ML19344A818
| ML19344A818 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/1980 |
| From: | Barnes I, Hunnicutt D, Roberds H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19344A811 | List: |
| References | |
| REF-QA-99900216 NUDOCS 8008220278 | |
| Download: ML19344A818 (13) | |
Text
,~
V U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900216/80-01 Program No.
51300 Company:
Tubeco Incorporated 123 Varick Avenue Brooklyn, New York 11237 Inspection Conducted: March 24-28, 1980 Inspectors:
//2' ath f/#/8)
H. W. R6berds, Contractor Inspector, Date ComponentsSection II Vendor Inspection Branch E-
~/n /s.c I. Barnes, Contractor Inspector Date ComponentsSection II VenporInspectionBranch i
s.
/ L.
J i
L.\\E. Ellershaw, Contractor Inspector
/ Date ComponentsSection II Vendor Inspection Branch r,
@A 2.---
l'/ /'
Observer:
1.
tO
-t U. Potapovs, Chief Date Vendor Inspection Branch Approved:
3 hA'
-wuAY
/7 O
D. M. Hunnicutt, Chief 7 Date ComponentsSection II Vendor Inspection Branch
)
l 8008220 R ftg
2 Summary Inspection Conducted March 24-28, 1980 (99900216/80-01)
Areas Inspected:
Implementation of 10 CFR 50 Appendix B Criteria and applicable codes and standards including actions on twenty-five (25) previous inspection findings. The inspection involved seventy (70) inspector hours onsite by three (3) NRC inspectors.
4 Results:
In the one (1) area inspected the following deficiency and deviations were identified:
Deficiency:
Compliance with 10 CFR 21-Failure to comply with contractually invoked 10 CFR 21, relative to required posting of Section 206 of the Energy Reorganization Act of 1974 and procedures (Notice of Violation).
Deviations: Actions on previous inspection findings - Identification of temporary attachment material used for a ground connection not in compliance with Criterion V of 10 CFR 50 Appendix B and Tubeco Procedure No. W-603 (Notice of Deviation, Item A); Control of the yellow copy of Form ZRW not consistent with Criterion V of 10 CFR 50 Appendix B and Tubeco Procedure No. W-600 (Notice of Deviation, Item B); Initiation of Form ZQL not consistent with Criterion V'of 10 CFR 50 Appendix B and Tubeco Procedure No. G-101 (Notice of Deviation, Item C); Qualification of Auditors not consistent with Criterion V of 10 CFR 50 Appendix B and Tubeco Procedure G-103 (Notice of Deviation, Item D); Documentation of NDE personnel training not consistent with Criterion V of 10 CFR 50 Appendix B and Tubeco corrective action response letter dated February 4,1980 (Notice of Deviation, Item E); Return of unused electrode not in compliance with Criterion V of 10 CFR 50 Appendix B and Tubeco Procedure No. W-602 (Notice of Deviation, Item F); Certain welding procedure specifications not consistent with Criterion V of 10 CFR 50 Appendix B, Section J-1 of the QA Manual and Section IX of the ASME Code (Notice of Deviation, Item G); a procedure addressing control of furnace settings had not been established as required by Criterion V of 10 CFR 50 Appendix B and Tubeco corrective action response letter February 4,1980 (Notice of Deviation, Item H); Preheat temperature was not recorded on the travelers as required by Criterion V of 10 CFR 50 Appendix B and Tubeco Procedure No. G-101 (Notice of Deviation, Item I); Welding procedure specification interpass temperature did not conform to the requirements of Criterion V of 10 CFR 50 Appendix B, Section J-1 of the QA Manual and Section IX of the ASME Cod / (Notice of Deviation, Item J);
covered electrodes not stored in ovens after hermetically sealed containers are opened as required by Criterion V of 10 CFR 50 Appendix B and Tubeco Procedure No. W-602 (Notice of Deviation, Item K); Segregation of weld rods in storage ovens not in compliance with Criterion V of 10HCFR 50 Appendix B and Tubeco Procedure No. W-606.0 (Notice of Deviation, Item L); Tubeco Procedure G-115 had not been revised to implement new forms as required by Criterion V of 10 CFR 50 Appendix B and Tubeco corrective action response dated February 4, 1980, (Notice of Deviation, Item M).
3 Unresolved Item:
Previously identified deviation dealing with evaluation of suppliers performance. Tubeco's QA Manual appears to be in conflict with the ASME Code regarding audits of NDE and heat treatment subcontractors.
(See DetailsSection III, paragraph B.1.)
4 DETAILS SECTION I (Prepared by H. Roberds)
A.
Persons Contacted
- W. Goldsmith, President
- L. Katz, Director, Quality Assurance
- H. W. Zitzelberger, Assistant Director, Quality Assurance
- T. Maggio, Supervisor of Inspectors S. Lau, Inspector, T-Shop J. Cronise, Manager, Nondestructive Examination P. Toyos, Foreman, T-Shop
- Attended exit meeting B.
Actions on Previous Inspection Findings 1.
(Closed) Deviation (Item A, Notice of Deviation, Inspection Report No. 79-01): The bay inspector did not make certain required entries on the traveler.
The inspector verified that the QA Manual, paragraph P-1-8 had been revised as committed and additional training had been given to the bay inspectors as committed.
2.
(Withdrawn) Deviation (Item B, Notice of Deviation, Inspection Report No. 79-01); No record of examination of fillet welds attaching code plates.
As a result of the ASME Code interpretation III-1-78-238 this deviation is withdrawn.
3.
(Closed) Deviation (Item C, Notice of Deviation, Inspection Report No. 79-01):
L.P. reports were not attached to the traveler after grinding off tack welds.
The inspector verified that procedure G-101 had been revised; however, the paragraph referenced in the corrective action response letter dated June 18, 1979 revised January 25, 1980 does not correspond to the paragraphs of G-101, Revision 3.
To ascertain that welding and inspection of temporary attachment are controlled the following deviations from commitments were identified:
See Notice of Deviation, Item A.
a.
b.
See Notice of Deviation, Item B.
c.
See Notice of Deviation, Item C.
5 4.
(Closed) Deviation (Item R, Notice of Deviation, Inspection Report No. 79-01) External Audits were not performed by auditors qualified in accordance with the procedure G-103.
To ascertain the committed corrective action was initiated the following deviation from corrective action was identified:
(See Notice of Deviation, Item D.)
5.
(Closed) Deviation (Item V, Notice of Deviation Inspection Report No. 79-01) certain Deviation Reports were not completed.
The inspector verified that G-102.2 and G-107.1 had been reviewed and the forms involved were revised. A training session was held on December 12, 1979 with QC personnel.
6.
(Closed) Deviation (Item W, Notice of Deviation Inspection Report No. 79-01) certain CAR's were not initiated to prevent further processing of nonconforming items.
The inspector verfied that QA/QC personnel had been given additional training and procedure G-102.2. and G-107.1. had been reviewed.
C.
Exit Meeting 1.
A post inspection meeting was held on March 28, 1980, at the Tubeco facility in Brooklyn, N.Y.
The results of the inspection were discussed with the management representatives denoted in paragraph A. above.
2.
Mr. Potapovs reiterated the concerns stated in the NRC letter of June 18, 1979 and advised the management representatives that the frequency of inspections would be increased.
3.
The inspectors summarized the scope and findings of the inspection which consisted of verification of corrective action and implementa-tion of steps to preclude recurrence on previous inspection findings.
4.
Management comments in general, were clarification on some aspects of certain findings.
(
6 DETAILS SECTION II (Prepared by I. Barnes)
A.
Persons Contacted L. Katz, Director of Quality Assurance H. W. Zitzelberger, Assistant Director of Quality Assurance L. A. Webber, Manager, Engineering
. G. Deniega, Welding Engineer L. Tune, Welding Engineer A. J. Maggio, Chief Inspector H. Restrepo, QA Technician P. Toyos, Foreman, T-Bay B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Item D, Notice of Deviation, Inspection Report
.No. 79-01): Procedure W-602 not revised in accordance with corrective action commitments, to include either the impact test criteria utilized by NB/NC-2400, or the requirements relative to l
.postweld heat treatment cooling rate.
The inspector verified that Procedure No. W-602, Revision 3, made appropriate provisions for the testing of welding materials
)
in accordance with the requirements of Section III of the ASME Code.
During review it was noted that the impact test acceptance criteria in the procedure, would provide qualification only up to 3/4 inch thickness application. The procedure was further revised by Tubeco (TC) during the inspection to qualify materials for up to 2 1/2 inch thickness application.
i
' 2.
(Closed) Deviation (Item E, Notice of Deviation, Inspection Report No. 79-01): Performance of two (2) weld repair cycles without either utilization of repair traveler form ZQL, or documentation of welding process information for the second repair cycle.
c The inspector verified that committed actions with respect to issue of Form ZQL and revision of Procedure No. G-101 had been accomplished.
During this inspection, a deviation from corrective i
action commitments was identified, which is described in Item E of the Notice of Deviation.
}
3.
(Closed) Deviation (Item F, Notice of Deviation, Inspection Report No. 79-01): Failure to prepare a procedure dealing with nameplates in accordance with corrective action commitments.
.The inspector verified that Procedure No. W-603, Revision 0, had 1
4 o<
m n
,---w w,werm<,,<s.<
ren g s e,--
7 been written to address control of temporary and non-structural attachments. The inspector also established that supplemental commitments were being added to the same log containing the original commitments.
4.
(Closed) Deviation (Item G, Notice of Deviation, Inspection Report No. 79-01): Failure of Bay Inspector to verify use of a welding procedure permitted by the drawing for a certain weld.
The inspector verified that:
The applicable QC drawings had been initiated by the a.
Project Engineer to indicate approval of the use of a submerged are welding procedure; b.
Procedure No. G-114, Revision 2, had been prepared which addressed drawing revisions; A training session had been held with Bay Inspectors, c.
Project Engineers and Shop Foremen on procedures to be followed when requesting production changes to drawings; and d.
An additional welding engineer had been hired to provide closer control of fabrication.
Closure of this item is also considered to close out a similar deviation on this subject, which is identified :s Enclosure Item No. 14 in Inspection Report No. 78-01.
While inspecting this item and observing current shop floor activities, an unrelated deficiency and two unrelated deviations from commitment were identified, which are described, respectively, in the Notice of Violation and in Items F and G of the Notice of Deviation.
5.
(Closed) Deviation (Item H, Notice of Deviation, Inspection Report No. 79-01):
Performance of submerged are welding at a different position to that required by the applicable welding procedure specification.
The inspector verified that:
I The applicable submerged are welding procedure and a.
welding operator had been qualified for the ZG position; b.
The procedure submitted to the client for approval ; and The training sessions on use of welding procedures had c.
been held with Inspectors, Foremen and Project Engineers.
i 8
6.
(Closed) Deviation (Item I, Notice of Deviation, Inspection Report No. 79-01): Acceptance of SA 155 KCF 70 Class 1 pipe from a vendor with weld metal Charpy v impact properties not in conformance with ASME Code requirements.
The inspector verified that appropriate disposition of affected materials had been sought from the client, committed reviews and instructions had been made and a checklist prepared relative to establishing adequacy of certification of incoming materials.
7.
(Closed) Deviation (Item J, Notice of Deviation, Inspection Report No. 79-01): Nuclear Quality Assurance Manual not revised as committed, to provide ASME Code required controls of attachment welds with respect to identified attachment materials and use of qualified welding procedures.
The inspector verified that committed actions had been accomplished with respect to procedure preparation and instruction of personnel.
8.
(Closed) Deviation (Item K, Notice of Deviation, Inspection Report No. 79-01):
Committed additional testing of welding procedure qualifications not performed.
This finding and the original finding on this subject, i.e.,
Enclosure Item 18, Report No. 78-01, have been closed on the basis of additional procedure qualificacion testing performed by TC during 1979. Further concerns about the adequacy of TC welding procedure specifications and their qualification are separately addressed in B. 14 of this Section.
9.
(Closed) Deviation (Item L, Notice of Deviation, Inspection Report No. 79-01):
Procedure' dealing with qualification of weld materials to comply with NB-4330 of the ASME Code not written as committed.
The inspector verified Procedure No. H-305, Revision 0, " Monitoring of Time at Post Weld Heat Treatment," had been issued and implemented and that supplemc-tal commitments were being added to the same log as original coruitments.
10.
(Closed) Deviation (Item M, Notice of Deviation, Inspection Report No. 79-01): Measures not established to assure that ferritic procedure qualification welds had been heat treated at least 80% of the maximum time to be applied to component weld material.
The' inspector verified that:
a.
WPS GT1-1 had been qualified for the postweld heat treated condition;
9 b.
A review had been performed of the other TC welding procedures relative to adequacy of postweld heat treatment qualification status; and Provisions had been made in the heat treatment control c.
procedure for monitoring accumulated postweld heat treatment time with respect to qualifications.
Closure of this finding is also considered to close out Enclosure Item 20 in Inspection Report No. 78-01 on the same subject.
(Closed) Deviation (Item N, Notice of Deviation, Inspection Report 11.
No. 79-01): Performance of heat treatment with rate controllers not set as committed at 25 F/hr. below the maximum code permissible rate.
This finding has been closed on the basis that enmmitted calibration of temperature rate setters in degrees per hour had been accomplished and a procedure addressing verification of furnace settings was made available by the end of the inspection.
The failure to finalize and issue this procedure by the committed date is reflected in a further deviation from corrective action commitments, which is described in Item H in the Notice of Deviation.
(0 pen) Deviation (Item 0, Notice of Deviation, Inspection Report 12.
No. 79-01):
Performance of heat treatments without using either surveyed furnaces or thermocouples in direct contact with the material being treated.
This item will remain open pending completion and review of the committed furnace temperature survey activities.
13.
(Closed) Deviation (Item P, Notice of Deviation, Inspection Report No. 79-01):
Definition of heat treatment requirements and review of heat treatment records not in accordance with Procedure H-303.1.
i The inspector verified that:
A nonconformance report had been prepared and submitted a.
to the client relative to the identified heating rate violation on Drawing A 438; b.
Furnace inspectors had received instructions relative to consulting a QA Engineer when procedure provisions were unclear; and i
Drawings were being furnished by the furnace inspector c.
for use in review of heat treatment charts.
Closure of this finding is is also considered to close out Enclosure
-Item 21 in Inspection Report No. 78-01 on the same subject.
10 14.
(Closed) Deviation (Item Q, Notice of Deviation, Inspection Report No. 79-01): Use of unqualified welding procedures for an application with stipulated Charpy-V impact test requirements and failure to assure compliance with Section III requirements relative to qualification of forming processes.
This finding has been closed on the basis that a Nonconformance Report was written, qualification testing of the bending procedure was performed, a review of Job No. 312261 was made for other affected assemblies and a seminar was conducted on the fabrication require-ments contained in Section III of the ASME Code.
It should be noted that the scope of qualification testing for the bending procedure was restricted to single sets of Charpy-V impact specimens in the strained and unstrained conditions, for three (3) heats of materials. The text of Section III of the ASME Code applicable to the affected contract (Winter 1973 Addendum) can be interpreted as permitting this approach.
This scope, however, would be inadequate for qualification of a bending procedure to a later Edition of Section III of the ASME Code.
It was. additionally established that no specific actions had been taken by TC with respect to the use of welding procedures, which were unqualified for the specific application.
From the comments made in the TC corrective action response letter of August 24, 1979, it would appear that this was based upon having alternate client approved welding procedures, which had been qualified with respect to notch toughness, and used the same parameters as contained in the welding procedures specified by Job No. 312261, Drawing B245.
A review was made of one (1) of the welding procedures, SM1-3, which was indicated by the TC letter as being qualified with respect to notch toughness, with the following examples of deviation from commitment being identified:
a.
Interpass Temperature 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...
Table QW-253 identifies an increase in the specified maximum inter-pass temperature as a supplementary essential variable for the shielded metal are welding process when notch toughness properties are applicable.
11 Contrary to the above, WPS SM1-3, Revision 1, did not include the interpass temperature supplementary essential variable, in that a minimum value rather than the maximum permissible temperature was specified.
It was additionally noted that the referenced Procedure Qualification Record (PQR) No. 18 also identified a miniana interpass temperature, precluding verification of the actual qualification temperature of the WPS.
b.
Postweld Heat Treatment Table QW-253 in Section IX of the ASME Code identifies QW-407.1 as an essential variable for the shielded metal are welding process. QW-407.1 states in part:
.A separate PQR is required for each of the following postweld heat treatment conditions specified in the WPS.
(a) no postweld heat treatment (b) post-weld heat treatment below the critical range.
Contrary to the.above, a PQR was not provided for the postweld heat treatment condition specified in WPS SM1-3, Revision 1; i.e. the WPS specified a postweld heat treatment below the critical range but was supported only by a PQR performed without postweld heat treatment.
c.
Notch Toughness Paragraph NB-4335.1, sub-paragraph (b), in Section III of the ASME Code states in part:
"...The impact test requirement and acceptance standards for welding procedure qualification weld metal shall be the same as specified in NB-2330 for the base material to be welded or repaired...
Paragraph NB-2332, sub paragraph (a) states in part:
Pressure retraining material... for piping.
. shall be tested as required in (1) and (2).
(1) Test three C specimens y
at a temperature lower than or equal to the lowest service temperature. All three specimens shall meet the requirements of Table NB-2332-1.
Table NB-2332-1 requires a C lateral y
expansion value of 25 mils for a wall thickness range of over 3/4 in. to 1 1/2 in.
Contrary to'the above, WPS SM1-3, Revisica 1, indicated a permitted base metal thickness range of 3/16-1 1/2 inch, although the supporting PQR showed weld metal C lateral y
expansion values of 30, 26 and 23.
(See Notice of Deviation, Item J).
12 DETAILS SECTION III (Prepared by L. E. Ellershaw)
A.
Persons Contacted L. Katz, Director, Quality Assurance V. Patel, Welding Supply Clerk H. W. Zitzelsberger, Chief Quality Engineer B.
Action on Previous Inspection Findings 1.
(Closed) Deviation Items (Report No. 79-01):
This item dealt with your failure to audit a heat treatment vendor.
Tubeco has implemented their committed corrective action in that the heat treatment vendor has been audited and the QA Manual has been revised.
However, we do have concerns relative to the wording in QA Manual Section G-1, paragraph G-1-4.E, which states in part:
. Vendors of Services who do not control the traceability of materials (e.g.,
NDE, cold bending, heat treatment, painting or pickling, machining, etc.) may be evaluated annually in lieu of an on-site audit, provided
.a triannual Survey is performed.
This appears to be in conflict with ASME Code Section III, Article NCA-3661 which states in part:
"...The NPT Certificate Holder shall be responsible for surveying, qualifying, and auditing the Quality Systems Programs of suppliers of subcontracted services (NCA-3125) including nondestructive examination contractors ~, Material Suppliers, and Material Manufacturers.
Therefore, we now consider this to be an unresolved item.
2.
(0 pen) Deviation Item T (Report No. 79-01):
This item dealt with the vendor audit program not being consistant with the QA Manual commitments. The inspector found that contrary to the corrective action commitments in your letter dated February 4, 1980, the forms have not been deleted from the requirements.
Therefore, a new deviation against corrective action commitments has been identified.
(See Notice of Deviation, Item M.)
3.
(0 pen) Deviation Item L (Report No. 79-01): This item dealt with nonconformance reports and the use of repair travelers.
This item shall remain open to allow you to respond to our letter of March 20, 1980, which requested you to provide a completion date regarding your verbal commitments during our meeting on March 7, 1980 L
13 4.
(Closed) Deviation Item X (Report No. 79-01):
This item dealt with the failure to incorporate procedural requirements in purchase orders for welding materials with delta ferrite requirements.
Tubeco has implemented their committed corrective action in that the procedure (W-602) has been revised, and purchase orders do comply with these requirements.
5.
(Closed) Deviation Item Y (Report No. 79-01):
This item dealt with two different lots of 1/8 inch type 7018 electrodes, identified with the same MTN.
Tubeco has implemented the committed corrective action in that Procedure W-602 has been revised (March 12, 1980), and a new procedure (W-606, " Mapping of Covered Electrode Storage") was developed and issued on March 18, 1980.
However, during reinspection of this area, two new deviations from commitment were identified.
(See Notice of Deviation, Item K and L).
The following information is relative to Item L.
Oven No. 6, identified as containing 5/32" and 3/16" type 7018 electrodes, MTN 9I 9688E and MTN 9F 7677E respectively, also contained twelve 3/16" type 9018 electrodes mixed in with the 3/16" type 7018 electrodes.
L