ML19309F232
| ML19309F232 | |
| Person / Time | |
|---|---|
| Issue date: | 02/07/1980 |
| From: | Barnes I, Hunnicutt D, Roberds H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309F223 | List: |
| References | |
| REF-QA-99900025 99900025-79-3, NUDOCS 8004290031 | |
| Download: ML19309F232 (11) | |
Text
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8004290 6
2 2.
Nondestructive examinations of fittings in one (1) ASME Section III Class 2 piping spool (with a design pressure and temperature, respectively, of 300 psig and 250 F) were not performed (See Details I, B.4.a).
B.
Paragraph 1.2.4 in Section 1.0 of the QA Manual states in part, "All personnel performing functions which affect quality shall be indoctri-nated and trained to a degree that proficency is achieved and maintained as required to fulfill the requirements of this Quality Assurance Pro-gram.
Contrary to the above, Quality Control Inspection personnel were not trained to a degree where required proficiency was maintained, as evi-denced by:
1.
Three (3) 1 inch Schedule 160 piping assemblies, S.O. Q4122AB-56, 58 and 61, were accepted as satisfactory by QC Inspection personnel and the assemblies shipped, although containing socket welds that were not in compliance with the size requirements of the applicable Visual Inspection Procedure,10-118 Revision 0.
2.
A 6 Inch Schedule 40 piping assembly was accepted by QC Inspection personnel as being in compliance with Visual Inspection Procedure,10-118 Revision 0, although in actual violation of paragraph 4.1.1 with respect to a localized area that had been ground below the specified required thickness.
(See Details I, C.4.a)
C.
Paragraph NC-5222 in Section III of the ASME Code states, "Circumferential welds shall be radiographed."
Paragraph NC-4453.4 in Section III of the ASME Code states in part, "The examination of weld repairs shall be repeated as required for the original weld...."
Contrary to the above, radiographic examination of a weld repair to Weld Joint SW-2, Iso SE-SI-04, was not repeated as required for the original weld.
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900025/79-03 Program No. 51300 Company:
Southwest Fabricating & Welding Co., Inc.
725 Sherman Street Post Office Box 9449 Houston, Texas 77011 Inspection Conducted:
December 5 and 19-20, 1979 Inspectors:
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7-PC I. Barnes, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch
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/' H. W. Roberds, Contractor Inspector Da~e t
ComponentsSection II
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Vendor Inspection Branch Approved by:
k wmuM f/7//O D. M. Hunnicutt, Chief
/Da t'e ComponentsSection II Vendor Inspection Branch Summary Special Inspection on December 5 and 19-20, 1979 (99900025/79-03)
Areas Inspected: Review and evaluation of nonconformances that have been identified at the V. C. Summer and Shearon Harris sites; including non performance of required material nondestructive examinations, inadequate inspection of piping assemblies and non performance of radiographic examination of repair welds.
The inspection involved a total of thirty (30) inspector-hours on site by two (2) NRC inspectors.
Results:
In the three (3) areas inspected, the following deviations from commitment were identified:
2 Deviations: Non-Performance of Required Material Non-Destructive Examinations - Failure to perform certaic material nondestructive examinations is contrary to Criterion V of 10 CFR 50, Appendix B, and customer specification CAR-SH-M-30 (Notice o." Deviation, Item A).
Inadequate Inspection of Piping Assemblies - Acceptance of piping assemblies with undersized socket welds and an assembly containing an area ground below wall thickness requirements is not in accordance with Criterion V of 10 CFR 50, Appendix B, and Section 1.0 of the QA Manual (Notice of Deviation, Item B).
Non-Performance of Radiograpuic Examination of Repair Welds - Failure to perform radiographic examination of weld repairs is not in accordance with Criterion V of 10 CFR 50, Appendix B, paragraph NC-5222 and paragraph NC-4453.4 in Section III of the ASME Code (Notice of Deviation, Item C).
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3 DETAILS SECTION I (Prepared by I. Barnes)
A.
Persons Contacted
- B. J. Goodwin, President and Chief Executive Officer j
- N. H. Moerke, Vice President, Engineering
- R. P. Bornes, Manager, Quality Assurance
- E. R. McAnally, Chief Engineer J. E. Harris, Project Manager T. Harris, Squad Supervisor, Engineering H. Kent, Squad Supervisor, Engineering T. Russell, Squad Supervisor, Engineering A. Bonin, Squad Supervisor, Engineering L. Hall, Squad Supervisor, Engineering
- Denotes those persons attending the exit meeting.
B.
Non-Performance of Required Material Nondestructive Examinations 1.
Introduction Southwest Fabricating & Welding Co., Inc. (SWF) were contacted in September, 1979, by Carolina Power & Light Co. Shearon Harris site personnel to ascertain why SWF had examined fittings in three (3) piping spools, Sales Order (S0) Q-3302-AF-5, 6 and 7, in accordance with ASME Section III Class 1 material nondestructive examination requirements, when the spools were to be installed in an ASME Section III Class 3 system (Liquid Radwaste).
Review by SWF showed that the examinations were performed as a result of a contractual requirement in paragraph 18.07 of Part Two of the applicable Ebasco piping specification, CAR-SH-M30.
Paragraph 18.07 requires that pipe, tube and fittings (over 2 inch nominal pipe size) used in Class 1, 2 and 3 safety-related piping systems be ultrasonically examined in accordance with NB-2552, NB-2560 (Summer 1973 Addendum),
when the design pressure exceeds 275 psig or the temperature exceeds 200 F.
Alternate examinations provided in NB-2551 are also required by paragraph 18.07, when product configuration or material conditions preclude effective ultrasonic examination.
During the SWF review, it was identified that although the fittings had been examined the pipe in the referenced spocls had not received the required ultrasonic examinations, resulting in the utility being informed and an investigation initiated to determine the scope of the problem.
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4 2.
Inspection Objectives The objectives of this area of the inspection were to review the nature and scope of the reported deficiency and determine any generic implications.
3.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA program requirements in Section 2.0 (Drawing and Specification Control), Section 3.0 (Procurement) and Section 5.0 (Process Control) of Revision 13 of the QA Manual.
b.
Examination of the SWF internal status report of December 5, 1979, on the subject, in terms of the methods used to identify the scope of the problem and the investigation results.
c.
Review of the following Architect-Engineer specifications applicable to current SWF contracts, in terms of material examination and test requirements in excess of ASME Code requirements.
(1) Brown & Root Specification 1LO20PS100-6.
(2) Stone & Webster Specification 582.
(3) Baldwin & Associates Specification BAK-2882-2.
(4) Sargent & Lundy Specification FL2741.
d.
Verification by examination of isometrics applicable to c. above that SWF was in compliance with customer special requirements.
4.
Findings a.
Deviation From Commitment SWF review of isometrics for all safety related systems, which exceeded the pressure and temperature limits of paragraph 18.07 in Part Two of Ebasco Specification No. CAR-SH-M-30, identified eight (8) piping spools from a total of two hundred and twenty three (223) where all materials had not received the required nondestructive examination. Each of these discrepancies is attrioutable to the failure of SWF Engineering to originally incorporate the testing requirement or detect the absence during the drawing checking process.
Four (4) spools (S.O. Q3302AF-5, 6, 7 and 8) were identified in the Liquid Radwaste System l
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(ASME Section III Class 3), with a design temperature of 500 F, where the required examination of the piping material had not been performed.
One of the spools, S.0.
Q3302AF-8, was detected prior to completion and shipment from SWF.
In the Service Water System (ASME Section III Class 3),
four (4) spools with a design temperature of 225 F were identified as being discrepant; three (3), S.O. Q3301AB-5, 6 and 23, for absence of examination of flanges, and one (1), S.O. Q3301AD-13, for absence of examination of pipe and fittings.
The inspector was informed that the latter spool was overlooked as a result of being a branch line connected to a main piping line, which had no applicable examination requirements.
In addition to the above, site personnel identified a further spool in the Chemical and Volume Control System (ASME Section III Class 2), with a degign pressure and temperature, respectively, of 300 psig and 250 F, where the fittings in the spool had not been examined.
Review of the Engineering isometric and shop detail sheet indicated that the assembly was released from Engineering with correct examination requirements.
In this instance, Material Control personnel had improperly deleted the fittings examination requirement from the shop drawing and QA failed to question the deletion during their review for approval of materials to be used in fabrication.
(See Notice of Deviation, Item A) b.
Generic Implications Inspector review of customer specifications and isometrics from four (4) other piping contracts, showed no other instance of failure to incorporate contract unique examination and testing requirements.
It would therefore appear from the information available, that this is not a generic problem but rather related to interpretation and implementation of a specific contract unique requirement.
6 C.
Inadequate Inspection of Piping Assemblies 1.
Introduction SWF was informed in November, 1979, by South Carolina Electric and Gas Company site personnel, that an inspection at site had found eight (8) out of fourteen (14) SWF welds in Schedule 160 socket weld fabrication to be undersized.
Corrective Action Request No. 059 was subsequently received by SWF from the utility, which identified that sixty-two (62) socket welds in Schedule 160 piping assemblies had been found to be undersized with respect to ASME Code requirements, from a total of two hundred and forty (240) re-inspected by Daniels Construction Compary Quality Control and utility personnel.
Socket welds with throat and leg approximately 1/8 inch undersize were reported as the worst condition found in this inspection.
SWF review established that they had received two (2) nuclear contracts to furnish two (2) inch and smaller piping, which utilized a socket weld fabrication technique.
In addition to V. C. Summer Unit 1 for which piping fabrication had been completed, piping assemblies containing socket welds were being furnished to the Carolina Power and Light Company for installation at Shearon Harris Units 1, 2, 3 and 4.
Re-inspection by SWF of socket welds in piping assemblies currently undergoing fabrication for this contract, confirmed that the problem was confined to only Schedule 160 piping, of which only three (3) pieces had been shipped to the Shearon Harris site.
These pieces, S. O. Q4122AB-56, 58 and 61, were requested by SWF to be returned for inspection and evaluation.
Carolina Power and Light Company identified an additional problem to the NRC concerning a six (6) inch Schedule 40 ASME Section III Class 2 piping spool, which had been shipped by SWF on July 31, 1979, for installation in the Shearon Harris Unit 1 Containment Spray System. A localized area was observed by site personnel adjacent to a lug, where a nonrequired fillet weld had been apparently removed by grinding and had resulted in removal of 0.125 inches from the 0.280 inch wall.
SWF was not dir'ctly contacted by the utility relative to this problem, but did.eceive a copy of the applicable Deficiency and Disposition Report from the Architect -
Engineer resident inspector at the SWF facility.
A visit was made by SWF management to the site on December 12, 1979, but they were unable to examine the reported condition, as a result of the area having already been repaired by site personnel.
7 2.
Inspection Objectives The objectives of this area of the inspection were to review the nature and scope of the reported deficiencies and determine any generic implications.
3.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA program requirements in Section 5.0 (Process Control) and Section 9.0 (Inspection and Nondestruction Examination) of Revision 13 of the QA Manual.
b.
Examination of the SWF internal summary report of December 4, 1979, describing the actions taken subsequent to being informed of discrepant socket welds at the V. C. Summer Unit 1 site.
c.
Interviews with cognizant persor.nel relative to:
(1) Methods used by SWF to measure socket weld sizes and changes made subsequent to problem identification.
(2) Socket weld status of the three (3) pieces returned from the Shearon Harris site.
d.
Review of SWF Engineering requirements on Shop Detail Sheets applicable to both contracts.
e.
Review of SWF Procedure No.10-118, Revision 0, " Visual Inspection."
f.
Review of SWF Procedure No. QC-101, Revision 1, "Cualifications of a Quality Control Inspector."
g.
Review of qualification and experience records for QC Inspectors, who had performed acceptance inspection of piping subsequently found to be discrepant.
4.
Findings a.
Deviation From Commitment Review of the Shop Detail Sheets applica le to the three b
pieces returned from the Shearon Harris oite showed that use of procedure 10-118, Revision 0, had been specified on the MRS. Discussion with SWF management, relative to the results
8 of re-inspection of socket welds in these assemblies, revealed the welds had been found to be locally undersized at overlap regions (resulting from grinding of the weld overlap).
Examination of qualification records for individual QC Inspectors who had accepted the assemblies failed to reveal objective evidence of the methods and training criteria used to assure familiarity and understanding of ASME Code and 4
SWF inspection requirements.
It should be noted, however, that records of QC training sessions were not reviewed during this inspection, which would have provided an alternative method of assessing the scope of SWF QC Inspector training activities.
Examination of the SWF Shop Detail Sheet for S.0. Q3302CJ-36 showed no evidence of any mistakes having occurred in fabrication with respect to deposition or removal of a non-required fillet weld. Reports of Nonconformance (RON) were not reviewed, however, to ascertain whether this operation had been accomplished using a RON.
Paragraph 4.1.1 in procedure 10-118, Revision 0, which was specified for use on this assembly, states, "The surface condition of the base material shall be inspected for defects that exceed the established specification." Shipment of the assembly, with a locally ground area of 0.125 inch depth in a 0.280 inch wall, indicates improper inspection relative to the stated requirement.
SWF management acknowledged responsibility to the inspector for the condition, although the assembly had al-ready been repaired before their visit to the Shearon Harris site on December 12, 1979. This decision was made based on evaluation of a photograph of the ground area, that had been taken by utility personnel. The failures to both prescribe documented instructions relative to socket weld acceptance criteria for V. C. Summer Sched-ule 160 piping, and to accomplish Shearon Harris inspections in accorance with the requirements of procedure 10-118, Revision 0, are considered contrary to Criterion V of Appendix B to 10 CFR 50.
(See Notice of Deviation, Item B) b.
Additional QA Program Concerns The inspector was informed that fabrication of V. C. Summer Unit I two (2) inch and smaller piping utilizing a socket weld construc-tion technique, was performed in the approximate time period of December, 1976, to August, 1978. Review of V. C. Summer (S.O.
Q4165 and Q4166) Shop Detail Sheets for this fabrication, showed no formal requirement relative to size of socket welds, in either the Engineering Notes, or in the form of a referenced procedure on the Manufacturing Record Sheet (MRS).
In response to questions concerning the criteria provided to and used by QC Inspectors for evaluation of adequacy of socket welds, the inspector was informed that the shop standard was applicable to these inspec-tions.
This standard was stated to consist of the same criteria
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as contained in procedure 10-118, Revision 0, which was con-i firmed by the inspector to include applicable ASME Section III l
Code requirements relative to socket welds.
It was noted, how-ever, that this procedure was approved on April 1, 1977, which post dates the start of fabrication on this contract.
The inspector was additionally informed that it was not the SWF practice to reference the use of a procedure on the MRS, unless there was a specific contractual requirement for submittal and use of that procedure.
The failure to provide, either docu-mented instructions on the MRS relative to inspection require-ments, or alternatively, a clear description in the QA Manual of what criteria are provided to and used by QC Inspection personnel to assure ASME Code compliance, would appear to represent both a programmatic weakness and contrary to the intent of Criterion V of Appendix B to 10 CFR 50.
c.
Generic Implications Socket weld fabrication for the V. C. Summer and Shearon Harris sites represents the only nuclear fabrication of this type, that SWF has performed to date. As such, the observed deficiencies do not appear to pose any generic problem regard-ing shop fabricated piping of this type.
It was additionally ascertained during the inspection that socket weld inspection of V. C. Summer piping was not performed using fillet weld gages.
Inspectors have now been equipped with such gages since the identification of this problem, wh:ch should improve the assurance of future fillet weld adequa'.y. As regards the other identified problem concerning grinding into the pipe wall, no information is currently available that would indicate i
this problem was other than an isolated instance of the failure of SWF production and QC personnel to discharge their respons-ibilities in accordance with QA program commitments.
D.
Exit Meeting The inspectors met with the management representatives denoted in paragraph A. above on December 20, 1979, at the conclusion of the inspection.
The lead inspector informed management that the special inspection performed was the result of information provided to Region IV by Region II of the Office of Inspection and Enforcement, relative to observed deficiencies in SWF products at the V. C. Summer and Shearon Harris sites.
The inspectors summarized the scope and findings of the inspection and requested review of QA program adequacy with respect to the observed product deficiencies. Management acknowledged the statements of the inspectors and had no specific questions relative to the findings as presented to them.
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10 DETAILS SECTION II (Prepared by H. W. Roberds)
A.
Persons Contacted N. H. Moerke, Vice President Engineering R. P. Bornes, Manager, Quality Assurance T. W. Jordan, NDE Level II (RT)
B.
Non-Performance of Radiographic Exarination of Repair Welds 1.
Introduction Southwest Fabrication & Welding Co. Inc. (SWF) were contacted on October 5, 1979, by South Carolina Electric and Gas V.C. Summer site persor.ael and informed that discrepancies had been detected in radiog>.aphy performed by SWF on fabricated pipe spools.
On S.O.
Q4166-S-1, containing four (4) butt welds, the steel stamping on butt welds one (1) and three (3) had been reversed from those located and identified on the shop drawing. Subsequently, weld one (1) was radiographed two (2) times, one time in accordance with identifica-tion and location on the shop drawing and later by the identification stamped on the pipe spool. On S.O. Q4166-S-54, containing two (2) butt welds, the welds were radiographed and one repair made with instructions issued to re-radiograph both welds 100%. The RT operator failed to follow instructions and re-radiographed the repair weld location only, but on the wrong weld.
2.
Inspection Objectives The objectives of this area of the inspection were to review the nature and scope of the reported discrepancies and determine if the problem had generic implications.
3.
Method of Accomplishment The preceding objectives were accomplished by:
Review of the QA Program requirements in Section 6.0 (Welding a.
Quality Assurance) and Section 9.0 (Inspection and Nondestruc-tive Examination).
b.
Review of SFW investigation of radiographic practices of October 5-24, 1979.
l 11 Review of radiographs of thirty-three (33) weld c.
repairs.
4.
Findings a.
Deviation from Commitments See Notice of Deviation, Item C.
b.
Comments As a result of SWF investigation of radiographic practices consisting of the review of radiographs of 2,767 pipe weld joints, 10 were found to require additional radiography due to film duplication and lack of coverage of some welds.
In order to determine if a generic problem did exist, relative to radiography of repair areas, the inspector reviewed radio-graphs of thirty-three (33) weld repairs.
Positive correlation of thirty-one (31) of the original and repair radiographs was established and that the repaired areas had been re-radiographed and the defects had been removed or brought within acceptable limits. This was accomplished by comparison of certain land marks in the weld and/or the parent base material on the orig-inal and the repair radiographs.
Of the two (2) repairs where positive correlation of the original and the repair radiographs could not be established, owing to absence of any identifying land marks, there was no reason to suspect that the repaired area had not been re-radiographed as required.
The information available to date indicates that the radio-graphic problem resulted primarily from confusion of weld joint identities.
Although no evidence of a similar problem was detected in film currently at the SWF facility, further insper-tion of this subject is believed necessary to provide sufficient assurance that a generic problem does not exist.
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