ML19345F460
| ML19345F460 | |
| Person / Time | |
|---|---|
| Issue date: | 11/04/1980 |
| From: | Kelley W, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19345F447 | List: |
| References | |
| REF-QA-99900239 NUDOCS 8102170516 | |
| Download: ML19345F460 (11) | |
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' U.S. NUCLEAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900239/80-01 Program 51300 Company:
Fisher Controls Continental Division 200 Main Street Coraopolis, Pennsylvania 15108 Inspection Conducted:
October 6-7, 1980 Inspectors:
/
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//!4 FC Wm. D. Kelley, Contr' actor Irrfpector
' Dite ComponentsSection I V
Vendor Inspection Branch
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J D.~ E. Whitesell, Chief Date Component Section I Vendor Inspection Branch Approved by:
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/////gp D. E.'hhitesell, Chief
' Date Component Section I Vendor Inspection Branch Summary Inspection on October 6-7, 1980, 99900239/80-01 Areas Inspected:
Implementation of Criterion V of Appendix B and the QA Manual requirements for assuring compliance with contract and code requirements.
Also to verify that reported construction deficiencies were processed, evaluated and reported in a manner consistent with NRC regulations.
The inspection involved twenty-four (24) hours by two inspectors.
Results:
In the two areas examined no deviations or unresolved items were identified in one of the areas.
In the other area it was determined that contrary to Criterion V of Appendix B and Section IV of the QA Manual not all of the code requirements were identified and accomplished during the manufac-turing process. (See Details Section C.4.h) 820 22 70 Dll"
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DETAILS A.
Persons Contacted Fisher Controls Company - Continental Division
- L. D. Baird - Quality Assurance Coordinator D. Button - Engineer, Nuclear Program R. Felton - Welding Engineering
- A. L. Gentile - Manager, Quality Assurance
- Denotes those who attended the Exit Interview (See paragraph D)
B.
General Review of Vendor's Activities 1.
The ASME issued the following Certificates of Authorization to FCC to use their symbol:
Certification No.
Symbol Product N-1387 N
Class 1, 2, & 3 valves N-1388 NA Class 1, 2, & 3 components, appur-tenances, & piping subassemblies.
N-1389 NPT Class 1, 2, & 3 valve parts, appur-tenances, & piping subassemblies.
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These certificates expire on May 19, 1982.
2.
FCC's contribution to the nuclear industry represents approximately one percent (1%) of its total workload. FCC - Continental Division, is completing all existing nuclear valve orders, and a corporate decision has been made that all future nuclear valves orders and manufacturing will be handled by the FCC Marshalltown, Iowa plant.
3.
A FCC corporate decision will be made in the immediate future con-cerning the retention of their ASME "NPT" Certificate of Authorization, for the manufacture of valve parts and appurtenances.
3 i
C.
Reported Construction Deficiency 1.
Background Information On February 22, 1980, the licensee verbally reported to the NRC Resident Inspector (RI) at Comanche Peak, that they had been informed by Fisher Control Corporation, Continental Division (FCC) that they had made certain weld repairs on nine (9) aluminum-bronze discs, without heat treat-ing the weld repairs as required by the code for SB148 alloy 594 i
material.
The RI was also informed that nine butterfly valves in the safety class 3, Service Water System, contained these aluminum-broaze discs.
On March 7, 1980, the licensee informed the RI that it had evaluated the safety significance of the problem, and had determined that the problem was reportable in accordance with 10 CFR 50.55(e).
2.
Objectives The objectives of this area of the inspection were to ascertain whether FCC had evaluated the problem to determine the cause, the
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safety significance, reportability and the generic impact in accor-dance with the requirements of 10 CFR 21.
3.
Method of Accomplishment The foregoing objectives were accomplished as follows:
a.
Review of Texas Utility Purchase Order (PO) No. CP-0600, Revision 4, dated April 10, 1975; and Design Specification (DS) No. 2323-MS-600, Revision 2, dated January 26, 1976; to ascertain the technical requirements specified by the customer.
b.
Review of Valve Data Sheets, and Appendicies 1 through 10 to l
ascertain the following concerning the Service Water Butterfly L
valves:
(1) Design pressure and temperature.
l (2)
Governing Codes and Code Class of the Service water valves.
(3)
Seismic requirements.
(4) Plant Condition for design (normal, upset, etc.)
(5) Service and environmental conditions including the service water chemistry.
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4 c.
Review of Specification No. 2323-GS-901, Revision 3, dated February 12, 1975, title " General Welding Requirements," and Specification No. 2323-GS-901-6.0, " Heat Treatment."
d.
Review of PO number 7X04051 dated May 8, 1977 from FCC to Frontier Bronze Corp, McCullum Bronze Division, to verify that the material was specified to be farnished to Section III Division I, 1974 edition through the summer 1975 addendum in accordance with Section II Specification SB148 alloy 954 It was noted that the PO specifisd "NO WELDING PERMITTED." It also invoked 10 CFR 21 on the material manufacturer.
Review of Frontier Bronze CMTR to verify that the material e.
furnished met the "as '.-ast" chemical and physical acceptance criteria established oy the material Specification SB148 for alloy 954.
f.
Review of Reject Material Report (RMR) No. 30751 dated 12-19-78 for Part No. PJA8759, Ht No. 534.
Rejected due to unacceptable LP indications.
It was noted that the disposition of RMR by the Materials Review Board (MRB) was to grind out indication, repair weld, PT and machine the hub.
It was observed that pertinent procedures and revisions were identified for both the Weld Repair and PT.
g.
Review of the Rework Record dated 12/28/78 for RMR 30751, to verify that the operations recommended by the MRB were accom-plished.
h.
Review of Welding Procedure Specification (WPS) #1C7 for joining P35 materials with GTAW, using AWS AS.7. Class RCUAL A-3 filler metal.
It was observed that the electrical amperage and voltage ranges were identified the travel speed was specified and the WPS qualification record was attached.
This WPS was identified as being the one specified on the Rework Record to be used for repair welding.
i.
Review of the CMTR for the weld metal to verify that the weld wire conformed to the filler material specified by the WPS.
j.
Review of letter from FCC - Coraopolis, to FCC - Marshalltown, dated October 5, 1979,
Subject:
"Possible Deviation from Requirements."
Identifying that the aluminum-bronze discs made from SB148-alloy 954 had not been heat treated following weld repairs and request-ing a meeting to evaluate technical aspects of the problem.
]
5 The memo appears to be an update as to the status of the continu-ing evaluation of the problem by FCC, and identifies that there were only seven (7) "as cast" discs in the field that were weld repaired by FCC, and all seven had been shipped to Texas Utili-ties, one disc had been shipped to Marshalltown for analysis and micro-structure examination, and one was on " Hold" in Coraopolis.
k.
Review of a TWX, from FCC Coraopolis to Gibbs & Hill's Project Engineer which outlines the progress of FCC's evaluation of the problem and identifies that FCC had determined that only nine aluminum-bronze discs had been repair welded without PWHT and seven (7) were in the field. The telegram also stated that FCC had revised the weld repair procedure to include PWHT, and all aluminum-bronze discs requiring weld repair will be processed per this revision.
1.
Review of FCC Interoffice Correspondence dated January 24, 1980 which documents the results of the FCC evaluation of the prob-lem, and the following determinations:
(1) Nine valves were identified by the customer's tag numbers as having aluminum-bronze discs which had been weld repaired but not PWHT as required by code.
(2) The purpose of the PWHT after weld repairs on SB148-9C 954 aluminum bronze, is to eliminate the third phase micro-structure which may form due to slow cooling rates following the welding process.
The existence of a third phase micro-structure, poses a potential for de-aluminifaction, which can leave a porous structure for a potential leakage path.
(3) A metallurgical examination of the micro-structure of a representative disc which had been weld repaired without portweld heat treatment, had been conducted, and the micro-structure examination shows that there is no third phase in the weld metal or in the heat affected zone adjacent to the weld repair. Apparently the cooling rate of the weld is rapid enough to prevent the formation of the third phase micro-structure.
(4) The failure to postweld heat treat the discs after weld repair did not conform to the Contract and Code requirements.
The impact on valve performance is thought to involve cor-rosion in salt water service since the amount of corrosion resistance is expected to be less than could be expected in an "as cast" disc without weld repair.
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(5) The solution to correct the deviation would be to heat treat the nine discs which had been weld repaired but not PWHT.
This would involve the return of the seven valve:
shipped to Texas Utility for disassembly, heat treat disc, and rebuild.
(6)
It was recommended that FCC contact Texas Utilities, and Gibbs & Hill and develop a mutually agreeable schedule and time table for the return of the seven valves.
m.
Review of letter from FCC to Gibbs & Hill (G&H) dated February 14, 1980 providing G&H with the results of FCC tests, evaluation and determination, for review by G&H and con-currence as to the recommended corrective action.
n.
Review of several TWX, Telephone logs, and other comaur.ications between FCC, G&H & TUI, arranging schedules and time frames for the return of the seven (7) valves from TUI, to achieve the least disruption of the site construction and test and start-up schedules.
o.
Review of letter from FCC to G&H, dated March 14, 1980 trans-mitting Fisher Welding Specification #1C7 Revision 3, noting that Revision 3 includes the information for PWHT, and Pittsburgh Com-mercial Heat Treating Company Procedure #13180, dated February 14, 1980 for G&J approval as agent for TUI.
p.
Review of TWX from G&H to FCC, dated March 27, 1980, stating that Procedures 1C7 and 13180 had been reviewed and both found to be acceptable.
q.
Re tew of Minutes of Meeting dated March 23, 1980, between FCC, G&H and TUI, representatives to establish a time table for the return of the seven valves for disassembly, heat treat disc or replace discs and pins, as appropriate, reassemble, and return valves to the site.
r.
Review of G&H Interoffice Memorandum dated March 19, 1980, which reported the results of a trip to FCC by G&H metallurgist, to review the documentation concerning FCC metallurgical analysis and determinations.
Since the representative disc was in Marshalltown, it was not available for review.
The CMTRs were available and from the physical properties recorded the metal-lurgist could reach certain determinations and conclusions.
The conclusions expressed in this report are as follows:
1.
The postulated catastrophic structural failure of the nine discs is not a credible event.
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2.
Gamma 2 is presumed to exist in the structure and a temper anneal in accordance with ASME III, Appendix I-84, footnote 5; is required for discs that were repair welded.
3.
Alloy lots 553 and 523 are the least likely to undergo dealuminumification and corrosion.
If a replacement sched-ule is made, valves with discs from these lots can be replaced last.
4.
Leakage due to corrosion in all " repair welded" discs is not immediate and there should be time to replace all such discs with heat treated discs in an orderly, scheduled manner.
The corrosion process on these non-treated discs is likely to begin once the valves are wetted.
Temper annealed discs will not experience corrosion."
x.
Review of letter from G&H to TUI dated March 21, 1980 transmitting a copy of the trip report by G&H metalurgist.
u.
Review of RMR number 34232, dated 9/15/80, rejecting 4" disc, part G21605, Material SB148-954, part S/N 8759. Reason, Material not heat treated.
MRB recommended disposition, dated 9-16-80, Rework by Heat treating.
v.
Rework Route Sheet for Part S/N A8759, DWG G21603 Revision D Material SB 148-954.
Operation 5 PWHT
- CMP = Continental Manufacturing Procedure.
w.
Reviewed CMP 1C7, Revision 3 to verify the procedure for weld repairs included a requirement for the weld repair to be post weld heat treated and had been properly reviewed, approved and
- issued, i
x.
Review CMP 1D1 Revision 0 to verify that no inconsistencies l
existed between the two heat treat requirements.
It was verified that CMP IDI established heatLup and cooling rates not contained t
in CMP IC7, Revision 3.
y.
Review of Procedure no.Section IV (Legal)-9 dated 1/1/78 pro-viding measures for evaluating and reporting defects, to ascertain whether it is consistent with NRC regulations.
z.
Inspected the bulletin boards within the facility to ascertain whether Section 206 of PL 93-438 was posted and information is available to FC personnel which identifies the company officials-to whom identified defects and/or deficiencies are to be reported.
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8 Discussions with cognizant FCC QA/QC, Engineering and Management a.
personnel concerning the reported construction deficiency.
4.
Findings From the documents reviewed and personnel interviewed, it was deter-mined that:
The deficiency was initially identified by FCC personnel; a.
b.
Actions were initiated in conformance with procedures to perform preliminary analysis and evaluation of the problem for reportability.
c.
From a review of QA/QC documents and records it was determined that only nine valves containing aluminum-bronze discs which had been repaired by welding, and had not been PWHT, and all nine of these valves had been or were to be shipped, to Texas Utility, Inc.
Comanche Peak.
d.
Seven of the nine valves had been shipped to the customer and of the two which were still in-house, it was recommended that the disc of one of the valves be sent to FCC - Marshalltown for sectioning and examination of the micro-structure by a metallurgist, and a metallurgical Engineering report made as to what changes weld repairs might have in the "as cast" condition of alloy 954 aluminum-bronze, that it would require PWHT to restore.
e.
The customer and his agent, Gibbs & Hill (G&H) were notified of the problem, and meetings were held to develop an acceptable time i
table for the return of the seven valves with minimum disruption j
of the test and start-up schedules.
l f.
The cause of the noncompliance with the Code required PWHT of SB148 - alloy 954 aluninum-bronze material, was attributed to the fact that Table I-8.4 of Mandatory Appendices, of Section III of the ASME code established the allowable stresses of SB-148 grade 954, in the "as cast" condition, and note (5) was overlooked.
Note (5) specifies that SB-148-954 is to be PWHT at 1150-1200 F for 1 br. for the first inch of cross sectional thickness, and hr. for each additional inch.
(
It was explained and verified that SB 148-954 had not been an approved Code material until the Winter 1973 Addenda to Section II, and that Article ND 4623.3 of the 1973 Addenda stated that PWHT of nonferrous metal was not mandatory, therefore, the FCC WPS No. IC7, for GTAW process used to repair weld the aluminum-i bronze discs, was not revised to require PWHT.
The requirement
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for PWHT of this specific alloy of aluminum-bronze established in Table 8.4 note (5) was missed until later.
g.
It was verified that WPS No. IC7, Kevision 3, the GTAW process used in repairing aluminum-bronze material, requires PWHT in the identical language of note (5) in Table 3.4,Section III of the ASME code.
h.
The failure of the QA program to identify the code requirement to PWHT repairs made by welding is considered a deviation from Section 4.0 of the QA Manual which states that in order to assure compliance with the customer's DS, a Specification Design Review Committee is established to determine design and processing requirements of the Customer's order and the SDR Report to Manufacturing Engineering, did not identify that PWHT was required after weld repairs of the disc material.
(See Notice of Deviation.)
5.
Corrective Action a.
A schedule has been agreed upon for FCC to PWHT the discs of the nine valves scheduled for Comanche Peak Unit 2, and the return of the seven valves shipped for disassembly, heat treat discs to comply with code, reassemble, and return valves to the site.
6.
Action to Prevent Recurrence The WPC IC7 has been revised to include PWHT of alloy 954 aluminum-a.
bronze casting where repairs are made by welding. and all future components manufactured from SB-148 grade 954 will be processed with this procedure.
b.
The pertinent Procedures and Administrative Practice Bulletins l
for handling nuclear orders, are being revised as required to police, and verify, that the Specification Design Review Reports i
correctly identify contract and code requirements and that all such requirements are correctly accomplished.
c.
FC has installed an electric furnace, and Heat Treat Procedures for performing required PWHT in house.
d.
FC has qualified a new material manufacture who furnishes all aluminum bronze material in the tempered annealed condition.
7.
Generic Impact FCC determined that the only SB-148 grade 954 aluminum-btenze as cast discs, which required repairs by welding, were in the nine butterfly valves furnished to Texas Utility, Inc. for Comanche Peak 1.
Therefore, the problem is not generic to any other nuclear facility.
10 8.
Comments The FCC metallurgical eagineering analysis determined that weld a.
repairs without PWHT of alloy 954 aluminum-bronze, can result in a microstructure which is considered undesirable for applications for which the alloy is normally specified.
This alloy during a slow cool, will percipitate a third phase, producing a micro-structure that affects the material properties of the alloy, i
The tensile strength of 954 is increased by the presence
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of this third phase micro-structure, however, the impact tough-ness and ductility are detrimentally affected.
The third phase micro-structure also poses a potential for de-aluminification, which i
means that salt-water environment can attack and disolve the aluminum in the alloy, leaving a porous structure with potential leak paths through it.
However, the micro-structure examination of a representative disc made from SB148-954, and repaired by welding but not PWHT, shows that there is no detrimental third phase micro-structure in either the weld metal, or the heat affected zones adjacent to the weld repairs.
The absence of the detrimental third phase micro-structure shows that the cooling rate of this part following welding was sufficiently rapid to prevent the formation of the third phase microstructure.
b.
The Gibbs and Hill (G&H) metallurgical evaluation which was based on the mechanical properties recorded on the CMIRs for the i
heat of metal from which the nine discs were manufactured concluded that a postulated catastropic structural failure of the nine discs is not a creditable event.
c.
FCC now purchases its aluminum-bronze castings from AMPCO, in the tempered annealed condition.
It appears that AMPC0 has performed tests to demonstrate that once SB148 grade 954 has been heat treated, subsequent welding will not cause the precipitation of the undesirable third phase micro-structure.
Based on these determinations, AMPC0 is attempting to have the code changed to reflect this.
i D.
Exit Interview At the conclusion of the inspection on October 7, 1980, the inspector met with the company's management, identified in paragraph A, for the purpose of informing them as to the results of the inspection. During this meeting management was informed no deviations or unresolved items l
were identified.
O 11 However, subsequent to the inspection, a review of the measures implemented by FCC to ensure that the contract and code requirements are identified and incorporated in appropirate design and manufacturing procedures and documents.
From this review, it was determined that the Specification Design Review (SDR) C)mmittee should have identified the code requirement to PWHT repairs by welding any items manufactured from SB 148 grade 954 materials.
This item was discussed with the QA. Manager by phone and he agreed that the item had been inadvertently overlooked and was not identified on the SDR Report to Msnufacturing Engineering.
He was informed that the oversite constituted a d -iation and would be so reported.
He agreed with j
the finding.
The company's management acknowledged the inspector's statement and had no additional comments.
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