ML20148R863

Notice of Deviation from Inspec on 780814-18

ML20148R863
Person / Time
Issue date:	09/11/1978
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148R820	List: ML20148R839 ML20148R863 ML20148R878
References
REF-QA-99900118 NUDOCS 7812010078
Download: ML20148R863 (4)

Text

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Walworth Company Greensburg Plant

$ NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on August 14-18, 1978, it appeared that certain of your activities were not conducted in full compliance with NRC requirements as indicated below:

A. Critorion V of Appendix B to 10 CFR 50 states in part that, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings . . . ."

Paragraph 2.3. of Section G-14, of the ASME accepted Nuclear QA Manual states that "The Authorized Nuclear Inspector is presented the QCS Check List for review and selection of Hold Points, if any. Review by the ANI is signified by signature and date. The Code part shall not be processed beyond that point until signed-off by the Nuclear Inspector."

Contrary to the above requirements, the following are examples where valves were processed beyond the Authorized Nuclear Inspector's des-ignated Hold Points:

1. Operation No. 31 of QCS-526-4 (heat No. G162-P2) described as "Present All Record Forms For Examination."

2. Operation No. 24 of QCS-164-5 (heat No.107G-P5) described as "Present All Record Forms For Examination." *

3. Operation No. 4 of QCS-918 (heat No. G701-P14) described as "Hyd ro Tes t. "

4. Operation No. 4 of QCS-918 (heat No. G701-P18) described as

" Hydro Test."

B. Criterion V of Appendix B to 10 CFR 50 states in part that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, type appropriate to the circumstances and shall be accomplished in accordance with these instructions, proce-dures, or drawings . . . . "

Paragraph 2.5. of Section G-13, of the ASME accepted Nuclear QA Manual states in part that ". . . Stamping shall be applied to low stress areas as designated by the Nuclear Engineer . . . ."

7812010078

Contrary to the above requirements, the Nuclear Engineer has never designated low stress areas for the stamping of nuclear valves.

C. Criterion V of Appendix B to 10 CFR 50 states in part that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, type appropriate to the circumstances and shall be accomplished in accordance with these instructions, proce-

! dures, or drawings . . . ."

Paragraph 2.2. of Section G-14, of the ASME accepted Nuclear QA Manual states in part that "The Manager of Quality Assurance shall mark the QCS Check List to indicate his Hold Points. The Code part shall not be processed beyond that point until signed-off by the Manager of Quality Assurance . . . ."

Contrary to the above requirements, Hold Points for operations 10 and 11 of QCS-915 (Heat No. G287-P1) identified as " Tag valve with ASME Code tag for manual valves, use ANSI B16.5 pressure rating" and

" Tag valve with special tag," respectively, were not signed-off by the Manager of Quality Assurance, although the valve was completed and shipped.

D. Criterion VI of Appendix B to 10 CFR 50 states in part, ". . . These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel . . . ."

Paragraph NCA-4134.6 of Section III to ASME Code states in part,

. . . These measures shall assure that the latest applicable doc-uments, including changes, are reviewed for adequacy and approved for release . . . ."

Contrary to these requirements, WC-C Procedures No. CDP-1, Revision 5, Procedure for Design of Body-Bonnet Flanged Joint and No. cdp-2, Revision 1, Procedure for Design of Body-Bonnet Flanged Joint for Valves to be used in Nuclear Service was transmitted to WC-G and WC-A on February 18, 1977, by WC-C memo and there is no documentary evidence that these procedures were reviewed and/or approved.

The inspector verified that the procedures had been used for the flange analyses of a 2-150# outside screw and yolk gate valve and a 6"-150# outside screw and yolk gate valve.

E. Criterion VI of Appendix B to 10 CFR 50 states in part, ". . . Changes to documents shall be reviewed and approved by the same organization that performed the original review and approval . . . . "

Paragraph NCA-4134.6 of Section III to the ASME Code states in part,

. . . These neasures shall assure that the latest applicable documents

including changes, are reviewed for adequacy and approved for release by authorized personnel . . . ."

Paragraph 2.4. of Section G-6, to the ASME accepted Nuclear QA Manual states in part, "Each procedure and revision thereof shall be approved by all of the following:

1. The Nuclear Engineer for conformance to Code and Customer require-ments, and for prescribing of appropriate quality level.

2. The Quality Assurance Engineer to assure that proper use of the procedure or revision will result in the required quality level, including any necessary identification and documentation."

Contrary to these requirements, eight addenda have been added to WC-G welding procedure specification 4-GWR, Revision 2, and had not been approved by the Quality Assurance Engineer as prescribed.

F. Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processess, including welding . . . are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes . . . ."

Paragraph NCA-4134.9 of Section III to the ASME Code states in part,

". . . Measures shall be established to assure that process, such as welding . . . are controlled in accordance with the rules of this section and are accomplished by qualified personnel using qualified procedures."

Paragraph NB-4361(b) of Subsection NB-4360 Qualification Requirements for Welding Specially Designed Welding Seals of Section III to ASME Code states in part, "The welding procedure shall be qualified as a new procedure specification and shall be completely requalified when any of the essential variables specified or listed in the following paragraphs are made in the procedure."

Contrary to these requirements, the welding procedure for canopy seals was not qualified as a new procedure in that the WC-G welding procedure specification 4-GWP, Revision 2, was qualified with a 3 inch thick test coupon using a groove weld but the welding procedure qualification record for the canopy seals states the qualification test was performed on 0.100 inch thick material with a fillet weld. In accordance with paragraph NB-4363 of Section III, the qualified thickness range for the canopy seal is from 0.090 to 0.200 inch thick naterial.

_4 G. Criterion IX of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that special processess, including welding . . . are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes . . . ." '

Paragraph NCA-4134.9 of Section III to the ASME Code states in part,

. . . Measures shall be established to assure that process, such as welding . . . are controlled in accordance with the rules of this section and are accomplished by qualified personnel using qualified procedures."

Paragraph QW-201.2 of Section IX to the ASME Code states in part, "The specific facts including the base metal specification Type and Grade

. . . and the essential variables . . . used in qualifying a WPS shall be recorded in a form called Procedure Qualification Report . ...

This form shall also record the test results. i It is required that the essential and nonessential variables of a WPS be followed in welding the test coupons. The WPS identification {

. . . shall be listed on the PQR. Tnese documents shall be certified '

{ by the manufactured . . ."

Article II of Sectior. IX of the ASME Code states in part, ". . . both the essential and nonessential variables for each welding process shall be included in the written welding procedure specification. If a change is made in one or more of the essential variables, as has been in the past, preparation of a new or revised welding procedure specification and requalification is required. If a change is made to one or more of the nonessential variables, listed in the qualified welding procedure specification, a new or revised welding procedure specification is required.

Contrary to these requirement:

1. Change to the nonessential variables to WC-G welding procedure specification 4-GWP, Revision 2, have been made by the addition of eight different addenda.

2. WC-G welding procedure specification 4-GWP, Revision 2, does not address the impact test but there is a procedure qualification l

record of impact values.

3. WC-G welding procedure specification 4-GWP, Revision 2, paragraph 1.6.4 states, "Above 8000F the rate of heating and cooling shall not exceed 1000F per hour. Below 8000F the pieces may be cooled in still air." However, the procedure qualification record states the heating above 6000F was 1300F per hour and cooling below 6000F was 1600F per hour.

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