ML19345D099
| ML19345D099 | |
| Person / Time | |
|---|---|
| Issue date: | 07/29/1980 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345D088 | List: |
| References | |
| REF-QA-99900086 NUDOCS 8012090065 | |
| Download: ML19345D099 (16) | |
Text
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i V
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION-IV Report No.
99900086/80-01 Program No. 51300 Company:
Hopkinsons Limited' Britannia Works Post Office Box B27 Huddersfield,' ENGLAND HD2 2UR Inspection Conducted:
June 23-27, 1980 W
Y 2-9 N C Inspectors:
I. Barnee, Chief Date ComponentsSection II V ' dor Inspection Branch b
E1CLJ kE L. E. Ellershaw, Contractor Inspector
/ Dat4 ComponentsSection II Vendor Inspection Branch Approved:
w 7 /2-9/tc)
I. Barnes, Chief Date Components Seetion II Vendor Inspection Branch Summary Inspection on June 23-27, 1980 (9990086/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria and appli-cable codes and standards; including action on previous inspection findings,
. manufacturing process control, nonconformances and corrective action, welding material control, nondestructive examination: magnetic particle (MT); liquid penetrant (PT); radiography (RT), qualification of personnel performing special processes - visual examination, testing of completed products (hydrotest) and
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weld heat treatment. The inspection involved a total of seventy-two (72) inspector-hours on site by two (2) NRC inspector-4 3
s 4.I.tq9&%S
2 Re'sult :
In the eight (8) areas inspected, no deviati_?s or unresolved items were identified in five (5) areas, with the followinc de 'iations being identi-fled in'the remaining areas:
Deviations: Manufacturing Process Control - Certain Manufacturing Orders did not provide all necessary instructions, ar required by Section 4 of the' QA Manual (Notice of Deviation,-Item A).
Torque wrench used in valve assembly was not checked and controlled for accuracy, as required by Section 8 of the QA Manual (Notice of Deviation, Item B).
Inadequate radius established to be present at an accepted bonnet flange to wall interface relative to the requirements of the applicable drawing (Notice of Deviation, Item C).
Movement of valve body castings to the next scheduled operation, without signoff of the preceding operation on the Foundry Check-off List, was contrary to Section 2 of the Foundry QA Manual (Notice of Deviation, Item F).
Welding Material Control - Identity of E7018 electrodes not maintained in foundry as required by QC Specification N6-1 (Notice of Deviation, Item D).
Qualification of Personnel Performing Special Processes - Visual Examination -
Personnel performing visual examinations were not qualified with respect to the vision requirements of paragraph NB-5521 in Section III of the ASME Code (Notice of Deviation, Item E).
Items Requiring Follow-up Inspec' tion Manufacturing Process Control - Certain section changes produced by machining not defined on Engineering drawings with respect to allowable radius (Details I, c.3.c).
Nonconformances and Corrective Action - Absence of documentation to indicate an analytical evaluation is being made of quality trends or reasons for nonconformances (Details I, D.3.b.).
c l
3 DETAILS SECTION I (Prepared by I. Baraes)
A.
Persons Contacted
- P.K. Thomas,' Deputy Managing Director
- R. Watson, Engineering Director
- F. Caudwell, Works Director-
- P. E.. Holt, QA Executive
- D. Croft, Works Manager
- K. Pycroft, Foundries Manager
- S. Palmer, Steel. Foundry Manager
- S. D. Brooke, Projects Engineer-
- R. A. Grimston, Chief Designer
- H. Robinson, Chief Inspector
- D. Fryer, Q. A. Engineer
- D. Waterworth, QA Engineer i
- A. Barker,- QA Eng ~ neer
- R. Higginbottom, hetallurgist J.~K. Clayton,. Design Engineer
.C. Smith, Design Engineer J. Ingleby, Chemist J. W. S. Downie, Product Investigation Engineer
- Denotes those persons attending the exit meeting.
B.
Action on Previous Inspection Findings 1.
(Closed) Deviation (Item A, Notice of Deviation, Inspection Report No. 79-02):
Performance of production welding operations on Works Order Nos.
17 SM 5634 and 24/SM 5224 in a sequence other than that specified on the Operations Charts, without either the approval of the QA Manager or prior amendment of the charts to indicate the changes.
The inspector verified that the committed training actions had-been performed and that a deviation report and corrective action request had been issue and appropriately resolved.
d 2.
(0 pen) Deviation (Item B, Notice of Deviation, Inspection Report No. 79-02):
QA acceptance of a body essting for Works Order No. 11/SM 5640 without ensuring that recair welding documentation was correct.
The inspector verified that a deviation report had been issued and the documentation errors corrected and that a review had-been
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4 performed of the Foundry Division certification for SA 216 grade WCB castings in response-to a corrective action' request on this subject.
The inspector was unable, however, to verify implementation of com-
- mitted preventive action (use of Check List), as a result of addi-tional castings not having been received from the Foundry Division in
.the time period following development of the check list. This item will remain open pending such verification dining a future inspection.
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3.
(Closed)-Deviation (Item C, Notice of Deviation, Inspection Report No. 79-02):
4 Failure of welding supervision to ensure that all parameters of weld-ing procedures were being followed by welders for the repair of castings.
The inspector verified that the committed welder training actions had been performed, the welding procedure specification revised to permit use of a 3/32 inch diameter wire and welds excavated and replaced in the identified casting.
4.
(Closed) Deviation (Item D, Notice of Deviation, Inspection Report No. 79-02):
Simultaneous issue of welding material to perform two welding proce-dures and failure to record the identity of the welds for which the materials were-issued.
The inspector verified that the committed training actions had been performed with respect to QA program requirements for issue of welding materials.
5.
(Closed) Follow-up Inspection Item (Details D.3.c.(1), Inspection Report No. 79-02):
Use of a power source for shielded metal arc welding in an amperage range below the calibrated range of the attached ammeter.
1 The inspector verified that a new ammeter with an appropriate scale for use:of the power source had been installed as. committed.
6.
(0 pen) Follow-up Inspection Item (D.3.c.(2), Inspection Report No.
79-02):
Scope and criteria used for. monitoring production welding by QC personnel not formally established.
d f
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The inspector verified that a formalized system had been developed for monitoring production welding and implemented with respect to machine shop welding ~ activities. 'The inspector was informed that absence of foundry repair welding activities on ASME valve castings had precluded performance of similar monitoring activities in the Foundry Division. This subject will be further reviewed in a future inspection relative to scope and results.
C.
Manufacturing Process Control (See also Details II, paragraph G) 1.
Objectives-The objectives of this area of the inspection were to verify whether:
A system had been established for the control of manufacturing, a.
which was consistent with applicable regulatory and contract requirements, b.
The system was implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of Section 2, Revision 13, of the QA Manual, " Sales Order, a.
Drawing and Specification Control."
b.
Review of Section 4. Revision 13, of the QA Manual, " Process Control."
Review of Section 8, Revision 12, of the QA Manual, " Calibration c.
cf Gauge and Measuring Equipment."
d.
Observation of manufacturing activities.
Examination of manufacturing order documentation for valve e.
bodies and lids (bonnets) with respect to:
_(1) Definition and control of sequencing of manufacturing operations to provide for compliance with ASME III fabri-cation requirements.
(2) Compliance with designated hold points.
s (3) Performance of required ASME Code nondestructive examina-tions.
6 (4) Completeness of operation sign off.
(5) Evidence of fabrication inspection definition and perfor-mance consistent with QA program commitments.
(6)
Inclusion of all required inspections, tests and examinations in the manufacturing order.
f.
Visual examination of selected items with respect to detailed drawing requirements.
3.
Findings a.
Deviations from Commitment (1)
Paragraph 5.0, sub paragraph 5.2 in Procedure N4-11, Revision 1, " Cleaning Procedure for Carbon Steel Valves,"
- states,
" Accessible internal surfaces of the valve assembly shall be visually examined for cleanliness. Should any item other than fluid be present i.e. grease, surfaces shall be cleaned with Esso Isopar Grade L and dried with air or clean cloths."
Sub paragraph 5.3 states, " External carbon steel surfaces shall be wiped with cloths soaked with an unused Esso Iso-par Grade L and air dried." Sub paragraph 5.4 states, "Each valve shall be placed in a drying oven until all fluid is evaporated."
Review of the documentation for a carbon steel valve observed being assembled, Order 71/SM 5222, showed, however, no requirement for this applicable examination and cleaning to be perfo rmed.
The inspector was subsequently informed by Hopkinsons Limited personnel, that this traveler deficiency had been established to be applicable to all ASME Section III carbon steel valves to be furnished for WPPSS Units 3 and 5.
During review of Deviation Reports and associated traveler documentation, the inspector observed that Order 28/SM 6666 and its associated special test specification, Q577A/31, failed to provide instructions relative to induction harden-ing, tempering and hardness requirements for 6mm. SA 479 valve heads.
The inspector was informed that the tempering
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cycle and hardness requirements for the material were per-formed using standard practice cards.
The cards were
7 submitted to the inspector to demonstrate their availabiJity.
Use of these cards was not referenced, however, by the manu-facturing order and no such instructions existed (or proce-dure) relative to the induction hardening cycle.
It should be additionally noted that 16 valve heads had been disposi-tioned to be scrapped on this Manufacturing Order, as a result of being " burnt" during the hardening, operation.
(See Notice of Deviation, Item A.)
(2) See Notice of Deviation, Item B.
(3) Visual examination of machined castings showed no apparent consideration had been given relative to the effects of machining flanges with respect ta cast radii at interface locations.
Local radii were created by flange back facing operations, which were a function of tool size and were contrary to the radius requirement of the applicable Engineering drawings.
This condition had not been detected by Quality Control Inspectors performing inspections of given machining operations and suggests, in part, inadequate final inspection of finished machined items relative to drawing requirements (See Notice of Deviation, Item C).
.b.
Unresolved Items None.
c.
Items Requiring Follow-up Inspection It was noted during the inspection described in a. above, that certain section changes produced by machining, were not defined on applicable Engineering drawings with respect to allowable radius or transition of sections.
Insufficient time was available during the inspection to fully evaluate this subject and con-sequently will be subject to follow-up during a future inspection.
D.
Nonconformances and Corrective Action 1.
Objectives The objectives of this area of the inspection were to ascertain that:
A system for the control of nonconformances and for assuring a.
effective corrective actions had been established.
m.
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.b.
'The system was properly implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of Section _12, Revision 12 of the QA Manual, ' Non-con-a.
formities and Corrective Action."
i b.
Review of Quality Control Procedure N12-2, Revision 2, "Non-conformities and Corrective Action."
c.
Examination of Deviation Reports issued for WPPSS Units 3 and 5 valves with respect to:
(1)
Identification of item (2) Description of nonconformance.
(3)
Identification of responsible parties.
(4) Method of resolution and inspection criteria.
I (5) Management participation in nonconformance report and corrective action review.
d.
Review of corrective action program relative to definition of responsibilities and effectiveness of follow-up actions.
3.
Findings Within this area of the inspection, no deviations from commitment a.
or unresolved items were identified.
b.
Items Requiring Follow-up Inspection:
Paragraph 12.10 in Section 12 of the QA Manual discusses the mechanics and constitution of a Quality Corrective Action Committee.
Review of the' minutes of meetings of this committee shows little documented basis, however, tol support a premise that an analytical evaluation is being made of quality trends or the reasons for nonconformances. This subject will be evaluated in greater depth at a future inspection.
1 m
- 9 E.
Exit Meeting An exit meeting was held on June 27, 1980, with the management representa-tives-denoted in paragraph A above. The inspectors summarized the scope and findings of the inspection, with particular emphasis placed on the need for a more. analytically based review of nonconformances, and deter-mination of corrective' actions. Management. acknowledged the statements of the inspectors with respect to the findings as presented to them and
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affirmed the. commitment of Hopkinsons Limited to the quality assurance pro-gram.
10 DETAILS SECTION II (Prepared by L. E. Ellershaw)
A.
Persons Contacted C. Boothroyd - Foreman, Fabrication Shop P. Clark - NDE Level I (RT)
R. Darroch - NDE Level II (PT)
G. Dyson - Foreman, Foundry Welders D. Fryer - Quality Assurance Engineer C. P. Heaton - Lab Instrumentation Technician S. Livesey - Test Foreman E. Robinson - Welding Engineer D. Waterworth - Quality Assurance Engineer D. Woolass - NDE, Level III Examiner B.
Welding Material Control 1.
Objectives The objectives of this area of the inspection were to verify that Hopkinsons Limited had implemented the requirements for welding material control in accordance with the QA Manual and applicable NRC and ASME Code requirements.
t 2.
Method of Accomplishment The preceding objectives were accomplished by:
Review of QA Manual Section 6, Issue C, " Welding Quality Assurance."
a.
b.
Review of Specification No. N6-1, Revision 4, " Welding Quality Control."
c.
Review of Specification No. BD-QC-SP-8, Revision 0, " Purchase Specification for welding material to ASME III Requirements for WPPSS 3 & 5."
d.
Observation of welding material storage areas.
Review of welding material Certified Material Test Reports.
-e.
4 -,
11 4
4 f.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Commitment See Notice of Deviation, Item D.
b.
Unresolved Item None C.
Nondestructive Examination: Magnetic Particle (MT); Liquid Penetrant (PT)
Radiography (RT).
1.
Objectives The o'ojecti is of this area of the inspection were to verify that Hopkinsons Ltmited had implemented the requirements for performing nondestructive examinations (NDE) 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 Section.7, Issue C, "Non-Destructive a.
Examination."
b.
Review of MT Inspection Procedure N7-3, Revision 7, dated September 19, 1978.
c.
Observation of MT being performed on Order Nos. 12/SM 5628, 12/SM 5629,-and 11/SM 5628.
d.
Review of PT Inspection Procedure N7-5, Revision 6, dated September 19, 1978.
Observation of PT being performed on three discs (Cast No. 284Z3, e.
284Z5 and 284Z10) on Order 25/SM 5229.
f.
Review of RT Procedure N7-2, Revision 11.
g.
Observation of RT set-up performed on a valve body for Order No. 12/SM 5629.
h.
Review certified material test reports associated with the mag-netic particle materials, liquid penetrant materials, and the Cobalt 60 source used for radiography.
i
s.
12 1.
Discussions with cognizant personnel.
3.
Findings d
a.
Deviation from Commitment None b.
Unresolved Item j
j None c.
Comment Ebasco specification 3240-41, Revision J, applicable to the j'
Washington Public Power Supply System order for WNP-3 and WNP-5, permits the use of ASTM E94-68, " Standard Recommended Practice for Radiographic Testing", in lieu of ASME Code Section V, Article 2, " Radiographic Examination."
4 Paragraph 7.2 of E94-68 states, "If there is any question about the adequacy of protection from back scattered radiation, a characteristic symbol (frequently a 1/8 - inch - thick letter B) should be attached to the back of the cassette or film holder, and a radiograph made in the normal manner.
If the image of this symbol appears on the radiograph, it is an indication that protection against back-scattered radiation is insufficient and that additional precautions must be taken."
i ASME Code Section.V Article 2, paragraph T-235 states."As a check
]
on back-scattered radiation, a lead symbol
'B', with minimum dimensions of inch (13 mm) in height and 1/16 inch (1.6) in thickness, shall be attached to the back of each film holder.
If 3
the image of the
'B' appears on the radiograph, protection from back-scatter is insufficient and the radiograph shall be consi-dered unacceptable."
The inspector questioned Hopkinsons' practice of not using a lead letter B to check on back-scattered radiation.
They responded by saying they had no questions about the adequacy of protection.
The inspector asked if an analysis had been performed and did they have any documented evidence to support their position.
They responded by stating they had no documentation which would support their position.
D.
Qualification of Personnel Performing Special Processes - Visual Examination 1.
Objectives n-., _,-
+
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m m,
13 The objectives of this area of the inspection were to verify that Hopkinsons Limited had implemented the requiremants for qualifying personnel performing visual examinations in accordance with the QA manual and applicable NRC and ASd2 Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 7, Issue C, "Non-Destructive Examina-tion."
b.
Review of Procedure QCP 7-1, " Training and Qualification of NDE Personnel."
c.
Discussions with cognizant personnel.
d.
Review of Procedure No. N 4-10, Revision 0, " Visual Examination Procedure for Pressure Boundary Bolting."
3.
Findings a.
Deviation from Commitments See Notice of Deviation, Item E. ASME Code Section III, Sub-section NB - 2581 requires that all bolting material be visually examined.
ASME Code Section V, Article 1, paragraph T-110 states in part, "This section of the Code contains requirements and methods for nondestructive examinations which are Code requirements (and) include.
. visual examination."
In recognition of these requirements, Hopkinsons Limited formu-lated and implemented Procedure No. N 4-10 (referenced in para-graph D.2.d.)
It appears that Hopkinsons did not consider visual examination to be a formal method of NDE, relative to personnel qualifica-tions, in that QC inspectors are utilized for that purpose.
The qualification program for QC inspectors is not as stringent as that of the NDE personnel relative to eye exami-
ans, in that the ability to read Jaegar Number 2 letters is
-inimum requirement rather than Jaegar Number 1 letters.
b.
Unresolved item None
. _ =.
i 14 E.
Testing of Completed Products (Hydrotest) 1.
Objectives
-The objectives of this area of the inspection were to verify that Hopkinsons Limited had implemented the requirements for testing of completed products (hydrotest) in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment i
The preceding objectives were accomplished by:
Review of QA Manual Section 4, Issue C, " Process Control."
a.
b.
Review of Procedure No, N4-8, Revision 16, " Hydrostatic Test Procedure for Carbon Steel Parallel Slide Valves."
c.
Observation of hydrostatic shell and back seat test performed on a 10 inch valve, works order No. 71/SM 5222.
d.
Verification of test pressures and minimum time at test.
4 Verification of test pressure gages before and after hydrotest.
e.
f.
Verification, through chemical analysis, of test medium pH and chloride content.
g.
Discussions with cognizant personnel.
3.
Findings a.
Deviation from Commitment None b.
Unresolved Items None F.
Weld Heat Treatment 1.
Objectives i
The. objectives of this area of the inspection were to verify that Hopkinsonr Limited had implemented the requirements for the control of postweld heat treatment (PWHT) in accordance with the QA Manual and applicable NRC and ASME Code requirements.
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15 4
2.
Method of Accomplishment The preceding objectives were accomplished by:
P 4
Review of ~QA Manual Section 9,. Issue C,~ " Heat Treatment."
a.
I b.
Review of Procedure QCP No. 9-1, Revision 4, " Furnace and Instrument Calibration."
l c.
Review of form " Stress Relieving Details of WPPSS 3 & 5 W.C.B.
Pressure Containing components", for accumulated -times at i
temperature.
d.
Review of PWHT charts and PWHT Summary Records.
I Review CMTRs of welding materials used before and after PWHT, to f
e.
i ascertain compatability relative to time used and required tests (as welded condition or PWHT condition).
i af.
Verification of holding times at temperature, and heating and cooling-rates.
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g.
Discussions with cognizant personnel.
i 3.
Findings a.
Deviation from Commitments None b.
Unresolved Items 4
None 1
G.
Manufacturing Process' Control 1.
Objectives j.
The objectives of this area of the inspection-were to verify that Hopkinsons Limited had implemented the requirements for manufacturing process control in accordance with the QA manual and applicable NRC and ASME Code requirements.
i 2.
Method of Accomplishment l
l The preceding objectives were accomplished by:
1 a.
' Review of QA Manual Section 4, Issue C, " Process Control."
t
16 b.
Review of in process Manufacturing Orders, applicable drawings and Special Test Specifications.
c.
. Review of in-process Fcandry Check-off Lists.
d.
' Discussions with cognizant personnel, Review of Foundry QA Manual, " Steel Castings for ASME III and e.
Nuclear Products", Issue A.
3.
Findings a.
Deviation from Commitment See Notice of Deviation, Item F.
Four valve body castings (Order No. 11/SM 5628-SN 506Z7, Order No. 12/SM 5629-SN 506Z9 and 506Z10) had been moved to the NDE area for final MT and RT after PWHT.
The Foundry Check-off Lists had not been signed-off, showing that PWHT had been performed.
It was determined that all but SN 506Z9 had received PWHT.
b.
Unresolved Items None
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