ML19305D081

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QA Program Insp Rept 99900047/79-02 on 791015-19. Noncompliance Noted:Storage Practices for Electrodes Not in Accordance W/Required Procedures,Absence of Mechanical Test Data & Failure to Prepare Mrr Before Weld Repairs
ML19305D081
Person / Time
Issue date: 11/15/1979
From: Barnes I, Hunnicutt D, Roberds H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19305D056 List:
References
REF-QA-99900047 99900047-79-2, NUDOCS 8004140043
Download: ML19305D081 (18)


Text

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j"U U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.

99900047/79-02 Program No. 51300 Company: Westinghouse Electric Corporation Nuclear Components Division, Tampa Plant P. O. Box 19218 Tampa, Florida 33616 Inspection Conducted: October 15-19, 1979.

Inspectors:

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/Ms/fj-I. Baints, Conttactor Inspector

/Da t6' ComponentsSection II Vendor Inspection Branch A$ fan

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H. W. Rdberds, Contractor Inspector

/ Da(6' ComponentsSection II Vendor Inspect' Branch Approved by:

8 hO D~d' D. M. Hunnicutt, Chief

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Date ComponentsSection II Vendor Inspection Branch Summary Inspection on October 15-19, 1979 (99900047/79-02)

Areas Inspected:

Implementation of 10 CFR 50, Appendix B criteria and applicable codes and standards; including action on previous inspection findings, manufacturing process control, joint fitup and welding, welding procedure specifications, welding material control, welder qualifications, special process personnel qualification (nondestructive examination), non-destructive examination (radiography), and nondestructive examination (liquid penetrant and magnetic particle). The inspection involved sixty-four (64) inspector-hours on site by two (2) NRC inspectors.

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Results:

In the nine (9) areas inspected, no apparent deviations or unresolved items were identified in three (3) areas; the following deviations and unre-solved items being identified in the remaining areas:

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Deviations: Action on Previous Inspection Findings - Issue, return and storage practices for electrodes is not in accordance with criterion V

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of 10 CFR 50, Appendix B, and Standard Division Procedure PQ3-006.2 (Notice of Deviation, Item A).

Joint Fitup and Welding - Noncompliance of production welding operations with process specification electrical parameter requirements is not in accordance with Criterion V of 10 CFR 50, Appendix B, and Section 9 of the i

QA Program Manual (Notice of Deviation, Item B).

2 Welding Material Control - Absence of mechanical test data for E-9018M i,

electrodes in the as wdded condition is not in accordance with Criterion V of 10 CFR 50, Appendix B, and NB/NC/ND-2400 in the ASME Section III Code (Notice of Deviation, Item C). Welding Procedure Specifications - Failure i

to test overlay cladding WPS for all permitted welding positions and first layer electrode sizes is not in accordance with Criterion V of 10 CFR 50, 3

Appendix B, and Section IX of the ASME Code (Notice of Deviation, Item D).

Manufacturing Process Control - Performance of weld and base metal repairs without preparation and issue of an M.R.R. and M.R.R.T. is not in accordance with Criterion V of,10.CFR 50, Appendix B, and Sections 9 and 12 of the QA Program Manual (Notice of Deviation, Item E).

Nondestructive Examination (Liquid Penetrant and Magnetic Particle) - Presence

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of rags and other foreign materials in penetrant containers is not consistent with Criterion V of 10 CFR 50, Appendix B, and halide and sulfur require-ments of Process Specification 84350JA (Notice of Deviation, Item F).

Unresolved Items: Manufacturing Process Control - Omission of operations in a feeder-traveler for removal of a generator shell brace and performance of a magnetic particle examination of the attachment area (Details I, G.3.b.(1)).

Absence of definition in QA Program Manual with respect to responsibilities of i

manufacturing personnel in the current manufacturing process control system relative to traveler documentation (Details I, G.3.b.(2)).

l Items Requiring Follow-up Inspection: Joint Fitup and Welding - Inconsistencies j

in Tampa Quality Assurance Instruction, T.Q.A.I.1.4.1, relative to interpass temperature recording requirements and adequacy of location of interpass temp-erature measurement (Details I, C.3.c. (1)).

Control of are air gouging re-lative to process specification requirements (Details I, C.3.c.(2)).

Welding Material Control - Electrode rebaking practices relative to requirements of NB-4642.3.(4) in Section III of the ASME Code (Details I, D.3.c.)-

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Other Items of Significance Effective October 1, 1979, the Westinghouse Electric Corporation reorganized the Business Units resulting in the formation of the Nuclear Components Div-ision, consisting of the Tampa and Pensacola Plants, the redesignation of the Tampa location from a Division to a Plant and the restructuring of the internal Departments.

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4 DETAILS SECTION I (Prepared by I. Barnes)

A.

Persons Contacted

  • J. E. Turner, General Manager, Nuclear Components Division
  • L. Conway, Design Engineering Manager, Tampa Plant
  • C. M. Ericson, Manufacturing Manager, Tampa Plant
  • N. J. Georges, Engineering Manager, Tampa Plant
  • T. D. Miller, Product Assurance Manager, Tampa Plant i
  • L. Van Duzer, Procurement Manager, Tampa Plant W. H. Beckley, Senior QA Engineer, Tampa Plant

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J. W. Bradley, Manager, Processes Engineering, Tampa Plant R. H. Dunn, QA Records Supervisor, Tampa Plant J. A. Fertic, Manager, QC/NDE, Tampa Plant E. P. Loch,. Manufacturing Planning Manager J. Goff, Unit Manager, Tampa Plant J. Maseda, QA Engineer, Tampa Plant J. P. Mortara, QA Manager, Tampa Plant M. Monkelis, Metallurgical Engineer, Tampa Plant i

E. Smith, Manager, Customer Services, Tampa Plant l

W. Woods, QC. Technician

  • Denotes those persons attending exit meeting.

j B.

Action on Previous Inspection Findings 1.

(Closed) Deviation (Item A, Notice of Deviation, Inspection Report No. 79-01): Weld log for the welding of a shipping cover on shop order 2973 did not account for 110 electrodes issued to three welders on a previous shift.

The inspector verified that the committed audit activities had been performed and that the Electrode Check Out Log, QCWC-1, had been revised.

It was also established that Standard Division Procedure PQ3-006 had been revised to delegate specific responsibilities to Manufacturing for the issue and' return of welding materials.

In-dependent observations by the inspector revealed no instance where incorrect welding materials were seen in use.

2.

(Closed) Deviation (Item B, Notice of Deviation, Inspection Report No. 79-01): Use of E-9018M electrodes on a pressurizer shall after exposure to ambient temperature and humidity for longer than the two (2) hours permitted by Process Specification 83050 RM.

The Westinghouse Electric Corporation, Nuclear Compements Division,

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Tampa Plant (WTP) corrective action response letter of March 27, 1979, states in part with respect to Item B of the Notice of Deviation in.

l Inspection Report No. 79-01, "... Standard Division Procedure, i

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5 PQ3-006.1, was revised to preclude recurrence of this finding." This finding has been closed on the basis that a revised Electrode Check Out Log was issued as committed and Standard Division Procedure PQ3-006.1 was revised (Note-after the committed March 31, 1979, date) to delegate specific responsibilities to Manufacturing for the issue and return of welding materials.

Hosever, during this inspection a further deviation from commitment was ii.entified relative to issue and-return of electrodes. Thirty (30), 1/8 inch, E-9018M electrodes were issued to a welder at 12:10 p.m. on Jctober 17, 1979, for the performance of Operation 15 (attachment of clips to a pressurizer shell longitudinal weld preparation) on the-feeder-traveler for Order No. GAPT 1891, Assigned Item 02AB. At 2:48 p.m.

twenty-one (21) electrodes were observed in the welder's possession. As of 4:40 p.m. the Electrode Check Out Log in the issuing crib had not been completed to signify either the return of electrodes from the operation, or, that all electrodes had been consumed in the operation.

The inspector was informed the following day by the Unit Manager, that in-vestigation had shown the original issue of electrodes had been consumed and the stubs returned to the issuing crib by another welder working with the individual observed. The return of these stubs was not entered in the Electrode Checkout Log to close out the transaction. At that time a fur-ther thirty (30) electrodes were issued to this welder, which the Elec-trode Check Out Log confirmed was accomplished, that would account for the electrodes. observed by the NRC inspector at 2:48 p.m.

It was additionally noted at 4:40 p.m. that the Tool Crib Attendant allowed a welder to complete the Electrode Check Out Log, rather than performing the function himself as required by paragraph 2.17 in Standard Division Procedure PQ3-006.2.

(See Notice of Deviation, Itc= A).

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(Closed) Deviation (Item C, Notice of Deviation, Inspection Report No. 79-01): Repair welding performed at an amperage value below the specified range.

Reinstruction of the particular welder and QC Technician was established as having been verbal and not documented to provide a record of corrective action. This finding has been closed, however, on the basis that the Quality Control Welder Log & Patrol Inspection Form, which is utilized by QC Technicians for monitoring production welding, was revised to require' verification of welding procedure revision and part being used for welding operations.

Independent observations by the inspector revealed no in-stance where an incorrect process specification was being used.

Failures of welding personnel to comply with process specification para-meter requirements were observed, however by the inspector, which are discussed in Petails I, paragraph C of this report.

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6 C.

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 WTP~ QA program and applicable ASME Code requirements.

2.

Method of Accomplishment The preceding objective was accomplished by:

Review of Section 8, Revision 2, of the QA Program Manual, a.

" Inspection."

b.

Review of Section 9, Revision 2, of the QA Program Manual,

" Welding Qualification and Control."

c.

Review of Tampa Quality Assurance Instruction (T.Q.A.I.)

1.4.1, Revision 0, " Measurement of Preheat and Interpass Tem-peratures."

d.

Review of Process Specification (PS) Pu81111 LA, Revision 2.

e.

Observation of automatic arc air gouging operations on Order No. PCGT 2584, Assigned Item AAC.

f.

Observation of production submerged arc welding operations (Order Nos. PLGT 2642 and GAGT 1881), shielded metal overlay cladding (Order No. CCGT-2095), shielded metal arc attachment and repair welding (Order Nos. PLGT 2642 and PCGT 2583, respec-tively) and automatic gas tungsten arc tube to tube sheet weld-ing, with respect to:

(1) Use of welding process specifications referenced by the applicable travelers.

(2) Availability of process specifications in work areas.

l (3) Use of welding materials required by designated process specifications.

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(4) Verification that welder, technique, welding position, electrical parameters and preheat temperatures were in accordance with process specification requirements.

g.

Review of QC Technician welding' surveillance records relative to program commitments.

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Verification of calibration status of meters on welding equipment.

3.

Findings a.

Deviation from Commitment Paragraph 9.4, sub paragraph 9.4.4, in Section 9 of the QA Program Manual states, "All welding operations are performed as indicated in Manufacturing Line-ups in conformance with Process Specifications P.S.I.'s and M.D.I.'s and as specified on the applicable drawings."

Contrary to the above, the following examples of welding operations not being performed in conformance with Process Specifications were noted:

(1) Process Specification, 82127 WX Issue 2, requires automatic gas tungsten arc tube to tube sheet welding to be performed using a voltage range of 11-13.

Contrary to the above, automatic gas tungsten arc welding using Process Specification 82127 WX Issue 2 was observed being performed on Order No. TCGT 2214, Assigned Item BA, y

with an arc voltage of 14.

(2) Process Specification, 82148 RR Issue 8, requires submerged are welding of the backchip area to be performed using respective amperage and voltage ranges of 550-620 and 28-32.

Contrary to the above, submerged arc welding of the back-chip area using Process Specification, 82148 RR Issue 8, was observed beiag performed on Order No. GAGT 1881, Assigned Item BAA01 (Tube Sheet to Lower Barrel Weld), with 530-550 amperes and 35-37 volts.

(3) Process Specification, 82121 UW Issue 1, requires shie?.ded metal are overlay welding with 3/16 inch E Ni Cr Fe -3 electrodes to be performed using an amperage range of 140-160.

Contrary to the above, shielded metal are welding using Process Specification 82121UW Issue 1 with 3/16 inch' E Ni Cr Fe-3 electrodes was observed being performed on Order No. CCGT 2095 (Tube Bundle Chamber Assembly) with-an amperage value of 170.

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8 (4) Process Specification 82121WV requires shielded metal arc welding with 1/8 inch E-9018M electrodes to be per-formed using an amperage range of 100-160.

Contrary to the above, shielded metal arc repair welding using Process Specification 82121WV with'1/8 inch E-9018M electrodes was observed being performed with an amperage value of 95.

(See Notice of Deviation, Item B.)

b.

Unresolved Items None.

c.

Items Requiring Follow-up Inspection (1) Tampa Quality Assurance Instruction (T.Q.A.I.), 1.4.1 Issue 1, in reference to welding preheat and interpass temperatures established by Processes Engineering in welding process specifications, places the responsibility for recording welding temperatures with the QC Technician.

The " Records" section of the same T.Q. A.I. requires, how-ever, that only compliance with the minimum specified pre-heat temperature be recorded by the QC Technician on the Quality Control Welder Log and Patrol Inspection form.

It was additionally noted that T.Q.A.I. 1.4.1 permits measure-

'm'ent of weld interpass temperature at up to T/2 inches (where T = base metal thickness) from the weld. The tech-nical validity of this approach to measurement of interpass temperature was not explored d tring this inspection.

(2) Automatic arc air gouging was observed being performed on Order No. PCGT 2584 with a travel speed of 30 inches per minute and the equipment ammeter indicating an apparent amperage value of 300.

Checks of actual amperage with a tong tester showed a value of 650 amperes was being used.

The ammeter on the equipment was not included in the cali-bration program and based on the measured amperage reading could not have been referenced by the equipment operator for control of the operation. The process specification required by the feeder-traveler for this operation, 81111 LA Issue 2, provided a non-mandatory table of_ recommended parameters for use in are air gouging, which the observed parameters were not in compliance with. This subject will' be reviewed in greater depth at a subsequent inspection.

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9 D.

Welding Material Control 1.

Objectives The objective of this area of the inspection was to determine if 4

welding material purchase, acceptance, storage and handling was in accordance with the WTP QA program and applicable ASME Code require-ments.

2.

Method of Accomplishment The preceding objective was accomplished by:

L Review of Section 7, Revision 0, of the QA Program Manual, a.

" Material Identification and Handling."

b.

Review of Section 9, Revision 2, of the QA Program Manual,

" Welding Qualification and Control."

o Review of Standard Division Procedure PQ3-006.2, " Welding c.

Material Control."

d.

Review of Manufacturing Department Instruction, M.D.I.79-017 Issue 1, " Instructions For Stores Attendants (Tool Crib &

i Stores) For Requisition, Baking, Holding & Issuing Weld Elec-trodes."

Review of Process Specification, 83050 RM Issue 1, " Welding e.

Electrode Baking For Nuclear Power Components."

f.

Examination of electrode ovens for material identification and temperature control.

g.

Examination of procurement and material test information for the following categories of approved welding materials:

(1) A submerged arc wire and flux combination observed in production use and applicable to pressure boundary appli-cations.

(2) E-9018M coated electrodes observed in production use for-repair and attachment welding.

(3) E-9018M coated electrodes indicated by manufacturing records to have been used for the performance of repairs to a steam generator after final postweld heat treatment.

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10 (4) E7018, E308L and E Ni Cr Fe-3 coated electrodes observed in electrode ovens in the Stores Welding Crib.

h.

Examination of Electrode Check.Out Log for electrodes observed in production application, with respect to compliance with Process Specification 83050 RM Issue 1 permissible exposure time to atmosphere requirements.

3.

Findings a.

Deviations from Commitment (1) See Notice of Deviation, Item A.

(2) Repairs to handhole buildups on Shop Order TCGT2213 were made by the SMAW process after final postweld heat treat-ment, using a temper bead technique. E-9018M, 1/8 inch, electrodes, Test No. To7973, were used for the repairs, which were procured in accordance with Haterial Drawing 2655A71 Sub. 1.

This drawing requires mechanical testing to be performed only in the postweld heat treated condition.

Review of the vendor Certified Haterial Test Report for the electrodes confirmed compliance with the material drawing, resulting in no mechanical test data being available for

.the noted condition of use.

(See Notice of Deviation, Item C).

b.

Unresolved Items None.

c.

Items Requiring Followup Inspection Control of electrode rebaking practices relative to verification of compliance with paragraph NB-4642.3, sub paragraph (4) in the ASME Section III Code.

E.

Welding Procedure Specifications 1.

Objectives The objective of this area of the inspection was to determine if the welding procedure specifications (WPS) used by WTP in production welding were being prepared, qualified and controlled in accordance with the WTP QA program and applicable ASME Code requirements.

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11 2.

Method of Accomplishment The preceding objective was accomplished by:

Review of Section 9, Revision 2, of the QA Program Manual, a.

" Welding Qualification and Control."

b.

Review of shielded metal arc (overlay and pressure boundary),

submerged arc and gas tungsten arc WPS, with respect to defi-nition of applicable essential supplementary essential and nonessential variables required by Section III and Section IX of the ASME Code.

Examination of the procedure qualification records (PQR) pro-c.

vided by WTP for the WPS referenced in b. above with respect to:

(1) Listing of all required essential variables.

(2) Consisting of essential variable values and ranges with those permitted by the WPS.

(3) Performance of all mechanical tests required by the ASME Code.

(4) Verification that the mechanical test results comply

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(5) Certification by the manufacturer.

3.

Findings a.

Deviation From Commitment Prior to performing a review of welding process specifications and supporting procedure qualification records on October 18, 1979, the inspector questioned why the process specifications did not list the identity of the applicable supporting PQRs, which is provided for in the ASME recommended format. The in-spector was informed that WTP did not do this because it would result in a need for frequent revision of the process specifi-cations.

Statements were made, at that time, to the effect that the WTP records system provided for ready identification and retrieval of appropriate PQRs for a given process specification.

Review of PS 82121 UW Issue 1 showed the use of nonspecific language relative to allowed welding position, i.e. "... It is preferable that all welding be done in the flat or downhand 1

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12 position." This statement does not in itself prohibit use of any other welding position. The process specification also permitted use of 3/32 inch, 1/8 inch or 5/32 inch electrode diameters for performance of first layer overlay welding. Examination of the two (2) PQRs provided by WTP as the applicable qualifications for PS 82121 UW Issue 1, TQ267 and TQ268, showed all first layer welding had been performed in the IG (Flat) position using 5/32 inch diameter electrodes.

After identification to Manufacturing Planning Management of the deviation from the requirements of QW-281.2 and QW-281.3 in Section IX of the ASME Code, additional PQRs were-presented to the inspector shortly before the exit meeting on October 19, 1979. After brief review the inspector was still unable to verify qualification of the process specification with respect to the welding position language used.

(See Notice of Devi-ation, Item D).

b.

Unresolved Item None.

F.

Welder Qualifications 1.

Objective The objective of this area of the inspection was to determine if welders and welding operators were qualified in accordance with Section IX of the ASME Code and the WTP QA program.

2.

Method of Accomplishment The preceding objective was accomplished by:

Review of Section 9, Revision 2, of the QA Program Manual, a.

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" Welding Qualification and Control."

b.

Review of qualifications for welders and welding operators observed performing production welding.

3.

Findings Within this area of the inspection, no deviations or unresolved items were identified.

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Manufacturing Process Control 1.

Objectives The objectives of this area of the inspcetion were to verify that:-

A system had been established for the control of manufacturing a.

processes, which was consistent with applicable regulatory and ASME Code requirements.

b.

The system was implemented.

2.

[etLod of Accomplishment The pc-ceding objectives were accomplished by:

Review of Section 6, Revision 0, of the QA Program Manual, a.

" Manufacturing Planning and Control."

b.

Review of Section 8, Revision 2, af the QA Program Manual,

" Inspection."

c.

Review of Section l'_, Revision 3, of the QA Program Manual, "Non-Conformance Control."

d.

Examination of traveler documentation for vessel subassemblies with respect to:

(1) Definition and control of sequencing of manufacturing operations to provide for compliance with ASME Section III Code fabrication requirements.

(2) Compliance with designated hold points.

(3) Performance of required ASME Code nondestructive examina-tions and at appropriate times of examination.

(4) Completeness of operation signoff.

l (5) Evidence of fabrication inspection definition and per-l formance consistent with QA program commitments.

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(6) Use of appropriate welding procedure specifications.

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. Findings a.

Deviation from Commitment See Notice of Deviation, Item E.

b.

Unresolved Items (1) The inspector observed on October 16, 1979, certain omissions in the feeder-traveler for a tube plate to lower barrel assembly on Order No. GAGT 1881, Assigned Item BAA01 A, Drawing No. 1105J17A01 05.

No Assigned operations could be located in the traveler for either l

the removal of a brace from the lower generator shell, or for performance of a magnetic particle examination of the brace to shell attachment area.

It was additionally noted that the brace had, in fact, been removed.

Insuf-ficient time was available during the inspection to as-certain the applicable Engineering fabrication and exam-ination requirements for the secondary side of the Westing-house steam generator. This item is considered unresolved pending definition of applicable examination requirements.

(2) Numerous cases of the failure of manufacturing personnel to sign off completed operations on travelers were observed

during the inspection. The text of the QA Program Manual relative to manufacturing process control still reflects the prior manufacturing control system used by WTP and does not specifically address the responsibilities of manufac-turing personnel with respect to documentation of completed operations. This item is considered unresolved pending revision of the QA Program Manual to clearly reflect the current WTP manufacturing control system.

H.

Exit Meeting A post inspection exit meeting was held on October 19, 1979, with the management representatives denoted in paragraph A. above. The inspectors summarized the scope and findings of the inspection and a request was made, that separate corrective action and steps to preclude recurrence response statements, be prepared for each identified item in the Notice of Deviation of Inspection Report No. 79-02. The lead inspector addition-ally requested that management make a further review relative to the adequacy of the current welding material control program. Management questions were confined primarily to establishing, that the observed mix up of electrodes in a holding oven, was a matter of mixed heats of the same type of electrode and did not involve other types of electrode.

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15 Management acknowledged the statements made by the inspectors and stated appropriate consideration of the findings would be made.

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16 DETAILS SECTION II (Prepared by H. W. Roberds)

A.

Persons Contacted H. W. Kerch, NUE Level III R. F. Steiner, Senior Quality Control Technician T. Vetter, Senior Quality Assurance Engineer C. Brown, Supervisor, NDE P. Carbone, Record Technician B.

Special Processes Personnel Qualification (Nondestruction Examination) 1.

Objectives The objectives of this area of the inspection were to verify that:

The employer, Westinghouse Tampa, has developed a written a.

practice for control and administration of NDE personnel training, examination, and certification in accordance with applicable NRC and ASME Code requirements.

b.

Perso'anel records are complete and are current.

Personnel performing nondestructive examination are qualified c.

for the method used and have current eye examinations as defined in SNT-TC-1A.

2.

Method of Accomplishment The preceding objectives were accomplished by:

Review of the Quality Assurance Manual section 10, revision 0, a.

" Nondestructive Examination, Non-NDE Examination and Special Processes."

b.

Review of T.Q. A.I. No. 4.6.1 revision 0, of 8/31/79,. " Training, Qualification and Certification of NDE Personnel."

Review of seven (7) NDE personnel certification and qualifi-c.

cation record packages including results of eye examinations.

3.

Findings

- Within this area of the inspection, no deviations from commitments or unresolved items were identified.

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Nondestructive Examination (Radiography) 1.

Objectives The objectives of this area of the inspection were to verify that:

Nondestructive examination (RT) is performed in accordance with a.

approved procedures.

b.

Nondestructive examination procedures meet the requirements of the ASME Code and other applicable requirements.

Work is accomplished by, and the test results are interpreted c.

by, appropriately qualified personnel.

2.

Method of Accomplishment The preceding objectives were accomplished by:

Review of the Quality Assurance Manual, Section 10, revision 0.

a.

b.

Reviev of Process Specification Nc. 84350 RT " Nuclear Power Components Radiographic Examination."

Review of Fourty-six (46) production radiogtophs.

c.

3.

Findings Within this area of the inspection, no deviations from commitments or unresolved items were identified.

D.

Nondestructive Examination (Liquid Penetrant and Magnetic Particle) 1.

Objectives The objectives of this area of the inspection were to verify that:

Nondestructive examination (MT&PT) is performed in accordance a.

with approved procedures.

b.

Nondestructive examination procedures meet the requirements of the ASME Code and other applicable requirements.

Work is accomplished by and test results are interpreted by c.

appropriately qualified personnel.

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Method of Accomplishment The preceding objectives were accomplished by:

Review of the Quality Assurance Manual, Section 10, revision 0, a.

b.

Review of Process Specification No. 84350 SA " Nuclear Power Components Dye Penetrant Examination."

c.

Review of Process Specification No. 84350 bni " Nuclear Power Components Magnetic Particle Examination."

d.

Observation of equipment and work are.s.

3.

Findings a.

Deviation from Commitments See Notice of Deviation, Item F.

b.

Unresolved Items None.

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