ML19347C139
| ML19347C139 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19347C133 | List: |
| References | |
| REF-QA-99900361 NUDOCS 8010160666 | |
| Download: ML19347C139 (2) | |
Text
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O' G. Dikkers and Company N. V.
Docket No. 9990036 /80-01 i
NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on June 12-13, 1980, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
Criterion V of Appendix B to 10 CFR 50 states:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Deviations from these requirements are as follows:
A.
Paragraph NB-4382 in Section III of the ASMF Code (1974 Edition through the Summer 1976 Addendum) states in part, "The essential variables for hard surfacing shall be the same as those for Corrosion Resistant Weld Metal overlay as given in Section IX...."
Paragraph QW-281.2, sub paragraph (e), in Section IX of the ASME Code states, with respect to Corrosion Resistant Weld Metal overlay process essential variables, "An increase, or decrease, of 100F or more in the minimum specified preheating temperature, or a change in the specified minimum or maximum interpass temperature." Paragraph QW-201.2 in Section IX of the ASME Code states in part, "The specific facts involved in quali-fying a WPS shall be recorded in a form called Procedure Qualification Record (PQR).
This form shall document the essential variables of the specific welding process or processes (as listed in QW-252 through QW-281) and the test results.
A change in any essential variable shall require requalification, to be recorded in another PQR."
i Contrary to the above, PQR E-Q 2443 00087 Rev. 2, which was identified as the qualifying record for shielded metal are hard surfacing WPS, EAP 2443 05001 Rev. 1, did not document the preheat and interpass temperature essential variables as listed in QW-281.2(e); in that the WPS permitted an increase in maximu;n interpass temperature and a reduction in minimum specified preheating temperature greater than 100 F.
B.
Welding Procedure Specification (WPS) EAP 2443.05001, Revision 1, a shielded l
metal are welding process for hard facing 6 required the use of 30-38 volts and an interpass temperature of 350 C-550 C (662 F - 1022 F).
The WPS l
further stated, "Interpass temperatures are to be measured with a contact l
thermometer."
l Contrary to the above, welding was observed being performed using the above procedure on Job No. ES 070, in which the following conditions were noted:
I 60201 6 J
i G. Dikkers and Company N. V.
2 i
l 1.
Interpass temperature, an essential variable, for this process, was j
not being measured, as the welder was not equipped to do so.
I 2.
The indicated voltage, a nonessential variable for this process, was between 22 and 24 volts.
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j C.
QA Manual Section 8.0, paragraph 8.9, states in part, "While approved Nuclear i
Vendors who were qualified by a Dikkers survey are manufacturing Code j
material, Safety Related Parts or providing Code services for Dikkers, the QA Manager shall annually schedule audits of each such vendor, to assure continued compliance with Code QA requirements. -- "
Contrary to the above, even though scheduled audits have been performed, i
certain ones did not assure compliance with Code QA requirements, in that j
an ASME Code violation was accepted, and certain ASME Code QA Program i
areas were not audited.
(Details Section, paragraph D.3.a.)
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