ML20148L320
| ML20148L320 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1978 |
| From: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148L308 | List: |
| References | |
| REF-QA-99900114 NUDOCS 7811200230 | |
| Download: ML20148L320 (4) | |
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l Lamco Industries, Incorporated Docket No. 99900114/78-02 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on August 7-11, 1978, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:
A. Criterion V of Appendix B to 10 CFR 50 and Paragraph NCA 4134.5 of the ASME Code Section III state, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, t of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."
Lamco's Procedure NIS, subparagraph 4.6.1.4, states in part, "The scrap material shall be disposed of by Quality Control."
Contrary to the above, the inspector observed " Scrap" items that had not been disposed of as required. (See DetailsSection I, paragraph
.C.3.a.)
- 8. Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including welding, . . . are controlled and accomplished . . . using qualified procedures . . . ."
Wel'd ing Procedure Specification (WPS) No. 6881-5, Revision A, which was the selected WPS for flux core arc welding in Operation 30.1G on Work Order No. 689120-12, required welding with "3/32" SFA 5.20 E70T-1 electrodes to .be performed using an amperage range of 350-550 and a C02 gas flow rate of 25-50 cfh.
Contrary to the above, the inspector observed flux core arc welding >
with "3/32," SFA 5.20 E70T-1 electrodes being performed using an actual amperage range of 320-340 and a CO2 gas flow rate of 80 cfh.
C. Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that 'special processes, including welding, . . . are controlled and accomplished . . . using qualified procedures in accordance with applicable codes . . . ."
Paragraph ..F-2431.1(c) in Section III of the ASME Code states in part with respect to qualification of welding material, "The welding of the test coupon shall be performed using the preheat and interpass temperatures to be used in production welding . . . ."
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2-Contrary.to the above, the test coupon for Heat'No'.-95098Z (SFA 5.20 E70T-1, "3/32") was welded using a 3500F maximum'interpass tem-perature and not the 5000F maximum interpass being used in production .
welding.
D. Criterion.IX of Appendix B to 10 CFR 50 states in part, " Measures ,
shall be established to assure that special processes, including welding, . . . are controlled . . . using qualified procedures in '
accordance' with applicable codes . . . ."
~ Paragraph QW-201.1 of the ASME Code,.Section IX,- states in part,
'!The welding procedure specification (WPS) shall list in detail . . . .
variables described'for each welding process as either essential or
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nonessential. (SeeQW-252through:QW-281.)"-
Paragraph QW-201.2 of thel ASME' Code Section IX, states in part, "The specific facts involved in. qualifying a WPS shall be recorded in a form called Procedure Qualifigation Record (PQR). This form shall ,
document the essential variables of the specific welding process on
- processes (as listed in QW-252 through QW-281) . . . . ~ . A change in any essential variable 'shall ' require-requalification, to be-recorded in another.PQR."
Table QW-255 in thel ASME.C6de Section IX, lists a change from a single gas to a mixture of gases as an essential . variable for the gas metal arc welding process. . Table QW-253 in the ASME Code,Section IX, lists an-increase in amperage or voltage as a supplemen-tary essential variable for the shielded metal arc welding process when notch toughness properties are specified.
Contrary to the above, the inspector observed the following wits respect to WPS No. 6881_-5, Revision A (gas metal arc welding process
- flux core) and WPS No'. 6881-4, Revision 8 (shielded metal arc weldingprocess):
- 1. WPS No. 6881-5, Revision A, permitted use of both an Argon -
C02 gas mixture and 100%.C02 gas, whereas the referenced supporting PQR for WPS No. 6881-5, Revision A, was qualified only with 100% C02 gas.
- 2. ' WPS No. 6881-4, Revision B, (utilized for applications with stipulated notch toughness properties) permitted a welding amperage range of 100-200 and a ' welding voltage range of 26-30, whereas the referenced supporting 'PQR was qualified with an amperage range of 115-125 and a voltage value of 26. -[
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-E. Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures
.shall be established to assure that special processes, including welding, . ... are controlled and accomplished . . . using qualified procedures in accordance with applicable codes ' . . . ." .
Paragraph NF-4335.1(c) in Section III of the ASME Code states with respect to weld procedure _ qualification tests, "The minimum require-ments for the. weld deposit. impact tests shall be in accordance with NF-2331." Paragraph NF-2331 in Section III- of the ASME Code stipulates
- a. minimum mils. lateral expansion value of 25 for three (3) impact specimens in applications over one (1) inch nominal wall thickness.
Contrary .to the above, WpS No. 6881-5, Revision A, was approved for .
use in thicknesses.up to four (4) inches, whereas the referenced supporting PQR showed mils lateral expansion values of 17, 22, and 24 in the weld deposit.
F. Criterion V of Appendix B to 10 CFR 50 states in part, " Activities affecting quality shall be presecribed by documented instructions, procedures, or' drawings . . . and shall be accomplished in accordance with these instructions, procedures, or drawings . . . ."
, Paragraph NF-4231.2 in Section III of the ASME Code states in part,
" Attachments which are welded onto the component support or parts' during the process of manufacture . . . but which are not incorporated into the final support are permitted provided the requirements . . .
below are met. _
(a) The material is suitable and compatible for welding to the ,
component support material. j (b) The welding material is. compatible with the base material.
(c) The welding procedures are qualified in accordance with Section IX . . . ."
Contrary to the above, the inspector observed temporary attachments welded to Work Order No. 688910, Part No. 6889-1-1, for which required controls could not be verified, .in that:
- 1. The temporary attachment material was not identified in- tenns of' suitability and compatibility for welding to component -
support material.
- 2. A procedure was not made available -to the inspector, which described the method used by Lamco to control the issue and use.of. temporary attachment materials.
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3.- The travele and welding records for the referenced assembly did not specifically document the welding' procedure and materials used for welding the attachments.
G. Criterion'IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processes, including
. . . heat treating . . . are controlled and accomplished . . . in accordance with applicable codes . . . ."
Paragraph NF-4333 in Section III of the ASME Code states in part with respect to postweld heat treatment of procedure qualification welds, " . . . The postweld heat treatment time at temperature shall be at least 80% of the maximum time to be applied to the component weld material . . . ."
Contrary to the above, a procedure qualification weld (PQR No.
01015301), applicable to the fabrication of Work Order No. 68840002, Part No. 6884-1-1, was not heat treated for 80% of the maximum time applied to the component weld material, as evidenced by the qualifica-tion being performed for four (4) hours at temperature and the compo-nent weld material receiving six and one quarter (6-1/4) hours at tem-perature.
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