ML19351E729
| ML19351E729 | |
| Person / Time | |
|---|---|
| Issue date: | 10/07/1980 |
| From: | Barnes I, Ellershaw L, Roberds H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351E716 | List: |
| References | |
| REF-QA-99900047 NUDOCS 8012190104 | |
| Download: ML19351E729 (11) | |
Text
n 6.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900047/80-02 Program No. 51300 Company: Westinghouse Electric Corporation Nuclear Components Division Tampa Plant Tampa, Florida 33686 Inspection Condu ted: September 8-12, 1980
/
I v
km O_L V
/0 7 [D Inspectors: o L. E. Ellershaw, Contractor Inspector pat 6 ComponentsSection II Vendor Inspection Branch
/ c/-7 /!?O
[ey-H.W.Roberds,ContractorInspector Date ComponentsSection II Vendor Inspection Branch m
Approved by:
dw
/o/7 /90 I. Barnes, Chief Date ComponentsSection II Vendor Inspection Branch Summary l
Inspection conducted September 8-12, 1980 (99900047/80-02) l l
Areas Inspected:
Implementation of quality assurance program in accordance with 10 CFR 50 Appendix B criteria, and other applicable codes and regulations
(
including: previously identified findings; design process management; design verification; design document control, and followup on a potential construction deficiency report.
The inspection involved 62 inspector hours on site by two NRC inspectors.
Results:
In the five areas inspected, there were five deviations from commit-ment identified and one previously identified deviation remaics open.
Deviations From Commitment:
Deviation against committed corrective action -
kTP is still failing to maintain segregation and identity of welding materials in holding ovens (See Notice of Deviation, It.em A.).
[
8012190 M
2 Deviation against committed corrective action - WTP did not address thermal gradients in a longitudinal direction.
(See Notice of Deviation, Item B).
Welding Material Control - the required chemical analysis of combinations of weld wire and fluxes was not performed.
(See Notice of Deviation, Item C.1.).
Design Document Control - manufacturing was not performed in accordance with approved work instructions and drawings (See Notice of Deviation, Item C.2.),
and the Reproduction Center did not send a copy of the release document to Product Assurance for a particular drawing.
(See Notice of Deviation, Item C.3.).
3 DETAILS SECTION I (Prepared by L. E. Ellershaw)
Persons Contacted R. H. Anderson - Manager, Field Reliability and QA J. W. Bradley - Manager, Processes Engineering T. Brown - Internal Audit Coordinator R. H. Dunn - Supervisor, QA Records R. L. Frolich - Process Engineer J. Goossen - Structural Mechanics Engineer L. Malizia - Process Engineer T. D. Miller - Manager, Product Assurance J. P. Mortara - Manager, QA P. M. Parker - Quality Assurance Engineer N. Ryan - Quality Control Technician B.
Action on Previous Inspection Findings 1.
(Closed) Deviation A (Report No. 80-01):
This item dealt with 4
Quality Assurance closing out-an internal audit finding dealing with a procedure revision, without performing a reaudit or verifying that agreed steps to prevent recurrence had been accomplished as committed.
WTP implemented the committed corrective action in that the procedure has been revised, and all internal audit findings are now being verified for implementation.
In addition, the QA Manual was revised to delete differentiation between major and minor audit findings.
2.
(Open) Deviation B (Report No. 80-01):
This item dealt with the following:
a.
Process Specification PS 83032GY, revision 4, did not either l
address permissible thermal gradients, or provide any criteria that would assure diminishing temperature outwards from the controlled band.
b.
Monitoring cf actual developed gradients was neither required of nor performed by the vendor during the heat treatment cycle.
l l
l WTP's response letter dated May 13, 1980, stated in part, "MRR l
034572 was written concerning the acceptability of the thermal l
stresses generated during the local postweld heat treatment l
MRR 034572 dealt specifically l
with the deviations from Process Specification 83032GY and the l
l
T l
4
{.
effects, if any, of the temperature gradients during the PWHT cycle."
l While the above did occur, it did not address the finding relative to the Process Specification failing to address i
permissible thermal gradients or providing criteria.that i
would assure diminishing temperature outwards from the con-trolled band. Further, it did not address monitoring of actual gradients during the heat treatment cycle.
The MRR dealt with circumferential temperature gradients, but not longitudinal gradients.
j As a result, a deviation against committed corrective action was identified.
(See Notice of Deviation, Item B.).
3.
(Closed) (Deviation C. Report No. 80-01): This item dealt with the forwarding of a signed Material Review Request Card and a completed Material Review Request-from (MRR) to records, without the disposition j
being satisfactorily completed with respect to Neater Well No. 97 e
in Pressurizer Shop Order THPT 2161.
The heater well was accepted J
with a sleeve wall thickness of 0.130" after rolling,_when the MRR j
required a' wall thickness of 0.136" - 0.143" -to be maintained.
?
WTP implemented their committed corrective action, in that the specific MRR has been corrected to reflect subsequent MRRs and l
Engineering Calculation Note JEG-1-3-14-80 was performed in which calculations supported the use of a wall thickness as low as 0.128",
without affecting the design criteria. The lack of cross reference between MRRs created this problem. A work place meeting was held on June 13, 1980,
. with all personnel involved with MRRs to review existing procedures and requirements dealing with MRRs.
i l
4.
(Close'd) Deviation D. (Report No. 80-01): This item dealt with proper' inspection operations necessary for repair welding of: shielded metal.
arc cladding on aanway bores in the steam generator channel head for l
Shop Order PCGT 2584, were not delineated on MRRT No. 033494, i.e.,
checking of cavity depths after grinding in cladding and/or base metal to determine the necessity for-additional postweld heat treet-ment.
In addition, the applicable QA document relative to cladding measurement, T.Q.A.I. No. 1.10.4 addressed measurement of clad thick-ness only for. cladding deposited by the automatic process.
l l
WTP_ implemented their committed corrective' action in that the mea-E surements of the cavities on this channel head had been taken, but not documented, as verified by the cognizant Quality Control' Technician.-
In addition,'a memo, dated August 26, 1980, was issued by. the Manager, l
l r m 's e
--e'--
t-e'-
~~e-wvP4-we+=w-e-
+-w'-v
- e'*e WW-e 9
r g.
1=---iw
+m*ee-+
w er--'-*3--
w m:
e.-i6i--'-
+
--t----*s
--pr%-*ei
5 Quality Assurance, to all QA Engineers, QC Technicians, QC/NDE Supervisors, and Manufacturing Engineers, stating in part, "it is imperative that verification of minimum wall, minimum clad, clad grindout depth,.ad any required NDE or welding (clad) occuring after PWHT be included in the feeder traveler information.
. or MRRT.
...These verifications must be performed and documented even though drawing dimensions have not been violated."
In addition TQAI 1.10.4 was revised, excluding reference to automatic clad only.
5.
(Closed) Deviation E (Report No. 80-01):
This item dealt with the wording of gas tungsten are welding procedure specification PS 82127 ML, which permitted changes in amperage and filler wire size, both nonessential variables for the process, without amendment to the WPS or a new WPS being required.
WTP implemented ';)eir committed corrective action in that PS 82127 ML was revised to eliminate the permitted changes in amperage and filler wire size.
A review of WPSs by Processes Engineering, was performed to verify compliance with ASME Section IX.
6.
(Closed) Deviation F. (Report No. 80-01): This item dealt with WTP's failure to maintain segregation and identity of welding materials stored in holding ovens.
WTP did perform corrective action in that the electrodes in question were segregated and the weld map on the oven door was corrected.
In addition, a meeting was held with all storeroom personnel on April 16, 1980, to review the requirements for segregation and maintenance of weld material identity.
l However, the actions taken to prevent recurrence were not adequate-in that the same type deviation was identified during this inspection.
A holding oven was identified with a map, which showed that the oven
~
l contained 3/32" Inco electrodes, Test Number TO 7647. _However, the oven also contained two canisters of 3/32" electrodes, identified as 8N12, which were not shown on the map, and which could not be traced to a Test Number.
(See Notice of. Deviation, Item A.)
In addition, during the review of welding material control, a review of specific heats of weld wire and batches of flux used,-was conducted.
Shop Order CDGT 2113 reflected the use of type 309 weld wire, heat number 8304 with flux, batch numbers 8321 and 7641, and type 308 weld wire, heat 8325 with flux, batch number 7641.
These materials were used in a
" buttering" or nozzle build-up operation. 'WTP did not have the chemical analysis as required by the ASME Code.
(See Notice of Deviation, Item C.1.).
g e
4 m
6 7.
(Closed) Unresolved Item No. C.3.b.(1). (Report No. 80-01):
This item dealt with interpretation of ASME Code,Section III, paragraph NB-4624.
WTP performed a PWHT of a repair weld in a circumferential weld in which the weld repair region was heat treated in the 1100-1150 degrees F temperature range.
However, a 250 degree F maximum temperature differential was permitted in the balance of the weld seam. The wording of NB-4624 could be interpreted, however, as requiring the entire seam to be heated after a weld repair to the range specified, i.e., 1100 - 1250 degrees F.
WTP submitted an inquiry to ASME and received a response dated August 28, 1980, which stated in part, "During heatup, soak and cooldown, the areas within the 15 feet band shall meet the 250F difference limitation. The soak cycle period may be initiated when the repaired area has reached the minimum required heat treat-ment temperature."
8.
(Closed) Unresolved Item C.3.b.(2)).
(Report No. 80-01): This item dealt with a WTP heat treatment sketch which permitted a temperature gradient of 250 degrees F between the weld repair region and any of the quadrant position thermocouples, which were spaced at approxi-mately 9 foot intervals. This allowed a gradient of approximately 28 degrees F/ft from the repair region.Section III of the ASME Code permits a temperature differential of 250 degrees F in any 15 ft. interval of weld length during the heating and cooling cycle, which is approximately 17 degrees F/ft.
Depending on the interpretation of the ASME Code requirement, this heat treatment could be regarded as either being in compliance or in violation of the ASME Code.
WTP submitted an inquiry to ASME and received a response dated i
August 28, 1980, which stated the question and response as follows:
" Question 1:
shall NB-4623 be interpreted to imply that temperature gradients less (than) 250 degrees F are required for distances less than 15 feet? Reply 1:
No."
9.
(Closed) Unresolved Item D.3.b.(1). (Report No. 80-01): This item l
dealt with a full bag of submerged are flux in the flux storage area, which had been accidentally torn, thereby exposing the flux to atmosphere.
WTP process specifications showed no programmatic requirements with respect to minimizing absorption of moisture in fluxes used for ferritic welds.
Westinghouse Research Memo 71-1D4-WELDS-M1 shows the results of an evaluation of fluxes to establish the moisture levels as received from the manufacturer, and their hygroscopic tendency when exposed to a high humidity environment.
7 The key result is that fused fluxes do not pick up chemical moisture and that baking the flux, prior to use, at 230 degrees F is sufficient to return the flux to its original low, manufactured level.
In addition WTP procedures require a 500 degrees F bake of all fluxes prior to use.
C.
Followup on Potential Construction Deficiency Report Houston Lighting and Power Co. (HL&P) notified Region IV, on April 3,1980, of a potential deficiency involving a linear indication in the Inconel
" belly band" cn the cold leg steam generator nozzle.
It was later deter-mined by the licensee to be a non-reportable deficiency.
A review of documentation associated with the particular steam generator involved, showed that WTP had performed a liquid penetrant examination of the Incocel " belly band" on June 14, 1978. An indication was observed which necessitated grinding and weld repair. After completion of repair welding, an additional liquid penetrant examination was performed on June 15, 1978, and the repair was accepted. A review of additional travelers for steam generators in which Inconel " belly bands" are deposited on no.-zles, revealed that all undergo a liquid penetrant examination. The liquid penetrant examinations were documented and signed-off by WTP LII NDE personnel.
It could not be ascertained as to why this particular linear indication was not identified by WTP.
D.
Exit Meeting A meeting was held at the conclusion of this inspection on September 12, 1980, with the following management representatives and the Authorized Nuclear Inspector (ANI):
A. M. Bandman - Manager, Materials Procurement l
L. Conway - Manager, Engineering J. A. Fertic - Manager, QC/NDE E. P. Loch - Manager, Manufacturing Planning l
C. R. Madonti - Manager, Materials and Commercial Operation T. D. Miller - Manager, Product Assurance J. P. Mortara - Manager, Quality Assurance J. A. Tortorice - Manager, Compenent Design L. T. Willey - ANI, Lumbermen's Mutual & Casualty Company The scope and findings of this inspection were summarized. Management acknowledged the statements made by the inspectors. Management was i
also informed that further review would be conducted by the inspectors upon their return to the Region IV office, which might result in additional findings.
As a result of the additional review, it was determined that a previously identified deviation would remain open, and an additional deviation against committed corrective action was identified.
8 DETAILS SECTION II (Prepared by H. W. Roberds)
A.
Persons Contacted L. Conway - Manager Tampa Engineering R. L. Sylvester - Component Design Engineer J. P. Mortara - QC Manager W. H. Beckley - Senior QA Engineer V. V. St ate - Design Control Engineer H. E. Johnson - Manager, Drafting Services B.
Actions on Previous Inspection Findings (Resolved) Unresolved Item (paragraph D.3.b.(2) Inspection Report No. 80-01)
E Specification G953431 revision 0 required the manufacturer to prepare and submit a quality plan for review and concurrence for components with a nonnuclear safety classification.
The inspector verified that a quality plan had been submitted and approved for six (6) purchase orders of 7/9/80.
C.
Design Process Management 1.
Objectives The objectives of this area of the inspection were to determine if procedures had been prepared to prescribe a system for the design process management, which is consistent with the commitments of the Quality Assurance Program, and, that the design process procedures are being properly implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 2 of the QA Manual " Design Control" b.
Review of the following documents to verify that procedures had been prepared, approved and reviewed in accordance with the QA program requirements (1) SPD Number PQ3-003.0 " Preparation of Emergency Manufacturing Information" (2) SPD Number PQ3-002.1 "G-Letter Procedure."
9 (3) SFD Number PQ2-004.0 " Release and Control of Design Specifications."
(4) SPD Number PQ2-001.1 " Drawing Control Procedure."
(5) SPD Number PQ2-003.0 " Request For Engineering Drawing Change."
c.
Review of Equipment Specification 953236 of 11/19/76 "Model F Steam Generator Reactor Coolant System" d.
Review of Equipment Specification G-953431, "Model D-5 Steam Generator."
3.
Findings Within this area of the inspection, no deviations from commitments or unresolved items were identified.
D.
Design Verification 1.
Objectives The objectives of this area of the inspection were to determite that procedures had_been prepared and approved, which prescribe a system for design verification that is consistent with the commitments of the Quality Assurance Program, and, ascertain that the procedures are effectively implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the Quality Assurance Program Manual, Section 3.0,
" Design Control".
b.
Review of the Quality Assurance Program Manual, Section 6.0,
" Document Control".
c.
Review of ten (10)' drawings-for the following:
l (1)
Independent verification by others than those who performed I
the original design (2) Drawings had been reviewed and approved by Product Assurance.
d.
Review of Design Procedures for signatures and dates of individ-ual who prepare, review and approve the procedure, including l
revisions.
10.
Interviews with cognizant personnel.
e.
3.
Findings Within this area of the inspection, no deviations from commitments or unresolved items were identified.
E.
Design Document Control 1.
Objectives The objectives of this area of the inspection were to determine that procedures had been prepared and approved, were prescribe a system for design document control that is consistent with the commitments of the Quality Assurance Program, and, ascertain that the procedures are effect ively implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the Quality Assurance Program Manual, Section 3.0,
" Design Control".
b.
Review of the Quality Assurance Program Manual, Section 5.0
" Instruction, Procedures and Drawings".
c.
Review of S.P.D. No. PQ2-001.1 " Drawing Control Procedure".
d.
Review of S.P.D. PQ2-008 " Drawing Preparation Procedure".
l e.
Reveiw of S.P.D. PQ2-003.0 " Request For Engineering Drawing Change".
[
3.
Findings a.
Deviations From Commitments (1) See Notice of Deviations, Item C.2.
Section 5.0 of the Quality Assurance Program Manual, paragraph 5.3.1 states in part, " Manufacturing, inspection and test activities are performed in accordance with approved work instructions, feeder travelers and drawings Contrary to the above, canufacturing was not performed on shop Order No. XART 3094 Item AAD, Mid-deck plate in accordance with approved work instructions, in that the i
L.
11 feeder traveler referenced drawing No. 1513E87 sub 2, which identified and located 202 2 inch diameter flow holes.
The plate, however, was manufactured with 208 2 inch diameter flow holes.
In addition to the above, the following items require clarification.
(a) Engineering was aware of the necessary revision to drawing 1513E87 sub 02 on 7/3/80 and did not initiate an Engineering Change Notice until 8/14/80.
(b) Manufacturing continued to work to undocumented instruc-tiens and completed shop orders XART 3093 and 3095, which did not conform to the drawing sub reflected on the Authorized Drawing List.
(c) Mid-deck plate 3094 was installed in 3093 FPL upper internals without the necessary d; umented changes.
(d) The completed copies of the ECN had not been received by data control as of 9/10/80 although the revised drawing, 1513E87 sub 3, had been released on 8/29/80.
(2) See Nutice of Deviation, C.3.
b.
Unresolved Items None.
i I