ML19290C530
| ML19290C530 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19290C516 | List: |
| References | |
| REF-QA-99900031 99900031-79-1, NUDOCS 8001220055 | |
| Download: ML19290C530 (3) | |
Text
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Bingham - Willamette Company Docket No. 99900031/79-01 NOTICE OF DEVIATION Based on the results of an hTC inspection conducted on April 9-12, 1979, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
A.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including
- welding,
. are controlled and accomplished... using qualified procedures in accordance with applicable codes.
Paragraph NB-4382 in Section III of the ASME Code (Summer 1976 Addendum) states in part, "The essential variables for hard surfacing shall be the same as those for Corrosion Resistant Weld Metal Overlay as given in Section IX, except as given in (a)... below:
(a)
Essential variables for the plasma arc welding process shall be the same as those for the gas tungsten arc process...."
Concerning plasma arc hard surfacing welding procedure specifications (WPS), PA-S1 and PA-S6, the following deviations from commitment were noted, in respect to ASME Section IX Code (Summer 1976 Addendum) requirements for documentation and qualification of essential variables:
1.
Paragraph QW-201.2 in the ASME Section IX Code states in part, "The specific facts involved in qualifying a WPS shall be recorded in a form called Procedure Qualification Record (PQR). This form shall document t,he essential variables of the specific welding process or processes (as listed in QW-252 through QW-281)...."
Contrary to the above, essential variables for the plasma are hard surfacing welding process, such as use of a mixture of gases, use of oscillation and number of electrodes used (PA-S1 PQR only), were not documented on the PQRs.
2.
Paragraphs QW-281.2 and QW-281.4 (Corrosion Resistant Weld Metal Overlay) in the ASME Section IX Code require the setting up of a new WPS and requalification for changes in deposit'ed weld metal composition, a change of 100 F or more in the minimum specified preheating temperature, a change in the minimum or maximum specified interpass temperature and a variation of more than 10 percent (10%) in travel speed.
Contrary to the above, changes to the qualified essential variables ~
identified above were made without a new WPS being set up and requalification being performed, as indicated by the following examples:
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2 a.
Changes in composition of deposited weld metal to those required by PA-S1 and PA-S6 were allowed by a BWC Welding Engineer memorandum dated rebruary 9, 1979.
b.
Maximum interpass temperature was not specified for either WPS and both WPSs permitted a minimum preheat temperature of 550 F, although the WPS was qualified at 750 F + 25 F.
c.
PA-S6 permitted a variation of more than 10 percent in travel speed from the qualified essential variable, i.e.
PA-S6 specified a travel speed range of 2 to 4 inches / minute whereas the supporting PQR was qualified at a travel speed of 3 inches / minute.
B.
Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that s;,ccial prccesses, including welding,
. are controlled and accomplisned... using qualified procedures in accordance with applicable codes.
Paragraph QW-201.1 in the ASME Section IX Code states in part, "The Welding Procedure Specification (WPS) shall list in detail.
variables described for each welding process as either essential or nonessential.
(See QW-252 through QW-281)."
Paragraph QW-201.2 sta tes in part, "The specific facts involved in qualifying a WPS shall be recorded in a form called Procedure Qualification Record (PQR). This form shall document the essential variables of the welding process or processes (as listed in QW-252 through QW-281).
A change in any essential variable shall require requalification, to be recorded in another PQR."
Concerning submerged arc WPS, CSA 1.2-2 Revision 1, the following deviations from commitment were noted, in respect to ASME Sections III and IX Code requirements for testing and qualification of essential variables, in applications with specified notch toughness requirements:
1.
Table QW-254 in the ASME Saction IX Code lists an increase in volume of weld metal deposited (for ferritic base metals of les; than 1 inch thickness) and an increase in amperage as supplementary essential variables for the submerged arc welding (SAW) process.
Contrary to the above, WPS CSA 1.2-2 Revision 1 permitted increases in amperage and volume of weld metal deposited above the range qualified in the listed supporting PQRs, CS 1.2-2(AW) and CS 1.2-2 (SR) for the SAW process; however, requalification was not per-formed nor another PQR issued.
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2.
Paragraphs NB/NC-4335.2 in the ASME Section III Code require impact testing of unaffected base materiol for all welding process procedure qualifications when joints are exempted from postweld heat treatment.
Contrary to the above, impact testing of unaffected base material was not performed for the SAW procedure qualification, CS 1.2-2(AW),
referenced by WPS CSA 1.2-2 Revision 1 for qualification of applications where joints are exempted from postweld heat treat-ment.
3.
Table QW-451.1 in the ASME Section IX Code permits a maximum material thickness of 2 inches to be welded when a procedure qualification test plate of ik thickness is employed.
Contrary to the above, WPS CSA 1.2-2 Revision 1 permitted up to 4 inches material thickness to be welded for the postweld heat treated condition, although qualified by a test p] ate of Ik inch thickness.
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