ML20003D882
| ML20003D882 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/1981 |
| From: | Barnes I, Ellershaw L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20003D878 | List: |
| References | |
| REF-QA-99900342 NUDOCS 8104010328 | |
| Download: ML20003D882 (7) | |
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U.S. NUCLEAR REGULATORY CCMMISSION I
OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900342/80-02 Program No. 51300 Company:
Lakeside Bridge and Steel Company 5300 North 33rd Street Milwaukee, Wisconsin 53207 Inspection Conducted:
December 15-19, 1980 A
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Inspector:
D.'
i,b b D S T/
L. I. Ellersnaw, Contractor Inspector Date Comocnents Section ~
Vendor Inspectior anch
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?- Si Approvec ty:
I. Sarnes, Chief Qate CcmconentsSection II Vencor Inspection Brancn Summary Inspection concucted Decemcer 15-19,1980 (999003a2/30-02)
Areas Inscected:
Implementation of 10 CFR 50 Acpendix 3 criteria, and applicaole coces and standards, including:
a Construction Deficiency Report; weld heat treatment, and welding material control.
The inspection involved 34 inspector-hours on sita.
Results:
In the three areas inspected, no deviations from commitment and two unresolved items were identified.
Unresolved Item:
Followup on a Construction Deficiency Report - Acc.eotance of a corrective action request response frcm a subcontractor, whicn did not address the cause of conditions adverse to quality (Details Section, paragraph 3.4.c).
Weld Heat Treatment - Identification (on a Tianufacturing process sheet for a postweld heat treated steam generator lateral sucport) of the use of a welding procedure scecification that was not cualified for a postweld heat treatment application (Details Section, paragraph C.3.b.).
l 810401032?
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OETAILS SECTION (Prepared by L. E. E11ershaw)
A.
Persons Contacted t
F. Cullen - Welding Foreman W. Jonas - NDE Level III Examiner R. T. Rozek - Director, Quality Assurance T. Smith - Chief Planner Y. T. Smith - Chief Weiding Engineer A. J. Was - Quality Assurance Engineer 3.
Follow-uo Cn A Construction Deficiency Recort (CDR):
===1.
Background===
A CDR was initiated by Duke Power Co. (Catawba Unit 1) on June 12, 1980, relating to defective welds being visually detected in an equipment hatch.
The equipment hatch and flange was fabricated by Lakeside Bridge & Steel Co. (L3&S), with certain welding and NDE performed by Chicago Bridge & Iron Co. (C3&I) on the flange to barrel section.
2.
Obiectives The objectives of this area of the inspection were to determine any generic implications and to verify that LS&S had taken the necessary steps to assess, correct, and preclude recurrence of the problem.
3.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of contractual requirements between Duke Power Co. and LS&S and, the requirements passed on to CS&I by LS&S.
b.
Review of correspondence between Duke and LS&S after the defective welds were discovered.
c.
Review of CS&I's Ultrasonic Test Procecure, UT1, Revision 0, dated March 12, 1979.
d.
Review of CB&I's Shoo Check List and UT Examination report for the No.1 Ucper Barrel.
a
3 Review of NDE qualifications for C3&I personnel performing the e.
shop ultrasonic examinations (UT).
f.
Review of Nonconformance Report No. 771-10, including recommended disposition, which was submitted to Duke by LS&S on June 5, 1980.
g.
Review of the resultant weld repair records, including verification of welding materials used in making the repairs.
h.
Review of UT and MT (magnetic particle examination) reports after repairs had been accomplished.
i.
Review of Corrective Action Request No. 54, wnicn requested C3&I to investigate the possible causes for their failure to detect defects during the performance of UT examination.
j.
Discussions with cognizant personnel.
4 Findincs a.
General Duke Power Comoany notified NRC Region II cy telepnene on June 12, 1980, that defective welds (slag inclusions) had been visually detectec during tne machining of certain weld preps.
As a result, Duke performec a UT examination and identifiec five areas wnicn they considered questionable.
The welds in question are in the area between the upper barrel and the containment flange.
LE&S fabricated the equipment hatch, barrel halves, and flange, including welding the equipment hatch to the uoper barrel, and CB&I welded the flanges to the barrel halves and UT examined those welds.
The configuration was such that radiography could not be performed.
The balance of welding and NOE is performed in the field.
Duke notified L3&S, who in turn, went to the site (Catawoa I) to review Ouke's findings.
L3&S performed a UT examination of the entire area.
Four locations were discovered with rejectable indi-cations.
The lower barrel to flange contained one which was lh" long, while the uoper barrel to flange contained three which were lh", l\\",
and 5 " long.
Duke requested L3&S to submit a Nonconformance Report (NCR) with a recommended repair disposition.
NCR 771-10 dated June 5, 1980, was sucmitted by LS&S and Duke accepted the disposition on June 5, 1980.
LE&S requested C3&I to accomcany them to the site for verification purposes.
The agreement reached at the site, was for LS&S to effect the repairs.
This was accomplished during the week of June 9, 1980.
UT and MT examinations on June 11,19e0 showed the recairec areas to be accectable.
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The inspector reviewed the weld repair reccrds, including:
welder's qualifications; welding procedure specification and its qualification, and the welding material qualifications.
In addition, the NDE reports, procedures and the qualifications of the personnel performing the NDE were reviewed.
LS&S subsequently sent a Corrective Action Request (No. 64) dated September 22,1980, to C3&I, requesting a written resconse relative to C3&I's assessment of the cause of the condition and their corrective action to prevent recurrence.
CB&I's response, dated October 27, 1980, and accepted by L3&S on November 3, 1980, addressed the fact that their UT procedure was written in accordance with Section V of the ASME Code.
They went on further by discussing the re-examinations performed at the site by both LB&S and CS&I using a 45 degree and 60 degree transducer.
CS&I's contention was that wnen using a 45 degree transducer, three of tne four indications were accentable and the fourth was a " borderline type defect," wnich they accepted as meeting tne acceptance criteria of their procedure.
However, wnen using a 60 degree transducer, two of the indications were rejectacle wnile the other two were "somewnat questionacle because of the lengtns of the defects."
LE&S's position was that all four indications were rejectable.
Regarding corrective action, CS&I stated, "On future work, consider-atign will ge given to the use of two different angle transducers (45 and 60 angles) for certain weld joint geometries sucn as encountered on this job, even though the two angle search is not required by ASME Section V, Article 5."
It would appear then, that in this case, the 60 angle transducer was better suited for detecting and defining these four indications.
ReviewgftheCB&I
'op UT examination reports indicated the use of a 60 angle transducer.
The C3&I corrective action response letter did not address, however, the failure of the snop examinations to detect the rejectable indications, that we5*ang'b5*4"*"t Y *St b-5 lished to exist by site examination with a 60 le transducer.
It was determined thet the only other nuclear work performed by CS&I for L3&S, was on a steam generator sliding base for St. Lucie 2.
This work was classified as non ASME.
During that joo, LE&S monitored the UT performed by CS&I.
L3&S stated that they had monitored scme MT, but no UT performed by C3&I on the Duke job.
They also cerformed a final visual examination before sniement.
5 b.
Nonconformances i
- None, c.
Unresolved Item The ASME Code requires that conditions adverse to quality, the cause of the condition, and the corrective action taken shall be documented, and that these requirements shall also extend to the performance of a subcontractor's corrective action measures.
Based upon the information available during this inspection (corrective action request and response), it ould accear that L3&S accepted a subcontractor's response without obtaining a documented cause for that subcontractor's failure to identify rejectable indications during shop UT examination.
C.
Weld Heat Treatment 1.
Obiectives The cojectives of this area of the inscection aere to verify tnat L3&S had implemented the requirements for the control of postweld heat treatment (PWHT) in accordance with the CA Manual and appli-cable NRC and ASME Code requirements.
2.
Method of Accomolishment The preceding objectives were accomplished by:
a.
Review of QA Manual Section 12, " Heat Treatment."
b.
Review of procedure No. 2.1, " Procedure and Specification For Thermal Stress Relieving For P and P aterials."
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c.
Review stress relief furnace load records and heat treat charts for components used in contracts C-9182 and C-9233.
d.
Review records of welding procedure specifications used and their procedure qualification records.
e.
Review of welding materials used and their certified material test recorts to ascertain their qualification for use in a PWHT condition.
f.
Discussions with cogni: ant personnel.
6 g.
Review of Manufacturing Process Sheets (MPS) used to delineate the applicable procedures to be used, and to provide for oper-ation performance sign-off.
3.
Findings 1
a.
Nonconformances None.
b.
Unresolved Item Ouring review of the MPSs, WPSs and PWHT Charts for the Steam Generator Lateral Support, No. 25-0-1-2, the following information was octained.
MPS 25.0.1 showed that certain weld seams had been welaed and subsecuent PWHT had been performed.
The WPSs and welding materials used, had been qualified for use in the P%HT condition.
The next '95 for this assemoly (MPS 25.0.1 X1) was issued and it shess it welding was performed on adcitional seams with a sign-of of April 15, 1980.
PWHT was signec-off on a
April 28, Subsecuent magnetic particle examination revealed at 1 which required repair welds.
These were of a size ar. depth wnica would not require PWHT.
Due to a previously identified problem regarding radiography (film density), LB&S agreed with their customer to re-raciograph certain areas.
This revealed additional rejectable indica-tions; thus, a repair MPS was generated (MPS 25.0.1 X2).
All identified, rejectable indications were weld repaired on September 30 and October 7,1980, using WPS 50-B-U3b, revision 3.
The part then received a PWHT on November 14, 1980.
WPS 50-B-U3b is not qualified in a PWHT condition.
LB&S exclained that the wrong WPS was shown as being used, that WPS 49-B-U3b was the one actually used.
A review and comparison of the two WPSs showed that they have icentical parameters with the exception that one is qualified for PWHT and the otner is not.
From a technical standooint, there are no problems.
- However, from a quality recora standooint, in wnien the records are used to demonstrate comoliance with various recuirements, there is a proolem.
In addition, this type of problem lends itself to questioning the adequacy of reviews performed on MPSs prior to their being issued to Manufacturing.
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Welding Material Control 1.
Objectives The objectives of this area of the inscection were to verify that LS&S had implemented the requirements for the control of welding materials in accordance with the QA Manual and applicable NRC and ASME Code requirements.
1 2.
Method of Acccmolishment The preceding objectives were accomplished by; a.
Review of QA Manual Section 10, " Welding."
b.
Review of aeiding material issue slips with subsequent review of associated certified material test reports.
c.
Observation of welding material storage areas, including weld rod storage ovens.
d.
Discussions with cognizant personnel.
3.
Findings a.
Nonconformances None.
b.
Unresolved Items None.
E.
Exit Meeting i
A meeting was held at the conclusion of this inspection on December 19, 1980, with the following management representatives.
G. Behnke - Executive Vice President W. Jonas - NDE Level III Examiner A. Jurevics - Vice President, Engineering i
R. T. Rozek - Director, Quality Assurance T. Smith - Chief Planner Y. T. Smith - Welding Engineer J. Watts - Vice President, Manufacturing A. J. Was - QA Engineer The scope and findings of this inspection were summarized.
Management ackncwledged the statements relative to the findings.
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