ML20052F155
| ML20052F155 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/07/1982 |
| From: | Vurpillat R BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.), TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20052F140 | List: |
| References | |
| NUDOCS 8205120177 | |
| Download: ML20052F155 (29) | |
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DCCYETED w:
UNITED STATES OF AMERICA 'C? [ 711 ^7"'
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 and COMPANY, ~et al. ) 50-446
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(Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses)
AFFIDAVIT OF R. J. VURPILLAT REGARDING BROWN & ROOT RESPCNSE TO ASME SURVEY AND RESURVEY I, R. J. Vurpillat, being first duly sworn, do depose and state: I am employed by Brown & Root, Inc. in the position of Power Group Quality Assurance Manager. As such I was responsible for implementation of corrective actio'n in the Brown & Root Quality Assurance Program for Comanche Peak in response to the findings of the ASME survey I team made at the October 12-14, 1981 Survey and the January 18-20, 1982 Resurvey. The purpose of this affidavit is to demonstrate that Brown & Root has taken appropriate correc-tive actions which assure that work performed under the authority of the ASME Certificates of Authorization issued to Brown & Root for Comanche Peak meets all applicable ASME Code standards. A statement of my educational and profes-sional qualifications is attached as Attachment 1.
8205120177 820510 PDRADOCK05000g Q
O I. RESPONSE TO OCTOBER 12-14, 1981 ASME SURVEY Brown & Root has taken appropriate actions in response to each of the itema identified in the November 23, 1981 letter from the ASME setting forth the findings of the ASME Survey Team of their October 12-14, 1981 survey of the Brown
& Root ASME OA Program for Comanche Pee.k. Attachment 2. In addition, Brown & Root has taken measures to assure that the matters identified by the ASME Survey Team will not recur and that all ASME Code work performed by Brown & Root at Comanche Peak in areas affected by those findings satisfy applicable ASME Code requirements. Each finding by the ASME Survey Team is dealt with separately, below.
A. Brown & Root ASME Quality Assurance j,
Manual for Comanche Peak ,
- 1. General The ASME Survey Team found as follows:
l The manual was vague, failed to establish required controls, responsibilities, or provide for objective evidence that required activities were satisfatorily performed.
i Analysis and Conclusion The QA Manual which was reviewed by the ASME Survey Team l
had been revised by Brown & Root several months before the l ASME Survey. These revisions were approved by the Authorized l
Nuclear Inspector for Comanche Peak at the time they were made.
However, when making these changes, some of the essential I
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features that had been described both in the original QA Manual and the implementing procedures were taken out of the QA Manual, although left in the procedures. In response to the Survey Team's Comment that these revisions left the QA Manual too vague, the QA Manual was subsequently revised to include the specific features which had remained in the procedures.
The manual established the Summer 1974 Addenda for piping and the Winter 1974 ,
Addenda for component supports as the Code effectivity. The manual addressed activities only permitted by later Code addenda; such as NX-2610, NA-3867.4(f) and supply of material - NCA-3820(e),
without any identification of the
/ applicability of these provisions.
This finding concerns the use by Brown & Root of specific ASME Code provisions from later Code Addenda than the Addenda specified in the Manual for the work being performed. Brown & Root.has verified, however, that the required details concerning the use of these later Addenda paragraphs are documented in the appropriate design documents, and ASME has been so advised.
- 3. Manual Control System The ASME Survey Team found, as follows:
The manual control system did not contain the exhibits displayed in the manual or any manual approval method.
The documents used to control and transmit the OA Manual were, in fact, not included in the QA Manual exhibits. Nevertheless, these control documents were part of the Quality Assurance program in that they were contained in implementing procedures. The QA Manual approval and transmittal was, in fact, performed in accordance with the program as detailed in those procedures. Subsequent to the ASME Survey, the subject transmittal forms were added to the Manual as exhibits.
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- 4. Process, Nonconformity and Document Controls The ASME Survey Team found, as follows:
The program elements of process control, nonconformity control and document control required significant changes.
The elements of control referenced by the ASME Survey Team were, in fact, part of the Brown & Root Quality Assurance system but were detailed in the I
QA implementating procedures rather than in the OA Manual. To correct this matter, Brown & Root has added more clarifying detail to the QA Manual.
- 5. Design Control Element The ASME Survey Team found, as follows:
The design control element (control of field 4 change design information and feed back of j construction information to the Owner) was missing from the Manual.
As in the previous comments, Brown & Root has always had implementing procedures regarding control of field change information from the design stage forward. In -
response to the ASME Survey Team's comment, Brown & Root added these. controls to the QA Manual. The ASME did not j require any change in the features of control.
- 6. Elements of Control - General All elements required changes to provide definitive information since few auditable
- controls were included.
The Survey Team requested that the specific details of controlling work, which were in the Brown &
Root implementing procedures, also be described in the QA i
Manual. The QA Manual was revised to accomplish this.
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B. Implementation of Brown & Root ASME Quality Assurance Manual for Comanche Peak
- 1. Document Control The ASME found, as follows:
The manual requires that the File Custodians in each department maintain a log of design changes received from the Owner.
The File'ustodian C is to mark the involved document to indicate that a design change had been received and then the document user checks the log to find the applicable design change (s).
The log being maintained by the QA Department File Custodian contained numerous mistakes and was missing information. Three of three design packages, checked by the team, contained design changes not properly identi-
- fied in the log.
The ASME Survey Team was describing a situation encountered with the QA Department File Custodian. Thir
, File Custodian was reviewing each completed document package to assure that all the editorial work, required signatures, and other specifics were properly documented prior to placing these document packages in storage files.
These documents were not working documents (i.e., not used for field work) but merely documents that were to be reviewed l after construction and prior to final stcrage.
i For the three design packages that were reviewed by the Survey Team, the document review had not yet been accomplished i
l although the records were in the File Custodian's hands. The l
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matter raised by the Survey Team concerns the timeliness in performing the review, not that the records were not being properly reviewed.
In response to this finding Brown & Root directed that all design change logs related to ASME Code work be reviewed by File Custodians to verify and update, if necessary, the current revision status of those documents. This review was performed to assure that the latest revisions and design changes are reflected in the design change logs. The review has been completed and all logs properly updated. To assure that this situation will not recur, the Document Control Center Supervisor has re-indoctrinated File Custodians on the requirements of file maintenance, including the time-i liness of reviews.
- 2. Instructions, Procedures & Drawings The ASME found, as follows:
Brown & Root Construction Procedure 6.9G, reviewed by the Site QA Manager, was in direct conflict with the OA Manual and the Code (NA-5241) in that it stated that the ANI would sign a blank process sheet and then B&R would add the ANI hold points.
The AIA representatives stated that this
' procedure was not honored by them and that they had requested the procedure to be re-The procedure has not been revised.
l vised.
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The purpose of the Site QA Manager's review is to assure that the procedure com-plies with the Code and the QA Manual.
The ANI on site used the procedure described above in order to establish " generic" hold points as he felt were necessary. The Survey Team, however, felt that the ANI should not sign blank process sheets to establish hold points. Accordingly, this Procedure has been revised and a new revision has deleted the paragraph which describes the establishment of ANI holdpoints. The ANI continues to use his own method of establishing hold points. In addition, to prevent recurrence of this situation, the Quality Assurance Department has been reorganized and additional Quality Engineers and a Codes & Standards Staff Assistant have been j
assigned direct responsibility for reviewing the procedures to assure compliance with the Code and the QA Manual.
- 3. Control Of Purchased Materials, Items And Services
- a. Vendor Control The ASME found, as follows:
B&R procured plate material from a vendor that they had surveyed and quali-fied as a Material Supplier of bolting and plate materials. The material had been formed into a saddle configuration by this i vendor. The B&R survey and qualification of the vendor did not address review of any
operation relative to forming and the B&R purchase order did not define a forming
, process or procedure.
This finding concerned material supplied by AFCO Steel. In response to it, Brown & Root conducted a review of the AFCO Steel procedures for forming, bending and rolling. In addition, Brown & Root conducted an audit on December 2-3, 1981 to verify that AFCO Steel was in compliance with the reviewed procedure. Based on the completion of an acceptable review of the procedure and the audit results, Brown & Root has identified on the Approved Suppliers List ,
("ASL") for AFCO Steel that the scope of permitted materials /
service includes formed plates. To assure that this situation does not recur, the Site OA Manager has directed Quality l
Engineering to insure, in accordance with current Brown &
Root OA Manual and implementing procedures, that requisitioned
! items or services are within the scope of the applicable supplier prior to purchase order approval.
- b. Production Shop The ASME found, as follows:
The same material addressed in C1 was observed in the production shop with work in process. This material had not been receipt inspected in noncompliance with the OA Manual and the material was not iden-tified as required by the B&R purchase order.
B&R had divided the material and transferred the material identification incorrectly.
B&R does not verify the transfer of material identification and during the review of the manual stated that this verification was unnecessary.
This material had been properly receipt inspected by OC receiving in accordance with the approved procedure at that time. A misunderstanding arose because the heat code (110) was marked on each piece of cut material immediately next to the shop or' der number (479) to produce what appeared to be a new number (110479) on one line, rather than two lines as on the original material. In any event, an Noncon-formance Report ("NCR") was written to cover all such items and this material has been marked with the entire heat number (803N80110) rather than the abbreviated heat code and .
verified for correctness.
To prevent recurrence of this matter, the OA Manual and QA Procedures and Construction Procedures have been
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revised and training on the revised precedures has been conducted and completed. A OC Inspector is now required to verify, prior to cutting a piece or dividing material from a bundle, that the transfer of markings to each piece is l correct. This verification is documented in accordance with l the revised procedures.
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- 4. Control Of Construction Processes
- a. Process Sheets The ASME found that:
Process Sheets were observed in pro-duction that had not been reviewed with the ANI for establishment of hold points in noncompliance with the B&R QA Manual and NA-5241 of the Code. The process sheets CC-068-002-S33R and AF-035-S33A are in-cluded in this finding although numerous such process sheets are in production.
(See B above).
This matter arose because of differences of opinion between two ANIS regarding the review of process sheets to establish hold points. The first ANI on site did not wish to review all process sheets for pipe hangers. He felt that his inspection of the installation of the pipe hangers would satisfy his requirements for inspections. A ,
! subsequent ANI felt that it was necessary to establish hold points on the process sheets. Some hold points were bypas. sed because of the inconsistency between the two ANIS ' approaches.
1 i This condition had been documented prior to the ASME survey in a NCR. With the concurrence of the ANI, the following actions were taken: (1) all process sheets, including Code-related Operation Travelers, are being i
routed through the ANI for preliminary review and establish-ment of hold points prior t- issuance, (2) welding documen-tation packages and Operation Travelers issued but not yet complete are being submitted to the ANI for review and
establishment of hold points and/or signature, and (3) travelers and welding documentation packages wnich have been completed are being referenced with the NCR number. These NCR's are and will continue to be reviewed by the ANI, prior to the items being certified. The NCR will remain open until corrective action is complete.
To prevent recurrence of this matter a procedure has been prepared and issued to include the requirement of ANI preliminary review to preclude issuance of the subject documents without such review.
- b. Welding Procedure Specification The ASME found, as follows:
Welding Procedure Specification 11012
', for welding with impact test requirements did not specify the travel speed but in-stead controlled the heat input by Volt / amp range and maximum bend width for a given electrode diameter. The Procedure Quali-fication Record 010AB1276 for this WPS recorded a bead width greater than that allowed by the WPS.
This concern of the Survey Team was resolved by subsequent additional procedure qualifications which tested all the worst case heat input conditions which might exist during welding.
The test results of these new welding procedure qualifications meet the requirements of the Code. In addition, all other similar welding procedures qualification records have been reviewed for adequacy.
Finally, an NCR on this matter has been issued and the welding procedure specification was revised to restrict the bead width to 5/16". Supplementary tests were performed on a test coupon which was welded using a 3/8" bead width, which qualified that welding procedure specification for the greater 3/8" bead width.
- 5. Nonconformity Control The ASME found, as follows:
Nonconformity Control Report (NCR)
M-2952 reported that a spool piece had been welded into the system backwards.
B&R OA determined the disposition to be rework and not repair and thereby the -
disposition to cut the spool piece out and reweld it in the correct configura-tion was not reviewed by welding engi-neering, as would have been required by a repair designation. There appeared to be no consideration of the heat input
effects on the material, etc. as would be ,,
expected with this type of nonconformance.
Although the welding control procedures were not described in detail in the OA Manual, appropriate procedures were and remain in place to assure that for those materials for which heat imput is a consideration, replacement welds for items to be repaired or reworked are evaluated by Brown
& Root Welding Engineering in accordance with the design criteria to assure that the properties of the material are not affected. Specifically, all Component Modification Cards ("CMCs*) which are written to remove and/or replace
welds are routed to Brown & Root Welding Engineering for review and the issuance of documentation for the replacement welds. Welding Engineering prepares new weld data cards for the replacement welds and performs evaluations of heat input
, effects at that time. CMCs are reviewed against design specifications and procedural requirements and those which are not in compliance are returned to the originator and documentation for replacement welds is not issued. This documentation system for all ASME welding is described in the Brown & Root QA Manual and assures Welding Engineering involvement in all welding activities. .
In any event, welds for the spool referenced in this finding were not stainless steel nor did they require Charpy l
impact testing. The material was Carbon Steel,, 2" Schedule
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40, Class 3. Further evaluation concerning heat input for this material was not, therefore, necessary.
- 6. Identification And Control Of Material And Items The ASME found, as follows:
Component Supports are procured as stamped items by the Owner. The Code Data Report does not list Code Case N-225.
The Component Support is supplied to B&R with only the Code Data Report by the
l Owner. B&R then cuts the component sup- ,
I port, removing the welds, and uses the material to fabricate cther component supp,. 3. B&R does not have the Certi-ficate of Compliance (C of C) for the material.
In response to this finding, Brown & Root has issued an NCR to address the deficiency identified. The component supports are supplied for Comanche Peak by ITT-Grinnell, and NPS Industries. ITT-Grinnell has provided required Code Data Reports in addition to Certified Material Test Reports, Certificates of Compliance as applicable or a single certification as appropriate. NPS Industries, however, had provided only the required Code Data Report. NPS Industries has been requested to provide Certificates of Compliance'or Material Test Reports, stating the type and
! grade of material supplied. The need for such documentation arises when revised designs are issued which require the cutting of the component supports, removal of the welds, and use of the material to fabricate or modify other component supports. Prior receipt of the required material certifica-tions from NPS Industries, the use of salvaged material and the fabrication or modification of Code supports was placed on administrative hold. Quality Engineering is reviewing the material certifications to assure acceptability of the documentation and the material supplied.
For new fabrication or modification, salvaged material 1 will be inspected and released in accordance with applicable procedures and documented in appropriate inspection reports.
Material which cannot be properly verified will not be used in Code applications. For salvaged material previously installed, the material used will be checked against and be traceable to proper documentation from the vendor. Material which cannot be traced to proper documentation will be identified in a NCR and removed.
F. Authorized Nuclear Inspector Involvement The ASME found, as follows:
The ANI hold points on process sheets have been bypassed on numerous occasions.
The ANI logbook documents these conditions
, and the volume would indicate a significant
,/ breakdown of the program and interface be-tween B&R and the Authorized Inspection Agency personnel (See B and D-1 above).
All missed hold points during the period reviewed by the ASME Survey Team have been documented in NCR's and resolved, including ANI concurrence. In addition, Brown &
Root has reviewed all NCR's initiated because of bypassing the hold points established by the ANI and/or Brown & Root QC. As a result of their review, a Corrective Action Request has been issued to construction by the Site QA Manager. A review of the NCR's referenced on the Corrective
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Action Request indicates that there has been a significant reduction in the frequency of missed ANI hold points since May of 1980. CAR's written in October, 1978, and April, 1979, apparently have resulted in this improved performance.
To prevent recurrence of this situation, Quality Engineering and the Codes & Standards Staff Assistant have been assigned direct responsibility for coordinating ANI activities and assuring that any concerns identified by the ANI are timely resolved or brought to the attention of management for resolution.
II. RESPONSE TO ASME NUCLEAR RESURVEY CONDUCTED JANUARY 18-20, 1982 On. January 18-20, 1982, the ASME Survey Team conducted a resurvey of the Brown & Root QA program for activities per-formed under the Brown & Root ASME Certificates of Tuthorization for Comanche Peak. The Survey Team recommended renewal of the j certificates upon completion of responses to three items and certification and approval of those items by the Authorized Nuclear Inspector Supervisor. Brown & Root has taken appropri-ate corrective actions in response to those findings and the ANI Supervisor has approvet and verified these actions. See Letter from Hartford Steam Boiler Inspection and Insurance Company to ASME, February 8, 1982. Attachment 3.
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A. Finding Number 1 The ASME Survey Team found that a material supplier (AFCO), which had been surveyed and qualified by Brown &
Root, had supplied materials which had been procured from other material suppliers which were not properly qualified.
In response to this finding, Brown & Root has restricted the 1,curces from which AFCO may procure ASME materials for use by Brown & Root at Comanche Peak. Until such time as AFCO may obtain an ASME Quality Sytems certificate as a Material Supplier, AFCO is limited to procuring materials from:
- 1. Materials manufacturers qualified by AFCO .
and holding current ASME Quality System t
Certificates,
- 2. Material suppliers who have a current ASME Quality System Certificate, or
- 3. Suppliers who are on the current Brown &
Root approved suppliers list for Comanche Peak.
In addition, all documentation associated with AFCO has been reviewed by OA Engineering. One material supplier, not falling in the above categories, was identified as having provided AFCO with material. All material supplied by this company has been identified as nonconforming and tagged in accordance with the Brown & Root QA Program. The material was evaluated by
Brown & Root Design Engineering and the disposition submitted to the ANI for concurrence. See Attachment 2 at 1-2. That concurrence has been received. See Attachment 2 at 1-2.
Subsequently, on February 5, 1982, AFCO also received their Quality Systems Certificate as a Material Supplier from ASME.
B. Finding Number 2 The ASME Survey Team found that a supplier of ASME Code items was not listed on the Brown & Root Approved Suppliers List. In response, Brown & Root has reviewed the current suppliers of ASME Code items to determine whether or not they appear on the Brown & Root Approved Suppliers List. Brown &
Root has verified that all suppliers of Code stamped items, including the supplier identified by ASME, hold valid certiti-cates of authorization. Brown & Root has placed those suppliers on the Approved Suppliers List. See Attachment 2 at 2.
C. Finding Number 3 The ASME Survey Team determined that some welding material which had been receipt inspected and accepted by Brown & Root had not been properly marked as so received.
In response, Brown & Root has reviewed all welding material on site to assure proper identification. This review has been documented by Quality Assurance. With respect to the particular material identified by ASME, Brown & Root has segregated and tagged such material in accordance with their
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QA Program and the material has been scrapped. In addition, all receiving inspectors have been retrained in the proper use of receiving procedures and material identification requirements. See Attachment 2 at 2.
III. CONCLUSION All findings and comments made by the ASME Survey Team as a result of the October 12-14, 1981 Survey and the January 18-20, 1982 Resurvey of the Brown & Root ASME QA Program for Comanche Peak have been responded to by Brown &
Root. These responses have demonstrated to the satisfaction ,
of the ASME Subcommittee on Nuclear Accreditation that Brown
& Root's AS;iE QA Program for Comanche Peak warrants issuance of the NA and NPT Certificates of Authorization to Brown &
Root for Comanche Peak. These certificates were reissued to Brown & Root on March 15, 1982. r (W.'J. Vprpillat l.
Subscribed to and sworn before me this 7th day of May, 1982.
x&Notary f Public M i
Ruth F. Kerns Notary Public, State of Texas.
. My Comission Expires 4 4 N-
. ATTACHMENT 1 RAY J. VURPILLAT STATEMENT OF EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS POSITION: Power Group QA Manager FORMAL EDUCATION: B.S. Chemical Engineering, Purdue University EXPERIENCE:
1980 - Present Power Group QA Manager, Brown & Root, Inc.
Manages' prograns and personnel of Power Group QA Department concerned with various maintenance projects throughout OK, MS, LA, TX, NB , FL and VA.
1968 - 1980 Assistant QA Manager, United Engineers and ,
Constructors. Was involved in the planning, management, and supervision of QA Programs related to design and/or construction of 16 commercial nuclear power plants and more than 10 fossil-fueled power plants.
/ 1967 - 1968 Associate, Gunite Services, Inc. Partner in a construction business involved primarily in concrete construction related to medium-sized private and commercial projects.
1964 - 1967 Warner Co., Director of Quality Control.
Responsible for attaining the quality of j concrete materials and ready mixed concrete production.
1956 - 1964 Pittsburgh Testing Laboratory, started as a trainee and later becane Philadelphia District Manager. Responsible for planning and supervision of all phases of inspection and testing functions related to medium-large construction projects.
PROFESSIONAL: Professional Engineer in Indiana and California Member of American Society for Quality Control Member of various American Concrete Institute and ASME Committees.
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ATTACHMENT 2
- /e , s '
, The American Society of Mechanical tEngincors g United Engineering Center 345 E. 47th St., New York, N.Y.10017 212444 7812 TWX 710-215267
\
November 23, 1981 ,- z g c 7,1 y E D CERTIFIED MAIL #P35 7143418 j 37 0..... O 300. WC.
f r- ' ~ ~
RETURN RECEIPT REOUESTED
- . - 1931
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BROW & ROOT, INC.
R.J. Vurpillat; QA Mgr..
4100 Clinton Irive
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li. 3. Y_,U *~ N
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Houston, TX 77020 ___
- - - ~ " - ~ '
Subject:
Report of ASME Nuclear Survey Conducted on October 12-14, 1981 for New NA & NPT (Replacing current site extension N-2222-2 & N'2223-2) at Comanche Peak Electric Station,' Units #16 d2; Clen Rose, TX.
An ASME Nuclear Survey was conducted at your facilities on the date and location shown above for the subject reqested Authorization.
As a result of the Survey, the Team has recot=nended that a Resurvey is required.
The ASME decision on the Teams reco=mendation vill be forwarded to you shortly.
The deficiencies noted in your program include, but are not limited to,.the fol-loving items which require corrective action:
I. Quality Assurance Manual s
' (A) The manual was vague, failed to establish required controls, responsibi-lities, or provide for' objective evidence that required activities were i satisfactorily performed.
(B) The manual established the Sutsner addenda 1974 for piping and Winter ad-denda 1974 for component supports as the Code effectivity. n e manual addressed activities only pemitted by later Code addenda; such as NX-2610 NA-3867.4(f) and supply of material - NCA-3820(e), without any identifi-cation of the applicability of these provisions.
(C) The manual control system did not include the exhibits displayed in the 1 manual or any manual approval method.
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(D) The program elements of process control, nonconfomity control and document control required significant changes.
(E) The design control element (control) of field change design information and feed back of construction information to the Owner) was missing from the manual.
Membe! . American Associabon of Engineering Socieues . ACCredetation Boarc for Engineerin; and Technclogy
. Br.ovn'& Root, Inc.
Eduston, TX Page 2 (7) All elements required changes to provide definitive information since few auditable controls were included.
II. Implacentation l
(A) Document Control - The manual requires that the File' Custodians in each department maintain a log of design changes received from the Owner.
The File Custodian is to mark the involved decu=ent to indicate that a design change had been received and then the document user checks the log to find the applicable design change (s). .
The. log being maintained by the QA Department File Cdstodian contained numerous mistakes and was missing information. Three of three design packages, checked by the t.ea=, contained design changes not properly identified in the log.
(B). Instruction Procedures & Drawings - B & R Construction Procedure 6.9G, reviewed by the Site QA Manager, was in direct conflict with the QA Manual and the Code (NA-5241) in that it stated that the ANI would sign a blank process sheet and then B & R would add the ANI hold points. The AIA re-presentatives stated that this procedure was not honored by them and that they had requested the procedure to be revised. The procedure has not been revised.
The purpose of the Site QA Manager's review is to assure that the procedure complies with the Code and the QA Manual.
(C) Control of Purchased Materials, Items and Services -
(1) Vendor Control - B & R procured plate material from a vendor that they had surveyed and qualified as a Material Supplier of bolting and plate
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materials. The material-had been formed into a saddle configuration by this vendor. The B'& R survey and qualification of this vendor did not address review of any operation relative to forming and the B & R purchase order did not define a forming process or procedure.
(2) The same material addressed in C1 was observed in the production shop dith work in process. This material h'ad not been receipt inspected in noncompliance with the QA Manual and the material was not identified as required by the B & R purchase order. B & R had divided the material and transferred the material identification incorrectly. E'& R does not verify the transfer of material identification and during the review of the manual stated that this verification was unnecessary.
(D) Control of Construction Processes -
(1) Process Sheets were observed in production that had not been reviewed with the ANI for establishment of hold points in nonco=pliance with the B & R QA Manual and NA-5241 of the Code. The process sheets CC-068-002-S33R and AF-035-023-533A are included in this finding although numerous such process sheets are in production. (See B above)
(2) Welding Procedure Specification 11012 for welding with impact test re-quirceents did not specify the travel speed but instead controlled the heat input by Volt / amp range and maximum bead width for a given electrode diameter. The Procedure Qualification Record 010AB127 for this WPS re-
, corded a beam width greather than that allowed by the WPS.
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Erown 6 Root Inc.
housten, TX Pa*ge 3 (E) Nonconformity Centrol - Nonconfor=ity Control Report (NCR) M-2952 re-ported that a spool piece had been, welded into the system backwards.
B 6 R QA deter =ined the disposition to be rework and not repair and thereby the disposition to cut the spool piece out and reveld it in the correct configuration was not reviewed by welding engineering, as would have been required by a repair designation. There appeared to be no consideration of the heat input effects on the material, etc.
^
as would be expected with this type of nonconformance.
(F) Identification and Control of Material and Items - Cc=ponent Supports are crocured as stamped ite=s by the Owner. The Code Data Report does not list Code Case N-225. The Co=ponent Support is supplied to B & R with only the Code Data Report by the Owner. B & R then cuts the com-ponent support, removing the welds, and uses the material to fabricate other component supports. B & R does not have the Certificate of Co=-
pliance (C of C) for the material.
(G) Authorized Nuclear Inspector Involvement - The ANI hold points on pro-cess sheets have been bypassed on numerous occasions. The ANI logbook documents these conditions and the volume would indicate a significant breakdown of the program and interface between B & R and the Authorized Inspection Agency personnel (See B and D-1 above).
It is called to your attention that the resurvey will include a review of the' entire program & its implementation, and all areas discussed by the Survey Team with your personnel should be given particular consideration. ..
Please note that arrangements to schedule dates for the resurvey have been made,and the exact dates have been or will be sent to you shortly. Note that the resurvey j
will not be held until we have received payment of our invoice for the subject survey.
If you disagree with the decision above and wish to sub=it additional information for.
reconsideration, you must make your intentions known, in writing, to this office, to
'ba received within five (5) working days after receipt of this letter. Your request for reconsideration must include the reasons.upon which the reconsideration is to be based.
If you have any questions concerning this survey or the resurvey, please contact this office. ,
Joseph A. Russo
~A (
Manager, Accreditation - N & SPPE (212) 644-8051
/CE cc: A1A - Hartford Steam Boiler Chen., SC-NA
R. P. I 1 FEB10"B2 /p THE H ARTFORD STE AM BOILER
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ATTACHMENT 3 HOUSTON OFFJCE - 4151 souTHwlyr FMLEWAY. $UrrE 20u. HOUSTON. TEX Ab 77U27 - (713) 623 2220
. February 8,1932 .
. Ms.' Ar1ene Spadafino -
Director of Accreditation .
- The A:erican Society of Hechanical Engineers -
United Engineering Center
' 345 East 47th Street New York, N.Y.10017 -
RE: ERO'.'N & ROOT. INC., COW #.CHE PEAK UNITS 1 & 2 GLEN ROSE. TEXAS 76043 .
ASME NUCLEAR SURVEY CONDUCTED JANUARY .18,19 & 20,1982 .
FOR RA & NPT CERTIEICATES OF AUTHORIZATION.
~,
Dear Ks. Spadafico:
lThe 1::plementation of the corrective action required by the three findings '
, (reports atteW) was verified as being cc pleted oc February 4,1982. - -
' Toe 'slecific corrective action taken is as lollows:
' :. ..:.n ;
FI,NDING #1 A. Letter has been written to AFC0 which restricts the sources in which
? they, AFCO, my procure ASME materials for use by Brown & Root, Inc.
., . ., ,,.at CPSES. AFC0 is limited to procuring saterials from:
. . . . 1. Xaterials manufacturers qualified by AFCD or holding current l
..~ . . ASE Quality System certificates (saterials).
. .,',I'j ~ . .
- 2. . Material suppliers who have a current ASME Quality System -
l
'. . Certificate (caterials). ..
AJ .* 3.
- Suppliers who are oc the current Brown & Root approved suppliers list for CPSES.
-t. " . ,
&" R. . All doemtation associated with AFC0 has been reviewed by QA -
~ Engireertog and one caterial supplier, not falling in the above categories, was identified as having provided AFC0 with caterial. .
~
I
. RECEIVED l EROWN & ROOT,1NC.
I i-ca 12 i982 1
! E. J. VURPILLAT, JR.
- , 2 ; g t; a t A RTFOR D hT1; A M IJ OI LLs t
- 1NtiPCCTJON AND int >UIMNC1/ COM1*ANY
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Brown & Root, Inc.
Page 2 All the material from this supplier has been identified as non-conforming and tagged in accordance with the'B & R QA. Program.
The nonconformance reports issued against this supplier's traterial are being evaluated by Design Engineering and Quality Engineering
- " ~-. - and the pmposed disposition will be submitted for ANI concurrence
., prior to implementation.
c..
. FINDING #2 Brown & Root, Inc. Quality Assurance has reviewed current suppliers of ASME Code items to determine whether or not they appear on the B & R approved suppliers list.
B & R has verified the validity of the applicable Certificate (s) of Authorization of all suppliers of code stamped items which includes Southwest Fabrication Inc. and has placed them on the B & R approved suppliers list.
FINDING f3 Brown & Root, Inc. issued a nonconforrance report, segregated arid tagged the abcve welding material in accordance with their QA Program, and this material. has been scrapped. :-.
' All welding material on site has been reviewed to assure proper identification. This review has been documented by Quality Assurance. All receiving Inspectors have been retrained in the proper use of receiving procedures and traterial identification requirements and thi's t' raining has been documented by Quality Assurance.
If more information is required or clarification is required, please do not hesitate to contact me. .
Yours truiy,
( &$ '&%
.- R.C. Howard
? Sr.'" Regional P,anager e Special Inspection SerYices Division -
cc: R.E. Tilton - ASME Team Leader cc: 5.M. Matthews - State of Texas i
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A.h*D COP 3ECTIVE ACTIONS
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The Arnerican Society of Mochenica. :.ngineers
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page ! of I.
This for= is to be used for the Inspection Specialist's verification of corrective actions taken by the Co:pa. y to findings identified during a su.mtey. After Sections I and II are cc pleted by the Team Leader and accepted by a Co=pany's representative, the cririnel for=
is left vith the Inspection Specialist a=d a ccty returned to ASE vith the team report.
The Inspection Specialist is to co=plete Section III asti trans=it all finding reports frc=
this su.rvey to AS.E vith details i=cluded in one (1) trans=ittal.
Cc= any is Survey Iceation Inspection Specialist: X/N-D /t/M// d i
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G,,asa:ac PasrK STCh1 GLtLhlc f* T I Beport Dead 112e Date: reMuan./ ZD i/9S*L C,les.> Rosc, TX Section I Finding # I- (Describe deficiency including Code para. (s) and QA =anual ref. (s) 3 AF"@ C n!'* Tc'l/"' S""'2-) "a"c'reo 4 Gu'~< #'eos/cwca a, sap ,, <.se:i 7 ,q e /34 2 .Svecy D o o Nor Aoucu, S* Le 'rH.a l' Ta f a ts' k # ' ' Cd '-t c rir <.1 Fs wr<9 tic.c .:fuPPLic o B y APCO CASc' /V -) s/.L f, SA 7&Jin t .$vi ee
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" Tea: Leader: 8 / / do Survey Dates: ,
1i,vaa.,If-7.0,/98~2 Section II - picoesed Corrective Action by the Co=cany I, A. P h .e % i nts be resk.4e<J 40 n6% no&e.%
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Title:
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Section III - S"-arv of Verification by Instection Suecie. list Including Actue.1 Corrective Actions Ta?en g g y /.m ./.s.: .- nr. !/;Gd 7e sGC '
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3/80 1
4 I ( AND COhEECTIVE ACTIONS (
' . . . ~ . . The Arnerican Society of Mechanical Engineers
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. ( / vanec Engineerag Cenier . ~,J5 E J':n 3: Aew v.<,. N 1 10017 2 2 444 312 Page l of l Date: . /JJJUAA/ 7 l', I0$'l-
- 4 This forn is to be used for the Inspection Specialist's verification of corrective actions taken by ti.e Co pany to findin6s identified during a su vey. After Sections I an:i II are co=pleted by the Tea = Leader and accepted by a Co=pany's representative, the oririnal form is left vith the Inspection Specialist and a cerv returned to ASE vith the tee.= report.
The Inspection Specialist is to co=plete Section III and trans=it all finding reports from this survey to ASE vith details included in one (1) T.rans ittal. .
Inspection Specialist: ,v e, . o / u,ca h Co=tany & Survey Iccation
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- Report Deam he Date: lY/3 20, l N 'L toca;; th g Ger.M ELCCibt G(f u Rt.st , *N Section I Finding # 2- (Describe deficiency including Code para. (s) and G =anual ref.(s) fuld c //,4Je' OGliQ Td .SWMJCTl Sud/fitVf2*] bdC Q. f, h'us, Svb r~nn.cah . E' C ^? 6 G. 1 El' 2 - R B -6.:( G ,
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Su.rvey Dates: /MuMtf /6. /c, / 9f' 2 -
Teer. Leader: E, e , 7 / 4 4.]
Section II - Protosed Corrective Action by the Co=cany '
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Co=pletion Date: 12I8#1 Co=pany Rep: _
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Title e- l'3 A l1C) tac <PJ d
Section III - S"- rv of Verifict. tion by Instection Suecialist Including Actual Correct.ite Actions Taken
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Verification Date: ) 4' C"'2-- 15?'C "# #
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3/50 - _
- ASMr SURVI'Y FTNDIEG R E ET_
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Ana co:.arcTIvr ACTIoss (,
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The American Society of Mochenical c.ngineers j
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vnne Eng.n<em; comer . 345 E 47n St e.e. vcer a v 10017 2:2 6u 812 Twx 7:o-sai 5s Page / of /
Data: t v v / w ,, 1 v l 'M 'L
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This for= is to be used for the Inspection Specialist's verification of corrective After Secticas I andaction:
II are taken by the Co=pany to findings identified during a. survey.
completed by the Team Leader and accepted by a Company's representa-ive, the o:irinal form is icft with the I=spection Specialist and a eo_ev. returned to ASMIall vithfinding the teereports
report. frc
Tha Inspection Specie. list is to co=plete Section III and transmit .
this survey to Afr. -ith details _ included in one (1) trans=i .tal.
Ce=oany & Survey Iceation Inspection Specialist: /h.e'A o e r</ulo
^6e.ewr19 N o w ., zo, 1 6 1-con.v,u nufod .s,eu,ac. .coch e gL' aepo:-t Deadline Date: '
GUAJ ban"., 7x.
Section I Finding # .3 (Describe deficiency including Code para.(s) and QA -=-ual ret.(s)
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. Team Leader: E . W L-lvn } Survey Dates:
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'^ Section II - pronosed Corrective Action by the Co=tany
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e 0-Co=pletion Date: 3[61 Company Rep:
Title:
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