ML19312E075
| ML19312E075 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1980 |
| From: | Kelley W, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19312E070 | List: |
| References | |
| REF-QA-99900214 99900214-80-1, NUDOCS 8006030167 | |
| Download: ML19312E075 (10) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900214/80-01 Program No. 51300 Company:
Anderson-Greenwood and Co.
5425 South Rice Avenue Houston, Texas 77081 Inspection Conducted: March 3-5, 1980 Inspectors:
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/d'[d Wm. D. Kelley, Contra'cfor Insppptor Date ComponentsSection I V
Vendor Inspection Branch 1$
o/kdbo D. E. Whitesell, Chief Date ComponentsSection I Vendor Inspection Branch
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Approved By:
D. E. Whitesell, Chief Date ComponentsSection I Vendor Inspection Branch Summary Inspection on March 3-5, 1980 (99900214/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix 3 and applicable codes and standards including, design and document control - design verification, manufacturing process control, control of special processes -
forming and bending of pressure retaining materials, and training qualifi-cation of personnel performing special processes. Also performed a general review of vendor's activities and conducted exit interview.
The inspection involved thirty-six (36) inspector-hour on site by two (2)
NRC inspectors.
Results: In the five (5) areas inspected, no deviations or unresolved items were identified in three (3) areas. The following were identified in the remaining two (2) areas.
Deviations:
Process Inspection-Visual Inspection (Details, paragraph G) Contrary to Criterion V of Appendix B (2) Training and Indoctrination (Detail paragraph D)
Contrary to Criterion II of Appendix B to 10 CFR 50, and the committments of Section 1.7 of the QA Manual.
8006030/Q
2 DETAILS (Prepared by D. E. Whitesell and Wm. D. Kelley)
A.
Persons Contacted Anderson-Greenwood and Company (AGCO)
B. Chin, Design Engineer i
- G. C. Donogan, Quality Assurance Manager C. Nichols, Welding Supervisor
- F. Pizzitola, Vice President, Quality Assurance J. Spector, Product Manager
- Denotes those persons who attended the exit interview (See paragraph H).
B.
General Review of Vendor's Activities 1.
The ASME issued the following Certificates of Authorization to AGC0 to use their symbol:
Certification No.
Symbol Product N-2203 N
Class 1, 2, & 3 valves N-2204 NPT Class 1, 2, & 3 valve parts, appurtenances and piping sub-assamblies N-2205 NV Class 2 & 3 pressure relief valves These certificates expire on August 4, 1981.
2.
The authorized inspection agency is Hartford Steam Boiler. The authorized nuclear inspector is an itinerant inspector.
3.
AGCO's contribution to the nuclear inductry represents approximately seven percent (7%) of its total workload.
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l C.
Design Computer Program Verification 1.
Objectives The objectives af this area of the inspection were to verify that:
Procedures had been prepared and approved by the vendor to a.
prescribe a system for design computer program verification which is consistent with NRC rules and regulations, and the vendor's commitments in the ASME accepted Quality Assurance
- Program, b.
The design computer program verification procedures are properly and effectively implemented by the vendor.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
Review of the ASME accepted Quality Assurance Manual a.
Revision B, (1) Section 3, " Design Control," and (2) Section 4, " Document Control,"
to verify that the vendor had established procedures to prescribe a system for design verification.
b.
Reviewed the documents referenced in paragraph a. to verify that:
(1) They had been prepared by the designated authority, approved by management, and reviewed by QA.
(2) They contained measures to verify the s.dequacy of i
design, require documented results of the design verification, required the design verilication to consider the importance to safety, identify the method of performing the design verification, identify items l
to be addressed during the design review, and prescribes the requirements for performing verification bf alternate calculations, oc by qualification test.
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4 c.
Review design verifications:
(1) N05-9025-114, "YPCB Bellows Sealed Globe Valve.
, and (2) N05-9025-107, " Seismic Analysis - Category 1 Active Inline 3NPS BWE Class 1500 Maximum WYE Pattern Valve,"
to verify that the design verification procedures are being implemented.
d.
Interviews with personnel to verify that they are knowledgeable in the procedures applicable to design verification.
3.
Findings a.
The inspector verified that:
(1) The vendor did not use a design computer program; however procedures had been prepared and approved by the vendor prescribing a system for design verification which is consistent with NRC rules and regulations, and the vendor's commitments in the ASME accepted Quality Assurance Program, and (2) The design verification procedures are properly and effectively implemented.
b.
Within this area of the inspection no deviations or unresolved items were identified.
D.
Training - Qualification of Personnel Performing Special Processes, 1.
Objectives The objectives of this area of the inspection were to verify that:
The vendor's qualification of personnel performing special a.
processes, other than welding, meets NRC rules and regulations and the ASME accepted Quality Assurance Program.
b.
All personnel performing special processes are qualified in accordance with the ASME accepted Quality Assurance Program.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
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5 Review of the ASME accepted Quality Assurance Manual a.
Revision B; (1) Section 1.7 of the QA Ma~nual; " Indoctrination and Training."
(2) Section 3, " Design Control,"
(3) Section 11, " Heat Treatment Control Process,"
i (4) Section 12, " Nondestructive Examination," and i
(5) Section 16, " Vendor Surveillance,"
to verify that the vendor had established procedurer for the control and adminirtration of personnel performing : raining and including special processes training, examination qualifi-cation and certification.
b.
Review of the sections of the Quality Assurance Manual referenced in paragraph a., to verify that they are cGasistent with ASME Code and ASNT Recommended Practice No. SNT-TC-1A requirements for the level of qualiification, education and experience levels, written examinations, and practical examinations for certification, period visual acuity and
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color vision examination, and periodic recertification.
Also the vendor had established procedures for training, i
indoctrination, and qualification of personnel performing j
special processes.
Reviewed the training, examination, and certification records c.
of; (1) Assemblers tad Testers, (2) Nondestructive Testers, and 1
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(3) Auditors, j
to verify that they have been trained, examined, and certified in accordance with the Quality Assurance Program requirements.
l d.
Interviewed personnel performing the following special i
processes; (1) Product Engineering, and I
(2) Nondestructive Testing, to verify that they were knowledgeable in their assignment and the information in the certification records was accurate.
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Findings a.
From the documents reviewed and discussions with various vendor's personnel it was determined that those individuals responsible for performing quality related activities were receiving periodic training to improve and maintain proficiency in their assigned duties and such training was being documented.
b.
The QA Manual commitments, requires the Director of Quality Assurance to develop outlines of the duties and responsibilities of the individuals, to be used as a guide in their training sessions. The Director of QA is also responsible for controlling the training which are scheduled and conducted under the responsibility of the department heads.
There was no evidence that the Director of QA had prepared c.
and approved the required training guides, or developed procedures for controlling the schedules and conduct of the training under the responsibility of the various department heads.
d.
This is a deviation (See Notice of Deviation Item A).
E.
Control of Special Processes - Forming and Bending of Pressure Retaining Materials 1.
Objectives The objectives of this area of the inspection were to verify that:
The forming and bending of pressr 2 retaining materials were a.
under a controlled system of fabrication which meets NRC rules and regulatione and the vendor's commitments in the ASME accepted Quality Assurance Programs.
b.
The controlled system of forming and bending of pressure retaining materials was effective in assuring product quality.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
Review of the ASME accepted Quality Assurance Manual Revision B, a.
Section 7, " Procurement."
b.
Review of the Approved Vendor's List.
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7 Interviews with personnel to verify they were knowledgeable c.
in the procedures applicable to forming of pressure retaining materials.
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Findings a.
The inspector verified that the forming of pressure retaining materials meets the applicable NRC rules and regulations, and the vendor's commitments in the ASME accepted Quality Assurance Program.
b.
The only forming of pressure retaining material performed for AGC0 valves is the forging of bodies and bonnets which is performed by vendors that have been surveyed, qualified, and placed on the approved vendors list in accordance with the requirements of the ASHE accepted Quality Assurance Program and in accordance with a AGC0 approved procedure.
Within this area of the inspection no deviations or c.
unresolved items were identified.
F.
Control of Special Processes-Welding, Heat Treatment 1.
Objectives The objectives of this area of the inspection were to ascertain whether the vendor's QA program provides for the control of welding and heat treating in a manner which ensures compliance with code and contract requirements. Also that the controls are effectively implemented and are consistent with NRC rules and regulations and the vendor's commitments.
2.
Method of Accomplishment The foregoing objectives were accomplished by:
a.
Review of Section 10; " Welding," of the vendor's QA Manual (QAM), to verify that the program required production welding to be performed by qualified personnel, using qualified procedures, and that procedures had been developed, approved and issued, and were available to the qualified personnel at the various welding stations.
b.
Review of Welding Procedure Specification (WPS) numbers, 05-9030-40, Revision E; for fillet welding P8 to P8 materials 4
using the Gas Tungsten Arc Weld (GTAW) process; WPS-05-9030-106, Revision C, for fillet welding P1 to P1 materials using either the Manual GTAW or Shielded Metal Arc (SMAW);
I WPS 05-9030-131, Revision A, for fillet welding P1 to P8 l
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8 materials using the GTAW process; and WPS, N05-9030-161, Revision 0, for wear resistant overlay (hardfacing) using P6, grade E410 weld metal, on P1 material.
It was noted that the specified preheat, the PWHT time and temperature were consistent with Section III, Table NB 4622.1.1 of the ASME code. The procedure qualification record (PQR) for each WPS was attached to provide objective evidence that the WPS had been properly qualified in compliance with the ASME code requirements.
Review of Section 11, " Heat Treatment Control Process," of c.
the QAM, to verify that the program provided for the control of heat treating processes in a manner that is consistent with the code and contract requirements.
d.
Review of Heat Treat Procedure; No. 05-9075-005, establishing the parameters for solution annealing 304 grade stainless steel; No. N05-9075-008, for PWHT of SA 216 carbon steel castings, to verify that the heating rates, time at holding temperatures and cooling rates and/or media were specified, and were consistent with code and contract requirements.
Discussion with the cognizant vendor personnel.
e.
3.
Findings It was determined that the welding and heat treating operations a.
were being controlled in a manner consistent with the NRC regulations, code requirements, and the vendors commitments.
b.
It was also demonstrated that the vendor has capability to perform limited heat treating operations in-house, however, the heat treating operations are currently being performed by a qualified subcontractor, using the vendor's approved heat treat procedures to control the work.
c.
No deviations or unresolved items were identified in this area of the inspection.
G.
Process Inspection-Visual Inspection 1.
Objectives The objectives of this area of the inspection were to ascertain whether the program provided for visual inspection of machined
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parts, weld surfaces, weld reinforcement, etc, during the manufacturing process.
2.
Method of Accomplishment The foregoing objectives were accomplished by the following:
A Review of the QAM, Section 8, " Process Inspection," to a.
ascertain whether the program identified what, how, and when in process inspections are to be made, and whether procedures have been developed to control visual inspections where required by code or contract requirements.
b.
Review of QAM Section 12," Nondestructive Examinations,"
to ascertain whether the qualification of personnel performing visual inspections are required and the certification of tests including acuity are required.
Review of QAM Section 8, " Receiving Inspection" to ascertain c.
what visual inspections are required in performing the receiving inspection.
d.
Review of Subsection NB, NC, ND, Article 2000, 4000 and 5000 to ascertain those items required by code to be visually examined and determine the acceptance standards.
Review of Section V Article 9, " Visual Examination" to e.
ascertain code requirements concerning visual inspections.
f.
Discussions with the vendor's cognizant personnel.
3.
Findings It was determined that approximately 7% of the valves being a.
manufactured were required by their purchase documents to be designed, manufactured, inspected and tested in compliance with ASME Class 2 and Clasa 3 components.
b.
ASME Section III Subsection NB 4367, and NC 4367 requires each test assembly for manual, machine,and semi automatic welding, to be sectioned to permit the entire underside of the weld to be visually examined by 10x to 15x,ND 4424' states in part,
"...the surface of welds shall be sufficiently free from
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coarse ripples, grooves, overlaps, abrupt ridges, and valleys..
." NC 5370 states in part; "...for specially designed welded seals shall be examined at 10x to 15x...
All surfaces shall be free of cracks, incomplete penetration, incomplete melting of insert on connumable type welds.
10 There was no evidence that procedures had been developed which c.
specified method, aids, illumination and acceptance standards to control such visual examinations.
d.
This is considered a deviation.
See example B in the Notice i
of Deviations.
H.
Exit Interview At the conclusion of the inspection on March 5, 1980, the inspector met with the company's management, identified in paragraph A, for the purpose of informing them as to the results of the inspection.
During this meeting the deviations were discussed and the evidence which supported the finding was identified.
The company's management acknowledged the finding and supporting evidence as being understood, but had no additional comments.
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