ML19309F320
| ML19309F320 | |
| Person / Time | |
|---|---|
| Issue date: | 10/25/1979 |
| From: | Barnes I, Ellenshaw L, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309F295 | List: |
| References | |
| REF-QA-99900338 NUDOCS 8004290212 | |
| Download: ML19309F320 (26) | |
Text
_ _.
O U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Repou. No.
99900388/79-01 Program No.
51400 Company:
Marvin Engineering Co., Inc.
251 West Beach Ave.
Inglewood, California 90302 Inspection Conducted:
September 18-21, 1979 Inspectors:
/c/25'/7 7 I. Barnes, Contractor Inspector Date ComponentsSection II Ve dor Inspection Branch hu D
/a/K n
{. E. Ellershaw, Contractor Inspector
/Dat/
ComponentsSection II Vendor Inspec ch t
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- [O I7 Approved by:
_p D. M. Hunnicutt, Chief
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Date /
ComponentsSection II 1
Vendor Inspection Branch Summary Special Inspection on September 18-21, 1979 (99900388/79-01)
Areas Inspected:
Implementation of 10CFR50, Appendix B, criteria and applicable codes and standards; including quality assurance program review, control of weld-ing, manufacturing process control and material identification and control. Also reviewed were measures adopted by Marvin Engineering Co., Inc. to implement 10CFR Part 21.
The inspection involved sixty-four (64) inspector-hours on site by two (2) NRC inspectors.
l Results: The inspection resulted in the identification of one infraction, one deficiency, twenty-seven (27) deviations from commitment and three (3) unresolved items, which are described as follows:
800.4290212
2 Infraction:
Compliance with 10CFR21 - Failure to comply with contractually invoked 10CFR Part 21, relative to adoption of procedures for evaluation of deviations (Notice of Vialation, Item A).
Deficiency: Compliance with 10CFR21 - Failure to comply with contractually invoked 10 CFR Part 21, relative to providing required posting of regulations /
procedures (Notice of Violation, Item B).
Deviations: Quality Assurance Program Review - Quality system not in conform-ance with Criterion I of 10CFR50, Appendix B, relative to providing required authority, organizational freedom and independence of personnel performing quality assurance functions (Notice of Deviation, Item 1).
Control of Welding - Certain welding procedures specifications not carried out in accordance with Section IX of the ASME Code, in that they did not specify nor were they qualified for a required solution annealing heat treatment, which is not in accordance with Criterion V of 10CFR50, Appendix B and Quality Manual A and B (Notice of Deviatiot, Item 2).
Use of unqualified welding personnel on
~ Job No. 1805 not in accordanae with Criterion V of 10CFR50, Appendix B, and Quality Manual A requirements (Notice of Deviation, Item 3).
Performance of cer-tain welder performance qualification tests could not be verified with respect to requirements of Criterion.V of 10CFR50, Appendix B, and Quality Manual A and B requirements (Notice of Devia: ion, Item 4).
Past and present practices relative to control of weld enerial issue chits are not in accordance with Criterion V of 10CFR50, Appendix 3, and (uality Manual A and B requirements (Notice of Deviation, Item 5).
Acceptance and use of welding material without evidence of review and examination is not in accordance with Criterion V of 10CFR50, Appendix B, and Quality Manual B requirements (Notice of Deviation, Item 6).
Failure to monitor welding areas and act on observed nonconformances is not in accordance with Criterion V of 10CFR50, Appendix B, and Quality Manual B require-ments (Notice of Deviation, Item 7).
Failure to prepare committed review reports relative to trend analysis of the welding program is not in accordance with Criterion V of 10CFR50, Appendix B, and Quality Manual A and B requirements (Notice of Deviation, Item 8).
i Manufacturing Process Control - Use of an inspection stamp assigned to another i
individual is not in conformance with Criterion V of 10CFR50, Appendix B, and Quality Manual A requirements (Notice of Deviation, Item 9). Performance of work I
l without authorization of manufacturing work orders on Job No. 1805 is contrary to Criterion V of 10CFR50, Appendix B, and Quality Manual A requirements (Notice of Deviation, Item 10). Failure to perform required final inspections on Job No.
1805 is contrary to Criterion V of 10CFR50, Appendix B, and Quality Manual A re-quirements (Notice of Deviation, Item 11). Failure to perform liquid penetrant inspections at designated points on manufacturing work orders and inability to verify actual performance of a required penetrant inspection are contrary to Criterion V of.10CFR50, Appendix B, and Quality Manual A requirements (Notice of Deviation, Item 12).
Incorrect certification of use of water washable penetrant materials for which no Manufacturer's Certification was on file, is not in confor-mance with Criterion V of 10CFR50, Appendix B, and the requirements of MEC Pro-l cedure, ME-12 Revision 0 (Notice of Deviation, Item 13).
1
3*
Failure to include contract requirements in the manufacturing order (M.O.)
i.e.,
~
liquid penetrant examinations, which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See Notice of Deviation, Item 14).
Failure to specify procedures and applicable revisions for specified operations within the M.O.s, which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual Requirements (See Notice of Deviation, Item 15). Failure to specify the correct welding procedure specification as defined by customer requirements which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See Notice of Deviation, Item 16).
Work was per-formed by manufacturing prior to release of certain M.O.s, which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See 1
Notice of Deviation, Item 17). Failure of manufacturing and inspection personnel to sign-off, stamp, and date completion of specific operations as listed on the M.O.s, which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See Notice of Deviation, Item 18). Failure of final in-spection function to verify and/or establish adequate documettation to provide objective evidence that inspection has been accomplished, wh. ch is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requ2 cements (See Notice of Deviation, Item 19). Failure to develop and submit to the customer, a visual examination procedure, which is contrary to Criterion V of Appendix B to 10CFR50 and General Electric Company Purchase Order 205-AM191 (See Notice of Deviation, Item 20.).
Failure to have current, applicable welding procedute specification in the welding area where the work was being performed is contrary to Criterion V of Appendix B to 10 CFR 50 and Quality H-aual requirements (See Notice of Devia-tion, Item 21.).
Failure to issue welder stamps, so certain welding operations cannot be attributed to a specific welder, which is contrary to Criterion V of Appendix B to 10 CFR 50 and Quality Manual requirements (See Notice of Devia-
)
tion, Item 22.).
Failure to perform the required liquid penetrant examinations of root passes, as shown by the M.O., which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See Notice of Deviation, Item 23).
By-passing customer verification / notification points and proceeding with manufac-turing, which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See Notice of Deviation, Item 24). Failure by the Nuclear Program Manager to sign Certificates of Conformance, which is contrary to Criterion V of Appendix B to 10CFR5 and Quality Manual requirements (See Notice of Deviation, i
i Item 25).
Material Identification and Control - Failure to maintain heat or detail numbers on components at all times, which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See Notice of Deviation, Item 26).
Failure to record material / component identification on the M.O.s, when the material / components were drawn from stores, which is contrary to Criterion V of Appendix B to 10CFR50 and Quality Manual requirements (See Notice of Deviation, Item 27).
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4 Unresolved Items:
Welding Material Receiving Inspection - Failure by MEC to have on file a certifi-cate of Compliance (C of C) for ER 308L weld wire, heat number N-5131.
A C of C was obtained form Sims Welding Supply, but it was dated the same day.
It provided no information relative to size, purchase order number, shipping date or invoice number-It was not established during this inspection whether a purchase order had ever been issued by MEC to Sims Welding Supply, (See Details Section, para-graph D.3.b.).
Manufacturing Process Control - Certain operations on M.O.s for Job 1349 and 1805 have been dated such that they could not have been performed as indicated (See Details Section, paragraph E.3.c.(1).).
Certain operations have been signed off (printed) with misspelled names on the M.O.s for Job No.
1805 (See Details Section, paragraph E.3.c.(2).).
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i
5 DETAILS SECTION (Prepared by I. Barnes and L. E. Ellershaw)
A.
Persons Contacted
- M. Gussman, President
- G. M. Friedman, Executive Vice President
- R. Barnack, Nuclear Program Manager
- R. Cowdrey, NDE Level II Inspector M. Gomez, Quality Control Inspector E. Hertel, Manufacturing Supervisor
- G. Kaufman, Production Control Manager
- R. Paul, Quality Assurance Manager
- J. E. Richardson, Quality Control Chief Inspector
- Denotes those present at the exit meeting.
B.
Compliance with 10 CFR 21 (I. Barnes) 1.
Inspection Objective The objective of this area of the inspection was to ascertain whether MEC and appropriate responsible officers had established and implemented procedures and other instructions as required to ensure compliance with 10 CFR 21 requirements relative to the reporting of defects and noncompliance.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Review of General Electric Company Purchase Order Nos. 282-KF295 Revision 00 and 205-AL709 Revision 0 relative to veri-fication of.ncorporation of 10 CFR 21 as a procurement re-quirement.
b.
Observation relative to posted notices in facility.
c.
Interviews of accompanying personnel.
3.
Findings Relative to 10 CFR 21.21 and 21.6 Requirements See Notice of Violation.
6 C.
Quality Assurance Program Review (I. Barnes) 1.
Inspection.0bjective The objective of this area of the inspection was to review the documented quality assurance (QA) program with respect to completeness of and methods used for addressing the quality assurance criteria of Appendix B to 10 CFR 50.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Examination of the Marvin Engineering Company, Inc. (MEC)
Quality Assurance Manual ASME Section VIII - Division 1 and Pressure Piping Section I, Revision 0, dated August 1, 1977, (hereafter referred to as Quality Manual A).
b.
Examination of the MEC Quality Control Manual No. 7, Revision 0, dated August 1, 1977, (hereafter referred to as Quality Manual B).
c.
Review of procedures used for the control of welding, heat treatment and non-destructive examination.
d.
Examination of system requirements relative to documentation and control of material identity and manufacturing processes.
e.
Interview of Chief Inspector and Nondestructive Examination (NDE) Level II Inspector.
3.
Findings a.
Deviation from Commitment The Statement of Policy in both Quality Manuals vests direct responsibility for monitoring and administration of the nuclear QA program in the Nuclear Program Manager. This individual has overall responsibility for all nuclear pro-duct activities at MEC; encompassing manufacturing, produc-tion control and planning, process and methods engineering, marketing contract administration and quality assurance. The NRC inspectors were informed by the Chief Inspector and NDE Level II inspector on September 18, 1979, that they reported to the Nuclear Program Manager and not to the MEC QA Manager.
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7 It was also stated that the Nuclear Program Manager is currently personally discharging the functions of Quality Control Engineer, Marketing Contract Administrator and Process and Methods Engineer, in addition to his overall responsibilities.
This organizational structure is not considered to be in compliance with Criterion I of Appendix B to 10 CFR 50, in that the quality assurance functions do not report to a management level, that will provide required authority and organizational freedom, including sufficient independence from cost and schedule.
(See Notice of Deviation, Item 1.)
b.
Unresolved Items None D.
Control of Welding (I. Barnes) 1.
Inspection Objective The objective of this area of the inspection was to verify that measures had been established and implemented, which provide for the control of welding in accordance with applicable ASME code, contract and regulatory requirements.
2.
Method of Accomplishment The preceding objective was accomplished by:
Examination of Section XXII Revision 0 of Quality Manual A, com-a.
mencing on page 50, " Welding Procedure and Welder's Qualification."
l b.
Examination of a. above subject matter in Quality Manual B, which commences on page 51.
1 c.
Examination of Section XXIII Revision 0 of Quality Manual A, commencing on page 53, " Weld Material Control."
d.
Examination of c. above subject matter in Quality Manual B, which com-mences on page 54.
Review of General Electric Company (G.E.) Process Specification, e.
209A4290 Revision 3, " Welding Requirements."
f.
Review of G.E. Process Specification, P50YP102 Revision 3, " Arc Welding of Austenitic Stainless Steel."
g.
Review of G.E. Process Specification, P50YP101 Revision 2, " Arc Welding of Carbon and Low Alloy Steels."
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h.
Examination of issued manufacturing work orders (?!.0.s) for Job No. 1805, relative to assignment of qualified welders.
i.
Examination of gas tungsten are welding performance qualifications for nine (9) welders presently identified on welder stamp list.
j.
Examination of available weld material issue chits from Job No.
1805 relative to both Quality ?!anual A weld material traceability requirements and use of materials required by applicable welding procedure specifications.
k.
Observation of production welding on Job No. 2480A, ?!.0. No. 543, with respect to compliance with WPS requirements.
1.
Examination of weld material issue chits for Job No. 2480A to establish current practices relative to compliance with Quality t!anual B weld material traceability requirements and use of ma-terials required by the assigned WPS.
m.
Examination of WPS FE-WP-2 Revision 1 and FE-WP-4 Revision 0, which were used in fabrication of feedwater spargers for Job Nos. 1349 and 2480A, relative to qualification of applicable Section IX of the ASME code,' essential variables.
n.
E..atz.n m en of available receiving inspection reports and Certified flaterial Test Reports for two (2) heats of SFA 5.9 ER308L gas tungsten arc welding wire, which were observed in production use on Job No. 2480A, bl.0. No. 543.
3.
Findings a.
Deviations from Commitment l
(1) Qualification of Welding Procedures Paragraph 1.0, sub-paragraph 1.1, on page 50 of Quality ?!anual A and on page 51 of Quality ?!anual B states, "All welding pro-cedures and welder qualifications shall be carried out in accordance with AStE Code,Section IX, Welding Procedure and Qualification and AStE Code Section III requirements.
Article II, Sub-Article QW-200, in Section IX of the ASME Code states in part,
. The WPS shall list in detail the P-Num-bers to be joined, the filler metals to be used, the range of preheat and postweld heat treatment, the thickness range, and all other variables required for each process both essential and nonessential... The WPS information may be presented in any form,
. as long as every essential and nonessential variable required by QW-252 through QW-281 is included...
Each manufacturer or contractor shall qualify the WPS by the
9 welding of test coupons and the testing of specimens, as required in this Code, and recording the welding data and test results in a document know as a Procedure Qualification Record (PQR). This form.shall document the essential varia-bles of the specific welding process or processes (as listed in QW-252 through QW-281...) and the test results.
A change in any essential variable shall require requalifi-cation, to be recorded in another PQR.
QW-156 in Section IX of the ASME Code lists QW-407.3 as an essential variable for the gas tungsten arc welding process.
QW-407.3 states, "For P-8 metal, the addition or deletion of a solution or stabliizing heat treatment."
Contrary to the above, gas tungsten are welding procedure specifications (WPS) ME-WP-2 Revision 0 and I, and ME-WP-4 Revision 0 did not either list nor were they qualified for a solution annealing heat treatment essential variable, although used in applications receiving a solution annealing heat treatment subsequent to welding, e.g. Job No.1349, M.0.
Nos. 478 and 480; Job No. 2480A, M.0. No. 543.
(See Notice of Deviation Item 2.)
(2) Assignment of Unqualified Welding Personnel on Job No. 1805 Twenty-eight (28) welding operations were identified on the manufacturing work orders for Job No. 1805, as being completed during September to December, 1978, by a welder named " Hung."
The welder stamp log shows only one (1) welder of this name, i.e. Hung Nguyen, W-10.
The MEC welder qualification records show, however, that this welder was not qualified for the use of any welding procedure until June 18, 1979, at which time he was certified as qualified for the use of WPS ME-WP-4.
A tabulation of the welding operations and the performance dates is shown below for Job No. 1805 using this welder. With the exception of M.0. 444, which is discussed further subse-quent to the tabulation, all welding operations involved the use of WPS ME-WP-4 Revision 0.
Manufacturing Work Order Operation Performance (M.O.) No.
No.
Date 437 50 12-16-78
)
90 11-05-78 210 11-23-78 250 11-28-78 l
10 Manufacturing Work Order Operation Perfo rmance (H.O.) No.
No.
Date 437 continued 270 11-29-78 310 11-29-78 350 12-03-78 370 12-03-78 420 12-07-78 439 70 9-04-78 100 9-05-78 140 9-05-78 220 9-07-78 441 150 12-08-78 210 12-09-78 442 120 12-03-78 180 12-03-78 443 90 11-30-78
- 444 50 12.-18-78 445 50 12-11-78 448 50 11-24-78 449 50 11-06-78 450 50 12-08-78 90 12-03-78 452 50 9-16-78 i
459 50 12-22-78 i
11 Manufacturing Work Order Operation Performance (M.O.) No.
Cont.
No.
Date 462 50 11-22-78 464 90 11-20-78
- M.0. No. 444 did not identify which MEC WPS was appli-cable for the performance of Operation 50. Uelding material issue chits were also not located during this inspection, which would allow identification of the materials and pro-cedure actually used. This fabrication operation, however, involves the welding of carbon steel items. The only MEC WPS identified as being appropriate for this operation is ME-WP-7 Revision 0, which utilizes the shielded metal arc welding process. Welder W-10 was not qualified as of this inspection to utilize the shielded metal are welding process.
(See Notice of Deviation, Item 3.)
(3) Welder Qualification Practices (a) Radiographic qualification of two (2) welders, Dat Tat Nguyen (W-16) and Hung Nguyen (W-10) was accomplished for the use of WPS ME-WP-4 Revision 0 on June 18, 1979.
Radiography was performed for the qualifications by General Inspection Laboratories.
Examinations of the radiographic ilms for these qualifications ou September 19, 1979, by both NRC inspectors, revealed the follcwing:
i.
Both films had been originally identified as being radiographic exposures of a test plate welded by welder W-10 i.e.,
lead letters had been placed on the test plate to produce a record on'the film of the welder identity, which in this instance was W-10 on both films attributed to W-10 and W-16.
f ii.
A paper tab had been attached to the film attiri-buted to W-16, changing the identity to W-16.
This tab had been initia11ed by the MEC NDE Level II Inspector, Robert Cowdrey.
iii.
The two (2) films appeared to be different expo-sures of the same test plate, in that three (3) test plate surface conditions were visible on
12 both films, which occurred at identical locations on the filas relative to the marking letters.
It is therefore considered that the QW-484 Qualifi-cation Forms for these welders, although attested to be correct by the MEC QA Manager and the Nuclear Pro-i gram Manager, do not support a true actual qualifi-1 cation status.
(b) The QW-484 Qualification Form for welder W-12, Dung V. Nguyen, relative to the use of WPS ME-WP-4 Revision 0, was attested to be correct by the MEC QA Manager and the Nuclear Program Manager on October 31, 1978.
This welder qualification form references General Inspection Laboratories Test No. 0801 as the basis for qualification. A copy of this Test No., which includes applicable film and reader sheet, could not be located for the NRC inspectors to review. A sub-sequent visit to General Inspection Laboratories was made on September 20, 1979, by the MEC NDE Level II Inspector, Robert Cowdrey, in an attempt to obtain a copy of the applicable Laboratory Test No. 0801 reader sheet.
Mr. Cowdrey informed the NRC inspectors on his return to MEC, thr.t the General Inspection Laboratories personnel he had spoken to, could find no evidence of the existence of a Laboratory Test No. 0801.
It is therefore considered that the QW-484 Qualifi-I cation Form for welder W-12, although attested to be correct by the MEC QA Manager and the Nuclear Program Manager, does not support a true actual qualification status.
(c)
The QW-484 Qualification Form for welder W-31, Jose G. Jimenez, relative to the use of WPS ME-WP-2 was
(
attested as being correct on October 31, 1978, by the MEC QA Manager and the Nuclear Program Manager. This welder qualitication form references General Inspection Laboratories Test No. 6436 as the basis for qualification.
Examination of Test No. 6436 showed, however, that radio-graphic examination was not made until August 23, 1979, l
and the reader sheet was not signed off until August 27, 1979.
It is not understood how a qualification form prepared in 1978 can reference a qualification test, which the records indicate was not accomplished until approximately ten (10) months later.
It is therefore considered that the QW-484 form for welder W-12, although attested to be correct by the MEC QA Manager and the Nuclear Program Manager, does not support a true actual qualification status.
13 (See Notice of Deviation, Item 4.)
(4) Control of Weld Material Issue (a) Job No. 1805 Of the four (4) weld material issue chits located during this inspection that were applicable to Job No. 1805, two (2) indicated that two separate issues of k lb. of 1/16 inch diameter Type 5356 aluminum alloy wire had been issued for use on Job No.1805 on October 27, 1978, to a
)
welder identified as Manuel. The welder stamp list iden-tifies Manuel Gomez, welder W-8, as the only welder of 1
that name. Both chits had not been filled out in their entirety, in that they did not indicate either the appli-cable Manufacturing Work Order (M.O.) No., or Operation No. that the welding materials were used for. Fabrication on this contract, however, involved only welding of car-bon and austenitic stainless steel, for which the use of an aluminum alloy gas tungsten arc filler wire would be totally incorrect.
The remaining two chits from Job No. 1805 pertained to the issue of SEA 5.9 ER308L wire (1/16 inch and 0.045 inch diameter) on October 27, 1978, and October 28, 1978 respectively. Neither of these chits was filled out in its entirety to provide required traceability, in that the M.0. No. and Operation No. where the materials were used was left blank.
(b) 9trrent Weld Material Issue Control on Job No. 2480A The NRC inspectors observed the following on September 20, 1979, with respect to five (5) weld material issue chits, dated from September 17, 1979, to September 20, 1979:
i.
0.045 inch diameter SFA 5.9, Type ER 308L wire, Heat 5131 (Note-correct heat number is N-5131) was issued to welder, Jose A. Jimenez, on September 17 and 18, 1979, for use on Job No. 2480 (Note - Job No. should have been entered as Job No. 2480A, which was the applicable number for identifying Quad Cities Unit
- 2) without completing on the weld material issue chit the applicable M.O. and Operation Numbers. This was identified on September 20, 1979, indicating daily monitoring by the Inspector was not in effect.
14 I
ii. A 1/16 inch diameter SFA 5.9 ER308L wire, Heat l
No. 7-61135, was issued to welder, Jose A. Jimenez, on September 20, 1979, without ccmpleting on the l
weld material issue chit the intended M.0. for use.
The Job No. was again incorrectly recorded as 2480.
iii. The same wire was issued to welder, Quan Hoang, on September 17, 1979, without completing on the weld i
material issue chit the intended M.0. and Operation Nambers of use. The Job Number was recorded on this j
chit also as 2480.
iv.
The saie wire was issued to welder, Ouan Hoang, on September 20, 1979, with the same deficiencies regarding the chit, as identified in iii above.
v.
The same wire was issued to welder, Jose G. Jimenez, on September 20, 1979, with the applicable M.0. of use not identified and the Job Number incorrectly identified as 2480.
(See Notice of Deviation, Item 5.)
(F) k'elding Material Receiving Inspection Paragraph 1.0, sub paragraph 1.1, on page 23 of Quality Manual B states, "All incoming material shall be received by Material Control Specialist. He shall initiate a Lot Ticket (Fig. 15) and route it to Inspection to be processed by the Receiving Inspector to determine acceptance or rejection 'of incoming material per Marvin Engineering Company Purchase Order."
Paragraph 1.0, sub-paragraph 1.3, on page 23 of Quality Manual B states, "The Receiving Inspector is responsible for verifying that all material or components purchased meet the' require-meats of the purchase order and bill of material. Materials must have proper documentation in accordance with Purchase Order and applicable codes."
Paragraph 4.0, sub-paragraph 4.1, on page 24 of Quality Manual B states in part, " Material Certifications per ASME Code SA, SB, SFA or ASIM that has been processed and accepted by the Receiving Inspector, shall be routed to the following depart-ments.
l l
A.
A copy retained for Inspection Department for Data l
Package.
1 i
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_ _ _.. _ _ _ _ _.. _. ~...
15 B.
A copy to Material Specialist for Production Control use and retainability...."
Paragraph 4.0, sub-paragraph 4.2, on page 24 of Quality Manual B states in part, "After Receiving Inspection.
. have completed their inspection of received material, Receiving Inspector shall fill out Lot Ticket in its entirety and affix his acceptance stamp to the Lot Ticket. Receiving Inspector shall route white and green copies of Lot Ticket to Material Specialist, confirming the acceptance of incoming material for close out of Purchase Order or partial shipment. Receiving Inspector shall retain pink copy of Lot Ticket (Fig.15)."
Paragraph 6.0, sub paragraph 6.1, on page 24 of Quality Manual B states, " Pink copy of Purchase Order is maintained by Re-ceiving Inspector to back up Lot Ticket for use in Inspection Department for traceability, review, accountability."
Paragraph 7.0, sub paragraph 7.1, un page 25 of Quality Manual B states, "All acceptable aaterial conforming to the Purchase Order and an applicable c'rawing copy will then be marked with the Lot Number or tagged and acceptance stamped by the Receiving Inspector."
Paragraph 2.0, sub paragraph 2.1, on page 54 of the Quality Manual B states in part, "All... electrode wire.
. in welding mat'erial storage room shall be identified by the lot number, heat number and size...."
Contrary to the above, the following was observed with respect to 36 inch length, 0.045 inch diameter, SFA 5.9 ER308L wire, Heat No. N-5131 (Manufacturer - Nemco Welding Alloys), which was observed in use on Job No. 2480A, M.0. No. 543:
(a) White, green, or pink copies of Lot Tickets could not be be located to indicate the material had ever been received by the Material Control Specialist, or subject to receiving inspection.
(b) A Certified Material Test Report for the material.was not filed by either Inspection or the Material Control Specia-list.
(c) The material in the MEC storage cabinet (not room as indi-cated in Quality Manual B) was not tagged or marked with a MEC Lot Number.
(See Notice of Deviation, Item 6) i
16 (6) Current Compliance with Welding Procedure Specification Requirements (See Notice of Deviation, Item 7.)
(7) Welding Program Nonconformance Trend Analysis After requesting to see the review reports referenced by paragraph 6.0, sub paragraph 6.1, on page 55 of Quality Manual A and on page 56 of Quality Manual B, the NRC in-spectors received Quality Audit and Trend Analysis Report forms, dated October 26, 1978. No review reports prepared by the Nuclear Program Manager were made available, to confirm the committed trend analysis for the welding pro-gram was being performed.
It could also not be ascertained in the time available, whether Inspectors had ever sub-mitted these forms relative to observed welding program nonconformances.
(See Notice of Deviation, Item 8.)
b.
Unresolved Items (I. Barnes)
It was not' established during the inspection whether a purchase order had ever been issued for Heat N-5131 to Sims Welding Supply, which the NRC inspectors were verbally informed was the supplier.
After discovery of the missing certification on September 20, 1979, by the NRC inspectors, MEC obtained a copy of a Certificate of Com-pliance for Heat No. N-5131 from Sims Welding Supply,1155 South Eastern, Los Angeles. Review of this Certificate of Compliance, which carried a Nemco Welding Alloys letterhead, showed it was dated September 20, 1979, suggesting it was specially generated and not on file at Sims Welding Supply. The Certificate of Com-pliance did indicate Heat N-5131 was sold to Sims Welding Supply, but provided no information relative to wire size, Sims purchase order number, shipping date or invoice number.
E.
Manufacturing Process Control (I. Barnes and L. E. Ellershaw) 1.
Inspection 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.
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17 2.
Method of Accomplishment The preceding objectives were accomplished:
Examination of Section XIII Revision 0 of Quality Manual A, which a.
commences on page 24, " Production Control Planning and Manufacturing Order."
b.
Examination of a. above subject matter in Quality Manual B, which commences on page 26.
Examination of Section XIV Revision 0 of Quality Manual A, which c.
commences on page 28, " Manufacturing Control In-Process Inspection."
d.
Examination of c. above subject matter in Quality Manual B, which commences on page 30.
Examination of Section XV Revision 0 of Quality Manual A, which e.
commences on page 31, " Control of Manufacturing Order."
f.
Examination of e. above subject matter in Quality Manual B, which commences on page 33.
g.
Examination of Section XVI Revision 0 of Quality Manual A, which commences on page 32, " Final Inspection and Records."
h.
Examination of g. above subject matter in Quality Manual B, which commences on page 34.
i.
Examination of issued manufacturing work orders (M.d.) for Job No.
1805, Job No. 1349, and M.0. No. 543 in Job No. 2480A with respect to:
(1) Definition and control of sequencing of manufacturing operations to provide for compliance with contract fabrication require-ments.
(2) Compliance with designated hold points.
(3) Performance of all designated inspections and nondestructive examinations.
(4) Evidence of definition of required fabrication inspection and performance consistent with QA program commitments.
(5) Completeness of operation signoff.
l (6) Performance of operations by appropriately qualified personnel.
I f
18 j.
Examination of Quality Manual A,Section XXI, " Inspection Guide and Test Control - Operating Status and Documentation,"
commencing with page 47.
k.
Examination of Quality Manual B, same subject, commencing with page 48.
1.
Examination of Quality Manual A,Section III, " Documentation Control and Data Requirements," commencing with page 2.
m.
Examination of Quality Manual B, same subject, commencing page 4.
n.
Discussions with cognizant personnel.
3.
Findings t
a.
Deviations from Commitment (I. Barnes) l (1) On questioning the Chief Inspector, James E. Richardson',
on September 18, 1979, relative to the use of another in-i dividual's assigned stamp, the following information was provided to the NRC inspectors.
Mr. Richardson stated that on transfer from the MEC Aircraft Products Division to the MEC Nuclear Products Division, his first major task was compilation of G.E. required data packages for Job No.1805.
At that time he initially did not have an assigned stamp.
He stated that the stamp in question, No. 23, was provided to him by an individual named "Duane Soles," for use in com-pilation of the data packages for Job No. 1805. This indi-vidual is not currently employed by MEC and was the former Production Control Supervisor in the MEC Nuclear Division.
How a Production Control Supervisor acquired control of a current employee's inspection stamp was not established during this interview.
(See Notice of Deviation, Item 9.)
(2) See Notice of Deviation, Item 10.
(3) See Notice of Deviation, Item 11.
(4) The Certified Test Reports of Non-Destruct.ive Examination -
Penetrant, which were supplied to G.E. for Job No.1865, Fuel Grapple Serial No. 6-612-989, indicated that all liquid penetrant examinations of this assembly were performed on January 21, 1979, i.e. each test report was signed as exam-ined by an NDE Level II employee, Robert Cowdrey, with a date O
19 1/21/79 hand entered. Each test report was also approved by the initials "RB" with the date 1/21/79 separately hand entered. The MEC personnel attendance records showed, how-ever, that Robert Cowdrey was not at work on January 21, 1979.
In response to questions relative to the use of Operation No. 10 for liquid penetrant examinations on Job No. 1805, Mr.
Cowdrey informed the NRC inspectors that he was aware of the i
G.E. contract requirements and performed the required exam-inations. Because of M.0, availability problems and awareness j
that the M.O.s did not specify all required examinations, he utilized Operation No. 10 on the Certified Test Reports. At no time during the inspection, however, did Mr. Cowdrey admit awareness that the majority of Job No. 1805 was fabricated without issue and use of applicable M.O.s.
(See Notice of Deviation, Item 12).
4 (5) Review of Certified Test Reports of Non-Destructive Examination - Penetrant, which had been supplied to G.E.
for Job No.1805, Fuel Grapple Serial Nos. 6-612-984 through 6-612-989, indicateo 5a the attached method technique data sheets that water washable liquid penetrant, type SKL-W, had been used relative to performance of examinations re-quired by G.E. Drawing Nos. 105D6421, 105D5850 and 166B9100.
The NRC inspector requested to see the Manufacturer's certi-fication for the halogen and sulfur content of the water washable liquid penetrant material used to perform these examinations. The inspector was informed by Mr. Robert Cowdrey, the NDE Level II Inspector who had prepared the method technique data sheets and signed the Certified Test Reports as performing the examinations, that water washable type penetrant had not been used by MEC for these examina-tions. He stated that he must have made an error in prepar-ation of the method technique data sheets, since solvent removable type liquid penetrant had been used. He then pro-duced a can of solvent removable type penetrant, for which certification was on file relative to halogen and sulfur con-tent. No explanation was provided on how such an error could have occurred.
(See Notice of Deviation, Item 13).
b.
Deviations from Commitment (L. E. E11ershaw)
(1) See Notice of Deviation, Item 14.
(2) See Notice of Deviation, Item 15.
20 Job 1805 has twenty-nine (29) ti.0.s (Numbers 436 thru 464) associated with it.
These M.0.s define ninety-nine (99) weld operations in which weld procedure specifications (WPS) are not specified in twenty (20) operations, and revision numbers are not specified for the remaining seventy-nine (79).
Two nondestructive examination operations are defined in which the revision numbers of the procedures are not specified.
Job No. 2480A has one (1) M.0. (number 543) associated with it.
This M.0. has eighty three (83) operations listed, but at the time of this inspection, fifty-six (56) operations had been performed. Of the fourteen welding operations defined to that point, five (5) did not specify the WPS to be used.
(3) See Notice of Deviation, Item 16.
Operations 50 and 90 on M.0. 447 of Job No. 1805 states,
" Weld per ME-WP-4."
Both operations were signed off as having been completed on 1-6-79, by Manule. The immediately following operations (60 and 100) are insoection operations which require the inspector to check per the drawing. Both of these operations were stamped off by Inspector No. 23.
A review of the drawing, 112C2594 Revision 5, referenced on the M.O., shows welding to be accomplished per P50YP101, a General Electric Company Specification entitled " Arc Welding of Carbon and Alloy Steels". The only qualified MEC welding procedure identified by the NRC inspectors to be qualified for use on carbon steel, is ME-WP-7.
The material designation as shown on the drawing is ASTM A-36.
(4) See Notice of Deviation, Item 17.
The following M.O.s (released on 10/19/78) for Job No. 1805 had their initial operations signed off and dated, as follows:
M.0. 436 - 10/16/78 M.0. 439 - 9/10/78 M.0. 442 - 10/10/78 M.0. 452 - 9/15/78 M.0. 456 - 9/10/78 M.0. 457 - 9/10/78 M.0. 458 - 10/15/78 All of the initial operations for the M.O.s above, were signed by Ed.
(5) See Notice of Deviation, Item 18.
4 21 Job 1805, completed and shipped, M.0. 436 thru 464, specifies 197 inspection operations including two (2) nondestructive examinations (NDE) of which four (4) were ncither stamped nor dated, and 190 were not dated.
It also specifies 182 manu-facturing operations in which 25 were neither signed nor dated, and three (3) were not dated.
l Job 1349, completed and shipped, General Electric Company Purchase Order Number 205-AL709 for Feedwater Spargers, M.0. 471 and 473 through 480, ryecifies fif ty-four (54) inspection operations, of which seven (7) were not dated. It also specifies 87 manufacturing operations, of which ten (10) were not dated.
Job 2480A, M.0. 543, which relates to four currently in-process feedwater spargers, specifies 27 inspection oper-ations including 10 NDE operations, of which 14 were neither stamped nor dated, five (5) were stamped and dated, but not for all four (4) feedwater spargers, and one (1) NDE operation (No-400) was signed off and dated by three (3) personnel not qualified for NDE. It also specifies 29 manufacturing opera-tions, of which eleven (11) were neither signed nor dated, five (5) were not signed, one (1) was not signed for three (3) feed-water spargers, and one (1) was neither signed nor dated for two (2) feedwater spargers.
(6) See Notice of Deviation, Item 19.
The final assembly of the Fuel Grapples is shown to have been accomplished on M.0. 436.
Operation 10, dated 10/16/78 and signed by Ed, states in part, " Draw from Stores"....
Operation 10 details approximately 79 subassemblies and major assemblies, in varying quantities, which are to be drawn from stores and utilized in the final assembly. Many of these items required certain manufacturing operations to be per-formed on them prior to being used in the final assembly.
Thus, they also have M.O.s in order for the manufacturing operations to be accomplished.
A review of ten (10) M.O.s for various subassemblies,and major assemblies revealed that they hadn't been manufactured as of the date (10/16/78) shown on M.0. 436 operation 10, which is the time they were supposed to have been drawn from stores.
Operation 20 on M.0. 436 is an inspection operation which states, "Insp: Verify Part No.'s and Amounts". This oper-ation was stamped off as having been accomplished by inspector number 23.
l i
22 i
The following is a list of the ten (10) M.O.s reviewed in detail showing Part Numbers and Names, and the final date shown in the manufacturing operations of that M.0.
In every case, the last two (2) operations on the M.0. are inspect -
check final assembly, and store for Fuel Grapple - Insp. to stores. None of these are dated.
(On or After) i M.0.
Part Number /Name Completion Date 437 769E520 G001, Grapple Tube 1-22-79 438 105D6424G002, Head Grapple 1-4-79 440 105D5162G001, Light, Fuel Grapple 1-17-79 441 105D5849G001, Grapple tube 12-9-78 442 105D5851G001, Grapple tube 12-5-78 444 112C2596G003, Hanger 12-18-78 445 158B8351G001, Mounting Plate 12-11-78 448 921D762G005, Hanger 11-24-78 449 136B1922G001, Air Supply 12-11-78 450 117C4318G002, Mounting Plate 12-3-78 t
Of the twenty-eight (28) M.O.s leading up to the final l
assembly M.O., twenty-three (23) were completed after the
" Draw.from Stores" operation on M.0. 436, thus the records in-dicate they weren't available to be drawn from stores.
(7) See Notice of Deviation, Item 20.
(8) See Notice of Deviation, Item 21.
(9) See Notice of Deviation, Item 22.
(10) See Notice of Deviation, Item 23.
l The following information is relative to the above deviation.
Job No. 2480A is the job number for the four (4) Feedwater i
Spargers being manufactured on M.O. 543.
(a) Operation 110 requires liquid penetrant (LP) examination of the completed welds on the header pipes and reducing tees. Just three (3) of the four (4) were recorded as l
being done, and their identification was not recorded on the M.0.
j (b) Operation 260 requires LP examination of the root passes on 128 adapters welded to the four header pipes (32/
pipe). The M.0. shows just one (1) header was done.
23 (c) Operation 270 requires completion of the weld. The M.0.
shows all four (4) headers were completed, thus preclud-ing LP examination of the root passes in the other three (3) headers.
(d) Operation 280 requires LP examination of the completed welds mentioned in c. above. The M.0. shows just one (1) was performed and it was not identified.
(e) Operation 370 requires tacking of orifice elbow assem-blies to the headers. The quantity shown is thirty (30) which is sufficient for only one (1) header. This operation was completed on 9-8-79.
(f) Operation 390 requires welding the elbow assemblies to the headers (root pass only).
This is shown to have been completed on 9-9-79.
(g) Operation 400 requires LP examination of the root passes.
This was signed off as being completed on 9-8-79, by three unqualified nondestructive-examination personnel.
(h) Operation 410 requires completion of the welds, and this was signed off on 9-9-79 for one (1) header, without any identification as to which header this operation was per-formed on.
(i) Operation 560, the next operation stamped off and dated, requires LP examination of the root passes on the end plates to the header. The M.0. shows that 6 root passes were examined, thus accounting for three (3) headers - i.e.
two (2) end plates per header. This was dated 9-14-79.
There is no identification recorded, as to which headers were examined.
1 In previous ingtances, it was noted that nondestructive examination (NDE) reports were dated after the examin-ation took place, as shown by the M.O.s.
Mr. R. Cowdrey, the NDE Level II examiner, explained that he often didn't have time to complete or fill out the NDE reports at the time of the examination, but he completed them at a later date based upon the information contained in the M.O.s It would appear that there might be some diffi-culty in doing this, based upon the lack of identity on the M.O.s, and the fact that the M.O.s show that all four (4) have not been examined.
24 (11) See Notice of Deviation, Item 24.
(12) See Notice of Deviation, Item 25.
c.
Unresolved Items (L. E. Ellershaw)
(1) Job No. 1349, M.0. 480, had the following anomalies:
(a) Operation 360, requires drawing extension rings from stores. This was stamped and dated 3-21-79.
(b) Operation 370 requires Inspection - verify and record.
This was stamped and dated 3-26-79.
(c) Operation 380 requires locating the extension rings per the drawing. This is not dated.
(d) Operation 390 requires inspection. This is stamped and dated 3-26-79.
(e) Operation 400 requires weld (root pass only). This is not dated.
(f) Operation 410 requires liquid penetrant inspection of the root pass. This is stamped and dated 3-22-79.
(g) Operation 420 requires completion of the weld. This is not dated.
(h) Operation 430 requires LP examination of the weld. This is stamped and dated 3-22-79.
(i) Operation 440 requires drawing end plates from stores.
This is dated 3-24-79.
(2) Throughout M.O.s 436 through 464 for Job No. 1805, numerous operations are dated, showing they were accomplished prior to the completion of preceding operations.
i Job No. 1805 has twenty-seven (27) operations, fourteen (14) of which are welding, signed off by Manule (printed), and one (1) welding operation signed off by Manual (printed).
The welders stamp log identifies just one (1) welder (Manuel Gomez, welder No. 8) whose name contains the word l
"Manuel."
The inspectors questioned Mr. Gomez as to whether or not he ever printed his first name as shown above. His response was, "No.
I have not."
The inspectors asked Mr. Gomez to write his name as he would on documentation at MEC. He responded i
by writing M. Gomez.
25 The welders stamp log showed that he also signs his name Manuel Gomez.
It should be further noted that Job 1805 had 59 printed en-tries shown as Hung, for boch welding and other manufacturing operations. The welders stamp log shows Hung Nguyen, welder No. 10.
Operation No. 490 on M.O. 437 had one printed entry as HNUG.
1 F.
Material Identification and Control (L. E. E11ershaw) 1.
Inspection Objectives The objectives of this area of the inspection were to verify that MEC had implemented the requirements for the identification and control of material, parts, or components in accordance with the Quality Manual and applicable NRC requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Examination of Quality Manual A,Section XII, " Receiving Inspec-a.
tor", including " Manufacturing Material Control", commencing with page 21.
b.
Examination of Quality Manual B, same subject, commencing with page 23.
Examination of Manufacturing Orders (M.O.) for the following Job c.
Nos. and contracts:
(1) Job No. 1805, General Electric Company (GE) contract 282-KF-295, Fuel Grapples.
(2) Job No. 1349, GE contract 205-AL-709, Feedwater Spargers.
(3) Job No. 2480A, GE contract 205-AM191, Feedwater Spargers.
d.
Observation of material identification of components being used on Job No. 2480A.
e.
Discussions with cognizant personnel.
26 3.
Findings a.
Deviation from Commitm-nts (1) See Notice of Deviation, Item 26.
(2) See Notice of Daviation, Item 27.
b.
Unresolved Items None.
G.
Exit Meeting A post inspection meeting was held by the inspectors on September 21, 1979, with the management representatives denoted in paragraph A. above. The inspectors summarized the scope and findings of the special inspection and informed management that documentation review would continue after the inspectors returned to the Region IV office, which could result in additional findings to those presented to them at the exit meeting. The lead inspec-tor additionally emphasized that this was not a routine QA program inspec-tion and because of the number and severity of findings, further enforce-ment actions by the NRC were possible.
Management was advised that the findings of this inspection would be docu-mented in a report and that written responses would be required concerning the specific concerns identified above.
Separate corrective action and steps to preclude recurrence statements were requested to be prepared for each reported finding. Measures to allow identification of proprietary information and the subsequent placement of the report and associated correspondence in the Public Document Room were also briefly discussed.
Management comments were mainly confined to two subject areas, namely 10CFR21 and the changing of welder identity on a welder performance quali-fication radiographic film. The President of MEC stated that he was per-sonally unaware of 10CFR21 requirements being placed on his company until this inspection. The Nuclear Program Manager informed the inspectors that 10CFR21 applicability was added by the General Electric Co. after completion of contract negotiations. He also stated that he had sought clarification of the meaning of the 10CFR21 requirements from the General Electric Co. on several occasions, without ever receiving any clear guidance.
In response to a specific question from the lead inspector, he stated that he had no correspondence or other documen-tation that would support his statements.
The NDE Level II Inspector informed the inspectors that General Inspec-tion Laboratories changed the identify of the welder on the performance qualification radiographic film and not him. His initials were placed
(
on the tab to simply signify that he was aware of the identity change.
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