ML19294B113
| ML19294B113 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1979 |
| From: | Barnes I, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19294B107 | List: |
| References | |
| REF-QA-99900086 99900086-79-2, NUDOCS 8002270159 | |
| Download: ML19294B113 (11) | |
Text
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9-U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900086/79-02 Program No. 51300 Company:
Hopkinsons Limited Britannia Works Post Office Box B27 Huddersfield, England HD2 2UR Inspection Conducted: November 12-16, 1979 Inspector:
_-a.
/2-749 I. Barnes, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch Approved by:
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42./7/7$P D. M. Hunnicutt, Chief
' D(te ComponentsSection II Vendor. Inspection Branch Summary Inspection on November 12-16, 1979 (99900086/79-02)
Areas inspected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards; including action on previous inspection findings, joint fitup and welding, welding material control, manufacturing process control, material identification and control, and liquid penetrant examination. The inspection involved thirty-six (36) inspector-hours on site.
Results:
In the six (6) areas inspected, no deviations or unresolved items were identified in three (3) areas', with the following deviations identified in the remaining areas:
Deviations: Manufacturing Process Control - Performance of welding operations in a sequence other that specified on the Operations Charts is not in accordance with Criterion V of 10 CFR 50, Appendix B, and Section 4 of the QA Manual (Notice of Deviation, Item A).
QA acceptance of body casting with incorrect repair doc-umentation is not in accordance with Criterion V of 10 CFR 50, Appendix B, and Section 5 of the QA Manual (Notice of Deviation, Item B).
Joint Fitup and Welding - Failure to assure welder compliance with all welding procedure g o w- @]
2 parameters for the repair of castings, is not in accordance with Criterion V of 10 CFR 50, Appendix B, and Section 6 of the QA Manual (Notice of Deviation, Item C).
Welding Material Control - Issue of materials for the performance of two welditg procedures and the failure to record appropriate weld identities for material use are not in accordance with Criterion V of 10 CFR 50, Appendix B, and procedure, N6-1 Revision 4 (Notice of Deviation, Item D).
Items Requiring Follow-up Inspection: Joint Fitup and Welding - Use of a power source for shielded metal arc welding in an amperage range below the calibrated range of the attached ammeter (Details D.3.c.(1)).
Scope and criteria used for monitoring production welding by QC personnel not formally established (Details D.3.c.(2)).
-.- - -. +..
3 DETAILS SECTION A.
Persons Contacted
- P. K. Thomas, Deputy Managing Director
- R. Watson, Engineering Director
- K. Remington, Sales Director
- P. E. Holt, Q.A. Executive
- R. Barrow, Q.A. Manager
- D. Croft, Works Manager
- R. A. Grimston, Design Manager
- K. Pycroft, Foundries Manager
- E. Robinson, Welding Engineer C. Boothroyd, Machine Shop Welding Foreman H. Robinson, Chief Inspector F. D. Woolass, Chief Radiographer B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Item A, Notice of Deviation, Inspection Report No. 79-01): Compilation of a certain Special Test Specification not accomplished in liaison with the Quality Assurance Engineer.
The inspector verified that the committed review of Special Test Specifications against relevant QC 100 forms had been performed, the note to QA Engineers had been issued, and the QA Manual amended to require QA verification of Special Test Specifications against QC 100 forms prior to approval.
2.
(Closed) Deviation (Item B, Notice of Deviation, Inspection Report No. 79-01): Radiographic reports did not contain film exposure dates and space for date was not provided on form 60512.
The inspector verified that actions had beea taken to record exposure date on radiographic film for the WPPSS contracts and that present radiographic practice included recording exposure date.
3.
(Closed) Deviation (Item C, Notice of Deviation, Inspection Report No. 79-01): Lead markers not placed to show film coverage in the axial direction on radiographs of Cast No. 221-9.
The inspector verified that lids from the subject heat had been re-radiographed using both circumferential and axial markers to demon-strate satisfactory film coverage. The inspector also established by review of recently exposed film, that current radiographic prac-tice was utilizing markers to demonstrate adequate axial direction film coverage.
3 4
4.
(Closed) Deviation (Item D, Notice of Deviation,. Inspection Report No. 79-01): Use of 1.25 MHZ frequency transducer for ultrasonic inspection, when a frequency of I HHZ was required by applicable procedure.
The inspector verified that procedure, N7-8 Revision 4, had been formally amended to permit the use of a frequency of 1 to 1.25 MHZ for ultrasonic examination of sections over 2 inches thick.
5.
(Closed) Unresolved Item (Details I, C.3.b., Inspection Report No.
79-01): Preparation and checking of detailed manufacturing drawings by same individual is inconsistent with Criterion III of 10 CFR 50, Appendix B.
The inspector verified that the Design Manager was performing independent reviews of detailed manufacturing drawings and docu-menting the reviews. Review of Quality Control Procedure, N2-2 Revision C (in a final draft stage as of the inspection), entitled
" Drawing Office Procedure for ASME Nuclear Power Components," also showed that provisions had been made to assure independent checking and approval of engineering drawings.
6.
(Closed) Unresolved Item (Details II, F.3.b, Inspection Report No.
79-01): Scope of QA program procurement controls nuclear with re-spect to procurement of different categories of valve items i.e.
i pressure boundary materials, non-pressure boundary (safety related) and non pressure boundary (non-safety related).
The inspector verified that procedure, N15-1 Revision 0, Safety Related Items for Nuclear Power Plants," had been prepared and issued, and which provided criteria for applicable procurement controls relative to safety related items.
C.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify whether:
A system had been established for the control of manufacturing, a.
which was consistent with applicable regulatory and contract requirements.
b.
The system was implemented.
I t
5 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 4, Revision 12, of the QA Manual, " Process Control."
b.
Review of Section 5, Revision 9, of the QA Manual, " Steel Pressure Containing Castings Manufactured by Hopkinsons Ltd. -
Foundries Division for Nuclear Application."
c.
Examination of manufacturing order documentation for valve bodies, lids (bonnets), discs, studs and spindles (s sms) with respect to:
(1) Definition and control of sequencing of manufacturing operations to provide for compliance with ASME Section III fabrication requirements.
(2) Compliance with designated hold points.
(3) Performance of required ASME Code nondestructive examinations and appropriate timen of examination.
(4) Completeness of operation signoff.
(5) Use of approved welding and nondestructive examination procedures.
(6) Use of appropriately qualified personnel.
(7) Evidence of fabrication inspection definition and performance consistent with QA progran commitments.
3.
Findings a.
Deviations from Commitment (1) The connection weld to body (Operation 120) was observed on successive days, November 13 and 14, 1979, to have been performed prior to Operation 110 (Welding in seats) for Works Order Nos. 17/SM 5634 and 24/SM 5224. Different welders were used for the two (2) Works Order Nos. (See Notice of Deviation, Item A).
(2) A 16 inch body casting (Cast No. W 178-9) was accepted by QA for manufacture, although the weld repair record for this casting indicated an apparent change to a welding
6 procedure specification (WPS) essential variable had been made, without performance of the requalification required by paragraph QW-201.2 in Section IX of the ASME Code. WPS N6-2, Revision 6, was used to perform gas metal are welding process repairs to the referenced body casting on an indi-cated date of September 27, 1979. Postweld heat treatment was identified by the repair record to have been performed on September 21, 1979, with no entry made to confirm that a postweld heat treatment had been performed subsequent to completion of repair welding. WPS N6-2, Revision 6, was qualified only for application in the postweld heat treated condition. Use of this WPS for a welded condition deposit would represent a change in an essential variable for this welding process and would require performance of requali-fication testing.
(See Notice of Deviation, Item B) b.
Unresolved Items None.
D.
Joint Fitup and Welding 1.
Objective The objective of this area of the inspection was to determine if production welding was controlled in accordance with the Hopkinsons Limited QA program and applicable ASME Code requirements.
2.
Method of Accomplishment
~
The preceding objective was accomplished by:
Review of Section 6, Revision 12, of the QA Manual, " Welding a.
Quality Assurance."
b.
Observation of production shielded metal arc welding operations (seat welding and body casting repair) and automatic gas tungsten are hard surfacing operations with respect to:
(1) Use of welding procedure specifications referenced by applicable process documentation.
(2) Availability of welding procedure specifications in work areas.
(3) Use of welding materials required by designated welding procedure specifications.
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(4) Verification that welder technique, welding position, electrical parameters and control of preheat and inter-pass temperatures were in accordance with welding procedure specification requirements.
Verification that welding personnel were appropriately qualified c.
for the observed production welding operations.
d.
Visual examination of flux core arc welding process repairs to one (1) body casting and review of welding procedure specification and welding materials used for performance of the repairs.
e.
Examination of available welding surveillance records relative to program commitments.
f.
Verification of calibration status of meters on welding equipment.
g.
Review of Ebasco Specification, 884-WA-75 Revision 1, " Supple-mentary Requirements For Welding of Nuclear Pressure Components."
3.
Findings a.
Deviation from Commitment Paragraph 6.2.4 in Section 6 of the QA Manual places the respon-sibility for velder compliance with welding procedure specification parameters on welding supervision. The following examples of fail-ure to comply with welding procedure, specification parameters were observed, relative to repair welding operations on a-10 inch valve body casting for Manufacturing Order No. 12/SM 5630:
(1) WPS N6-2, Revision 6, which was the applicable prccedure used for performance of flux core arc welding process re-pairs to the outside of the casting, requires the use of a 1/8 inch diameter SEA 5.20 E70T-1 wire. This WPS also restricts use of a weave bead technique to a maximum bead width of one (1) inch. Visual examination of the repair welds showed, however, that repairs had been made with a
" puddling" technique to a maximum bead width of two (2) inches. Review of available welding materials in the storage area showed only a 3/32 inch diameter SEA 5.20 E 70T-1 wire had been procured for this contract. Con-trolled use of this wire diameter would have required re-vision of WPS N6-2, Revision 6, relative to allowable amperage range.
(2) WPS N6-16, Revision 6, which was observed in use for the performance of shielded metal arc welding process repairs
~
8 to the inside of the casting, requires an are voltage range of 20-26 to be maintained when welding with 7/32 inch dia-meter E 7018 electrodes. This WPS also restricts interpass temperature to a maximum of 300 C.
Shielded metal are welding operations were observed with an arc voltage range of 30-34 and with no measurement performed of developed interpass temperature during deposition of successive weld beads.
(See Notice of Deviation, Item C).
b.
Unresolved Items None.
c.
Items Requiring Follow-up Inspection (1) A power source (SMAW No. 9) was observed in the Machine Shop welding area, which had an ammeter attached, where the de-fined range increments commenced at 100 amps. This power source is used, however, for certain shielded metal are welding applications where the required amperage range is r21ov 100 amps.
Insufficient time was available during the inspection, to review the measures in effect to assure the adequacy of this equipment.
(2) Paragraph 6.6.1 in Section 6 of the QA Manual state.-s in part, "All welding shall be subject to monitoring by Q.C. Personnel during the welding process.
." The inspector was in-formed that monitoring of welding was performed by the weld-ing engineer (a member of the Quality organization at Hopkin-sons Limited). The scope of monitoring of welder compliance with welding procedure specification requirements could not be established, however, in that only preheat and interpass temperature measurement records had been maintained, and no formalized monitoring criteria relative to required para-meter checks had been established.
E.
Welding Material Control 1.
Objectives The objectives of this area of the inspection were to determine if welding material purchase, acceptance, storage and handling were in accordance with the hopkinsons Limited QA program and applicable ASKE Code requireme.ts.
9 2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of Section 3, Revision 12, of the QA Manual, a.
" Procurement Control."
b.
Review of Section 6, Revision 12, of the QA Manual, " Welding Quality Assurance."
c.
Review of procedure, N6-1 Revision 4, " Welding Quality Control."
d.
Observation of foundry and machine shop welding material storage areas with respect to storage practices, temperature and identification control.
Verification of electrode oven temperature control in velding e.
areas.
f.
Verification of appropriate provisions having been made to assure required segregation of welding materials and main-tenance of identity to the point of consumption.
g.
Examination of issue records for welding materials observed in production application.
h.
Examination of procurement, acceptance and material test information for welding materials observed in production application, in terms of:
(1) Compliance with QA program requirements.
(2) Verification of Hopkinsons Limited review and acceptance.
(3) Compliance with procurement documents and referenced specifications.
3.
Findings a.
Deviation from Commitment See Notice of Deviation, Item D.
b.
Unresolved Items None.
&M?
J 10 F.
Material Identification and Control 1.
Objective The objective of this area of the inspection was to verify that material identification and control duri.; manufacturing was in accordance with applicable regulatory, code and contract require-ments.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Review of Section 3, Revision 12, "Procureuent Control" and Section 4, Revision 12, " Process Control," in the QA Manual, with respect to:
(1) Verification that a system has been established for re-taining positive identification of materials (traceable to Certified Material Test Reports) at time of receipt, after cutting or dividing the material, and during the manufacturing cycle.
(2) Verification that provisions were made to assure use of identified accepted items during valve assembly operations.
b.
Examination of identification on cast bodies, discs, bonnet studs and seats, which were observed in either storage or manufacturing operations.
Comparison of the above identities against receiving inspection c.
records for purchased iters and Hopkinsons Limited process docu-mentation for internally produced items.
d.
Verification that the QA program defined receiving inspections controls were functioning.
Examination of Certified Material Test Reports for the referenced e.
items for compliance with the procurement documents and referenced material specifications.
3.
Findings Within this area of the inspection, no deviations from commitment or unresolved items were identified.
11 G.
Liouid Penetrant Examination 1.
Objective The objective of this area of th-inspection was to verify that liquid penetrant examination is performed in accordance with approved pro-cedures.
2.
Method of Accomplishment The preceding objective was accomplished by:
Review of Section 7, Revision 12, of the QA Manual, "Non-Destructive a.
Examination."
b.
Review of liquid penetrant examination procedure N7-5, Revision 6.
c.
Observation of liquid penetrant examination operations on one (1) seat.
d.
Review of personnel qualifications.
3.
Findings Within this area of the inspection, no deviations from commitment a.
or unresolved items were identified.
b.
Insufficient activity was available during the inspection te per-form a comprehensive review of this NDE discipline. This subject will be further reviewed during a subsequent inspection.
H.
Exit Meeting A post inspection exit meeting was conducted on November 16, 1979, with the management representatives denoted in paragraph A above. The inspector summarized the scope and findings of the inspection, with particular emphasis being placed en the finding identified as Item C in the Notice of Deviation of this report. Management acknowledged the statements of the inspector with respect to the findings as presented to them and affirmed the commitment of Hopkinsons Limited to the quality assurance program.