ML19345B946
| ML19345B946 | |
| Person / Time | |
|---|---|
| Issue date: | 09/05/1980 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345B937 | List: |
| References | |
| REF-QA-99900209 NUDOCS 8012020808 | |
| Download: ML19345B946 (10) | |
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S. NUCLEAR REGULATORY COMMISSION--
4 0FFICE.OF INSPECTION.AND ENFORCEMENT ~
REGION IV-i A
Report No.
99900209/80 02:
Program No."51300' Company: -
?Bergen-Paterson Pipesupport Corporation 48'Winnisquam Avenue.
Laconia, :New' Hampshire '03246 Inspection <at:
Laconia, New Hampshire-t.
- Inspection;conduc[t d:
' August 4-8, 1980 b
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" Inspector:
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". E'. Ellershaw, Contractor Inspector.
/ Date-1.
Ve' dor > Inspection Branch component Section'II Approved by:
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.-l%.Barnes, Chief
'- DAte
'. Component Section II 1'
l Vendor Inspection-Branch Summary:
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Inspection conducted August 4-8, 1980_(99900209/80-02) 4 Areas Itspected:
Implementation of 10 CFR.50 Appendix B Criteria, and applicable codes'and-standards: including:' material;identificationiand control; product acceptance -weld material control; procurement docue nt control; welder quali--
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fication and 'a' Part 21 ~ report. The inspection invob ed 34 inspector-hours 4
-on site.
3 Results:
Inithe six~ areas inspected, thrca deviations from commitment were F
identified.
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IDeviations:From Commitment: -Product-Acceptance - material ~was released for l
use without--being checked-in accor'danc'e with purchas'e order requirements (Notice of Deviation, Item A.).
- Procurement Document: Control - drawing requirements for~a special yield i-strength were not. incorporated into: purchase documents (Notice of Deviation,-
. Item : B. )'.
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' Welder Qtialification :- certain welders are :not qualified, in accordance with Code Case.N-55,Lto perform. friction welding (Notice of Deviation, Item C.).
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_ 18012020i g y
2 DETAILS SECTION (Prepared by L. E. Ellershaw).
A.
Persons Contacted G. R. Amsden - Quality Assurance Engineer H. Accornero - QC Administrative Assistant D. Baron - Weld Room Attendant W. F. Becksted - Manager, Quality Assurance E. Cloutier - Assistant Plant Manager M. R. Fandetti - Manager, Manufacturing L. Goupil - Welding Foreman A. Lee.- General Foreman J. K. Rule - Welding Engineer D. Sanville - Order Controller R. A. Stokes - Chief Examiner B.
Material Identification and Control 1.
Objectives The objectives of this area of the inspection were to ascertain the validity of an allegation made on May 28, 1980 regarding pipe supports being fabricated from unidentified materials and to verify that Bergen-Paterson Pipesupport Corp. (BP) had implemented the require-ments for material identification and control in accordance with the QA Manual and applicable NRC and ASME Code requirementa.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review the details of the allegation.
a.
b.
Review QA Manual Section 8, " Identification and Control of Materials," revision 1 dated June 1, 1980.
c.
Review of procedure BP-8-1,
' Material Issue."
d.
Review of procedure BP-13-2, " Marking."
Observation and review of the following three in-process jobs:
e.
7500-0142-28; 7410-5031-01, and 202-1041-000. The review consisted of:
'(1) observing each detail part for identification (there were 22 detail parts in all).
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-(2) comparing the detail part? identification with the Material-Requisitions, which are kept in each Traveler package.
(3) ' reviewing the_ Material Log. Sheets for each detail part to assure identity had been maintained and that material had
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been released by Quality Control.
(4) review of. Receiving Reports for all of the above material.
(5) review of alla:ertified Material Test Reports (CMTR)
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associated witu therabove material.
f.
Observation of accepted and stored material, and its identification.
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Review of Material Log Sheets and CMTRs for the stored material.
h.
-Observation of lot coding identification for mass produced com-ponents, which have been released for use, and subsequent review of associated documentation.
i.
10bservation of transfer of material identification during stock cutting operations and subsequent verification by. Quality Control.
j.
Discussions with cognizant personnel.
3.
Findags a.
Allegation The validity of.the allegation regarding unidentified material 4.
being used for ASME Code,Section III, Subsection NF work, was not substantiated.
b.
-Deviation From Commitment None.
c.
Unresolved Item None.
C.
Product Acceptance 1.
Objectives
. a:
The objectives of this. area:of the_ inspection were to verify that BP, had' implemented-the requirements for product / material acceptance in accordance with the QA Manual and-applicable NRC and ASME Code require-ments.
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4 2.
Method ~of Accomplishment The preceding' objectives were accomplished by:
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a.
Review of QA Manual Section 8, " Identification and Control of-
. Materials," revision 1 dated June, 1, 1980.
b.
Review of procedure BP-7-1, " Receiving."
c.
Review of' procedure BP-7-2, " Material Certification Review."
d.
Observation of 12 different lots of welding material, and a review of associated CMTRs and the Purchase Orders used for ordering the welding material.
Review of the Material Log Sheets associated with the above e.
welding material.
f.
Discussions.with cognizant personnel.
3.
Findings a.
Deviation-From Commitment See Notice of Deviation, Item A.
BP issued purchase order (PO) BL-22556 for the procurement of
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500 lbs. of 3/16" diameter Lincoln LH-72, 9018 B3 electrodes per ASME Specification SFA5.5 Section II C,'1977 Edition, Winter '77' Addenda.
The PO required a CMTR for each lot of electrodes and that testing shall be in the'as-welded condition.
The material was accepted-on October 6, 1978, and subsequently issued for use.
Some of~this welding material remains and is still available for use.
The-CMTR from Hobart Bros._ Company dated September 19, 1978, shows theLchemical analysis and the physical' properties to be-typical'rather than test results from each lot, and the physical properties'were acquired using test specimens that had been postweld-heat treated rather than being in the as-welded condition.
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b.
-Unresolved Item
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None.
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D.
LWelding Material Control 11.
? Objectives The objectives of this area of the inspection werecto verify that BP-hadLimplemented the requirements for'the control of welding material istorage andTissuance'in accordance with the~QA Manual and applicable ERC~and:ASME Code-requirements.
2.
Method of Accomplishment'
.The preceding objectives were accomplished by:
a.
Review of QA Manual-Section 8, " Identification 'and Control of Materials,"; revision 1 dated June 1, 1980.
bi.
Review of procedure BP-8-2, " Weld Filter Metal' Control."'
Observation of.. welding materials located in stores and in holding c.
ovens.
d.
Review of CMTRs for 12'different lots of welding materials observed in holding ovens.
Review of welding material issue slips and verification,.by e.
observation, of welding materials in possession of the welders.
e f.
Comparison of welding' material issue slips and Fabrication Records to assure correct documenting of'the welding material used.
g.
2 Discussions with cognizant personnel.
3.
Findings a.
Deviation'From Commitment None.
b.
> Unresolved Item None.
E '.
Procurement Document Control
-1.
' Objectives The objectives of this area of the: inspection were to verify that
- BPThad-implemented the requirements for the control of procurement w
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? documents;in ' ace'ordance.with the 'QA Manual,and applicable NR'C and t
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'ASME' Code-requirements.
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r2.
Method'of~ Accomplishment The. preceding: objectives:werefaccomplishEd by:
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a.
Revie'w'of.QA' Manual'Section 7,." Procurement Control," revision-O dated March:1, 1979.
)b.
Review of 15 purchase' requisitions, the subsequent purchase.
' orders,;the applicable drawings, and'the bills-of-material, to:
'(1). assure review'byythe Quality Control Department.
.(2) assurematerial.,requirementswe'ie. passed'ontosuppliers.
(3). assure documentation requirements'were passe. on to suppliers Review the Approved 1 Vendors List-(AVL) and compare the purchase c.
orders against-the AVL.
d.
Discussion with-cognizant.persennel.
3.
Findings-a.
Deviation From Commitment See Notice of-Deviation,: Item B.
Purchase Order C-31713 was issued to U.S.' Steel Company for
" x 80" x 96" Long Plate, Hot Rolled mild steel plate to ASME-SA'36.
The material was-received and accepted based upon the CMTRs for
'U.S. Steel companyl -The CMTRs, dated May 9, 1980, showed two 1 Yield Strength values (42,100 psi and 40,400 psi), for' Heat No.
'74A011. :This'is acceptable per the material specification.
However,-note 4_on' drawing 202-1025-000'for-tha Rod End Base Plates (which -were observed being fabricated -in the. shop) states,
" Material: Specification:
SA'515.Gr. 70;fSA 516 Gr170;.SA 36 Minimum. Yield - 48 ksi;-A588 Gr./A.
BP.did:not pass.the minimum-yield requirement on to their supplier.-
F.
IWe'ider Qualification-
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- Objectives :
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2 I
7 The objectives of this area of the inspection were to verify that-BP had implemented the requirements for welder qualification in accordance with.the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
R? view of QA Manual Section 9, " Control of Special Processes,"
a.
revision 1 date June 1,- 1980.
b.
Review of procedure BP-9-28, " Administration of_ Welder's Per-formance Qualification Test."
- c..
Review of-the Welder Qualification Maintenance Report which identifies the. qualified welders.
d.
Review welder qualification records for seven welders and four welding operators certified as being qualified for friction welding.
Review of ASME Code Case N-55 (1609-1), " Inertia and Continuous e.
Drive Friction Welding," approved on August 28, 1978.
f.
Discuss'- =1th cognizant personnel.
3.
Findags a.
Deviation From Co.nmitment See Notice of Deviation, Item C.
BP has developed five-Friction Welding (FRW) welding procedure specifications (WPS):
10-1 and 10-2, both dated March 31, 1980; 10-3 and 10-4, both dated May 29, 1980, and 11-1 dated May 20, 1980. The applicable procedure qualification-records (PQR) show that the tests used.to qualify the respective WPSs, con-sisted'of bend tests and tensile -tests.
Welding operator _ No. 2 qualified UPS :10-2, and No. 8 performed
'the actual FRW on the other four WPSs, thus,'they are-considered 1
qualified as stipulated by Code Case N-55.
However, two_other
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welding operators-(Nos. O and 1) are also shown to be qualified-to perform FRW using WPS 10-2, but tensile tests were not per-
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-formed on test coupons from their work as shown 'by their qualifi-cation test. Thus, they are not qualified in acordance with Code.
. Case N-55.
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'In addition, Code Case N-55 : requires the duplication of the WPS' requirements-in order to.be qualified.
Therefore, it would appearLthat changes in~ parameters between WPSs would necessitate requalification for each change. The Performance Qualification Records of welding operators 2 and 8, do not designate which WPSs they are qualified to, thus tending to indicate they are each qualified for all five WPSs.
b.
Unresolved-Items None.
G.
10 CFR Part 21 Report
===1.
Background===
BP notified NRC by letter. dated June 20, 1980,' of inadequate clearance between pipe clamp Part 2640, and the bolt heads attaching the fore-ward bracket to the mechanical shock arrestor.
Part 2640 was originally designed to. mate with'a Mechanial Strut Assembly, Part 2540.
Customer requirements necessitated a modifi-cation to this clamp in order to mate with a Pacific Scientific Company, Mechanical Shock Arrestor.
This particular application is designated Special Part 2541, or Modified _Part 2540.
2.
Objectives The objectives of this follow-up inspection were to ascertain that the reporting organization, aad implemented the requirements in accordance with 10 CFR 21 and had:
Met the requirements for reporting the deficiency.
a.
b.
Performed an evaluation of the condition, including making an assassment of generic implications.
c.
Assigned responsibility for effecting corrective action and preventing' recurrence.
' 3 '.
Method of-Accomplishnent The preceding objectives were-accomplished by:
. Verifying that' the'. requirements for reporting " reportable a.
deficiencies" have been posted, and that procedures have been initiated to provide'for the reporting process, l
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-b.
Review-10'CFR 21 report and associated _ documents including:
(1) affected. Load Capacity Data' Sheets (LCDS); 2410, 2540, 2640.35'and 2640.65.
(2) BP's notification to'their customers.
(3) Work Procedure BP-6-9 "Non-standard Product Drawing Control System," dated'May 31, 1979.
c.
Discussions with cognizant personnel.
4.
Findings BP met.the requireme'nts for reporting the deficiency, by letter to NRC dated June 20, 1980... An evaluation of the condition and an assessment of generic implications was made.
It was detennined that the condition could be corrected by one of two ways:
rotating the mechanical shock arrestor (MSA) 180 (end for end), because the smaller end of the MSA has no external bolt heads, thus there would be no interference with the free movement of the clamp; or, modify the clamp ears by rounding off the squared ends of the clamp thus eliminating the interference. Either of these methods will have no affect on the design load or performance of the units..The affected drawings have been revised.
The generic aspects were evaluated and it was determined that two out of the seven different sized clamps used for this application, were affected.
Notification ias made to the following customers:
Lousiana Power
& Light Company (Waterford Unit 3? and Bechtel Power Corporation (Wolf Creek). Three units had been shipped to the Waterford site, and two units had been shipped to the Wolf Creek site.
BP had performed an interference-check by analysis, using drawing tolerances,- but failed to consider the bolt heads.
It wasn't until an actual physical check was performed, that this condition.was obse rved.
The measure taken'to prevent recurrence,-was the implementation of
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procedure BP-6-9, which places. hangers using 'non-standard products on hold until a complete engineering and quality analysis is~per-
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formed.
.e H.
Exit' Meeting A meeting was held?at the conclusion of this inspection on August 8, 1980 with the.following management representatives:
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- W. F.'Beckstid - Manager, Quality As'suran'ce.
E. Cloutier Assistant Plant Manager M.- Fandetti' - Manager of Manufacturing H. Noreen,"Jr. - Director,' Quality Assurance J. Keyes:- Stewart - Administrative Quality Control The scope and.' findings of this inspection were summarized. Management acknowledged the statements relative to the findings.
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