ML19343B342
| ML19343B342 | |
| Person / Time | |
|---|---|
| Issue date: | 07/28/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19343B333 | List: |
| References | |
| REF-QA-99900039 NUDOCS 8012230249 | |
| Download: ML19343B342 (3) | |
Text
.
Rhine-Schelde-Verolme Zware Apparatenbouw b.v.
(RSV-A)
Docket No. 99900039/80-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on June 16-20, 1980, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
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 accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Deviations from these requirements are as follows:
A.
Paragraph 5.5.3 in Chapter 5 of the QA Manual states in part, "The Managcr QA shall arrange Vendor and Subcontractor Surveys when requested by the Manager Procurement.
"The Manager QA shall assign the Surveyors and provide each Surveyor with applicable Checklists to assure compliance with the ASME Code.
Each Surveyor shall complete the checklist cnd make a written recommendation to the Manager QA.
The Manager QA shall approve or disapprove Vendors and Subcontractors on the basis of Surveyors recommendation and completed checklists and be responsible for the necessary follow-up action.
Contrary to the above, Thyssen Draht A.G. was approved and used as a supplier of welding materials, without accomplishment of the follow-up actions required by the results of a sur":.y performed on June 26, 1979.
(See Details, 3.1.)
B.
The RSV-A corrective action response letter dated August 28, 1979, states in part with respect to Item D of Inspection Report No. 79-01, ".
.The Manager QA issued a Corrective Action Request
. requesting per September 1, 1979:
All welding of temporary attachments to be handled as written in Sub-Chapter 8.1 of the Quality Assurance Manual, that is:
preparation of 1)
Master Traveler with applicable WPS and NDE.
]
2)
Process Sheet with applicable Weld Instruction.
3)
Production Control Drawings if needed.
4)
Welding records, documenting weld material used and welders qualification.
8012230$19
2 Contrary to the above:
1.
Thermocouple clamps were welded to Order No. 30822, Suborder 61005, Piece 0102, Assembly 002/004, for the final inductive postweld heat treatment of the bottom head to lower shell circumferential seam, without stipulation of the applicable WPS to be used in the Master Traveler For Rework.
2.
Welding records, which documented weld material used and welders qualification, were not prepared for this operation.
C.
Paragraph 13.4.1 in Chapter 13, Revision 10, of the QA Manual states in part, "Any nonconformities found during construction by QA department personnel shall be reported on a Nonconformity Report.
The QA dept. personnel issuing the Nonconformity Report (NCR) shall obtain a NCR number from the QA Project Engineer who maintains a log of NCR issuance for each Manufacturing order.
The QA department personnel that prepares the NCR shall enter a holdpoint on the Master Traveler at the sequence where the nonconformity was found thereby stopping work on the item. Copies shall be sent to the Manager QA.
Contrary to the above:
1.
Sequence T-9 on the Master Traveler for Rework (Order No. 30822, Suborder 61005, Piece 0102, Assembly 002/004) was signed off on June 5, 1980, which released the assembly for final inductive local postweld heat treatment, without preparation of a Nonconformity Report and entry of a holdpoint at this sequence relative to an identified I.D. thermocouple location nonconformity.
2.
A Nonconformity Report was not prepared as of June 18, 1980, with respect to Sequence T-10 (Final postweld heat treatment), although the I.D. thermocouples had been identified as not reaching the 1105-1175 F temperature range required by the applicable process specifi-cation, PS-53.24 Revision 0.
The heat treatment cycle had been completed on June 10, 1980, and deferred examination operations had been performed subsequent to the cycle.
D.
Paragraph NB-4231.2 in Section III of the ASME Code states in part,
" Attachments which are welded to component during construction but which are not incorporated into the final component such as.
postweld heat treatment equipment are permitted, provided the requirements.
below are met y
1.
The welding material is compatible with the base material and is certified in accordance with NB-2130.
2.
The attachment weld or the area after removal of the attachment is postweld heat treated in accordance with NB-4600."
3 Contrary to the above:
a.
Incompatible welding material was used to attach thermocouple clamps to the I.D. of Order No. 30822, Suborder 61005, Piece 0102, Assembly 002/004, in that metallographic examination of removed clamps showed that ferritic electrodes had been used to attach the clamps to austenitic stainless steel weld cladding.
b.
0.D. vessel location thermocouple clamp attachment welds were made that were not postweld heat treated to the temperature range required by NB-4600.
(See Details, H.3.a. (2).)
E.
QA Manual Chapter 10.0, paragraph 10.3, states in part, ".
. The Cali-bration Program shall detail:
. Required frequency of calibration for each equipment
. (and) Calibration Records.
. The Manager QA is responsible for issuing the Calibration Program Procedures to all persons who have a responsibility for calibration.
The Manager Plant Engineering and Maintenance shall follow-up to assure that cali-brations are beirg performed within the frequencies established by the Calibration Program." Paragraph 10.5 states in part, " Records of cali-bration shall be maintained... and shall contain as minimum:
Results of calibration.
Contrary to the above, the Manager Plant Engineering and Maintenance did not assure that calibrations were performed within the established fre-quencies, and all results of calibration were not recorded in the records of calibration.
(See Details, G.3.a.).
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