ML20032E397
| ML20032E397 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1981 |
| From: | Barnes I, Oller R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20032E393 | List: |
| References | |
| REF-QA-99900267 NUDOCS 8111200519 | |
| Download: ML20032E397 (13) | |
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U. S. NUCLEAR REGULATORY COP 911SSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900267/81-01 Program No. 51300 Company: Tube Turns Division of Chemetron 7100 Katy Road, P. O. Box 393 Houston, Texas 77001 Inspection Conducted:
January 19-23, 1981 Inspectors:
4 2"/['M' R. E. Oller, Contractor Inspector Date ComponentsSection II.
Vendor Inspection Branch Y
M
- 2. rt I. Barnes, Chief Date ComponentsSection II Vendor Inspection Branch Approved by: I8W
- 2. - Pf - Bt I. Barnes, Chief Date ComponentsSection II Vendor Inspection ~ Branch Summary Inspection on January 19-23, 1981 (99900267/81-01)
Areas Inspected:
Implementation of 10 CFR Part 50, Appendix B Criteria, other NRC requirements and applicable codes and standards, including management meeting, action on previous inspection findings, internal audits, manufacturing.
process control, procurement document control, procurement source selection, and testing of' completed products.
The inspection involved 48 inspector-hours on site by two NRC inspectors.
Results: Within the seven (7) areas inspected, no norconformances or unresolved items were identified in three (3) areas, with the following identified in the remaining areas:
Nonconformances i
l Internal Audits:
Contrary to Criterion XVIII of Appendix B to 10 CFR Part 50 and QA Manual Pro-j cedure TTH0 22-214, paragraph 5.0, there were no corrective actions provided l
and follow up audits were not performed with respect to the numerous significant i
8111200519 810220 l
PDR GA999 EMVC 99900267
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deficiencies identified by the auditors duri g a QA Program audit performed in a
January 1980, and a QA Manual Procedures audit performed in May 1980 (Notice of Nonconformance, Item A.).
Manufacturing Process Control:
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and QA Manual Procedure TTH0 22-206, paragraph 3.6, applicable welding procedure revisions were not located at the tack welding station or at the outside seam welding staLion.
Prior to the end of the inspection, corrective action was performed by placing the applicable procedures at all welding stations (Notice of Nonconformance, Item B.).
Contrary to Criterion V of Appendix B to 10 CFR Part 50, paragraph ND-2561(b) in Section III of the ASME Code, and Material Specification SA-655, the postweld heat treatment temperature employed for P-4 material and a procedure qualification weld was not consistent with NB-4620 requirements, and NB-4620 cooling rate requirements were not addressed in the applicable heat treatment procedure (Notice of Nonccnformance, Item F.).
Contrary to Criterion V of Appendix B to 10 CFR Part 50, paragraph 3.1 in QA Manual Procedure TTH0 22-213 and paragraphs 5.1 and 5.2 in QA Manual Procedure TTH0 22-211, a documentation package was finalized without evidence of nonconforming ovality measurements being reported to the Mancger Plant Quality or the Final Inspection Report being reviewed by Quality Control for data compliance to order requirements (Notice of Nonconformance, Item G.).
Procurement Source Selection:
Contrary to Criterion V of Appendix B to 10 CFR Part 50, and QA Manual Procedure TTH0 22-205, paragraph 3.2, a copy of the June 1980 survey was not maintained at the Houston plant for Union Carbide Linde Division, Niagara Falls, N.Y., who was a supplier of welding flux to the Houston plant (Notice of Nonconformance, Item C.).
Testing of Completed Products:
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraphs 2.0 and 8.3 in QA Manual Procedure TTH0 22-209, a master pressure gage did not bear a sticker indicating the calibration due date and the serial numbers of pressure i
gages used for certain hydrostatic tests were not recorded on Daily Inspection Reports (Notice of Nonconformance, Item D.).
Contrary to Criterion V of Appendix B to 10 CFR Part 50 and paragraphs 4.1 and 4.2 in QA Manual Procedure TTH0 22-203 Revision 0, Plant Quality neither rejected an unacceptable tensile strength value obtained for certain SA-155 piping, nor issued and processed a i
nonconforming Material Report (Notice of Nonconformance, Item E.).
Unresolved Items l
None
(
I l
l a
3 DetailsSection I (Prepared by R. E. Oiler)
A.
' Persons Contacted W. Harper, Supervisor, Welding and Processing 2nd Shift
- P. Lazar, Production Manager
- L. Love, Materials Control Manager
- M. McCrary, Manager Plant Quality F. Muesse, Supervisor QC
- R. Shaw, Plant Manager
- R. Wyatt, Assistant Manager Plant Quality
- Attended both the Management Meeting and.the Exit Meeting.
B.
Management Meeting l
l 1.
Objectives The objectives of the Management Meeting were to meet with Plant Management to establish communications and to discuss the purpose and intent of the Vendor Inspection Branch (VIB) direct inspection program.
2.
Method of Accomplishment The' preceding objectives were accomplished by the inspector's pres-entation and the resulting discussions covering the following:
~
a.
NRC policies and organization.
b.
VIB program objectives and how these objectives are to be accomplished.
c.
VIB organization.
d.
Inspection areas to be covered.
e.
Basic inspection techniques of the VIB.
f.
Enforcement procedures applicable to vendors, including Section 206 of the Energy Reorganization Act of 1974 and Part 21 of 10 CFR.
h.
The White Book.
i.
Questions.
9 4
3.
Results No unusual questions or discussions developed or occurred during the management meeting.
C.
Action on Previous Inspection Findings 1.
(0 pen) Deviation A (Report No. 80-01):
Failure to have the specified welding procedure TT11-1803, Revision 3, at the welding station during tack welding of a pipe for production order HPM 49-3251, Item 001.
The inspector found that the new Manager Plant Quality had issued upgraded welding procedures to the Froduction Department for all welding stations.
This action was documented by a memorandum dated June 19, 1980.
The memorandum also indicated that the tack welding procedures No. TT11-1803, Revisions No. O and No. I were at the station.
1 However this was determined to be currently not'the case, in that Revision No.1 of the procedure was not in the procedure book at the tack welding station.
Prior to the end of the inspection the NRC inspector verified that Revision No. 1 had been placed in the tack welding station book.
The indicated preventive action by QC of frequent checking of all welding procedures books could not be verified.
During the Exit-Meeting, Tube Turns Houston management indicated that they will provide documented QC monitoring of all welding procedures books.
While the corrective action is closed, the preventive action for this item remains open.
2.
(0 pen) Deviation B (Report No. 80-01):
Failure by the welder to i
have the correct Weld Rod Control Record while performing pro-i duction welding on a pipe for order HPM-49-3256, Item 002.
The inspector found by examination of in process Weld Rod Control Records and the related Routings (travelers) that the proper records are now being used for specific jobs. The QC monitoring of this activity was not documented and could not be verified.
In the Exit Meeting, the Tube Turns Houston management indicated that they will provide documentation of QC monitoring of this activity.
The corrective action for this item is closed but the preventive action remains open.
D.
Internal Audits I
1.
0~jectives o
The objectives of this area of the inspection were to verify that i
i f
5 the following items were controlled in accordance with the QA Manual and applicable NRC and ASME Code requirements:
a.
A written system has been established to assure that internal audits are performed and controlled in accordance with appli-cable codes to verify compliance with all aspects of the QA program.
b.
Planned and periodic internal audits are performed in accordance with written procedures or checklists by qualified personnel not having direct responsibilities in the areas being audited.
c.
Audit results are documented and reviewed by management having responsibility in the area audited, d.
Followup action, including reaudit of deficient areas, are taken where indicated.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Procedure TTH0 22-214, Revision 0
" Audit Procedure".
b.
Review of the Tube Turns Houston schedule of monthly audits for the period of June,1979, through May,1980.
c.
Review of records of the monthly internal cudits of QA Manual procedures, originated by the Houston Manager Plant Quality, and performed during the above period.
d.
Review of records of the internal audit of the entire Houston QA program on 1-29-80, initiated by the Vice President-Engineering, Louisville Plant, and performed by the QA Consultant, Louisville Plant.
e.
Review of records of certification of training of the auditors who performed the internal audits, f.
Discussions with responsible personnel.
3.
Findings a.
Items of Nonconformance See Notice cf Nonconformance, Item A.
6 b.
Unresolved Items None.
E.
Manufacturing Process Control (See also DetailsSection II) 1.
Objectives The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QA Manual and applicable NRC and ASME code requirements.
a.
A written system has been established to assure that manu-facturing processes are controlled in accordance with appli-cable codes.
b.
Measures have been established and implemented to control the manufacturing processes by use of process sheets, travelers, checklists or procedures.
c.
The process sheets, travelers, checklists or shop procedures used included:
the document numbers and revisions to which the processes, inspections or tests conforined; the results of completion of the specific operations; the signature, initials or stamp of the Authorized Inspector and date, were shown for activities he witnessed.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Procedures TTH0 22-202, " Production and Process Control" and TTH0 22-206 " Welding Operation Control."
b.
Observation of piping base material in the following stages of ranufacture; and review of the accompanying production routings (travelers) and welding material issue control records (where applicable), and procedures:
(1) Flame cut plates 0.875" thick with identification stamping ready for rolling.
(2) Plate being hct formed by rolling.
(3) Formed plate being grit blasted.
(4) Formed plate after fitup and tackwelding.
7 (5) in;ide diameter longitudinal seam welding of pipe.
(6) Outside diameter longitudinal seam welding of pipe.
(7) Piping prepared for radiography of the longitudinal seam weld.
c.
Review of the following production records for completed order HPM 427932-001, Lot J-3198 to verify that the appropriate records were properly completed, signed and dated.
(1) Production Routing (traveler).
(2) ASME Code Stamped Symbol Rubbing.
(3) Detailed Analysis Report dated 12-15-80.
(4) NM-1 ASME Data Report.
(5) Laboratory Work Sheet (for test specimen sampling and testing).
d.
Discussions with responsible personnel.
3.
Findings a.
Items of Nonconformance See Notice of Nonconformance, Item B.
b.
Unresolved Items None.
F.
Procurement Source Selection 1.
Objectives The objectives of this area of the inspection were to verify that the following items were controlled in accordance with the QA Manual, and NRC and ASME Code requirements.
a.
A written system has been established to assure that procurement source selection is controlled in accordance with code require-ments.
b.
Procedures have been prepared, approved and implemented, which will assure that procurement source selection includes inte-grated action by one or more responsible departments such as quality assurance and purchasing.
J
i e
8 c.
Evaluations of subcontractors include such measures as:
on cite survey of subcontractor's capabilities including a quality assurance program; acceptance based on a subcontractor being a holder of a valid ASME N type symbol authorization applicable to the items or services to be supplied; a history of-subcon-tractors' performance, and evaluation of other applicable require-ments specific to the purchaser.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Proccdure TTH0 22-205, paragraph 3.0, " Approved Vendor List."
b.
Review of the " Approved Vendor List," dated 1-5-81, with emphasis on the vendors used by Tube Turns Houston.
c.
Review of records of the most recent survey of six vendors used by the Houston plant.
d.
Discussions with responsible personnel'.
3.
Findings a.
Items of Nonconformance See Notice of Nonconformance, Item C.
b.
Unresolved Items None.
G.
Exit Interview 1.
The inspectors cet with management representatives denoted in paragraph A. at the conclusion of the inspection January 23, 1980.
2.
The following subjects were discussed.
a.
Areas inspected.
b.
Status of corrective action for the previously identified deviations.
c.
The nonconformances identified in this report.
9 3.
The manufacturer's representatives were asked to formulate the corrective action response to nonconformances, in accordance with the three (3) conditions identified in the inspection report cover letter.
4.
Management's comments were related to clarification of the findings.
]
10 DETAILS SECTION II (Prepared by I. Barnes)
A.
Persons Contacted-M. McCrary, Manager, Plant Quality R. Wyatt, Assistant Manager, Plant Quality B.
Testing of Completed Products 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
Products are assembled in accordance with approved procedures and that ancillary materials' comply with approved specifications.
b.
Functional tests of products are performed in accordance with approved test documents.
2.
Method of Accomplishment.
The preceding objectives were accomplishec by:
a.
Review of QA Manual Issue 3, Procedure TTH0 22-207, Revision 0,
" Product Inspection."
b.
Review of QA Manual Issue 3, Procedure TTH0 22-208, Revision 0,
" Nondestructive Examination and Pressure Testing."
1 c.
Review of QA Manual Issue 3, Procedure TTH0 22-209, Revision 0,
" Calibration of Measuring cnd Test Equipment."
d.
Examination of hydrostatic test stand.
e.
Review of Tube Turns - Houston (TTH0) Procedure TTH0 08-013, F
Revision 5, " Hydrostatic Testing of Pipe."
f f.
Review of Procedure TTH0 17-005, Revision 4, " Calibration Instructions," with respect to calibration requirements for pressure gages.
g.
Examination of production routings and hydrostatic test records i
for two recent orders for ASME Section III welded piping.
1
11 3.
Findings a.
Items of Nonconformance (1) See Notice of Nonconformance, Item D.
The identity on the calibration sticker for master pressure gage, S/N 7009, indicated that it had been applied by the organization providing a calibration service for pressure gages to Tube Turns - Houston.
Review of the calibration card file for pressure gages indicated that calibrations were being performed prior to installation of the master gage on the hydrostatic test stand and not at a predeter-mined time interval.
Subsequent to the inspection, a review was made by the inspector of the inspection history for Tube Turns - Houston.
This review indicated that a failure to calibrate pressure gages at a 3 month frequency had been identified as a deviation from commitment during Inspection 78-01.
The Tube Turns corrective action response letter of April 18, 1978, committed to the calibration of master pressure gages each 3 months regardless of "in service" dates, with a recall system implemented by the Manager, Quality Control to notify the Quality Control Supervisor 2 weeks prior to calibration due date.
It would appear that this corrective action commitment is not currently being adhered to.
(2) See Notice of Nonconformance, Item E.
SA 387 Grade 11, Class 1 material was procured from a material supplier using the option permitted by NCA 3867.4(e) in Section III of the ASME Code.
The base material tensile test performed in accordance with this option to verify compliance of the material with the material specification, produced a tensile strength value of 85, 620 p.s.i., which exceeds the maximum value of 85,000 p.s.i. permitted by the material specification.
No information was made available to the inspector as to the basis for no actions being taken with respect to the unacceptable test result.
C.
Procurement Document Control 1.
Objectives The objectives of this area of the inspection were to ascertain and verify that a system for procurement document control had been pre-scribed and that the system was effectively inplemented by Tube Turns - Houston, i
l J
I '.
12 2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Procedure TTH0 22-205, Revision 0, " Procurement Control."
b.
Review of two material procurements with respect to QA program and customer requirements.
c.
Review of vendor certification with respect to procurement requirements.
d.
Discussions with quality management personnel.
3.
Findings No items of nonconformance or unresolved items were identified in this area of the inspection.
D.
Manufacturing Process Control 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
A system had been established for the control of manufacturing processes, which was consistent with applicable regulatory and ASME Code requirements.
b.
The system was implemented.
2.
Method of Accomplishment The preceding objectives were accomplished by:
a.
Review of QA Manual Procedure TTH0 22-202, Revision 0, " Production and Process Control."
b.
Review of QA Manual Procedure TTH0 22-207, Revision 0, " Product Inspection."
c.
Review of QA Manual Procedure TTH0 22-208, Revision 0, "Nondestruc-tive Examination and Pressure Testing."
d.
Review of QA Manual Procedure TTH0 22-210, Revision 0, " Heat Treatment."
i
13 e.
Review of QA Manual Procedure TTH0 22-211, Revision 0,
" Documentation."
f.
Review of QA Manual Procedure TTH0 22-213, Revision 0, "Noncon-formances and Corrective Action."
g.
Examination of production routings for two recent welded piping orders with respect to:
(1) Definition and control of sequencing of manufacturing operations to provide for compliance with ASME Section III Code fabrication requirements.
(2) Compliance with designated hold points.
(3) Performance of required ASME Code nondestructive examina-tions and at appropriate times of examination.
(4) Completeness of operation signoff.
(5) Evidence of fabrication inspection definition and per-formance consistent with QA program commite. ants.
(6) Use of appropriate welding procedure specifications.
3.
Findings a.
Items of Nonconformance (1) See Notice of Nonconformance, Item F.
No cooling rate instructions were provided by Procedure TTH0 01-005.
Examination of production routings for two piping contracts, invs1ving SA-387 Grade 11 Class 1 and SA-515 Grade 70 starting materials, showed that a re-roll sequence followed the postweld heat treatment cycle.
It could not be ascertained from the routings, whether the re-roll was performed after cool down of the material, or immediately altar completion of the required time at the postweld heat treatment holding temperature.
Furnace l
charts were not reviewed during this inspection to check whether the recorded cycle terminated at completion of the held period.
(2) See Notice of Nonconformance, Item G.
b.
Unresolved Items i
None.
i