ML19347C141
| ML19347C141 | |
| Person / Time | |
|---|---|
| Issue date: | 07/18/1980 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19347C133 | List: |
| References | |
| REF-QA-99900361 NUDOCS 8010160676 | |
| Download: ML19347C141 (8) | |
Text
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4 U. S. NUCLEAR REGULATORY COMMISSION I
0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900361/80-01 Program No. 51300 3
Company:
G. Dikkers and Company N.V.
j Industriestaat 15, P. O. Box 12 1
7550 AA Hengelo, Province of Overijssel
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THE NETHERLANDS l
Inspection conducted:
June 12-13, 1980 i
Inspectors:
O"o 7.df/$ o I. Barnes, Chief Date ComponentsSection II Vendor Inspection Branch b
$8A 7AC/sc gi - L. E. Ellershaw, Contractor Inspector Date l
ComponentsSection II Vendor Inspection Branch I
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Approved by:
8W v4Wl'c I. Barnes, Chief Date
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ComponentsSection II Vendor Inspection Branch a
Summa ry 4
Inspection on June 12-13, 1980, (99900361/80-01)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B, criteria and applicable codes and standards; including action on previous inspection findings, joint fitup and welding, evaluation of supplier performance and control of noncon-i formances.
The inspection involved thirty-two (32) inspector-hours on site by two (2) NRC inspectors.
Results:
In the four (4) areas inspected, no deviations or unresolved items were identified in two (2) areas, with the following deviations being identified in the remaining areas:
Deviations: Joint Fitup and Welding --- Qualification of hard surfacing welding l
procedure specification EAP 2443 05001 Rev. I was not in accordance with Criterion l
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V of 10CFR 50, Appendix B, and the preheat and interpass temperature essential j
variable requirements contained in paragraph NB-4382 in Section III of the 2
ASME Code and paragraphs QW-201.2 and 281.2 in Section IX of the ASME Code
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(Notice of Deviation, Item A.).
Shielded metal are hard surfacing operations I
were not performed in accordance with Criterion V of 10 CFR 50, Appendix B,
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and the voltage and interpass temperature requirements of the applicable j
welding procedure specification, EAP 2443 05001 Rev. 1 (Notice of Deviation, 1
Item B.),
i Evaluation of Supplier Performance --- Performance of vendor audits was not i
in accordance with Criterion V of 10 CFR 50, Appendix B, and Section 8 of the
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QA Manual with respect to assuring vendor compliance with ASME Code requirements (Notice of Deviation, Item C.).
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DETAILS SECTION i
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(Prepared by I. Barnes and L. E. Ellershaw)
A.
Persons Contacted 1
C. S. Craig, Chief Executive
- R. J. Howe, Technical Manager
- J. C. G. Heetebrij, Works Manager, Valve Plant
- H. Oude Vrielink, Acting Quality Assurance Manager J. A. Grobben, Quality Assurance Consultant K. Knijnenberg, Welding Supervisor G. W. Koers, Quality Assurance Engineer i
J. Wilts, Metallurgist and Welding Engineer
- Denotes those persons attending the exit meeting.
l B.
Action on Previous Inspection Findings (I. Barnes) 1.
(Closed) Deviation (Item D, Notice of Deviation, Inspection Report i
No. 79-01):
Digital thermometer used in production welding not j
calibrated at specified period.
4 The inspector verified that the calibration function had been transferred to the Works '" _ager's organizational responsibilities and satisfactory Quality Assurance audit criteria had been developed and were being utilized.
2.
(Closed) Deviation (Item F, Notice of Deviation, Inspection Report No. 79-01): Absence of QA Manager approval of drawing revision 4
numbers in the Project Engineering Index.
The inspector verified that the committed QA Manual revision, which eliminated the necessity for QA Manager approval of drawing revision j
numbers, had been approved and implemented.
l 3.
(Closed) Deviation (Item I, Notice of Deviation, Inspection Report No. 79-01): Absence of heat code marking on socket head cap screws located in the accepted nuclear material hold area.
The inspector verified that the committed QA Manual revision, which provided for container identification for items one inch or less nominal diameter, had been approved and implemented.
4.
(Closed) Deviation (Item A, Notice of Deviation, Insection Report No.
79-02):
Absence of QA Program provisions for assuring the quality of safety related parts, other than those coming under the jurisdiction of the ASME Code.
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4 The inspector verified that programmatic actions had been taken, by QA Manual revision and by preparation of a supplement to the Nuclear QA Manual, to provide for future client definition of safety related items and addition of vendors of safety related items to the Nuclear Vendors List. Written statements had also been obtained from the two major subcontractors, Sempress b.v. and Seltz A.g., a testing to compliance with all purchase order requirements.
l 5.
(Closed) Deviation (Item B, Notice of Deviation, Inspection Report No. 79-02): Revised internal audit program was not implemented by
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committed corrective action response letter date.
The inspector verified that the internal audit procedure, QA 000002 Revision 2, had been implemented on a comprehensive and continuing basis.
6.
(Closed) Deviation (Item C, Notice of Deviation, Inspection Report No. 79-02): Failure to use ASME Section III required production welding preheat and interpass temperature ranges in the preparation of a qualification test plate for certain coated electrodes.
The inspector verified prior to the inspection, that the submitted l
revised welding material specification provided for the use of current production welding preheat and interpass temperature ranges.
During i
the inspection a review was made of the mechanical property information j
obtained from re-testing the identified electrodes, to assure their adequacy with respect to Code and customer requirements.
7.
(Closed) Deviation (Item D, Notice of Deviation, Inspection Report i
No. 79-02): Failure to review a certain completed Nonconformance Report with the ANI for his acceptance of the completed resolution.
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The inspector verfied that the referenced Nonconformance Report and associated traveler had been reviewed by the ANT, documented re-instruction had been given to the QA Engineers and committed audits had been implemented with respect to the use and completion of Non-conformance Reports.
8.
(Closed) Deviation (Item E, Notice of Deviation, Inspection Report No. 79-02):
Shop Order Travelers not functioning as master control 4
documents for the performance of all required examinations, inspections, reviews, witness and hold points, in that caseings and valve items were released to stores as acceptable without performance of all required inspection and review activities.
1 The inspector verified that weld material identification had been added to the affected travelers, new NDE reports had been designed and were in use and current Shop Order Travelers had been revised 4
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i to require QA Engineer audit prior to transport of items to stores.
1 It was additionally established that the QA Manual had been revised to clarify traveler sign-off requirements and committed training had been conducted.
J 9.
(Closed) Deviation (Item F, Notice of Deviation, Inspection Report i
No. 79-02): Scope and documentation of Charpy-V impact testing of l
seat forgings was not in accordance with the requirements of the material specification and Section III of the ASME Code.
j The inspector verified that the committed sketches had been prepared, which depicted specimen orientation and location.
A review was made for adequacy of the impact test data generated from a forging processed j
in the previously untested heat treatment load and it was verified that the QA Engineer had received a training course on procurement control requirements.
It was additionally noted that the internal audit program had been prepared to include this subject matter in the scope cf activities.
10.
(Closed) Deviation (Item G, Notice of Deviation, Inspection Report 4
No. 79-02):
Inclusion of a vendor on the Approved Vendors List, who had been identified by Dickers survey to have QA program deficiencies, and without any statement on the survey report by the QA Manager l
regarding vendor qualifications or limitations of use.
The inspector verified that the vendor was not currently on the Approved Vendors List, a QA Engineer had been given sole responsi-bility for control of internal and external auditing, and that a corrective action system for audit findings had been devised and 4
implemented by the assigned individual.
C.
Joint Fitup and Welding (L. E. Ellershaw) 1.
Objectives The objectives of this area of the inspection were to verify that G. Dikkers & Co. had implemented the requirements for the control of joint fitup and welding in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 14.0, " Welding," issue 12.
b.
Observation of in-process hard facing, using the shielded netal are process (SHAW), on Job No. ES 070.
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c.
Review of welding procedure specification (WPS) EAP 2443.05001 j
revision 1 and a comparison between the required parameters and those being used as observed in b. above.
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d.
Discussions with cognizant personnel.
3.
Findings a.
Deviations From Commitment I
(1) See Notice of Deviation, Item A, (Prepared by I. Barnes).
.1 (2)
See Notice of Deviation, Item B.
It should be noted, that the above deviation was detected during the only in process welding observed during chis inspection.
Operation 10k of traveler 4423.1525./0100. revision 4, required i
SMAW hard facing on a Disc, using WPS EAP 2443.05001, revision j
1.
The Stellite electrodes being used, were from Heat No. 2802 j
and were 3/16".
j b.
Unresolved Item None.
l D.
Evaluation of Suppliers Performance (L. E. Ellershaw) i 1.
Objectives The objectives of this area of the inspection were to verify that G. Dikkers & Co. had implemented the requirements for evaluating their supplier's performance in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplihsment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 8.0, " Procurement Control," issue 12.
b.
Review of Approved Nuclear Vendor List, revision 13 dated May l
27, 1980.
c.
Review of seven different vendor history files, which included vendor audits, checklists and reports.
d.
Discussion with cognizant personnel.
7 3.
Findings a.
Deviation From Commitment I
See Notice of Deviation, Item C. Audit Check List Section 10 (NDE) of Vendor Audit Report No. 012/3 dated February 13-14, 1980, states, " Black light intensity checked for MT examination."
1 The Dikkers' auditor responded with, "Yes. Every two months.
j Records of examination are maintained." This item, accepted by Dikkers, is contrary to ASME Code Section V, Article 7 require-ments, in that paragraph T-725.3 requires a black light intensity j
check at least once every eight hours.
In addition, the audit l
check list did not address corrective action and audits, which are ASME Code QA Program requirements.
The Vendor Audit Report shows that there were two findings, neither of which has been responded to by the vendor.
Vendor Audit Report No. 032/4, dated October 16, 1979, shows that the only QA Program areas audited were calibration, heat treatment i
and nondestructive examination.
The vendor was approved, without j
limitations, even though two deviations were identified and just j
one has been responded to.
j b.
Unresolved Item None.
i E.
Control of Nonconformances 1.
Objectives 1
The objectives of this area of the inspection were to verify that G. Dikkers & Co. had implemented the requirements for the control of nonconformances in accordance with the QA Manual and applicable NRC and ASME Code requirements.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 19.0, "Non-Conformities," issue 12.
b.
Review of eight Non-Conformity Reports (NCR) in which disposition had been made, to assure ANI's concurrence.
c.
Review of two Repair Travelers associated with NCRs having a repair dispostien.
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d.
Observation of nonconforming material, to assure that material is identified with Hold Tags.
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Review of monthly Defect Analysis Reports.
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Discussion with cognizant personnel.
3.
Findings a.
Deviation From Commitment
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None.
1 b.
Unresolved Item None.
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F.
Exit Meeting An exit meeting was held on June 13, 1980, with the management representa-tives denoted in paragraph A, above.
The inspectors summarized the scope and findings of the inspection and informed management that a final further inspection would be recommended to NRC management on the inspectors return to the U.S.A.
Management acknowledged the statements of the inspectors and commented, with respect to the ficding identified as item A, in the l
Notice of Deviation, that the current qualification status of this welding procedure specification had been discussed with, and had the approval of, their former Authorized Nuclear Inspection Specialist.
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