ML19318B198
| ML19318B198 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19318B180 | List: |
| References | |
| REF-QA-99900711 99900711-80-1, NUDOCS 8006250119 | |
| Download: ML19318B198 (4) | |
Text
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Leckenby Company Docket No. 99900711/80-01 NOTICE OF DEVIATION Based on the results of an NRC inspection ccaducted on March 17-20, 1980, it appears that certain of your activities were not conducted in accordance with NRC raiuirements as indicated below:
A.
Criterion V of Appendix B to 10 CFR 50 states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantita-tive or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." In addition, customer contracts imposed American Welding Society (AWS) D1.1 and SNT-TC-1A.
Deviations from these requizements are as follows:
1.
AWS D1.1 requires the actual amps, volts, and travel speed be recorded for FCAW and ESW weld procedure qualifications.
Contrary to the above requirements, the amps, volts, and travel speed were not recorded for the qualification of WP-00-12-13-06 which was used in production welding on Contract No. 2808-90.
2.
AWS D1.1 requires the actual number of weld passes be recorded or specified on the weld procedure (WP) for FCAW and SMAW processes.
Contrary to the above requirements, the actual number of weld passes were not recorded on WP-00-20-01-02 which was used in production welding on Contract No. 2808-90.
3.
Contract specification 2808-90 requires weld procedures to be qualified to the thickest material to be used which was four (4) inches for FCAW and SMA processes.
Contrary to the above requirement WP-00-20-01-02 had been qualified for a one (1) inch maximum thickness and later used to produce four (4) inch production welds on Contract No. 2808-90.
4.
ESW WP-00-12-13-06 was qualified to weld in a thickness range of 1.5 to 3.3 inches.
Contrary to the above requirement, WP-00-12-13-06 was used to produce four (4) inch production welds on Contract No. 2808-90.
5.
Both AWS D1.1 and contract specification 2808-90 requires post weld heat treatment of test plates for the ESW welding process procedure qualifications.
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2 Contrary to the above requirement, test plates were not post weld heat treated for the qualification of WP-00-12-13-06 which was used in production welding for Contract No. 2808-90.
6.
ESW WP-00-12-13-06 was qualified with a two (2) electrode technique in accordance with AWS D1.1.
Contrary to the above, WP-00-12-13-06 was used in production welding of Contract No. 2808-90, with a single electrode technique.
7.
SNT-TC-1A requires three types of test examinations for all levels of nondestructive test (NDT) personnel certifications.
Contrary to the above requirements, one (1) NDT technician was certi-fled as a level II MT inspector with no documented evidence of exam-inations.
8.
Customer Contract No. 2808-90-EC requires all NDT personnel to be certified in accordance with SNT-TC-1A.
Contrary to the above requirement, one (1) individual performed acceptance ultrasonic test (UT) on steel plates identified as b56 and F56 without being qualified for UT.
9.
Contract No. 2508-90-EC requires that UT be performed after post weld heat treat.
1 Contrary to the above requirement, the UT report for job numbers 5869 and 0124 were dated two (2) days prior to post weld heat treating.
10.
SNT-TC-1A does not permit a level I NDT inspector to conduct indepen-l dent tests, interpre*,any test results, or write a report of test results.
Contrary to the above requirements, a level I NDT inspector did conduct, interpret, and issue a report for a liquid penetrant (LP) test of module base 3A, item No. B-10 (spent fuel rack) on 5-28-78.
l 11.
SNT-TC-1A requires all NDT personnel to be certified by examination.
l Contrary to the above requirement, one (1) individual was certified 1
on 6-12-79 and performed level II LP inspections without having been
)
examined.
12.
SNT-TC-1A requires all NDT personnel to be certified by examination.
Contrary to the abeve requirement, two (2) persons were certified on 6-12-79 for Level II leak testing and performed said leak tests without examination.
3
- 13. AWS D1.1 requires either acid etching, magnetic particle test (MT),
or LP to define the extent of cracks.
In addition, it requires that 4
sound metal be removed at both ends of the crack prior to weld repairs.
Contrary to the above requirements, neither acid etching, MT, or LP i
was used to define the extent of cracks, nor was sound metal removed prior to making weld repairs for rejection tag numbers 5256, 5325, 5412, 6055, 6056, 6058, 6059, 6069, 5443, 5444, 5445, 5446, and 5447 for Contract No. 2808-215.
14.
Customer contracts require'the vendor to submit its quality assurance (QA) manual for review and approval.
Contrary to the above requirement, the vendor's QA manual was com-pletely revised on 3-10-80, but was not submitted to the customer for review and approval.
15.
Quality Control Procedure No. 7.3 requires rejected material to be identifi-d by a red rejection tag and placed in a segregated area.
Contrary to the above requirements, approximately fifty (50) fixed spannert, for Job No. 6780 were found to have been rejected and placed in segregation but was not identified with red rejection tags.
- 16. Department Operating Procedure No. 515.0 states that manufacturing will not proceed past an inspection operation until said operation is " bought off."
Contrary to the above requirement, it was observed that operation numbers 885 and 890 of manufacturing work order (shop traveler) No.
6738-5 were bypassed. The two (2) operations were for dimensional and LP inspections respectively.
- 17. Contract No. 231073 requires all welding to be performed in accordance with qualified and approved welding procedures.
Contrary to the above requirement, it was observed that welding was being performed on a spacer block type A assembly identified as job number 6738-21 without a qualified or approved welding procedure.
In addition, said welding was being performed with an uncalibrated unit.
- 18. All of the vendor's welding procedures using weld wire, specify a required wire travel range, e.g. 41 to 49 inches per minute for weld procedure No. 701A-6738.
Contrary to the above requirement, the vendor does not verify weld wire travel speeds on a routine basis.
~
4 B.
Criterion XVII of Appendix B to 10 CFR 50 states:
" Sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analysis.
The records shall also include closely related data such as qualifications cf personnel, procedures, and equipment.
Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Records shall be identifiable and retrievable. Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility."
Contrary to the above requirements, the actual inspector for approximately one hundred two (102) NDT reports for contract no. 2808-90-EC could not be identified.
Examples as follows:
1.
LP inspection report no. 5308 showed a photocopied signature of an LP inspector while the inspection report data had been entered at a later date in a different hand wri'.ing.
2.
The NDT inspector's signature had been photocopied for NDT report no. PWS 1-1 while the inspection data was entered later by an uniden-tified person.
C.
Criterion II of Appendix B to 10 CFR 5'J, states in part; "The applicant shall establish --- a quality assurarce program which complies with the requirements of this appendix. This program shall be documented by written policies, procedures or instructions and shall be carried out ---
in accordance with those policies, procedures, or instructions."
Contrary to the above, the Leckenby Quality Assurance Manual, Revision 5, dated March 7, 1980, had not been documented by written policies, procedures and instructions in a manner consistent with the requirements of Appendix B to 10 CFR 50. As an example, the QA manual does not prescribe a system to control design to assure that the design basis and related quality activ-ities are correctly translated into fabrication drawings, bills of materials and procurement documents and that deviations from such standards are 1
properly controlled.
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