findinas a.
Deviation from Commitment None.
b.
Unresolved Item None.
v H.
Held Heat Treatment 1.
Objectives The objectives of this area of the inspection were to verify that LB&S had implemented the requirements for the control of post weld heat treatment (PWHT) 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 10.0, " Welding," revision 3 dated October 25, 1978, and Section 12.0," Heat Treatment,"
revision 3 dated October 25, 1978.
b.
Review of Procedure No. 2.1, " Procedure and Specification for Thermal Stress Relieving for PI Materials," revision 2.
c.
Review of Procedure No. 2.2, " Stress Relieving of Weldments,"
revision 2.
d.
Review of Weld Procedure Specifications (WPS) which delineate PWHT requirements and their supporting PQRs to verify PWHT times and teT.peratures.
e.
Review of time-temperature recordings to assure that accumu-lated times at temperature did not exceed that which is allowed by the PQRs.
f.
Observation of thermocouple placenent and locations on a part being prepared for PWHT.
g.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Commitment None.
b.
Unresolved Item There is no definition in the above mentioned PWHT procedures as to how the beginning and ending of a PWHT holding period is determined.
s
. Procedure 2.1, paragraph 4.0 states in part, "... During the heating and cooling period, there shall not be a greater variation in temperature than 2500 F within any 15-ft.
interval of weld length." Procedure 2.2, paragraph 3.0 states in part, "... A maximum of 5 thermocouples and a minimum of three thermocouples shall be attached for each furnace luad."
Paragraph 4.0 states in part, "... During the heating period, there shall be no greater variation in temperature throughout the portion of the part being heated than 2500 F within any 15-ft. interval of length...
During the holding period there shall be no greater dif-ference than 1500 F between the highest and lowest tempera-ture throughout the portion of the assembly being heated."
The question arises, particularly for large parts which undergo several PWHTs and have three to five thermocouples attached, and in which the heating and cooling rates approx-0 imate 100 F/ hour and with the maximum allowable 1500 F spread between the highest and lowest temperature, as to when the starting and ending of PWHT is determined.
Procedure 2.1 stipulates a PWHT range as between 1100c p and 12500 F.
A review of time-temperature charts for piece mark 8-1-1, Ring Girder Segment, for Contract 9166, revealed that certain sections of the part may have possibly exceeded the allowable time at temperature.
With a heating and 0
cooling rate of 1000 F/ hour and a 150 F spread between high and low temperatures, certain sections are "first in -
last out" of the PWHT temperature range. This could amount to as much as three to four hours difference in time at PWHT temperature between sections of the part.
If tha part receives subsequent PWHTs, under the same conditions, then the allow-able time at temperature could be exceeded.
I.
Desiqn Process Management, Design Verification, and Design Document Control 1.
Objectives The objectives of this area of the inspection were to verify that LB&S had implemented the requirements for design process manage-ment, design verification, and design document control in accord-ance with the QA Manual and applicable NRC and ASME Code require-ments.
. 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 1.0, " Control of Design Speci-fications," revision 3 dated October 25, 1978.
b.
Review of QA Manual Section 2.0, " Control of Design Analysis and Design Drawings," revision 3 dated October 25, 1978.
c.
Review of QA Manual Secticn 3.0, " Control of Material Speci-fications," revision 3 dated October 25, 1978.
d.
Review of the following documents relative to Contract 9182, Units 1 and 2:
(1)
Furchase Order 1163-89-Q dated May 12, 1977 (Unit 1).
(2)
Purchase Order 2061-89-Q dated May 12, 1977 (Unit 2).
(3) Design Specification Y-2797 " Furnishing, Fabricating and Delivering NSSS Support Steel," dated June 10, 1976, with Amendment 1 dated May 15, 1978, and Amendment 2 dated October 25, 1978.
(4) Dasign Drawings S-1113, S-1113, S-1115, S-1089, and S-1109 with latest revisions, and the applicable fabri-cation drawings, to assure that changes to the design drawings were incorporated in the fabrication drawings.
e.
Review of drawing and procedure approvals by the customer, as required by contract.
f.
Discussions with cognizant personnel.
3.
Findinos a.
Deviation from Comnitment None.
b.
Unresolved Item None.
.. J.
Exit Interview A meeting was held at the conclusion of this inspection on December 15, 1978, with the following management representatives:
G. Behnke - Vice President, Marketing V. W. Coddington - President A. Jurevics - Vice President, Engineering E. W. Kasdorf - Executive Vice President R. Kubit - Chief Structural Engineer W. T. Langer - Director, Purchasing J. H. Mortenson - QA Administrator R. T. Rozek - Director, Quality Assurance R. Shaw - Assistant Vice President, Contracting J. W. Wa tts, Jr. - Vice President, Manufacturing A. Wos - Quality Assurance Engineer The scope and findings of this inspection were summarized. Management acknowledged the statements relative to the findings. Additional infor-mation relative to the deviation from commitment was discussed during a telephone conversation with J. H. Mortenson, QA administrator, on December 19, 1978.