ML19344A814
| ML19344A814 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19344A811 | List: |
| References | |
| REF-QA-99900216 NUDOCS 8008220263 | |
| Download: ML19344A814 (4) | |
Text
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Tubeco, Incorporated Docket L'o. 99900216/80-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on March 24-28, 1980, it appears that certain of your activities were not conducted in accordance with NRC requirements.
Criterien V of Appendix B to 10 CFR 50 states:
" Activities affecting quality shall be prescribed by documented instruc-tions, 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 determin-ing that important activities have been satisfactorily accomplished."
Deviations from these requirements are as follows:
A.
Tubeco Incorporated (TC) Procedure No. W-603, Revision 0, Paragraph 603-4.0, sub paragraph a.1 states in part:
. Attachment material shall be identified by marking, color coding or other suitable means.
Contrary to the above, a welder was observed using a ring of material, which was tack welded to a pipe, for a ground connection, which was not identified by marking, color coding or other i
suitable means.
B.
Tubeco Incorporated Procedure No. W-600, Revision 0, Paragraph 600-4.0, sub-paragraph 14 reates:
"The yellow copy (Form ZRW) shall be retained with the QC copies of that production order."
Contrary to the above, the yellow copy (Form ZRW) was not retained with the QC copies of the production order for Job No. 707500 Dwg 2188 for three (3) temporary attachment welds.
It was also noted that the temporary attachment material could not be identified.
C.
Tubeco Incorporated Procedure No. G-101, Revision 3, Paragraph K.1. (A) states: " Form ZQL shall be initiated by NDE personnel upon discovery of an unacceptable indication within a weld."
Contrary to the above, for ZQL was not initiated upon discovery of i
an unacceptable radiographic indication within a weld on Job No. 312251 Dwg 5798 in that an area of the weld had an excavation and form ZQL was not with the QC copies of the production order.
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D.
Tubeco's corrective action response letter dated June 18, 1979, states, Procedure G-103 will be adhered to.
Tubeco Procedure No. G-103, Revision 1, Paragraph C.2.(E), states in part:
.A total of 10 points shall be required to qualify as an Auditor for nuclear related audits.
Paragraph E.1 states in part:
... The candidate shall pass a written examination.
a grade of 70% shall be considered passing..
Contrary to the above, Procedure G-103 was not being adhered to in that a review of personnel qualification records revealed the following:
1.
Two auditors that were qualified to perform internal nuclear audits did not receive a total of 10 points on the evaluation criteria.
2.
Two auditors did not pass the written examination with the required 70% grade.
E.
The TC corrective action response letter dated August 24, 1979, states in part with respect to Notice of Deviation Item E in Inspection Report No. 79-01:
...A training session will be held with the NDE personnel to review the use of Form ZQL...." The completion schedule status for this commitment was indicated by the letter as alre:dy done. The TC corrective action response letter dated February 4, 1980, states with respect to Item E training session documentation, " Documentation is maintained by a signed record of attendance and minutes of training session."
Contrary to the above, minutes and a signed attendance record were not maintained to document performance of a training session with NDE personnel (other than the NDE Supervisor) on the use of the Form ZQL.
F.
Paragraph 7.3.1. in Procedure No. W-602, Revision 3, states in part:
. Electrodes which remain after a shift shall be returned to ovens...
s Contrary to the above, a 1/8 inch diameter, type E7018 electrode (Code RRR092) was observed on March 25, 1980, in a subassembly for Job No.
707500, Drawing 1931; with the last recorded use of this size and type of electrode on the assembly being March 21, 1980.
G.
Paragraph J-1-2B in Section J-1 of the QA Manual states in part:
Procedure specificiations... shall conform to all requirements of the ASME Boiler and Pressure Vessel Code,Section IX...."
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Paragraph QW-201.1. in Section IX of the ASME Code states in part:
. The WPS information may be presented in any format.
as long as every essential and nonessential variable required by QW-252 through QW-282 is included...."
Contrary to the above, submerged arc WPS sal-1B, Revision 2, and shielded metal arc WPS SMI-1B, Revision 2 did not include use of the welding procedure specifications in applications not requiring postweld heat treatment (an essential variable for both processes), although required by current shop drawings to be used in such a manner.
H.
The TC corrective action response letter dated February 4,1980, states in part with respect to Notice of Deviation Item N in Inspection Report No. 79-01:
. A procedure for establishing and verification of proposed furnace settings by qualified personnel will be established.
." A completion date of March 15, 1980, was given by the February 4,1980, letter for this commitment.
Contrary to the above, a procedure addressing control of furnace settings was not established until March 26, 1980, and as a result of identification of its absence by the inspector.
I.
Paragraph 101-4.3C, sub paragraph 4 in Procedure No. G-101, Revision 3, states: "In space (12) the actual preheat temperature shall be recorded as OK by using a tempil stick or other measuring material or equipment to verify that minimum temperature was met.
The requirement shall be listed on the drawing or the weld procedure."
Contrary to the above, preheat temperatur2 was not recorded as OK in space (12) of the travelers for Job No. 312251, Drawings 645 and 649, to provide verification that the minimum specified preheat temperature of the weld procedure had been met for the production welds in the assemblies.
J.
Paragraph J-1-2B in Section J-1 of the QA Manual states in part:
. Procedure specifications.
. shall conform to all requirements of the ASME Boiler and Pressure Vessel Code,Section IX, and where applicable, shall include the special requirements of Section III, Div. 1, of that Code.
." Paragraph J-1-2C states in part:
All procedures specification shall be qualified and shall be approved by the Tubeco Welding Engineer.
. Contrary to the above, procedure specification SM1-3, Revision 1,
- did not conform to the interpass temperature requirements of section.IX of the ASME Code and was not appropriately qualified in accordance with the postweld heat treatment and impact test requirements, respectively, of Section IX and Section III of the aSME Code (See-Details II, B.14. ).
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K.
Procedure No. W-602, Paragraph 7.2 states in part:
. Sufficient oven capacity shall be provided to store all covered electrodes whose hermetically sealed containers have been opened...."
Contrary to the above, all covered electrodes are not stored in ovens after their hermetically sealed containers have been opened.
Tubeco's practice has been to open the hermetically sealed containers, remove and place in the ovens the needed amount, then tape over the open end of the containers. Thus, there were numerous containers with taped ends observed in the storage area, partially filled with covered electrodes.
L.
Procedure No. W-606.0, Paragraph 606-4, states in part:
.At no time shall rods of two different MTNs be placed in the same oven section, nor shall rods of different specification be placed in the same oven....
Contrary to the above, rods of different specifications, thus different MTNs (Material Traceability Numbers), were mixed together in the same oven section. (See DetailsSection III, Paragraph B.5.).
M.
Tubeco's revised, corrective action response letter dated February 4, 1980, relative to Deviation Notice, Item T states in part:
. Forms which no longer serve a useful purpose will be deleted from the requirements.
A completion date of February 29., 1980, was established.
It was also stated that new forms had been prepared, appropriate to the type of vendor.
The deletion and addition of new forms would require a procedural change (Procedure G-115).
i Contrary to your corrective action commitments, even though new forms had been prepared, Procedure G-115 had not been revised to implement the new forms and to delete those which were no longer serving a useful purpose.
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