ML20032E396
| ML20032E396 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20032E393 | List: |
| References | |
| REF-QA-99900267 NUDOCS 8111200518 | |
| Download: ML20032E396 (5) | |
Text
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Tube Turns (Houston)
Division of Chemetron Docket No. 99900267/81-01 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on January 19-23, 1981, it appears that certain of your activities were not conducted in accordance with NRC requirements.
A.
Criterion XVIII of Appendix B to 10 CFR Part 50 states in part:
"A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program..
Audit results shall be documented ard reviewed by management having responsibility in the area audited.
Followup action, including reaudit of deficient areas, shall be taken where indicated."
QA Manual Procedure TTH0 22-214, caragraph 5.0, " Reports and Corrective Action", states in cart:
"5.1 Reports Detailed findings of the audit shall be forwarded to the head of the department audited with copies to the Plant Manager-Houston. The findings report shall include the results of the audit and require a response from the depart-ment head within a specified time, for action to be taken to correct deficiencies found in the audit and the date they will be completed.
5.1.1 The Mgr. Plant Quality shall follow up to receive replies promptly and to review and accept or reject the replies.
He shall establish a date within five working days after the corrective action is to be completed for a follow up to verify that the corrective action has been taken.
5.1.2. Summary reports of audits including recommendations shall be furnished to the Vice President-Engineering and Vice President Manufacturing (Louisville).
Contrary to the above, the following ccnditions were identified in regards to the January, 1980, internal audit of the entire program iniT.iated by the Vice President - Engineering and the May, 1980, internal audits of seven QA Manual Procedures initiated by the Manager Plant Quality:
811120051By%h PDR GA999 PDR 99900267
I s
2 1.
There were no corrective actions provided or follow ups mada with respect to numerous significant deficiencies identified by the auditors in both types of audits.
2.
There was no recora of the Manager Plant Quality having made written requests fqr corrective action responses from the depart-ment heads where tns deficiencies were found.
3.
There was no record of the Manoger Plant Quality having received corrective action responses, having followed up to receive replies, or of having performed a reaudit ta verify that corrective actior, was taken.
B.
Criterion V of Appendix B to 10 CFR Part 50 requires activities affecting quality be accomplished in accordance with documented instructions, pro-cedures, or drawings of a type appropriate to the circumstances.
QA Manual Proceduce TTH0 22-206, paragraph 3.6, states, "The Production Manager is responsible that copies of welding procedures are available at the welding stations."
Contrary to the above, the following conditions were identified:
1.
Revision 1 of welding procedure TT11-1803 was not available at the fitup and tack welding station.
2.
Welding procedure TTH0-0102, Revised 6-12-80, which was specified on the routing for inprocess outside longitudinal seam welding, was not available at the welding station.
Prior to the end of the inspection, corrective action was accomplished for the identified conditions, by placing procedure books containing the above procedures at the above locations and at other welding stations.
C.
Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality be accomplished in accordance with documented instruc-tions, procedures, or drawings of a type appropriate to the circumstances.
QA Manual Procedure TTH0 22-205, paragraph 3.2, states in part:
.. A file of vendors survey results of the vendors used by Houston : hall be maintained by the Mgr. Plant Quality and these surveys shall be reviewed and accepted by the Mgr. Plant Quality."
Contrary to the above, a review of survey records and the Approved Vendor List (AVL) dated 1-5-81, for six vendors used by Houston,
3 showed that the survey record dated 6/80 in the A.V.L. for Union Carbide Linde Division, Niagara Falls, N.
Y., a supplier of welding flux, was not maintained at the Houston Plant.
l D.
Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality be accomplished in accordance with documented instruc-tions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 2.0 in QA Manual Procedure TTH0 22-209, Revision 0, states in part, "... Each item shall bear a sticker (Exhibit 209-1) indicating date of last calibration, calibration due date and approval of the indi-vidual performing the checking." Paragraph 8.3 states, " Daily Inspection Reports shall record the serial number of gages used at Final Inspection and Hydrostatic Testing tc provide records for reference if this equip e t is found to be discrepant."
Contrary to the above:
1.
Master pressure gage, S/N 7009, which was observed on the pipe hydrostatic test stand, did not bear a sticker indicating tne calibration duc date.
2.
The serial numbers of pressure gages used for hydrostatic testing of welded pipe, applicable to Customer Purchase Order Nos. D-94694.35 and E3035-311, were not recorded on Daily Inspection Reports.
(See DetailsSection II, paragraph B.3.a.(1)).
E.
Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality be accomplished in accordance with documented instruc-tions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 4.1 in QA Manual Procedure TTH0 22-203, Revision 0, states, "Results of all metallurgical and chemical tests are furnished to Manager Plant Quality for review and acceptance or rejection.
Re-tests are made as permitted by specifications.
Results of tests are maintained and used for release for further production, preparation of Detailed Analysis Reports and release for shipment." Paragraph 4 2 states, "In the event of failure of tests the Manager Plant Quality shall place a Hold on the material until disposition of nonconforming materials is determined.
A nonconforming Material Report shall be issued and processed before releasing for further production."
Contrary to the above, Plant Quality neither rejected an unacceptable tensile strength test value obtained for SA-155 piping material, Lot No. J3206, nor issued and processed a nonconforming Material Report in regards to the test result.
(See DetailsSection II, paragraph B.3.a.(2)).
4 F.
Criterion V of Appendit B to 10 CFR Part 50 requires that activities affecting quality be prescribed and accomplished in accordance with docu-mented instructions, procedures, ov' drawings of a type appropriate to 'he circumstances.
Paragraph ND-2561(b) in Sectior, III of the ASME Code states in part, "Postweld heat treatment of procedure qualification welds shall conform to the applicable requirements of Section 5.7 of this specification and Section IX of the Code.
Paragraph 5.7.1 states in part, "Postweld heat ureatment shall be performed in accordance with NB-4620 of Section III, Division 1, of the Code..
Contrary to the above:
1.
Postweld heat treatment of the procedure qualification weld for welding procedure specification TTH0 14-0402, which was used for submerged arc welding of ASME Section III Cliss 3 SA 155 piping (fabricated from SA 387 Grade 11, Class 1 material, ASME P No. 4) g on TT ORD 427912, was performed at 1350 F and not the 1100 - 1250 F holding temperature range required by NB-4620 for this material.
2.
Procedure TTH0 01-005, which was used for postweld heat treatment of TT ORD 427912 above, igcorrectly prescribed a holding tempera-ture range of 1250 - 1400 F and also did not provide instructions in regards to the cooling rate requirements of NB-4620.
(See DetailsSection II, paragraph D.3.a.(1)).
G.
Criterion V of Appendix B to 10 CFR Part 50 requires that activities affecting quality be accomplished in accordance with documented instruc-tions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 3.1 in QA Manual Procedure TTH0 22-212, Revision 0, states, "It is the responsibility of production and quality control department and all other personnel to report any nonconforming material or product to the Mgr. Plant Quality."
Paragraph 5.1 in QA Manual Procedure TTH0 22-211, Revision 0, states, "Using the documentation requirements prepared for the order, the docu-mentation check list, and a review of the order and ASME Section III requirements the final documentation package is prepared by Quality Control." Paragraph 5.2 states, "Before finalizing, each document shall be reviewed for inclusion of all required information and for compliance of the data to the order requirements."
Contrary to the above, the documentation package for customer purchase order D94694.35, TT ORD 427912, was finalized and accepted, without any evidence that either nonconforming final inspection pipe ovality mea-surements had been reported to the Mgr. Plant Quality, or that the Final
5 Inspection Report containing the ovality measurements had been reviewed by Quality Control for data compliance to order requirements.
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