ML19344F389
| ML19344F389 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/1980 |
| From: | Sutton J, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19344F374 | List: |
| References | |
| REF-QA-99900109 NUDOCS 8009150217 | |
| Download: ML19344F389 (14) | |
Text
-
(~f
' \\
,s U.S. NUCLEAR REGUIATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900109/80-01 Program No. 51300 Company: Eittsburgh - Des Moines Steel Co.
Eastern Division, Neville Island Pittsburgh, Pennsylvania 15225 Inspection Conducted: March 24-28, 1980 Inspect k
JJ//4/M s-J. W. Sutton, Contract'or Inspector Date ComponentsSection I Vendor Inspection Branch e/. -
I/l o J / 4 /A d P.
E'.
Whitesell, Chief
~Date
(;omponentsSection I Vendor Inspection Branch
/)s r
Approved by: A.
e e/]
S//4//$r D. E. Whitesell, Chief Date ComponentsSection I Vendor Inspection Branch Summary Inspection on March 24-28, 1980 (99900109/80-01)
Areas Inspectad:
Implementation of 10 CFR 50, Appendix B and the applicable codes and. standards, including the vendor's action on previous inspection findings; follow-up of reported construction deficiencies to assess cause, corrective action, and generic impact. Review of QA Program (continuing)
Authorized Nuclear Inspection Interface, and welding procedures.
Results:
In the five (5) areas inspected no deviations or unresolved items were identified in two (2) areas. The following were identified in the remaining three (3) areas. Two inspectors spent fifty siz_(561 inspector hours, 2009150 N
2 Deviations:
Control of Spect.al Processes, welding procedures:
1.
Documentation of installation and remwal of temporary attachments not.being documented on the Fabrication Check List (FCL).
(Notice of Deviation, Item A).
2.
Welders not maintaining electrical characteristics of the welding procedures.
(Notice of Deviation, Item 3.)
Unresolved Items:
1.
Reporting requirements and documentation of the. Corporate QA auditor activities should be classified.
(Details Section C.3.b).
2.
Lack of a policy statement that the Corporate QA manual is in com-pliance with the requirements of 10 CFR 50/N.45.2. (Details Section.C.3.b.(2)).
3.
Correlation of the electrical requirements of Welding Procedure Speci-fication (WPS) and Procedure Qualification Record (PQR) requirements of Procedure 68-4 is to be reviewed for consistency - the present documents do not record the same electrical parameters.
3 DETAILS SECTION I (Prepared by J. W. Sutton)
A.
Persons Contacted
- D. Davis, QA Manager (Plant)
- G. C. Harpere, Eastern Division Manager
- L. L. Johnson, Plant Manager W. Jones, President
- K. Kolkmeier, Vice President Operations
- A. J. Mueller, QA Manager (Acting)
- D Metzler, Welding Superintendent Factory Mutual Engineering R. J. Ciacch, Nuclear Inspection Supervisor M. Minick, Authorized Nuclear Inspector (ANI)
- Denotes those persons who attended the exit interview.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Report No. 79-01). Fabrication Check List (FCL) not prepared.
The inspector reviewed documentation and instructions to Foreman and employees stating that no work will be performed without a
.FCL.
Production Planring now generates all FCLs.
2.
(Closed) Deviation (Report No. 79-01) Calibration stickers not attached to test recorders. The inspector verified that calibration record cards have been generated and the pressure recorders have been calibrated.
Inspectors have been tastructed to check all instruments and during listing for current calibration.
3.
(Closed) Deviation (Report No. 79-01) Engineering Instruction Speci-fication did not reference customer's required tests.
The inspector reviewed all correspondence between PDM and customers to determine that the specification in question has been revised to allow the use of the electrical wire used in the air locks in ques-tion. Engineering requirements will be reviewed more closely for preparation of Purchase Orders.
4.
(Closed) Deviation (Report No. 79-01) QA documentation clerk not
~
4 The inspector reviewed audits and monitoring reports of the QA inspectors indicating that reviews have been made of Purchasing activities as required by the manual monitoring activities are being performed on a monthly basis - manual revised to show the change of monitoring activities.
5.
(Closed) Unresolved item (Report No. 79-01) Clarification of Corp-orate line authority for the QA Program is required.
The inspector verified that the corporate QA Manual Organizational Chart has been reviewed to correctly indicate the line of authority.
6.
(Closed) Unresolved item (Report No. 79-01) Availability of Design and Stress Analysis for the ANI should be clarified. The inspector verified that the QA manual indicates that stress analysis reports are: made available to the ANI prior to find stamping.
This was verified with the ANI.
7.
(Closed) Unresolved item (Report No. 79-01) Clarification is required as to how the Corporate QA Auditor can perform an annual corporate QA Audit of the Central Division.
The inspector verified that the Corporate QA Manual has been revised to allow an auditor other than the Corporate QA Auditor to audit the central Division to prevent an audit of one's own Division.
C.
QA Program Review (Organization - Program) 1.
Objectives The objectives of this area of the inspection, were to ascertain whether the QA Program has been documented in writing, and it is being correctly implemented in a manner that will ensure that the components were manufactured in compliance with code requirements, and meets the prescribed quality standards. Also, to ascertain whether the prcgram is consistent with NRC regulations, contract, and code requirements.
2.
Method of Accomplishment Review of PDM's Corporate QA manual, Revision 7, dated a.
December 12, 1979.
b.
Review of PDM's Appendix A.
(Pittsburgh Plant) QA Manual, Revision 8 issued January 30, 1980.
5 V
Review of appropriate Nganization charts to verify that the c.
QA staff is_ independent from the pressures of cost and schedul-ing and has access to. upper management.
d.
Review of the documents aoncerning the authority, duties, and responsibilities of the Quality Assurance staff, to verify that they have the independence to identify quality problems, initiate appropriate corrective action, and the authority to stop work.
3.
Findings a.
Deviations None.
b.
Unresolved Items It was brought to managements attention that during the inspec-tors continuing review of the corporate QA manual that certain arecs were still not clarified.
(1) Reporting requirements and Documentation of the Corporate QA Auditor is not clearly' defined-in the manual. The President's statement that the Corporate QA Coordinator shall have the responsibility of monitoring the overall effectiveness of the implementation of the Quality Assur-ance Program. The manual does not indicate a yearly report will be generated. Management indicated that the matter will be reviewed.
(2) The Policy Statement which commits the Corporate QA manual to be in compliance with the requirements of Appendix B to 10 CFR 50/N45.2, has been removed. The Division managers statement indicates that the Corporate QA manual conforms only to the requirements if the ASME Boiler and Pressure Vessel Code,Section III, Divisions 1 and 2.
Management indicated that this item would be reviewed and appropriate action taken.
D.
Contro1~ of Special Processes, Welding Procedure Specifications Use
-and Control 1.
Objectives The objectives of this area of the inspection were to verify that welding procedure specifications used for production welding are controlled and use in accordance with the PDM QA Program and NRC
.and the contract and' Code requirements.
4
+
.n.-
.a.
,. ~,..,,,. -
~
6 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the corporate QA manual subsection 13.2 " Welding."
b.
Review of the following welding procedures / qualifications and specifications.
76-47, 68-4, 68.4 Revision E, 70-11 c.
Review of Four (4) welders Performance and WPS qualification records.
FN-1A-AC and DU.
d.
Review of the following FCLs to verify that the welding opera-tions including the WPS to be used were identified.
FCI81, FCL13, FCL1336, and FCL1339.
Observation of welding activities in the shop area.
e.
f.
Review of welding equipment calibration requirements.
g.
Discussions with shop personnel.
3.
Findings p.
Deviations See enclosure item 1.A and B.
b.
Unresolved Item The electrical requirements established by the Welding Procedure Specification (WPS), and used in the Procedure qualification (PQR) of Procedure 68-4, should be reviewed for consistency.
The present documents do not record consistent electrical parameters, c.
General l
Time did not permit all welding activities to be completely reviewed. Further review of this activity will be performed i
during a subsequent inspection.
6 i
i
.y---
7 E.
Authorized Nuclear Inspector (ANI) Interface 1.
Objectives The objectives of this area of th-inspection were to ascertain whether procedures had been p tepared and approved, which describes the system to be implemented for the achievement of interface activ-ities are consistent with th3 NRC rules, Code requirements, and the QA Program commitments.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished as follows:
Review of PDM's QA Manual Section 1.3 - 1.4 and 1.5, to a.
ascertain whether the system provides for interface with the ANI and/or the Authorized Inspection Agency (AIA) to review the Design Specification (DS), and provide the inspection services, required by code, on all code items covered by the customer's order and design specification (DS).
b.
Review of nonconforming reports to verify that changes in the customer's design specifications (DS) are reviewed with the ANI to inform him of the status of the inspections and tests of the items when it is removed from the manufacturing j
process.
Review of QA Manual, to verify that measures have been provided c.
to make available Material Certifications and the QC Source and/or Receiving Inspection Reports, for review by the ANI, and that such reviews are documented.
d.
Review of QA Manual, to verify that a system has been provided to maintain the identification of materials, and that the identification is transferred when it becomes necessary to divide the material, also to verify that the ANI is provided the opportunity to verify that the identification of material is properly maintained and documented.
e.
Review of QA Manual; to ascertain whether measures have been established for the ANI to witness any welding procedure, and/
or any welder performance qualification tests, and to request the requalification of any procedure or welder, to ensure proper qualification and/or any welder performance qualifi-cation tests, and to request the requalification of any pro-cedure or welder, to ensure proper qualification and/or accept-able welding performance.
8 f.
Review of the QA Manual, to verify that the program provides for the application of the code stamp only with the authori-zation of the ANI after acceptable pressure testing, certifi-cation of the Manufacturer's Data Report, and stamping only in the presence of the ANI.
g.
The Daily Log Book maintained by the ANI was reviewed, to verify that NVD is making its QA/QC documents available to the ANI for his review, to provide assurance that the code requirements are complied with and that the product quality has been achieved.
3.
Findings The ANI activities as documented in his log book, and by documents reviewed, supports a findings that the vendor is properly imple-menting its interface responsibilities with the ANI in a manner consistent with the NRC rules, Code requirements, and its QA program commitments. The ANI is a full time Inspector.
F.
Exit Interview The inspector met with management repre~sentatives (denoted in paragraph A) at the concitsion of the inspection. The inspector summarized the scope and findin p of the inspection. The management representatives had no comment in response to the items discussed by the inspector.
h
{-
i 9
DETAII.S SECTION II (Prepared by D. E. Whitesell)
A.
Reported Construction Deficiencies 1.
Unqualified Weld Wire a.
Background Information The Pittsburgh Des Moines Steel Company's (PDM) QA program has a requirement that before any material can be transferred from plant to site, or from one contract to another, that the mater-ial and all of the pertinent documentation shall be reviewed by the QA Document Supervisor, as to the acceptability of the material, and the completeness, accuracy, and legibility of all documents relating to.the material.
On or about 7-23-79, certain heats of 8018-C3 weld filler metal was to be transferred from PDM contract 13691 for use on PDM contract 15676, and during the document check for acceptability it was discovered that the weld wire had been purchased to PDM Electrode Procurement Specification no. ES 7.
5.1. which requires the CMTR to report the test results in the l.
as welded condition only.
Therefore it was determined that the weld filler metal complied with subsection NE and NF 2431.1, but did not comply with subsections NE and NF 2431.2 for impact tests, which requires the weld metal to be PWHT for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> mini-mum, and the CMTR to report the mechanical properties of the material in both the as-welded and the PWHI condition.
PDM notified its customer by telecopier concerning this matter on 8-24-79.
b.
Objectives The objectives of this area of the inspection were to ascertain the following:
(1) Whether a breakdown in the QA program occured.
(2) The action implemented to correct the problem.
(3) The action implemented to prevent recurrence (4) Whether the safety significance has been evaluated in compliance with 10 CFR 21.
i l
- =
r 10 c.
Method of Accomplishment The foregoing objectives were accomplished by:
(1) Review of the QA Manual Section 8, which is the procedure which establishes the responsibilities and identifies what actions are to.be taken in transfering materials from plant to plant, plant to site, or job to job, to ascertain how, when, and what activities are to be performed to verify the accepubility of the material, or other item (s) being transferred.
(2) -PDM letter to Bechtel Power Corporation, dated August'24, 1979, identifying the problem, and referencing the WPS, drawings, drawing details, sections and weld seams, where the welding procedures were used for ASME Section III, Subsection NF application, to verify that the customers notification was complete, accurate, and provided adequate information for the customer to perform a safety evaluation of the problem and determine its reportability under 50.55(e) or part 21.
(3) Review of a letter from PDM Project Engineer to the customers, dated September 6, 1979 and identified as ClB-152-1820, which identified Hope Creek Units 1 and 2 as being PDM contract 15676 under Bechtels PO no.10855-C-152(Q). This letter was an update to the reported problem and contained the chronology of the status of the ongoing corrective action PDM had initiated to deter-1 mine the extent, and generic impact, of the problem and the action proposed if PDM to prevent recurrence.
(4) Review of Engineering Corrective Action Report (ECAR) dated 9-6-79 wit' attachments identifying by heat ID l
numbers, each weld seas and assembly number, where the suspected wire had been used.
(5) Review of approved corrective-action for ECAR 138 Revision B for contract 15675 (Hope Creek Unit 1) which documents that only three heats of the questionable electrodes were used in welds for which it was not qualified. The heat ids were A2988, A2133, and A3297.
It was also documented that A2988 had been re-tested by the supplier, and the original CMTR had been amended to report the. mechanical properties of the weld metal, in both the "As-Welded" and PWT condition.
(6)
Review of the CMTR dated 6/15/76, Amended,7 + 25 F for 6 9/6/79 D **#ifY 6
that the weld metal had been PWHT at 1125 additional hours, to comply with the code required eight hours minimum, and to ascertain whether the mechanical
~
l 11 properties were within acceptable limits. Also, that the Charpy V notch tests had been performed, and the test 1
results were recorded in both the as-welded and PWHT conditions.
(7) Review of Pittsburgh Testing Laboratory (PTL) report number 802600 and number 802591, both dated 12/26/1979.
i Reporting the results of an all weld metal tensilg test of g
Electrode heat ED A2138 and 8913 after PWHI @l100 -1175 F
-by PDM. The test report was certified by PTL to have been performed per ASME Section II part C, SFA 5.1 and 1974 ASME Section III, Division I, Subsection NF 2431.1 with addenda to and including winter 1974.
(8) Discussions with cognizant PDM personnel.
l d.
Findings (1) From the documents reviewed it was determined that the QA program requires tLe wel?.ing engineer to furnish the Project Engineer with material and/or electrode specifi-cations, which are reviewed by the Project Engineer for compliance with the contract and code requirements.
These QA program requirements were followed, in the procure-ment of weld metal using electrode specification no. ES 7.
5.1.
The third paragraph of this specification requires the vendor to furnish test results in the as-welded condi-tion only, which is consistent with Subsection NF 2431.1.
The requirements of Subsection NF 2431.2(c) which requires electrode materials that are to be impact tested, to be tested La both the as-welded and PWHT condition, were i
inadvertently overlooked by both the welding ~ engineer and the Project Engineer. However, the checks and balances designed into the QA program eventually identified the problem.
(2) Corrective Action (a) Once the pronL-% was identified, the QA/QC records were searched to identify the heat numbers of elec-trodes purchased for nuclear ~ contracts under the ES7.5.1 material specification. With this information, the wire could be traced to the various assemblies and weld seams where it was consumed. From the fabrication documents PDM could determined that Subsection NF2431.2 was applicable to only three heats of the electrodes which were identified as. being PDM's heat code numbers A2988, A2138, and A3297. which were used on contract 15675 and one heat, - #A8913, on contract 15676.
i
\\
12 (b) The supplier had some of the weld metal identified as PDM heat A2288 and were able to P%1fT the metal at 1125 F + 257 for six (6) additional hours and amended the original CMTR to record the mechanical properties in both the as-welded and PhliT conditions, and to perform Charpy impact tests on the material in both the aswelded and Pk11T conditions. This test brought heat number A2988 in compliance with NF2431.2.
The weld wire had been ociginally PWHT at 1125 F +
~
25 F for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> therefore the 6 additional hours met the required time at temperature required in NF2431.2(c).
(c) Heat numbers A2138 and A8913, had been used to make several butt-welds from which test coupons were removed, and tested by PDT for PDM in the actual Pk11T condition of 1100-1175 F for 2 5/8 hours. From the reported test results it was determined that the impact tests and mechanical properties of the weld metal was within acceptable limits in the PhliT con-dition that it had received during fabrication.
(as PDM has not been able to obtain coupons from weld seams using heat A3297, and have, or will, remove all welds using this suspected weld metal, and reweld the seams with properly qualified weld metal.
(e) A written procedure was developed, and approved by the customer, for controlling the removal of the weld metal test coupons, rnd for the weld repairs of the cavities left by the coupon removal.
(3) Corrective Action to Prevent Recurrence (a) An Electrode Specification number ES 7.5.2 Revision B, dated 2-15-80 was developed and approved for use by purchasing for procuring welding electrodes to SFA 5.5 for SMAW process to be used on contracts that are specified to be derigr.ed, manufactured, tested, and inspected in complian e with the ASME Section III, Division I Subsections NE and NF.
It was verified that this specifications included the requirements of Subsection NE and NF 2431.1 and 2431.2 of the ASME code.
(b) All contract data packages and the CMTRs are being reviewed by the QA Purchasing Checker and where l
[
l
13 appropirate, copies of the Amended CMTRs are being included.
(c) All future purchases of weld wire will be to Electrode Specification ES 7.5.2 Revision B.
Particularly in procuring weld metal to use on nuclear contracts that are required to be fabricated in compliance with Section III, Subsections NE, or NF, of the ASME codes.
(4) Evaluation of Safety Significance (a) PDtf stated that the condition had been reported to the Construction Permit holder in sufficient detail to enable him to evaluate its safety significance.
(b) PDtf does act consider the problem to be a threat to safety or meet the criteria of a significant deficiency under 10 CFR 50.55(e)(1) for the following reason.
(c) The wire as purchased was PWHT for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, which qualified it for 2.5 (80%) at PWT temperature and the actual time at PWHT temperature (2.625 hours0.00723 days <br />0.174 hours <br />0.00103 weeks <br />2.378125e-4 months <br />) would not significantly alter its as-welded properites, and the welds would have the capability to resist stresses equal to that of the base material it joined.
2.
Malfunction of Interlocks on Personnel Hatch a.
Backaround Information During the final inspection and functional testing of the mechanical interlock system of the Containment Personnel Hatch for Hope Creek Unit 1 (PDM contract no.15675-Assembly no.
303L),-it was discovered that during the panic sequence of the functional test, the door, when slammed closed, would rebound to the extent that the door latches would not engage the keepers.
However, the rebound was not sufficient to actuate the' interlock status lights. Under such circumstances, the status lights would indicate that the door was closed and ' locked, when actually it was in the closed position only.
b.
Objectives l
The objectives of this area of the inspection were to ascertain the following:
(1) PDM's corrective action I
14 (2). The action taken to prevent recurrence.
c.
Method of Accomplishment The above objectives were accomplished by:
(1) Review of Engineering Corrective Action Request (ECAR) number 31862, dated 6-18-79, which describes the malfunc-tion of the door locks and false indications of the door lock status lights.
It was observed that the ECAR was executed in compliance with the QA program requirements.
(2) Review of Drawing SPA 39, Revision 0, dated 6-8-79, which a design drawing, for a " Personnel Access Airlock Door Closing Snubber," which had been designed in response to ECAR #31862.
(3) Review of ECN number 273 & 450 to verify that the approp-riate drawings were to be revised to incorporate the door snubbers.
(4) Review of Drawing SPA-2 Revision 26 dated 6-13-79, for the containment bulkhead, and Drawing SPA-3, Revision 13, dated 6-13-79 for the atmosphere bulkhead, to verify that they each had been revised to incorporate the door snubbers delineated on Drawing SPA-39.
(5) Discussions with cognizant PDM personnel, d.
Findings (1) To correct the malfunction identified in ECAR dated 6-18-79, PDtf had designed a dashpot snubber, to reduce the closing impact which was experienced under panic operation.
(2) The snubber assembly procedure was included on drawing SPA 39, and its location on the two bulkheads were identi-fied on drawings SPA 2 and SPA 3.
(3) After Installation the function of the interlock system was tested several times under panic operation, to assure that the door interlocks and status light malfunctions had been elminated.
(4) Since the malfunction was identified by PDtf prior to shipment, the malfunction does not meet the criterion for reportability under 10 CFR 21.
_.,-.c
,.-s
~ ~