ML19343B344
| ML19343B344 | |
| Person / Time | |
|---|---|
| Issue date: | 07/28/1980 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19343B333 | List: |
| References | |
| REF-QA-99900039 NUDOCS 8012230255 | |
| Download: ML19343B344 (13) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900039/80-01 Program No. 51300 Company: Rhine-Schelde-Verolme Zware Apparatenbouw b.v.
Heijplaatstraat 4, P. O. Box 221 Rotterdam, THE NE1HERLANDS Inspection Conducted: June 16-20, 1980 Inspectors:
W 7/w/ro I. Barnes, Chief Date ComponentsSection II Vendor Inspection Branch
[
s 9
hEU 2 eY '/b L. E. Ellershaw, Contractor inspector
/
D(te ComponentsSection II Vendor Inspection Branch Approved by: [ b.
r 7,A.P40 I. Barnes, Chief Date-ComponentsSection II Vendor Inspection Branch
'^
Summarv Inspection or. June 16-20, 1980 (99900039/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards, including action on previous inspection findings, reactor vessel material surveillance program, welding material control, internal audits, control of nonconformances, equipment calibra-tion, and weld heat treatmnt. The inspection involved seventy-four (74) inspector-hours on site by ;wo (2) NRC inspectors.
Results:
In the seven (7) areas inspected, no deviations or unresolved 4
items were identified in four (4) areas, with the following deviations being identified in the remaining areas:
Deviations: Action on Previous Inspection Findings - Approval of Thyssen Draht A.G. for the supply of welding materials without accomplishing b012230254 e
2 the follow-up actions required by the results of a survey performed on June 26, 1979 (Notice of Deviation, Item A.).
Failure to prepare welding records and define applicable WPS to be used for attachment of thermcouple clamps for the local postweld heat treatment of the Black Fox Unit 1 bottom head to lower shell circumferential seam, as committed in the RSV-A corrective action response letter dated August 28, 1979 (Notice of Deviation, Item B.).
Weld Heat Treatment - Failure to issue required heat treatment operation Nonconformity Reports and enter hold points on the Master Traveler (Notice of Deviation, Item C.).
Use of incompatible welding materials and performance of attachment welds in vessel locations not postweld heat treated in accordance with the temperature requirements of NB-4600 in Section III of the ASME Code (Notice of Deviation, Item D.).
Equipment Calibration - Failure to assure performance of calibrations within the established frequencies and record all calibration results (Notice of Deviation, Item E.).
3 DETAILS SECTION (Prepared by I. Barnes and L. E. Ellershaw)
A.
Persons Contacted B. J. A. Sluis, Managing Director
- M. Lodder, Manager, Quality Assurance
- A. Van Haasen, Manager, Manufacturing
- G. J. Van der Vlies, Manager, Projects
- W. N. Van de Poll, Executive Secretary
- P. C. DeRuiter, Manager, Production
- C. Klootwijk, QA Shop Engineer
- J. H. Van Eldik, QA Engineer A. Waasdorp, QA Project Engineer F. Smeets, QA Project Engineer E. Lathouwers, QA Engineer E. Nieuwland, Supervisor, Stress Analysis P. Visser, Calibration Engineer
- L. Dykstra, Authroized Nuclear Inspector, Hardford Steam Boiler Inspection and Insurance Company 2
- Denotes those persons attending the exit meeting.
B.
Action on Previous Inspection Findings (I. Barnes) 1.
(Closed) Deviation (Item A, Notice of Deviation, Inspection Report No. 79-01):
Special welding course not accomplished in accordance with corrective action commitments.
The inspector verified that the special course on Welding Procedure Qualifications was conducted on September 14, 1979, by N. C. Kist Associates, and, that Corrective Action Request Forms and a Corrective Action log were now being used.as the control vehicle to accomplish requests for actions. During this review an additional deviation from commitment was identified relating to corrective action follow-up at vendor facilities, which has been documented as Item A in the Notice of Deviation.
A survey was performed by RSV-A of Thyssen Draht A. G., Hamm, West
)
Germany, on June 28, 1979, to determine their qualification as a vendor of welding wire for ASME Code applications.
The survey identi-fled that the internal audit program was only addressed in the German language version of the QA Manual (and not the English Language version)
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and that external audits of material manufacturers, material suppliers L.
4 and subcontractors were not being performed. A conditional qualified vendor status was transmitted to Thyssen Draht A.G. on July 3, 1980, requiring a 10-week corrective action response relative to performance of vendor audits and revision of the QA Manual to include the internal audit program.
Prior to receiving any response from Thysen Draht A.G., an order was placed on July 5, 1980, for the supply of SNi3Mo wire.
The Corrective Action Request was not returned by Thyssen Draht A.G. until January 10, 1980, owing to the vendor claiming the original transmittal was not received.
In their response, Thyssen Draht A.G. committed to revise the English language version of the QA Manual by February,1980, to be consistent with the German language version. They also stated that because of world wide trading they were unable to perform external audits of material suppliers in most cases. No documented evidence was made available to the inspector to demonstrate that RSV-A had either questioned the adequacy of the latter statement, or, had determined that the Thyssen Draht A.G.
QA program was in compliance with the exception permitted by NCA-3867.4(e) in Section III of the ASME Code relative to auditing of material suppliers.
RSV-A acknowledged receipt of QA Manual revisions from Thyssen Draht A.G. in a letter dated March 13, 1980, with no comment made relative to compliance of the revisions with the outstanding corrective action commitment. Review by the inspectors of the revised QA Manual showed, however, no reference to an internal audit program.
(See Notice of Deviation, Item A.)
2.
(Closed) Deviation (Item B, Notice of Deviation, Inspection Report No. 79-01):
Permitted use of 1G, 2G, 3G, 4G, and SG positions by WPS PS-36.23 Revision 4 for the deposition of austenitic stainless steel overlay, although only qualified in the 1G position.
The inspector verified that the committed revision to WPS PS-36.23 had been accomplished to restrict the buttering application of this procedure on the safe ends of N5 nozzles to the IG position.
A review was also performed of the weld records applicable to the buttering of the Black Fox Unit 1 N5 nozzles to verify the 1G position
.had been used for this operation.
3.
(Closed) Deviation (Item C, Notice of Deviation, Inspection Report No. 79-01):
Performance of production welding that was not in full compliance with the requirements of the applicable welding instruc-J tions.
The inspector verified that a nonconformity trend analysis program was in effect, which provided for monitoring of production welding nonconformities.
The inspector also established that affected personnel had been made cognizant of the identified nonconformity l
5 and informed RSV-A personnel that their response indicated a lack of understanding of the ASME Code with respect to nonessential variables,.
in that Section IX permits changes without requalification only by revision of an existing WPS or preparation of a new WPS.
4.
(Closed) Deviation (Item D, Notice of Deviation, Inspection Report No. 79-01): Welding instructions not provided as required by NB-4231.2 in Section III of the ASME Code with respect to attachment of thermocouple nuts for the control of postweld heat treatment on Order No. 30822, Suborder No. 61000.
This finding has been closed on the basis that a Corrective Action Request was issued, which provided for the welding of temporary attachments in accordance with Sub-Chapter 8.1 of the QA Manual.
The failure to implement these commitments, with respect to the final local postweld heat treatment of the bottom head to lower shell circumferential seal in the Black Fox Unit I reactor vessel is reflected by a deviation from corrective action commitments.
This finding is identified as Item B in the Notice of Deviation.
5.
(Closed) Deviation (Item E, Notice of Deviation, Inspection Report No. 79-01):
Rules not established in Quality Procedure No. 9.09.01 (E), as required by SNT-TC-1A, covering the duration of interrupted service which would require re-examination and re-certification of NDE personnel.
The inspector verified prior to the inspection, that the previously submitted revision to Quality Procedure No. 9.09.01(E), now made suitable provision relative to the duration of interrupted service which would require re-examination and re-certification of NDE personnel.
6.
(Closed) Deviation (Item F, Notice of Deviation, Inspection Report No. 79-01):
Improper signoff of a master traveler operation with respect to measurement of overlay clad delta ferrite content for a welding operation that had not been accomplished.-
The inspector verified by review of the RSV-A response to the 79-01 Inspection Report, that instructions had been issued by the QA Shop Engineer to the QA Shop personnel relative to correct completich of process control documents.
7.
(Closed) Deviation (Item A, Notice of Deviation, Inspection Report -
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No. 79-02): Failure to include process specification revision numbers utilized to accomplish a given manufacturing operation on certain master travelers.
The inspector verified by review of a sample of 25 completed travelers in the QA files and five (5) active travelers in the shop, that process
6 specification revision numbers utilized to accomplish given manu-facturing operations were being entered in master travelers. Review of the RSV-A response to Inspection Report No. 79-02 prior to the inspection, confirmed by examination of the training course attendance roll that actions had been taken to assure QA Department personnel cognizance of QA Manual process control requirements.
8.
(Closed) Deviation (Item B, Notice cf Deviation, Inspection Report No. 79-02):
Failure to perform both documented design reviews of stress reports (sizing calculations) prepared by another company and submit detailed stress analyses of each Black Fox vessel component for buyer's approval a minimum of one (1) year before vessel comple-tion.
The inspector verified that the committed QA Manual revision had been performed and by sampling from Document No. SR-029-30822 Revision 0 (List of Stress Reports), that RSV-A had completed a documented review of the stress reports prepared by CBIN.
It was also established that a Deviation Request had been submitted to the buyer, requesting a change in the submittal requirements for the Black Fox Unit I stress report from one year to one month before shipment.
9.
(Closed) Deviation (Item C, Notice of Deviation, Inspection Report No. 79-02): Material test coupons for the Black Fox Unit 2 vessel steam outlet nozzle safe and forgings were supplied to a sketch, which designated an incorrect thickness location with respect-to applicable ASME Section III requirements.
The inspector verified by review of the Nonconformity Reports appli-cable to the identified error, examination of the re-test data for the forgings and by interview of the responsible QA Engineer,,.that product adequacy had been established and there appeared to b6 no evidence that error had occurred in other than the identified forgings.
10.
(Closed) Unresolved Item (Details, B.3.b.,
Inspection Report No. 79-02):
This item has been resolved as a result of the preparation by RSV-A of Document SR-050. Revision 0 (Local final weld (005/004) heat treat-ment) and SR-051 Revision 0.(Heat treatment of. weld 002/004 of Black Fox 1).
Review of~these documents showed analysis had been performed relative to allowable thermal gradients, which encompassed the inspector's concerns relative to nozzle locations.
11.
(0 pen) Unresolved Item'(Details, D.3.b., Inspection Report No. 79-02):
4 Absence of QA program requirements relative to customer supplied items.
A copy of the General Electric Co. Nuclear Energy Business Group.
Certificate of Authorization for use of the N-Stamp had been received by RSV-A in order to demonstrate that their customer was suitably u
7 qualified to furnish items for incorporation in the Black Fox reactor vessels. No specific requirements relative to customer supplied items had been placed in the documented QA program, however, since the last inspection.
This item remains unresolved pending definition of suit-able requirements in the formal QA program.
C.
Reactor Vessel Material Surveillance Program (I. Barnes) 1.
Objective The objective of this area of the inspection was to ascertain whether RSV-A had implemented a program for the preparation and supply of surveillance material that was consistent with regulatory and con-tractual requirements.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Review of GE letter 78-45-1883, dated November 29, 1978, defining applicable contractual portions of GE Specification Nos. 21A9507, Revision 0, and 22A5599, Revision 0.
b.
Review of GE Specification N21A9507, Revision 0, " Reactor Pressure Vessel (RPV), Surveillance Samples."
c.
Review of applicable paragraphs in GE Specification No. 22A5599, Revision 0, " Surveillance Semples, Reactor Vessel."
d.
Review of Regulatory Guide 1.99.
e.
Review of paragraph 4.7 in GE Purchase Specification No. 21A9477, Revision 7, " Surveillance Program Requirements."
f.
Examination of GE Vessel Irradiation Data Drawing 166B7466, Revision 0.
g.
Examination of RSV-A Drawing ED-165, Revision 3, " Coupon From Core Region Ring 005."
h.
Review of ASTM E185-73, " Surveillance Tests For Nuclear Reactor Vessels."
s 1.
Verification from GE 238 in. BWR-6 Vessel Arrangement Drawing that only shell course 005 was located in the reactor core region.
j.
Verification that correct base material and welding material had been employed for the perparation of surveillance test plates, and the welding parameters used were consistent with vessel fabrication practices.
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8 3.
Findings Within this area of the inspection, no deviations from commitment or unresolved items were identified.
D.
Welding Material Control (L. E. Ellershaw) 1.
Objectives The objectives of this area of the inspection were to verify that RSV-A had implemented the requirements for the control of welding material in accordance with the QA Manual.and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Manual Chapter 8.1, " Welding", Revision 8.
a.
b.
Review of 13 Welding Material Requisition Forms for welding material issued for use on a reactor vessel prior to final PWHT.
Review of Certified Material Test Reports of the above material, c.
to assure all Code required tests had been perfo::med in a PWHT condition.
d.
Verification of required tests for wire / flux combinations.
Observation of welding materials in holding ovens, after release e.
by Receiving Inspection, to assure identify and traceability is being maintained.
f.
Discussion with cognizant personnel.
3.
Findings a.
Deviation From Commitment None.
b.
Unresolved Item s
None.
E.
Internal Audits (L. E. Ellershaw) 1.
Objectives
9 The objectives of this area of the inspection were to verify that RSV-A had implemented the requirements for scheduling, performing, and documenting the results of, internal audits in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Chapter 14.0, " Audits And Corrective Actions",
Revision 9.
b.
Review of actual audit checklists used, and audit reports docu-menting the results of all internal audits performed in 1980.
c.
Review results of annual management audit.
d.
Discussion with cognizant personnel.
3.
Findings a.
Deviation From Commitment None.
b.
Unresolved Item None.
c.
Comment The inspector expressed concern about the adequacy of the internal audit checklist used for Nondestructive Examination (NDE).
The checklist basically addresses qualification of NDE personnel and procedures, and the reporting of results of NDE examinations.
The checklist does not address the actual implementation of performance of NDE examinations.
The observation of technique and/or set-up for all methods of NDE performed by RSV-A, should be addressed in the audit checklist.
F.
Control of Nonconformances (L. E. Ellershaw) 1.
Objectives s
The objectives of this area of the inspection were to verify that RSV-A had implemented the requirements for identifying and controlling nonconformances in accordance with the QA Manual and applicable NRC and ASME Code requirements.
i
10 2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Manual, Chapter 13, " Control of Nonconformities,"
a.
Revision 10.
b.
Review of 10 Nonconformity Reports (NCR) and the associated Master Travelers, to assure the stated disposition had received all required approvals and the NCR numbers had been referenced on the Travelers.
c.
Review of 6 Master Travelers for Rework, associated with the above NCRs, to assure the disposition as stated on the NCR was correctly I
transcribed to the Master Traveler for Rework, and performed.
d.
Discussion with cognizant personnel.
I 3.
Findings a.
Deviation From Commitment None.
b.
Unre' Item None.
G.
Equipment Calibration (L. E. Ellershaw) 1.
Objectives l
The objectives of this area of the inspection were to verify that l
RSV-A had implemented the requirements for the calibration and control of measuring instruments in accordance with the QA Manual and appli-cable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
l a.
Review of QA Manual Chapter 10, " Instrument and Gage Control,"
Revision 9.
b.
Review of Calibration Procedure No. 9.10.01(E), Revision 6, dated June 12, 1979.
c.
Observation of vertaus measuring equipment including; impact testing machine, micrometers, verniers, optical micrometer, tong meters, measuring tapes, and magnaflux yokes.
i.
I J
11 d.
Review of calibration records for the above equipment.
e.
Discussions with cognizant personnel.
3.
Findings a.
Deviation From Commitment j
See Notice of Deviation, Item E.
The following equipment was determined to be out of calibration, as a review of the calibration records showed type equipment, frequency, last calibrition, date, and due date:
Equipment Frequency Last Calibration Date Due Date Verniers, S/N 04-01 Once a Year 4-20-79 week 15, 1980 Verniers, S/N 04-03 Once a Year 4-20-79 week 15, 1980 Verniers, S/N 04-07 Once a Year 4-13-78 week 15, 1979 Verniers, S/N 04-32 Once a Year 9-25-78 week 36, 1979 Magnaflux Yoke ID 362 Once a Year 1-24-79 week 4, 1980 1
Optical Micrometer Once every This equipment was S/N 12-02 2 Years acquired 1-1-74.
The records show it has not i
been calibrated since acquisition.
Measuring Tape Once a Year 4-20-78 week 15, 1979 S/N 05-22 Measuring Tape Once a Year 7-26-78 week 15, 1979 S/N 05-16 Measuring Tape Once a Year 7-26-78 week 15, 1979 S/N 05-12 The following equipment had been calibrated, but the results were not entered into the calibration records:
Magnaflux Yoke, ID 363 l
Master Gages, S/N 95-05, S/N 95-07, and S/N 95-09 b.
Unresolved Item None.
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t
12 H.
Weld Heat Treatment (I. Barnes and L. E. Ellershaw) 1.
Objectives The objectives of this area of the inspection were to verify that RSV-A had implemented the requirements for the control of Postweld Heat Treatment (PkHT) in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Chapter 8.2, " Heat Treatment," Revision 8.
b.
Review of PkHT Procedure PS-53.21, "Postweld Heat Treatment,"
Revision 2, dated October 13, 1976, c.
Review of PkHT Procedure PS-53.24, " Local PhWT of the Circum-ferential Weld Seam between Item 002 (Bottom Head) and Item 004 (Shell Course) by means of Inductive Heating," Revision 0, dated February 19, 1980.
d.
Review of PWHT Procedure PS-53.23 Revision 4, " Local Postweld Heat Treatment of the Closure Seam by means of inductive heating."
e.
Review of heat treatment charts and records for intermediate PkHT, final Ph1T and local PkHT after final PkHT, for the Black Fox Unit 1 Reactor Vessel Lower Head Assembly, f.
Review of thermocouple placements for local PkHT to ascertain thermal 3radient control.
g.
Review of calculations of thermocouple temperature deviations with a subsequent comparison against the allowable deviation as defined in German Standard DIN 43710, which is invoked by Calibration Procedure No. 9.10.01(E), Revision 6, dated June 12, 1979.
h.
Examination of Master Travelers covering the two local PWHT cycles-performed on the Black Fox Unit I reactor vessel with respect to compliance with the QA Manual requirements contained in Chapter 6, Revision 9, " Process Control and Material Identification";
Sub-Chapter 8.1, Revision 8, " Welding"; and Chapter 13, Revision 10, " Control of Nonconformities."
3.
Findings a.
Deviations from Commitment (I. Barnes)
13 (1)
See Notice of Deviation, Item C.
(2) Absence of welding records for attachment of thermocouple clamps, which were used in the performance of the local postweld heat treatment of the Black Fox Unit 1 bottom head to lower shell circumferential seam, precluded direct review of the welding procedure (s) and welding materials used. At the inspectors' request, the clamps, which in error had been attached off location on austenitic stainless steel weld cladding on the I.D. of the vessel, were removed and sub-jected to metallographi; examination. The results of this examination indicated carbon steel clamps had been welded to the cladding using ferritic electrodes.
Thermocouple clamps were welded to various locations on the vessel to provide measurement of developed thermal gradients during the two (2) local postweld heat treatment cycles per-fo rmed.
In the case of the vessel closure seam, weld records were prepared, which showed welding procedure specification PS 39.21, Revision 3, had been used for attachment of the thermocouple clamps.
This WPS was qualified only for use in the postweld heat treated condition.
Clamps were attached at several locations outside of the heated band, which did not attain the postweld heat treatment temperature range required by NB-4600 in Section III of the ASME Code.
(See Notice of Deviation, Item D.)
b.
Unresolved Items None.
I.
Exit Meeting A post inspection meeting was held on June 20, 1980, with the management and Authorized Inspection Agency representatives denoted in paragraph A. above. The inspectors summarized the scope and findings of the inspection. Specific concerns were expressed by the lead inspector with respect to the findings, which are identified as Items B, C, and D in the Notice of Deviation of this report, in that they indicated an apparent QA Program breakdown with respect to both definition of tech-nical requirements and manufacturing process controls. Management were additionally informed, that a recommendation would be made to NRC manage-ment by the inspectors on their return to the U.S.A., to increase the j
frequency of inspections to four (4) month intervals until completion of fabrication of the two (2) Black Fox reactor vessels. Management acknowledged the statements of the inspectors with respect to the findings as presented to them and affirmed the commitment of RSV-A to the quality assurance program.
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