ML20031B097
| ML20031B097 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/1981 |
| From: | Barnes I, Roberds H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20031B066 | List: |
| References | |
| REF-QA-99900059 NUDOCS 8109280596 | |
| Download: ML20031B097 (23) | |
Text
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l U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 39900059/81-01 Program No. 51300 Company: Ametek, Incorporated Schutte & Koerting Division, Bethayres Plant 2381 Philmont Avenue Bethayres, Pennsylvania 19006 Inspection Conducted: Much 24-27,1981 Inspectors:
I 8w<f r- < - P /
[-H.W.Roberds,ContractorInspector Date Reactive Inspection Section endor Inspection Branch l2w C-t - e s I. Barnes, Chief Date Reactive Inspection Section Vendor Inspection Branch Approved by:
Mm 5- / - F/
I. Barnes, Chief Date Reactive Inspection Section Vendor Inspection Branch Summary Inspection conducted on March 24-27, 1981 (99900059/81-01)
Areas Insoected:
Implementation of 10 CFR Part 50, Appendix B criteria and applicable codes ar.d standards, including:
an initial management meeting; l
manufacturing process control; review of special welding applications; welding l
procedure specifications; visual examination of welds; procurement control; I
radiographic examination; and special processes personnel qualification l
The inspec. tion involved 56 inspector-hours on site by two NRC inspectors.
Results:
In the eight areas inspected, the following nonconformances, unresolved items and item requiring further inspection we*e identified:
Nonconformances: Manufacturing Process Control - Sign-off, utilization and review of Process Sheets were not accomplished in accordance with Criterion V R
l 9.9900059._
l
2 of 10 CFR Part 50, Appendix B and Sections 3, 9, and 15 of the QA Manual (Notice of Nonconformance, Item A).
Personnel performing visual examinations had not been qualified in accordance with the requirements of Criterion V of 10 CFR Part 50, Appendix B and NC/ND-5521(a) in Section III of the ASME Code (Notice of Noncon-formance, Item B).
A procedure providing applicable ASME Section III Code weld j
acceptance criteria was not listed on Process Sheets for visual examinations of welds, as is required by Criterion V of 10 CFR Part 50, Appendix B and Section 9 of the QA Manual (Notice of Nonconformance, Item C).
Quality Assurance review of Process Sheets for the Cherokee 2 Unit 1 shutdown heat exchanger for completeness was not accomplished in accordance with criterion V of 10 CFR Part 50, Appendix B, paragraph NC-5272 in Section III of the ASME Code and Section 9 of the QA Manual (Notice of Nonconformance, Item D).
Forming procedure qualification test was not performed as is required by Criterion V of 10 CFR Part 50, Appendix B and para-graph NC-4213 in Section III of the ASME Cade (N m ce cf Nonconformance, Item E).
Review of Special Welding Applications - Performance of required mechanical testing of submerged arc welding materials were not accomplished as is required by Criterion V of 10 CFR Part 50, Appendix B, CE Project Specification No. 6473-PE-301, Revision 04 and NC-2300 in Section III of the ASME Code (Notice of Nonconformance, Item F).
Heat number of strip for overlay cladding operations was not recorded on Welding Material Issuance & Weldment Record, as required by Criterion V of 10 CFR Part.50, Appendix B and Section 10 of the QA Manual (Notice of Nonconfor-mance, Item G).
Performance of production strip cladding operations was not accomplished in accordance with Criterion V of 10 CFR Part 50, Appendix B and j
the amperage requirements of welding procedure specification 79WP-0001, Revision 1 (Notice of Nonconformance, Item H).
Welding Procedure Specifications - Base material used for procedure qualification 77WP-0019 was not in accordance with Criterion V of 10 CFR Part 50, Appendix B and paragraph NC-4335.2(b)(4) in Section III of the ASME Code (Notice of Noncon-formance, Item I).
Procurement Control - Procurement of studs and nuts from a vendor not identified in the Approved Vendor List was not in accordance with Criterion V of 10 CFR Part 50, Appendix B and Sections 6 and 8 of the QA Manual (Notice of Nonconformance, Item J).
Failure to document ultimate disposition of nonconforming studs and nuts was not in accordance with Criterion V of 10 CFR Part 50, Appendix B and paragraph NCA-4134.15 in Section III of the ASME Code (Notice of Nonconformance, Item X).
1 Absence of a QA program requirement for at least an annual audit of suppliers of subcontracted services was not in accordance with Criterion V of 10 CFR Part 50, i
Appendix B and paragraphs NCA-3561(a) and NCA-3853(d) in Section III of.the ASME Code (Notice of Nonconformance, Item L).
Unresolved Items: Manufacturing Process Control - Past compliance with designated J
ANI hold points could not be established (Details, paragraph C.3.b).
VisuC Examination of Welds - Presence of an incomplete weld in a previously
% ped heat exchancer, for which insufficient time was available during the
3 inspection to cetermine either the adequacy of the section thickness, or the consistency with the surface requirements of paragraph NC-4424 in Section III of the ASME Code (Details, paragraph F.3.b).
Procurement Control - Compliance of heat exchanger tubing with design minimum wall thickness requirements could not be verified for the bend areas (Details, paragraph G.3.b).
Items Requiring Further Inspection: Manufacturing Process Control - Adequacy of QA program controls with respect to shop devietion from process sheet prescribed sequence of manufacturing operations (Details, parag*aph C.3.c).
4 DETAILS SECTION (Prepared by H. W. Roberds and I. Barnes)
A.
Persons Contacted
- G. Paul Lynam, Vice President and General Manager
- W. G. Abbott, Director, QA W. J. DeGrasse, Welding Engineer
- R. Gower, Factory Manager
- J. J. Grady, Manager, Product Engineering
- C, Grondalski, Contracts Administrator
- B. Hartwick, Design Engineer
- E. J. Lux, Manager, QA
- Denotes those persons attending both the initial management meeting and the exit meeting.
- Denotes those persons attending the exit meeting only.
B.
Initial Management Meeting (I. Barnes) 1.
Objectives An initial management meeting was conducted to acquaint the vendor's management with the NRC responsibility to protect the health and safety of the public and to inform them of certain responsibilities imposed on vendors by the " Energy Reorganization Act of 1974" (Public Law 93-438).
Those in attendance are denoted in paragraph A.
2.
Methods of Accomplishment The preceding objectives were accomplished by:
a.
Describing the historical events that indicated the need for the Vendor Inspection Program.
b.
Explaining the inspection base and how the inspections are conductad.
c.
Describing how inspection results are documented and how proprie-tary items are handled, including the vendor's opportunity to review the report for the purpose of identifying items considered to be proprietary.
d.
Describing the vendor's responsibility in responding to identified nonconformances, in regard to providing corrective action measures
5 and steps to preclude recurrence.
e.
Identifying that all reports and correspondence are placed in the Public Document Room.
f.
Identifying the publication and function of the " White Book,"
Licensee Contractor and Vendor inspection Status Report., NUREG-0040.
g.
Explaining the recent reorganization of the Vendor Inspection Branch and the functions of the Reactive Inspection Section.
3.
Findings The Bethayres facility is currently completing shutdown heat exchangers for Duke Power Company Cherokee Unit 2 and performing rework operations on shutdown heat exchangers previously furnished to Cherokee Unit 1 and WPPSS-WNP3/5.
The plant is presently planned to close in mid-1981 and is operating under an extension to their ASME Certificate of Authoriza-tion (N-1870), which was originally scheduled to expire on December 31, 1980.
Ametek, Inc. retains Factory Mutual System as their Authorized Inspection Agency and is served by an Authorized Nuclear Inspector on an itinerant basis.
C.
Manufacturing Process Control (I. Barnes) 1.
Objectives The objectives of this area of the inspection were to ascertain whether:
a.
A system had been established for the control of manufacturing, which was consistent with applicable regulatory, code and contract requirements.
b.
The system was implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of Section 9, Revision 0, of the QA Manual, " Control of Manufacturing Processes, Examinations & Test-Systems."
b.
Review of Section 4, Revision 1, of the QA Manual, " Handling, Storage, Shipping & Preservation."
c.
Review of Section 15, Revision 0, of the QA Manual, "Examina-tion & Inspection Program.
f m
m
6 d.
deview of Section 16, Revision 2, of the QA Manual, " Control of Nonconforming Items."
e.
Examination of issued manufacturing process sheets for the following previously completed and shipped heat exchangers with respect to the criteria contained in f. below:
(1) WPPSS-WNP 3, Unit 1 (Shop Order (S.0.) N77-40187-001).
(2) Duke Power Cherokee 1, Unit 1 (S.0. N77-40189-001).
(3) Duke Power Cherokee 1, Unit 2 (S.0. N77-40189-002).
(4) TVA Yellow Creek 2, Unit (Shop Order not recorded).
f.
The criteria used for examination of the manufacturing process sheets described in e. above were as follows:
(1) Definition of and control of sequencing of manufacturing operations to provide for compliance with contract fabri-cation requirements.
(2) Compliance with designated hold points.
(3) Performance of all designated inspections and nondestructive examinations.
(4) Evidence of definition of required fabrication inspection and performance consistent with QA program commitments.
(5) Co.upleteness of operation signoff.
(6) Performance of operations by appropriately qualified personnel.
(7) Specific evidence of performance of required cleaning and drying operations and inspections for cleanliness and drynes s.
(8) Definition of identity of applicable procedures and instructions.
g.
Review of technical requirements in Combustion Engineering (CE)
Specification No. SYS 80-PE-301 Revision 01, " General Specifi-cation For Shutdown Heat Exchanger For System 80 Standard Design."
h.
Review of supplementary technical requirements and amendments to the CE General Specification contained in CE Project Specification No. 6473-PE-301 Revision 04, " Project Specification For Shutdown Heat Exchanger For Duke Power Company."
u
7 1.
Review of supplementary technical requirements and amendments to the CE General Specification contained in CE Project Specification No. 14074-PE-301 Revision 03, " Project Specification For Shutdown Heat Exchanger For Tennessee Valley Authority Yellow Creek Nuclear Plant."
j.
Review of the manufacturing process sheets applicable to the Duke Power Cherokee 2, Unit 1 shutdown heat exchanger (S.0. N77-40192) being currently fabricated at the Bethayres facility.
k.
Review of QA record requirements contained in CE Specification No.
GQC-76-042, dated March 16, 1976, " Administration of QA Requirements For CE NSSS Suppliers."
1.
Review of Ametek Cleaning Procedure No. 785-0153 H.
m.
Review of cleaning and inspection requirements in Procedure No. 109, dated April 2, 1976.
n.
Review of Cleaning Procedure No. 80CP-100 Revision 1, which was being used for the returned Duke and WPPSS units and also for the Duke Cherokee 2 units.
o.
Review of CE Specification No. 00000-PE-001, Revision 2, " Cleaning and Painting Requirements for Reactor Auxiliary System Components."
p.
Review of CE Specification No. -0000-PE-312, Revision 5, " General Engineering Specification For A Shell and Tube Type Heat Exchanger."
q.
Review of the training records for the current inspection personnel.
3.
Findings a.
Nonconformances (1) See Notice of Nonconformance, Item A.
A review was performed of process sheets for complete assembly for Standard System 80 Shutdown Cooling Heat Exchangers, in regard to evidence of performance of required inspections and sign off of operations by inspection personnel.
Specific attention was placed on inspection requirements for cleanli-ness and dryness and documented evidence of accomplishment of those requirements, as a result of both the site identifi-cation of residual water containing high chloride content in the WPPSS-WNP 3 shutdown heat exchangers and the subsequent discovery of contaminants in the WPPSS WNP 3/5 shutdown heat exchanger tubing.
)
8 (a) WPPSS-WNP 3 Unit 1 (S.O. N77-40187-1) 1.
Operation No. 100 required an inspection to be performed for dryness and cleanliness subsequent to Operation No. 90 (Drain after hydrotest, dry with shop-oil filtered air). Operation No. 100 was not signed off to denote the inspection had been accom-plished.
It was additionally noted that no procedure was referenced in the process sheets for performance of the Operation No. 100 inspection.
Cleaning Pro-cedure No. 109 was identified on the appropriate Bill of Materials for the unit, however, which is a OA program approved alternate source for reference documents.
Review of this procedure did not reveal any specific requirement to either clean or inspect the inside of the heat exchanger tubing, 11.
Operation No. 130 required a visual inspection to be performed of plug to cap welds, which had been made in Operation No. 110 and dressed for liquid penetrant examination in Operation No. 120.
This inspection operation no. was not signed off to denote the inspection had been accomplished.
No procedure was also identified for Operation No.
130 in regard to the visual acceptance criteria.
iii.
Operation No. 150 pertained to acceptance of liquid penetrant examination of the Operation No. 110 welds and was unsigned.
Procedures were identified in Operation No. 140 for performance of the liquid penetrant examinations.
The NRC inspector did not verify that liquid penetrant examination reports were on file for this operation.
(b) Cherokee 1 Unit 1 (S.O. N77-40189-1) l Operation No. 100, which as discussed in (a) 1. above was an inspection for cleanliress and dryness after I
hydrotest was also unsigned for this unit.
l (c) Cherokee 1 Unit 2 (S.0. N77-40189-2) i.
Operation Nos. 70, 80, and 90, which pertained to Ametek inspector, Code and customer witness of the hydrostatic test of the tubeside of the heat exchanger were all unsigned.
A hydrostatic test report was available, however, which was signed by all three parties and confirmed that all had witnessed the test.
i i
9 ii.
Operation No. 100 was also unsigned for this unit, to denote an inspection had been made for cleanli-ness and dryness.
iii.
Operation No. 130 was also unsigned for this unit, to denote a visual inspection had been made of the dressed plug to cap welds.
(d) TVA Yellow Creek 2 Unit 1 i.
Operation No. 20 pertained to the cleaning of the inside of the Front Shell to Tube Sheet Assembly using Procedure No. 78S-0153H.
The assigned inspec-tion point was not signed to denote an inspection of the cleaning operation had been performed.
ii.
Operation No. 270 required the roll expansion of tubes in the tube sheet and cleaning of the inside of the tubes with felt plugs in accordance with Procedure No. 785-153H with Addendum 1.
No inspec-tion point was provided by the Process Sheet for this operation to provide verification of suitable tube cleanliness.
iii.
Operation No. 400 required cleaning of the interior of the channel in accordance with Procedure No.
785-0153 with Addendum 1.
No inspection point was assigned to this operation.
iv.
Operation No. 580 pertained to draining and drying of the unit subsequent to hydrostatic test, utilizing Procedure No. 785-0153H with Addendum 1.
The assigned inspection point was not signed to denote the required inspection for dryness and cleanliness had been performed.
v.
Operation No. 584 pertained to Code stamping of the name plate and affixing to the vessel.
No inspection operation was assigned to this operation and no hold point had been assigned by the Authorized Nuclear Inspector.
It was not determined how this activity could be controlled in a manner consistent with ASME Section III rules for code stamping, if no provisions were made in the Process Sheet to assure QA control of the activity.
(e) General - Certificates of Cleaning Operations had been included in the documentation packages provided to the customer, as is required by CE Specification No. GQC-76-042.
1 E
]
10 The documented basis supporting preparation of these Certificates was not established during this inspection.
(2) See Notice of Nonconformance, Item B.
It was established during the inspection, resulting from the observations of an apparently visually unacceptable circum-ferential weld in a previously shipped unit (see paragraph F.3.b.), that no provisions had been made in the QA program to assure that inspection personnel performing visual examinations had the required expertise and cognizance of applicable ASME Code requirements.
No examination had been administered to inspection personnel to provide a verifiable standard of expertise of a level commensurate with those methods addressed by specific SNT-TC-1A documents.
Review of the training file for two current inspectors at the Bethayres facility, showed that one inspector had been assigned as an inspector since September 27, 1980 and from the file record had not received any fabrication inspection training.
The other inspector was ident'ified to have per-formed as an inspector since July 1978.
The training file indicated that this individual had received instruction since that time in the following fabrication related subjects; mis-match and edge preparation; TEMA tolerances; fitup inspection; weld gages and gage use; and vessel ovality requirements.
The training content could not be evaluated, however, in that no documented instruction material was available for review."
(3) See Notice of Nonconformance, Item C.
No procedure was listed on Process Sheets fo: application to designated visual examinations of welds.
In response to questions, the NRC inspector was informed that no procedure l
had been prepared, which addressed ASME acceptance criteria l
for welds, e.g. fitup requirements, permissible reinforcement, l
undercut, surface requirements.
Review of heat exchanger drawings and welding procedure specifications also failed to identify the above information.
The NRC inspector was finally shown extracts from the Code, which addressed reinforcement and mismatch criteria, and which it was stated had been pro-vided to the inspectors by the QC Supervisor.
(4) See Notice of Nonconformance, Item D.
l Observation of the Cherokee 2 Unit 1 (S.0. N77-40192-1) heat i
exchanger and review of the applicable process sheets revealed the following sequence of. fabrication with respect to the inlet and outlet nozzles:
L-
-~
11 (a) The inside. surfaces of the nozzles were overlay clad (Weld 220) in Operation No. 10 of the process sheet.
The bottom radius (heel) of each nozzle was not clad at that time, although a designated part of Weld 22C.
(b) A liquid p;netrant examination of the overlay cladding in the noz7.les was performed in operation No. 30 and was completed on October 3, 1980.
The test report prepared for the examination identified Weld 22C had been found acceptable and made no reference to the fact that Weld 22C was still incomplete.
(c) The nozzles were fitted and tacked into the unit in Operation No. 380 and nozzle welds (Welds 6C and 7C) performed in Operation Nos. 420 and 440.
The balance of Weld 22C was accomplished concurrent with these operations, although not specifically addressed in the process sheets.
(d) A liquid penetrant examination of Welds 6C and 7C was required to be performed in Operation No. 490, without any identification that a portion of Weld 22C remained to be examined.
The process instructions were thus not consistent with the actual overlay cladding practice used for the nozzles, in that neither the applicable welding operation for the balance of nozzle cladding, nor the required examination were included.
(5) See Notice of Nonconformance, Item E.
Paragraph 4.2.2.6 in Combustion Engineering, Inc. (CE)
Specification For Shutdown Heat Exchangers For System 80 Standard Design," states, " Impact testing in accordance with Paragraphs NC-2310 and ND-2310 of the Summer 1972 Addenda of Reference 3.2.1 is required for pressure retain-ing materials."
This requirement is reiterated in the Project Specifications for specific licensee equipment, as illustrated by the require-ment shown in Item F. of the Notice of Nonconformance from Project Specificatien No. 6473-PE-301, Revision 4, " Project Specification For Shutdown Heat Exchanger For Duke Power Company." Data Sheet 1 in Project Specification No 6473-PE-301, g
Revision 4 shows a lowest service temperature of 40 F.
In response to questions concerning qualification of forming processes for heat exchanger shell courses, cs is required by Section III of the ASME Code for the CE material requirements, the NRC inspector was informed that no procedure qualification test had been performed. A review was not made during the
\\
12 inspection of the method of manufacture of the heat exchanger heads, to determine if these requirements were also applicable to this item.
b.
Unresolved Items Paragraph 9.3.1 in Section 9 of the QA Manual states, " Hold Points designated by the Authorized Inspector shall no' be by passed."
t Review of process sheets for completed and shipped units showed, however, instances where Author l zed Nuclear Inspector (ANI) hold points were not either signed off by the ANI, or information inserted to show the ANI had waived the hold ooints.
(1) WPPSS - WNP 3 Unit 1 Process Sheets (a) Shell Part F Designated ANI Hold Points for Operation Nos. 162, 193 and 334 were not signed off.
(b). Shell PT "FA" Designated ANI Hold Points for Operation Nos. 220, 262, 375, 480, 162, 479, and 503 were not signed off.
Opera-tion Nos. 220, 232, and 375 had been marked, however, with a notation to see QA Records.
(2) Yellow Creek 1 Unit 1 Process Sheets (a) Rear Shell Assembly Designated ANI Hold Points for Operation Nos. 50, 120, i
140, 220, 260, 280, 330, 490 and 500 had not been signed off.
I l
(b) Front Shell Assembly A designated ANI Hold Point for Operation 110 was unsigned.
(
(c) Channel Assembly l
A designated ANI Hold Point for Operation 220 was unsigned.
l (d) Complete Assembly I
l Designated ANI Hold Points for Operation Nos. 520, 530, and 540 were unsigned.
i l
l
13 In response to questions concerning unsigned hold points, the NRC inspectors were informed that hold points had not been by passed and that review of the ANI Log Book would confirm specified ANI inspection Sold points had been accomplished.
This item is con-sidered unresolved, pending a determination of the inspection status of these hold points.
c.
Items Requiring Further Inspection Paragraph 3.1.9.3 in Section 3 of the QA Marmal states in part,
" Process Sheets shall be prepared from data in Shop Order Folder indicating:..
3.1.9.3.4 Sequence of Operations...."
Paragrapt, 3.1.12.1 states with respect to shop responsibilities,
" Fabricates in accordance with instructions on Process Sheets, drawings and procedures." Review of current Process Sheets showed that the Shop was not totally complying with the prescribed sequence of operations, as 111:sstrated by the following example.
A circumferential vessel weid, Weld 4F, was performed on Cherokee 2 (5.0. N77-40192) in May, 1980.
Operation No. 400, which pertained to dressing and visual inspection of the final weld, was still unsigned by Quality Control as of this inspection.
Subsequent operations on the Process Sheet, including radiographic examination of Weld 4F, had been performed.
The basis for proceeding to radio-graphic examination, without assuring visual-acceptability of a weld, was not determined.
On questioning the shop deviations from a prescribed manufacturing sequence, the NRC inspector was informed that the QA program did not require total adherence to the defined sequence. No program-matic provisions were identified during QA Manual review, however, which either addressed this subject, or required Q.A. review of proposed sequence deviations to assure necessary quality appraisal activities could be accomplished.
D.
Review of Special Welding Applications (I. Barnes',
1.
Objectives
-The objectives of this area of the inspection were to determine:
a.
If measures had been provided to assure that special welding-applications such as cladding and tube-to-tube sheet welds were in conformance with the additional requirements established by Sections III and~IX of the ASME Code.
b.
The measures were implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
e
14 a.
Review of Section 10, Revision 1, of the QA Manual, " Welding Controls."
b.
Observation of reciadding operations on the WPPSS-WNP 3 Unit 1 (S.0. N80-45601) tube sheet and examination of welding material issue records.
c.
Verification that the applicable welding procedure specification (WPS), 79WP-0001, Revision 1, had been appropriately qualified with respect to:
(1) The additional essential variables contained in QW-280 in Section IX of the ASME Code.
(2) Chemical analysis had been performed and was consistent with the analysis range contained in the WPS.
(3) Correct base metal thickness had been used for the test-assembly.
d.
Verification that the welding operator had been appropriately qualified for overlay cladding operations.
e.
Review of WPS 77WP-0026, which had been used for deposition of the channel flange overlay on the WPPSS-WNP 3 units that were subsequently established to have cracking problems.
f.
Examination of the supporting Procedure Qualification Record (PQR) for WPS 77WP-0026.
g.
Examinatirn of WPS 77WP-0028 and its supporting PQR.
This shielded metal arc WPS was identified to have been used in WPPSS-WNP 5 and Cherckee 1, Unit 2 channel flange overlay operations.
h.
Review of manufacturing reccrds to ascertain which WPS had been used for overlay of the Yellow Creek Shutdown heat exchangers.
i.
Review of Certified Material Test Rer--ts in documentation packages furnished to CE.
3.
Findings a.
Nonconformances (1) See Notice of Nonconformance, Item F.
Paragraph NC-2420 in Section III of the ASME Code states in part, "The required tests shall be conducted... for each combination of heat of bare electrodes and lot of submerged
I 15 arc flux...." Paragraph NC-2431 requires the performance cf a tensile test for welding material: addressed by NC-2420 and-also an impact test for welding materials, when used in applications where the base materials have not been exempted from impact testing.
During review of a customer documentation package for Cherokee 1, the NRC inspector observed a Certified Material Test Report (CMTR) for a submerged arc welding material combination (L60 electrode, Lot DD320; Lincolnweld 780 flux, Lot IJ7), which presented typical mechanical test properties and not the ASME Section III Code required actual test properties for the combination.
Specifically, the test report, which was furnished for materials procured by Ametek Purchase Order No. 26329, dated January 24, 1977, presented test results from testing performed on another combination of electrode heat and flux lot on May 13, 1976.
These test results were identified as being representative for the actual materials furnished.
It was additionally noted that the Charpy-V impact values identi-l fied.in the CMTR were impact energy values and not the specimen lateral expansion values required by the contractually specified Edition and Addenda of the ASME Code.
Further review of this subject identified that Ametek sub-sequently imposed actual testing for submerged arc combina-tions on their vendor.
A submerged arc combination received on January 4, 1979 (L60 electrode, Lot No. 63J; Lincolnweld 780 Flux, Let No. 62K) was supplied with actual test results for the combination.
Impact energy values were again supplied, without the Section III required lateral expansion values.
Examination of the applicable Ametek Purchase Order (No.
~
88991E) and accompanying Form SA-195B technical data sheet showed that this was the result of Ametek not invoking the applicable Section III requirements.
Insufficient time was available during the inspection to determine the full scope of the problem, or identify whether any other pressure boundary welding materials had oeen procured without refert..ce to the technical require-ments of Section III of the ASME Code.
(2) See Notice of Nonconformance, Item G.
(3) See Notice of Nonconformance, Item H.
(4) During this review the procurement related Items J and K in the Notice of Nonconformance were identified.
Further discus-sion on Item K is included in paragraph G.3.a.(3).
t
16 b.
Unresolved Items None.
c.
Comments (1) The available evidence indicates that the identified cladding problems in certain of the shutdown heat exchangers were the result of the failure in welding materials selection to compensate for effects on overlay composition of dilution by base material.
Review of WPS 77WP-0026 and WPS 77WP-0028 showed that Type 308L welding materials were used for first layer overlay, which with dilution by the carbon steel base material during production welding could produce a brittle martensitic structure.
(2) Overlay analysis chip samples from the original procedure qualification test plates were reported to have been taken at a greater distance from the base metal interface than is permitted by QW-462.5 in Section IX of the ASME Code.
Review of current procedure qualification records for present overlay processes did not show the specific depth of sampling for analysis. The NRC inspector was informed, how;ver, that samples were taken at within 0.02 inches frt - the minimum thickness qualified, which is the QW-462.5 requirement.
(3) WPS are available for current cladding operations that utilize a Type 309'comoosition for first layer cladding and which will preclude the condition identified in (1) above.
(4) Tube to tube sheet welding was not avaluated during this inspectio1, as a result of the absence of any production welding of this type.
E.
Welding Procedure Specifications (I. Barnes) 1.
Objective The objective of this area of the inspection was to determine if the weldirg procedure specificJitions used in production welding were being prepared, qualified and controlled in accordance with the vendor QA program and applicable ASME Code requirements.
2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Review of Section 10, Revision 1, of the QA Manual, " Welding Controls."
17 b.
Review of the WPS discussed in paragraph D. above and WPS Nos.
80WP-0004, Revision 2; 79WP-0006, Revision 1; 77WP-0016, Revision 0; and 77WP-0018, Revision 1.
c.
Examination of the supporting PQRs for the WPSs identified in b.
above with respect to:
(1) Listing of required essential variables.
(2) Consistency of essential variables values and ranges with those permitted by the WPS.
(3) Performance of all mechanical tests required by Sections III L
and IX of the ASME Code.
(4) Verification that the mechanical test results complied with ASME Code requirements.
(5) Certification by the manufacturer.
3.
Findings a.
Nonconformances See Notice of Nonconformance, Item I.
b.
Unresolved Items None.
F.
Visual Examination of Welds (I. Barnes) 1.
Objective The objective of this area of the inspection was to determine if compl'ted welds meet visual standards established by Section III of the ASME Code and the vendor QA program.
2.
Method of Accomplishment The preceding objectiva was accomplished by:
a.
Review of Section 10, Revision 1, of the QA Manual, " Welding Controls."
b.
Review of Section 15, Revision 0, of the QA Manual, " Examination and Inspection Program."
18 c.
Visual examination of the returned Cherokee 1, Unit 2 shutdown heat exchanger (Original S.0. N77-40189-2) welds with respect to:
(1) Weld surfaca finish and appearance.
(2) Absence of surface defects.
(3) Shape of fillet welds.
(4) Approximate weld reinforcement.
(5) Grinding and machining practices.
3.
Findings a.
Nonconformances None.
b.
Unresolved Items During visual examination of the Cherokee 1 Unit 2 heat exchanger, which was painted on the outside diameter (0D), the NRC inspector observed what initially appeared to be a localized undercut condition at the OD of the channel flange to channel barrel circum-ferential weld.
Further examination showed that the observed surface groove was significantly deeper than initially observed, because of a buildup of paint in the groove during vessel painting.
On removal of some of the paint film, it became apparent that one side of the groove was the original weld preparation surface and that the observed condition represented an incomplete weld.
The depth of the condition visually appeared to be 1/16 to 3/32 inch, but the NRC inspector was unable to get a dimensional inspection performed to confirm this.
This item is considered unresolved pending a determination that required section thickness was maintained and that the surface of the weld was consistent with the requirements contained in paragraph NC-4424 in Section III of the ASME Code.
G.
Procurement Control (H. W. Roberds) 1.
Inspection Objective The objective of this area of the inspection was to ascertain, that the purchase of components, materials and supplies b:cd in the manufacture of safety related components, was consistent with the commitments of the Quality Assurance Program, Code and regulatory requirements.
b-
'f.
19 2.
Method of Accomplishment The preceding objective was accomplished by:
a.
Review of the QA Manual, Section 6, " Purchasing Control".
b.
Review of the QA Manual, Section 8, " Vendor Control".
c.
Review of Procedure No. 76-QC-0009, " Vendor Performance Evaluation."
d.
Review of Purchase Order No.13N-4815-2-1.
e.
Review of Purchase Order No. 27699 dated June 29, 1977.
f.
Review of Purchase Order No. 80838, dated September 15, 1978.
g.
Verification of heat nos on tubing for the WPPSS-WNP 3 Unit 1 shutdown heat exchanger, S.0. N80-45601.
h.
Review of Combustion Engineering General Specification for Shut-down Heat Exchanger for System 80 Standard Design, Specification No. SYS 80-PE-301, Revision 01.
i.
Review of Babcock & Wilcox Specification No. 08-1024000008-1,
" Heat Exchanger for Auxiliary System Service." (Decay Heat System).
3.
Findings a.
Nonconformances (1) See Notice of Nonconformance, Item L.
Paragraph 1.2.3.3.1 in Procedure No. 76-QC-0009, Revision 2, states, "The Quality Control Supervisor will review the Vendor's File to analyze any trends in Performance as estab-lished by NCR's and advise the QA Manager for Corrective Action on vendor or removal from the Approved Vendor List.
Paragraph 1.3.2 states, '_' Consideration for re-audit shall be made by Quality Assurance based on, but not limited to, the following factors:
1.3.2.1 Type of material, parts or services supplied.
1.3.2.2 Type of nonconformities such as material integrity.
1.3.2.3 Response to request for corrective action.
1.3.2.4 Frequency of purchases."
Paragraph 1.3.3 states, "If a re-audit of a vendor's facility is required to maintain the vendor on the Approved Vendor's
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20 List, Quality Assurance will arrange and conduct the audit."
Paragraph 22.1.1 in Section 22, Revision 1, of the QA Manual states in part, "The Manager - Quality Assurance is respons-ible to prepare and shall review the manual within 30 to 90 days after receipt of Editions and Addendas to the Code for possible changes...."
Revision 1, to Section 8 of the QA Manaul involved changes to both scope and the referenced paragraph 8.4.2 and was dated October 27, 1980, in the QA Manual.
Appendix I in the QA Manual, " Manual Revision Log," showed a signoff of Revision 1 by the Inspection Specialist on December 8, 1980.
(2) See Notice of Nonconformance, Item J (Prepared by I. Barnes).
(3) See Notice of Nonconformance, Item K. (Prepared by I. Barnes).
Purchase Order No. 82090 was placed with Ridgwood Bolt of Maspeth, New York for the supply of one inch SA-193 Grade B7 steel studs and SA-194 Grade 2H hex nuts.
The purchase order required that only domestically produced material be used and that the material was to be supplied in accordance with ASME Section III, Class 2, 1974 Edition through the Winter 1975 Addenda. A statement with respect to the supply being in accordance with the referenced Code was required to appear on all documentation.
A Certified Material Test Report (CMTR) was received from Ridgwood Bolt for the furnished studs and nuts, which showed that the steel had been produced by the Ovako Inatra Steel Works (believed to be Finnish).
No refer-ence was also included in the CMTR to the material being furnished in accordance with ASME Section III Code, Class 2 requirements.
The non-domestic origin of the material and the failure to reference compliance with ASME Section III Code requirements were identified by Ametek in NCR 17984, dated September 18, 1978.
A disposition of the NCR was made on September 25, 1978, with a determination made to request corrected documentation from the vendor.
Review of the QC Supervisor's NCR Log showed that NCR 17984 was closed out on September 27, 1978.
The basis for closeout of the NCR could not be established by the NRC inspector, in that neither amended documentation, nor any other form of supporting information could be located that would support use of these materials in an ASME Sect 1on III component (WPPSS-WNP 3).
---mm.
m
.m
.- ~-.
u.
m -- m
c 21 s
Review of the CMTR by the NRC inspector also identified, that the ASMF Section III Code required documentation of the material heat treat cycle, had not been included and that the mechanical test results were listed for information only.
b.
Unresolved Items Compliance of heat exchanger tubing with design mininum wall requirements could not be verified, in that Ametek bad not imposed in their purchase orders to tube benders that the bender either qualify the forming procedure used, or perform wall thickness measurements of the bend area.
c.
Other Findings WPPSS has performed a borescope examination of the I.D. of tubing in Ametek furnished decay heat removal heat exchangers for WNP 1 and 4.
This examination has been reported to have revealed linear indications along the weld centerline in a number of tubes in the WNP 1 units.
Tubing in all of the units was also reported to have displayed surface contamination including:
black patches; dark green deposits; red to rust colored deposits; rust colored welds; and intermittent areas totally black in color.
Eddy current examinations have also been performed of tubing in these units, but to date the eddy current indications have not been positively correlated with tubing defects.
Both WPPSS and CE have performed eddy current examination of WNP 3 shutdown heat exchanger tubing.
Examination by CE of removed tubes, with metallographic examination of sections taken from locations exhibiting defect indications, has been reported to have shown the presence of both pits and linear defects.
The I.D. linear defects were described to be a non-fusion condition resulting from mislocation of the weld with respect to the weld preparation.
Copies of the tube manufacturers' eddy current examination pro-cedures were not available at Ametek.
A comparison could thus not be made with the techniques used by WPPSS and CE to establish the difference between the inspections and ascertain why the WNP 3 defect indications were not detected by the tube manufacturer.
H.
Radiographic Examination (H. W. Roberds) 1.
Objectives The objectives of this area of the inspection were to verify that:
/
22 a.
Radiographic examination is performed in accord ~.ze with approved procedures, b.
Radiographic examination procedures meet the requirements of the ASME Code and other applicable contract requirements.
c.
Work is ' accomplished by and test results are interpreted by appropriately qualified personnel.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the Quality Assurance Manual, Section 15, " Examination at Inspection Program."
b.
Review of the Quality Assurance Manual, Section 20, "Nondestruc-
~
tive Examination."
c.
Review of RT Procedure No. 3.20H.1-2 " Radiographic Examination of Welds".
d.
Review of 14 production radiographs on Job No. 9603022/6773.
3.
Findinas Within this area of the inspection, no nonconformances or unresolved items were identified.
I.
Special Processes Personnel Qualification (Nondestructive Examination)
(H. W. Roberds) 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
The employer, Ametek, has developed a written practice for control and administration of NDE personnel training, examination and certification in accordance with applicable NRC and ASME Code requirements.
b.
Personnel records are complete and are current.
c.
Personnel performing nondestructive examination are qualified for the method used and have current eye examinations as defined in SNT-TC-1A.
/
23 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of the Quality Assurance Manual, Section 20, " Nondestructive Examination."
- b.
Review of Procedure No. 77-NDE-0001, " Written Practice for Quali-fication and Certification of NDE Personnel," Revision 1 of April, 1977.
c.
Review of five NDE personnel certification and qualification record packages, including results of eye examinations.
3.
Findings Within this area of the inspection, no nonconformances or unresolved items were identified.
J.
Exit Meeting An exit meeting was held with the management representatives denoted in paragraph A. above at the conc.lusion of the inspection on March 27, 1981.
The inspectors summarized the scope and findings of the inspection, with particular concern expressed in regard to the adequacy of the manufacturing process control documentation for the time period preceding mid-1980.
Man-agement was advised that the findings would be documented in a report, which would require written corrective action and steps to preclude recurrence response statements for those findings identified as items of nonconformance.
Management was also informed that it was appreciated that the facility status could have some effect on their report response particularly in regard to steps to preclude recurrence.
Management comments were confined primarily to clarification of identified findings and a specific question on how many items of nonconformance would be in the report.
In response to this question, management was informed that this determir.ation had not been made as of the exit meeting and would be accomplished in the Regional Office after completion of review of the inspection findings.
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