ML19318B206
| ML19318B206 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1980 |
| From: | Barnes I, Ellershaw L, Hunnicutt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19318B191 | List: |
| References | |
| REF-QA-99900047 99900047-80-1, NUDOCS 8006250127 | |
| Download: ML19318B206 (16) | |
Text
.
O VENDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900047/80-01 Program No. 51300 Company:
Westinghouse Electric Corporation Nuclear Components Division, Tampa Plant P. O. Box 19218 Tampa, Florida 33686 Inspection Conducted: March 10-14, 1980 3/N//#O Inspectors:
c-um I. Barnes, Contractor Inspector Date Comp nentsSection II Venc.o
.s ection Branch V
LA cLA D b
LV E. Ellershaw, Contractor Inspector
/Datg' CamponentsSection II Vendor Inspection Branch Approved by:
/[
Y_
$ 8//EO v.
'D. M. Hunnicutt, Chief
Date ConponentsSection II Vendor Inspection Branch Summarv Inspection on March 10-14, 1980 (99900047/80-01)
Areas Inspected:
Implementation of 10CFR 50, Appendix B criteria and applicable codes and standards; including internal audits, review of weld heat treatment, manufacturing process control, review of special welding applications, material identification and control, welding material control, procurement control and corrective action program. The inspection involved 64 inspector-hours on site by two (2) NRC inspectors.
Results:
In the eight (8) areas inspected, no apparent deviations or unresolved items were identified in three (3) areas; the following deviations and unresolved items being identified in the remaining areas:
Deviations:
Internal Audits -- Actions not taken as required by Criterion V of 10CFR 50, Appendix B, paragraph NCA-4134.18 in Section III of the ASME Code and Section 14 of the QA Program Manual, to assure agreed steps to prevent recurrence of a certain internal audit finding had been accomplished as committed.
(Notice of Deviation, Item A.).
l d006250l D
2 Review of Weld Heat Treatment -- Instructions not provided to heat treatment service vendor in accordance with the requirements of Criterion V of 10CFR 50, Appendix B, and paragraph NB-4624, sub-paragraph 3 in Section III of the ASME Code, to assure a gradually diminishing temperature outwards from the controlled circumferential band (Notice of Deviation, Item B.).
Man.facturing Process Control -- Signed Material Review Request and completed MRR forwarded to Records without satisfactory completion of the disposition regarding a certain heater well wall dimension, which is contrary to Criterien V of 10CFR 50, Appendix B, and Section 12 of the QA Program Manual (Notice of Deviation, Item C.).
Proper inspection instructions, as required by Criterion V of 10CFR 50, Appendix B, and Section 12 of the QA Program Manual, not in-cluded on a traveler issued for repair of cladding (Notice of Deviation, Item D.).
Review of Special Welding Applications -- Wording of a WPS, PS 82127 ML, Revision 7, not in accordance with Criterion V of 10CFR 50, Appendix B, and paragraph QW-201.1 in Section IX of the ASME Code with respect to permitting nonessential variable changes in production welding without the required amendment of the WPS or issue of a new WPS (Notice of Deviation, Item E.).
Welding Material Control -- Welding materials not segregated in a holding oven as required by Criterion V of 10CFR 50, Appendix B, and Section 9 of the QA Program Manual (Notice of Deviation, Item F.).
Unresolved Items: Review of Weld Heat Treatment -- Compliance of a local postweld heat treatment instruction, which permitted use of a 250 degree F temperature differential in a 15 ft. interval of weld length during the hold period (for a cycle performed subsequent to repair of a previously postweld heat treated seam), with the requirements of paragraph NB-4624, sub paragraph 3 in Section III of the ASME Code. (Details I,C.3.b. (1)).
Compliance of a local postweld heat treatment sketch, which permitted a 250 degree F temperature differential in a nics '9) ft. interval of weld length during the heating and cooling cycle, with ASME Code requirement for a 250 degree F differential in a 15 ft. interval of weld length to be main.
tained.
(Details I, C.3.b.(2)).
Manufacturing Process Control -- Absence of QA Program requirements with respect to minimizing absorption of moisture by submerged arc fluxes used for welding ferritic materials (Details I, D.3.b.(1)).
Apparent non-submittal required by E-Specification G 953431, Revision 0 of a quality plan addressing design, materials, fabrication, inspection and testing of non-Code and non-nuclear safety items for review and concurrence (Details I, D.3.b.(2)).
t 3
DETAILS SECTION I (Prepared by I. Barnes)
A.
Persons Contacted
- J. E. Turner, General Manager, Nuclear Components Division
- C. M. Ericson, Manufacturing Manager, Tampa Plant
- T. D. Miller, Product Assurance Manager, Tampa Plant
- J. P. Mortara, QA Manager, Tampa Plant
- J. M. Divens, Manager, Shop Operations, Tampa Plant
- J. W. Bradley, Manager, Processes Engineering, Tampa Plant
- J. A. Fertic, Manager, QC/NDE, Tampa Plant R. H. Dunn, QC Records Supervisor, Tampa Plant P. M. Parker, QA Engineer, Tampa Plant J. R Maseda, QA Engineer, Tampa Plant L. A. Malizia, Pre ess Engineer, Tampa Plant M. Soltic. Supervisor, Wcld Training Center
- Denotes those persons attending exit meeting.
B.
Internal Audits 1.
Objectives The objectives of this area of the inspection were to:
a.
Ascertain that a system has been prescribed and documented for auditing, which is consistent with the commitments of the QA Program.
b.
Determine that the system has been properly and effectively implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of Section 14, Revision 2, of the QA Program Manual, a.
" Quality Audits."
b.
Review of Tampa Quality Assurance Instruction (T.Q.A.I.) No.
5.3.1, Revision 0, " Lead Auditor Qualificatioa."
c.
Review of T.Q.A.I. No. 5.3.2, Revision 1, " Internal Audit Qualification."
4 d.
Examination of - dit checklists used to perform the 1979 audits,of the QA Program.
Verification that the audit check lists provided for adequate e.
measurement of departmental compliance with the documented QA program.
f.
Review of team leader qualifications.
g.
Verification of reporting of audit results to responsible levels of management.
h.
Review of follow-up actions regarding implementation of agreed corrective actions for audit findings in the Manufacturing Department.
i.
Review of audit frequencies relative to QA program commitments.
3.
Findings a.
Deviation from Commitment The Manufacturing corrective action response letter of November 29, 1979, to QA stated in part with respect to achieving control of transfer of welders by a weekly computer run, rather than Form TA-00061A required by Standard Division Procedure SDP PQ3-005.1, ".
. The above procedure will be revised by Manufacturing Engineerir.g to incorporate the necessary changes by December 21, 1979."
Contrary to the above, procedure SDP PQ3-005.1 had not been revised by Manufacturing Engineering as of March 12, 1980.
l No follow-up action had been performed by QA to verify accomplishment of this commitment, which was made in response to Audit Finding No. 44 from the 1979 audit of Manufacturing (See Notice of Deviation, Item A.).
b.
Unresolved Items None.
c.
Comment Paragraph 14.5.6 in Section 14 of the QA Program Manual is unclear with respect to definition of both criteria used to assure committed corrective actions are accomplished and major and minor audit items.
5 C.
Review of Weld Heat Treatment 1.
Objective The objective of this area of the inspection was to determine if heat-treatment related to welding is specified and performed in accordance with the Westinghouse Nuclear Components Division, Tampa Plant (WTP) QA program and applicable ASME Code requirements.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Rr 'tw of Section 10, Revision 1, of the QA Program Manual.
b.
Review of WIP local and furnace postweld heat treatment Process Specifications, which had been approved for use with Shop Order TCGT 2211.
Examination of two (2) local and two (2) furnace postweld heat c.
treatment time-temperature charts with respect to compliance with Process Specification requirements.
d.
Verification of review of heat treatment charts being performed by WTP personnel.
e.
Assuring a tracking system was in effect with respect to accumulated component postweld heat treatment time versus test material heat treatment qualification times.
f.
Verification that heat treatment temperature recorders were in an active calibration status.
3.
Findings a.
Deviation from Commitment During March 10-12, 1980, a local postweld heat treatment of the Z seam (Channel Head to Tube Sheet) in Steam Generator Shop Order TCGT 2211 was observed in progress. The heat treatment was being performed by a vendor (Cooper Electroheat) and was necessitated by a weld repair having to be performed, to eliminate a rejectable radiographic indication that was found after per-formance of an original local postweld heat treatment of the Z seam by %TP personnel. The vendor performed the heat treatment with resistance heaters on the outside of the vessel and an approximately two (2) ft. wide band of insulation over the heaters. The inspector was unable to ascertain by observation what, if any, insulation had been applied to the inside surface of the Z seam.
i 1
1
6 Operation 100A-10 on the repair traveler, MRRT 033932, required the heat treatment to be performed in accordance with Process Specification 83032 GY.
A heat treatment sketch also formed part of the traveler, which defined specific thermocouple locations to be used by the vendor.
These locations comprised the following outside diameter locations -- centerline of weld repair, two (2) inches on either side of the repair and at quadrant positions on the Z seam from the weld repair. One (1) inside diameter location was specified, which was on the Z seam underneath the weld repair.
No fc; mal instructions were provided to the vendor relative to required gradients or measurements to be made outwards from the seam.
In addition, paragraph 4.1, sub paragraph 4.1.1 in Process Specification 83032 Gi, Revision 4, states in part, Insulate only if needed to meet the requirements of this specification." With this instruction, the vendor was only required by place sufficient insulation to assure required circumferential gradients around the Z seam were achieved.
(See Notice of Deviation, Item B.).
b.
Unresolved Items (1) The vendor was instructed by the MRRT 033932 heat treatment sketch to commence the hold period when the weld repair region reached the required 1100 - 1150 degrees F temperature range. A 250 degree F maximum differential was permitted between the repair region and the quadrant position ther-mocouples throughout the cycle, precluding the necessity for heating the entire Z seam to the 1100 degrees F minimum temperature required by the ASME Code and PS 83032 GY, Revision 4.
The wording of paragraph NB-4624, sub paragraph 3, in section III of the ASME Code can be interpreted, however, as requiring the entire seam to be heated after a weld repair to the range specified by the Subarticle, i.e.
1100 - 1250 degrees F.
This sub paragraph requires local heat treatment to be performed by heating a circumferential band around the component to a temperature within the specified Subarticle range. The sub paragraph simply states with respect to heat treatment after repair welding, ".
This procedure may also be used for postweld heat treatment after repairs."
The technical basis presented by WTP personnel to support the practice used, consisted essentially of:
7 (a) The seam had been previously postweld heat treated in accordance with ASME Code provisions and, with the exception of the repair region, did not require to be heated again into the range specified by the Subarticle.
(b) A safe temperature differential was used, in that the ASME Code does permit a gradient of 250 degrees F in any 15 ft. interval of weld length during the heating and cooling cycle.
This item is considered unresolved pending specific evidence being made available, that this practice is considered by ASME to meet the intent of paragraph.VB-4624, sub paragraph 3.
(2) The MRRT 033932 heat-treatment sketch permitted a gradient of 250 degrees F between the weld repair region and any of the quadrant position thermocouples on the Z seam. The outside diameter of the steam generator Z seam was 135 inches, which produces an approximate spacing of nine (9) feet between adjacent thermocouples. ~Ihe sketch thus permitted a gradient of approximately 28 degrees F/ft from the repair region to the adjacent quadrant thermocouples.
Section III of the ASifE Code permits a temperature differential of 250 degree F in any 15 ft. interval of weld length during the heating and cooling cycle, which corresponds to a gradient of approximately 17 degrees F/ft. The ASME Code does not provide, however, any guidance on the manner of interpretation of the permitted 250 degrees F temperature I
differential in a 15 ft. interval of weld length. The last treatment cycle in question produced a maximum actual differential of 190 degrees F between the weld repair region and an adjacent quadrant thermocouple. The maximum temperature differential between the weld repair region and the furthest quadrant thermocouple, i.e. a distance of approximately 18 feet, was 220 degrees F.
Depending on the manner of interpretation of the ASME Code requirement, this heat-treatment cycle can be regarded as eithez in violation of the ASME Code, or in compliance,
]
with respect to developed gradients.
This item is considered unresolved pending:
1 (a) Verification that the thermal stresses created by the 190 degrees F differential in a distance of nine (9) feet are analytically acceptable, i
t 8
(b) Specific clarification being obtained of ASME Code requirements relative to developed gradients in postweld heat treatment.
D.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
A system had been established for the control of manufacturing processes, which was consistent with applicable regulatory and ASME Code requirements.
b.
The system was implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 6, Revision 0, of the QA Program Manual,
" Manufacturing Planning and Control."
b.
Review of Section 8, Revision 2, of the QA Program Manual,
" Inspection."
Review of Section 12, Revision 3, of the QA Program Manual, c.
"Non-Conformance Control."
d.
Examination of material, fabrication and QA Program requirements for steam generator manufacture in Westinghouse General E-Specifications G 953431, Revision 0 (Marble Hill and Comanche Peak Unit 2), and 952341, Revision 1 (South Texas Project).
e.
Examination of Shop Order PCGT-2384, Assigned Item BB, steam generator channel head assembly traveler documentation with respect to:
(1) Definition and control of sequencing of manufacturing operations to provide for compliance with ASME Code fabrication and examination requirements.
(2) Compliance with any designated hold points.
(3) Completeness of operation signoff.
(4) Evidence of fabrication inspection definition and perfoonance consistent with QA program commitments.
9 (5) Resolution of identified nonconformances in a manner consistent with ASMI Code and QA program requirements.
f.
Verification that a welder observed performing repairs to cladding on manway bores had been appropriately qualified for the welding process used and specific application.
g.
Review of Shop Order THPT 2161, Assigned Item 02, pressurizer lower head assembly traveler documentation with respect to:
(1) Evidence of performance of all ASME Code required liquid penetrant examinations of heater well to lower head welds.
(2) Use of only welders who had been appropriately qualified for the heater well to lower head and heater to heater well welds.
(3) Resolution of identified nonconformances in a manner consistent with ASME Code and QA program requirements.
h.
Observation of shop manufacturing practices.
3.
Findings a.
Deviations from Commitment (1) See Notice of Deviation, Item C.
(2) On March 12, 1980, the inspector observed gas tungsten are repair welding operations being performed to clad manway boxes in Assigned Item BB, Shop Order PCGT-2384.
Review of traveler documentation for the assembly, showed the repairs were being performed using the traveler issued to correct a nonconformance, MRR 033494. This nonconformance had been identifiad as a result of the surface condition of 4
the original shielded metal are cladding being determined to be too rough to perform an acceptable liquid penetrant examination in accordance with process specification (PS) 84350 JA.
The repair traveler required.ne following sequential operations: Verify MRR No. entered; PT per 84350 JA before repair; Weld repair per PS 82121 UR or PS 82127 ML; Record welding; Prep for PT; PT 84350 JA; Continue normal cycle.
The repair welding operations observed by the inspector were in two (2) categories; cosmetic in accordance with the. nature of the reported nonconformance and also repairs made as a result of the discovery of rejectable penetrant indications in the cladding.
O 10 The repairs observed by the inspector were being performed using the gas tungsten are WPS, PS 82127 ML.
Paragraph 11.2 in PS 82127 ML, Revision 7, states with respect to cladding repair, " Prior to weld repair per the applicable paragraph of this specification, Quality Control will check the depth of the grindout."
Sub paragraph 11.2.1 states, "If the grindout is not within 1/32" of the base metal the weld-repair does not require a post weld heat treatment." Sub paragraph 11.2.2 states, "If the grindout is within 1/32" of the base metal or if the base metal has been exposed but not to a depth greater than 3/32" or 10%, whichever is the lesser, and the individual grindout area is less than 10 square inches, a non post weld heat treated weld repair per the applicable section of PS 82121 XN is permissible.
However this is to be done only if the component cannot be feasibly PWHT'd per PS 83032 GT."
As noted above, the repair traveler did not require Quality Control to check grindout depths in the cladding and records were not made available to confirm the checks were, in fact, being performed by QC Technicians at the time of liquid pe.eetrant examination acceptance of cavities.
Examination of the applicable QA document relative to cladding measure-ment, T.Q.4.I. No. 1.10.4, Revision 0, showed that the document required measurement of clad thickness only on cladding deposited by automatic processes. No programmatic requirement for measurement of clad thickness for cladding deposited by manual processes was located. To establish adequacy of cavity depths with respect to the heat treatment and special repair provisions of PS 82127 ML, would necessitate knowledge of original clad thickness. The inspector was subsequently informed that the original clad thickness had been checked by Quality Control personnel for this specific case, although not programmatically required to be done.
Review of the entire traveler documentation for the assembly showed that the final scheduled postweld heat treatment had been previously performed, which increases the significance of absence of documented traveler repair control provisions.
1 (See Notice of Deviation, Item D.).
b.
Unresolved Items (1) During the inspection, the inspector observed a full bag of Linde 0091 submerged are flux in the B600 flux storage area, which had been accidentally torn, thereby exposing the
.,9
i 11 flux to atmosphere.
Review of WTP process specifications showed no programmatic requirements with respect to minimizing absorption of moisture in fluxes used for ferritic welds. The inspector was verbally informed that this flux was not particularly hygroscopic.
Insufficient time was available during the inspection to ascertain the technical basis for the absence of any formalized controls relative to storage practices for this type of submerged are flux.
This item is considered unresolved pending either development of appropriate controls or submittal of technical data to support current practices.
(2) Note 1 in paragraph 3.1 (Design Basis) of E-Specification G953431, Revision 0, " Reactor Coolant System Model D-5 Steam Generator, " states, "For those items designated as
' Code Class-not applicable' and safety classification as NNS (Non-Nuclear Safety) the design, material, fabrication, inspection and testing.shall be to applicable industry codes and standards. The manufacturer shall prepare and submit a quality plan for review and concurrence."
The inspector requested to see a copy of the quality plan i
and evidence of WTP customer review and concurrence for the referenced E-Specification, which was applicable to the Comanche Peak Unit 2 and Marble Hill sites. Discussion with QA management failed to indicate a quality plan, as such, had been submitted for these items.
Insufficient time remained in the inspection to fully establish the correct status of this subject and will thus be con-sidered as and unresolved matter pending addtional review.
E.
Review of Special Welding Applications 1.
Objective The objective of this area of the inspection was to determine if special welding applications such as tube to tube sheet welds and cladding conformed to the requirements of the WTP QA program and the additional requirements established by ASME Code Sections III and IX.
2.
Method of Accomplishment The preceding objective was accomplished by:
o 12 Review of Section 9, Revision 2, of the QA Program Manual, a.
" Welding Qualification And Control."
b.
Observation of tube to tube sheet welding operations on Shop Order CDGT 2111 and review of applicable process specification, PS 82127 WX.
Observation of shielded metal are Inconel 182 overlay operations c.
and review of applicable process specification, PS 82121.
d.
Observation of gas tungsten are repair operations to shielded metal are cladding on Shop Order PCGT-2384 and review of applicable process specification, PS 82127 ML.
3.
Findings a.
Deviation from Commitment Table 1 in PS 82127 ML, Revision 7, defines applicable aelding parameters to be used with the gas tungsten are weldinr process, including ASME Code amperage and filler wire size noner ential variables. A footnote to this Table states, however, "This table is to be used as a guideline only; parameter settings may vary according to the requirements of the joint / weld being made."
Use of such language permits changes in amperage and filler wire size to be made in production welding, without performing amend-ment of the WPS or issue of a new WPS required by QW-201.1 in Section IX of the ASME Code.
(See Notice of Deviation, Item E.).
b.
Unresolved Items None.
c.
Comment Insufficient time was available in the inspection to perform a comprehensive review of this subject. Additional review will be accomplished during a future inspection.
F.
Exit Meeting
-A post inspection exit meeting was held on March 14, 1980, with the management representatives denoted in paragraph A. above. The inspectors summarized the scope and findings of the inspection. Management acknowl-edged the statements made by the inspectors and had no specific questions regarding the findings as presented to them.
i
13 DETAILS SECTION II (Prepared by L. E. Ellershaw)
A.
Persons Contacted R. H. Anderson - Manager, Field Reliability and Quality Assurance S. G. Anderson - Senior Buyer A. Arnold - Stores Attendant A. M. Bandman - Manager, Materials Procurement M. Barth - Quality Assurance Engineer W. H. Beckley - Senior Quality Assurance Engineer W. F. Courtney - Senior Quality Assurance Engineer C. Doniel - Supervisor, Receiving and Storage R. Dunn - Supervisor, QA Records K. L. Fox - Manufacturing Supervisor J. S. Young - Field Service Engineer B.
Material Identification and Control 1.
Objectives The objectives of this area of the inspection were to verify that WTP had implemented the requirements for the identification and control of material in accordance with the QA Program Manual and applicable NRC and ASME Code requirement.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Program Manual Section 7.0, " Material Identification and Handling."
b.
Review of Steam Generator Final Major Parts Lists.
c.
Review of Pressurizer Final Major Parts Lists.
j d.
Review of Transfer of Parts on Components Requests.
e.
Observation of parts / components for identification, and a review of Test Number Logs in Receiving Inspection to verify that identification.
f.
Review of QA records for steam generator tube bundles to verify the accuracy of tube identification in which certain tubes had been transfered from other Shop Orders.
e 14 g.
Observation and follow-up on temporary attachment identification.
h.
Discussions with cognizant personnel.
3.
Findings Within this area of the inspection, no deviations from commitment or unresolved items were identified.
C.
Welding Material Control 1.
Objectives The objectives of this area of the inspection were to verify that WTP had implemented the requirements for the control of welding materials in accordance with the QA Program Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Program Manual Section 9.0, " Welding Qualification a.
and Control."
b.
Review of standard Division Procedure PQ3-006.3, " Weld Material Control dated March 8, 1980.
c.
Review of Process Specification 83050RM, " Welding Electrode Baking For Nuclear Power Components" dated October 7,1977.
d.
Review of certifications for certain wire / flux combinations.
e.
Review of Acceptable Weld Materials List.
f.
Review of WC-1 form, used to issue welding materials to welders, and observation of welding materials possessed by welders to verify the accuracy of WC-1 forms.
g.
Review certified material test reports of 14 different velding
==terials.
h.
Observation of baking and holding ovens.
i.
Discussions with cognizant personnel.
a e
15 3.
Findings a.
Deviation From Commitment See Notice of Deviation, Item F.
b.
Unresolved Items None.
D.
Procurement Control 1.
Objectives The objectives of this area of the inspection were to verify that WTP had implemented the requirements for procurement control in accordance with the QA Program Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Program Manual Section 5.0, " Control of Purchases and Services."
b.
Review of Purchase Requisitions, Purchase Orders, and Purchase Order Change Notices to verify: quality assurance review; use of approved vendors, and the delineation of special quality assurance requirements.
c.
Review of the Approved Supplier List.
d.
Review records pertaining to vendor quilifications and vendor audits.
e.
Review of source inspection records.
f.
Discussions with cognizant personnel.
3.
Findings Within this area of the inspection, no deviations from commitment or unresolved items were identified.
6 O
e 16 E.
Corrective Action Program 1.
Objectives The objectives of this ares of the inspection were to verify that WTP had implemented the requirements for a corrective action, program in accordance with the QA Program Manual and applicable
.VRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Program Manual Section 13.0, " Corrective Action."
b.
Review of open and closed corrective action reports (CAR) generated during 1979 and 1980.
Verification of CAR distribution, responses, follow-up, and c.
review and acceptance by quality assurance.
d.
Review analysis reports relative to Material Review Requests (MRRs), and radiography defects.
Discussions with cognizant personnel.
e.
3 Findings Within this area of the inspection, no deviations from commitment or unresolved items were identified.
_