ML20148R878
| ML20148R878 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/1978 |
| From: | Hunter V, Kelley W, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20148R820 | List: |
| References | |
| REF-QA-99900118 NUDOCS 7812010082 | |
| Download: ML20148R878 (16) | |
Text
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VEliDOR INSPECTION REPORT U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INRECTION AND ENFORCEMENT REGION IV l
Report No.
99900118/78-03 Program No.
44060 Company:
Wilworth Company Greensburg Plant Post Office Box 1103 Greensburg, Pennsylvania 15601 Inspection Conducted: August 14-18, 1978 Inspectors:
/Nb,'
- 1 -
O' M Wm. D. KcIley, Contractor Inspector, Vendor Date l
Inspection Branch
/ [W f//--ff V. H. Hunter, Contractor Inspector, Vendor Date Inspection Branch l
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//-k D. E. Whitesell, Chief, Components Date Section I, Vendor Inspection Branch Approved by:
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-//" N D. E. Whitesell, Chief, Components Dete Section I, Vendor Inspection Branch I
Sunma ry inspection on August 14-18, 1978 (99900118/78-03)
Areas Inspected:
Implementation of 10 CFR 50, Appendix B and applicable codes and standards including, design document control, audits, special welding applications, evaluation of suppliers, and manufacturing process control-machining, also, action on previous findings, interface with Authorized Nuclear Inspector, and management meetings.
The inspection involved eighty-eight (88) inspector-hours on site by three (3) NRC inspectors.
781201008%
w
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ ___- - - Results:
In the five (5) areas inspected, no apparent deviations or unresolved items were identified in two (2) areas.
The following were identified in the remaining three (3) areas.
Deviations:
Design Document Control (DetailsSection I, paragraph E.3.a.);
Special Welding Applications (DetailsSection I, paragraph G.3.a.);
Manufacturing Process Control-Machining (DetailsSection III, paragraph B.3.a.)
l l
___. _ _-___-_____-__-_ - __-_____ DETAILS SECTION I (Prepared by Wm. D. Kelley)
A.
Persons Contacted Walworth Company - Corporate Engineering Office (WC-C)
+R. O. Hunt, Corporate Director of Quality Assurance
+J. E. Palmer, Vice President of Manufacturing Walworth Company - Greensburg Plant (WC-G)
- P. J. Bauman, Chief Inspector
- J. A. Fabian, Quality Assurance Engineering
- G. J. M. Hill, Manager of Quality Assurance
- R. G. Knopf, Section Head Inspector
- E. M. Petrosky, Nuclear Projects Manager S. N. Shields, Manager of Engineering
+*J. B. Weinzierl, Plant Manager Walworth Company - Aloyco Plant (WC-A)
J. L. Hawley, Nuclear Engineer Hartford Steam Boiler Inspection and Insurance Company (HSB)
+C. F. Balsley, Regional Manager
- Denotes those persons who attended Exit Interview.
(See paragraph I.)
+ Denotes those persons who attended the Corporate Management Meeting.
(See paragraph D.)
B.
Previous Inspection Findings (Closed) Deviation (Report 78-01):
Contrary to Criterion III of Appendix B to 10 CFR 50 and paragraphs NCA-4134.3(a) and (b) of Section III to the ASME Code, there was no implementing procedure or documented evidence that assured the overall design was reviewed for design adequacy.
I The inspector verified that Sections G-6, 8, 9, and 10 to the WC-G l
ASME accepted Quality Assurance Manual, had been revised to provide
)
the implementating procedures and documentary evidence necessary to assure the overall design was reviewed for adequacy. The revised QA I
)
Manual, Revision 6, was accepted by the Authorized Inspection Agency's l
Specialist.
l
_4 (Closed) Deviation (Report 78-01):
Contrary to Criterion XII of Appendix B to 10 CFR 50, Section G-18 to the ASME accepted QA Manual, and paragraph 3.1 of MIL-C-45662-A, there was no calibration data to substantiate calibration of the thermocouples and temperature recorder used to monitor the heat treat furnance.
WC-G letter of March 17, 1978, to NRC-IEIV stated additional proce-dures would be developed for the calibration of thecmocouples and temperature recorders and would be fully implemented by September 1, 1978.
Subsequent to the letter WC-G made the decision to subcontract the calibration to a qualified service company.
The inspector verified a contract for calibration services four times per year was accepted by WC-G on May 18, 1978, and calibration of thermocouples was performed on June 20, and 21, 1978.
(Closed) Deviation (Report No. 78-01):
Contrary to Criterion XVIII of Appendix B to 10 CFR 50 and paragraph 3.1.5 of Section G-22 to the QA Manual, there was no documented evidence that the appropriate supervisors were informed of the findings and recommendations resulting from the audit conducted in August 1977, by an independent auditor.
The inspector verified that all of the appropriate supervisors had been informed of the findings and recommendation of the August 1977, audit.
(Closed) Deviation (Report No. 78-01):
Contrary to Criterion XVIII of Appendix B to 10 CFR 50 and paragraph 3.1.1.(d) of Section G-23 to the ASME accepted QA Manual, there was no documented evidence of a training session being held prior to the internal audit dated December 20, 1977.
The inspector verified a memo of training was written for all sub-sequent internal audits.
(Closed) Unresolved Item (Report No. 78-01):
WC-G specified the maximum safe stem torque in their motor request specifications; however, the motor operator supplier did not assure WC-G that this value was not exceeded in the event of torque switch failure.
The inspector verified that WC-G contacted the valve operator manufac-ture and they stated their operators will not destruct at stalled motor torque due to torque switch failure.
WC-G stated that their valves are designed for motor operator stalled torque where there will be no violation of the pressure boundary; however, the valve may l
become inoperable.
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. (0 pen) Unresolved Items (Report No. 78-01):
1.
Welding procedures were being corrected using " white-out" and approval signature blocks were pasted on it.
2.
The welding procedure qualification records stated the current range, but does not state the current used in preparing qualification test coupons.
l 3.
The impact tests valves were not documented on the procedure qualification records.
The inspector will review these unresolved items on a subsequent inspection.
l (Closed) Unresolved Item (Report No. 78-01):
WC-G procedure WGQC-1, Revision 5, stated the procedure was established for the purpose of implementing the requirements of Section 17 of the Walworth Company Greensburg Plant, General Policy Manual, and Section G-23 of the Walworth Company - Greensburg QA Manual.
The QA Manual required the reponsible supervisor to respond to an audit finding within thirty (30) days of the date f the audit report and the Quality Policy Manual required ten (10) days.
The inspector verified that the General Policy Manual had been revised to require the responsible supervisor to reply within thirty (30) days of the date of the audit report and the General Policy Manual is now in agreement with the QA Manual, Revision 6.
C.
Ma'nagement Meeting A meeting was held on August 14, 1978, with the responsible officers of the Walworth Company's Greensburg facilities to explain that the purpose of this team inspection was to ascertain whether appropriate corrective actions had been implemented concerning (1) Feedback to design to reconcile all differences between the initial design and the "as-built" conditions; (2) the accuracy and completeness of the QA/QC records, including the shop routing sheets, (QCS check lists);
and (3) Welding Control.
These appear to be areas where deviations t.ere identified by both NRC inspectors and customer inspectors, and are indicators that the company's QA program may not be effectively implemented.
D.
Corporate Management Meeting A meeting was held on August 17, 1978, with the Walworth Company's Corporate Vice President of Engineering, and the Director of Quality
... _. _ _ _. _ _ _ _ _. Assurance, the Greenburg facility's Plant Manger, and the Authorized Inspection Agency's Regional Manager to discuss Walworth performance record concerning the effectiveness of its QA program as implemented.
The NRC informed Walworth that its approved QA program appeared to be adequate to ensure compliance with the NRC rules, and Code requirements.
However, the implementation of the various program requirements were not sufficiently effective to establish confidence that the quality level prescribed by its customers for Code items was consistently being achieved.
The Vice President for Engineering, reiterated the company's policy statement concerning Quality Assurance and the quality and relia-bility of its products.
He informed the NRC representatives that the policing, to ensure effective implementation of program require-ments, would be escalated to the extent necessary to ensure that the quality level prescribed for the items being manufactured are success-fully achieved on a routine basis.
E.
Design Document Control 1.
Objectives The objectives of this area of the inspection were to ascertain whether procedures had been developed and properly implemented to control the review, approval, release and issuance, of design documents in a manner consistent with NRC rules and regulations, ASME Code requirements, and the vendor's QA program commitments.
2.
Method of tc p mplishment The object ves of this area of the inspection were accomplished by:
a.
Review of the ASME accepted QA Manual, Revision 6:
(1)
Section 9, Design control, and (2)
Section 19, Documentation to verify that the vendor had established procedures to prescribe a system for design document control.
b.
Reviewed these selective procedures:
(1) WC-C Procedure No.
CDP-1, Revision 5, Procedure for Design of Body-Bonnet Flange Joint, and
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ (2) WC-C Procedure No.
CDP-2, Revision 1, Procedure for Design of Body-Bonnet Flanged Joint for Valves to be used in Nuclear Service to verify that they had been prepared by the designated authority, approved by management, and reviewed by QA.
c.
Review of WC-G Design Stress Report ASME Section III, Division 1, Class 1, 12" 1500# Gate Valve Figure No. 5262PS, to verify that it provided for identification of personnel responsible for preparing, reviewing, approving, and issuing design documents; and that the review and approval of significant changes were performed by the same personnel.
Also to ascertain whether minor changes to design documents, that do not require review and approval, are ider,tified, d.
Review of WC-G memo to WC-C dated January 8,1976, to verify that the distribution lists are current and that the proper documents are identified, accessible, and are being used.
e.
Interviewed personnel to verify whether they were knowledgeable in the procedures applicable to design document control.
3.
Findings a.
Deviations See Enclosure, Item D.
b.
Within this area of the inspection no unresolved items were identified.
F.
Audits 1.
Obiectives The objectives of this area of the inspection were to verify that procedures had been prepared and approved by the vendor that prescribed a system for auditing which is consistent with NRC rules, Code requirements, and the commitments of the ASME accepted QA Manual. Also, to verify whether these audit procedures were being properly and effectively implemented by the vendor.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
a.
Review of the ASME accepted QA Manual, Revision 6:
(1) Section G-4, Organization, and (2) Section G-23, Audit to verify that procedures had been established to prescribe a system for auditing, which is consistent with NRC regulations.
b.
Review of WGQC-11, Revision 5, Walworth - Greensburg, QA Procedure Instruction for Internal Audit of Quality Program, to verify it had been prepared by the designated authority, approved by management, and reviewed by QA.
c.
Review of Section G-23 of the ASME accepted Nuclear QA Manual, Revision 6, to verify it identifies the organizations responsible for auditing and their responsibilities; establishes audit personnel qualifications and training, and that the audits l
are performed by qualified personnel. Also, to verify that the essential elements of the audit system is established.
1 d.
Review of the audit schedules to assure that the audits of quality activities during design, procurement and manufacture are planned, documented, and conducted in the prescribed manner, and assures coverage of all aspects of the QA program.
e.
Review of selective audit reports to verify that they include provisions for written plans, team selection, team orientition, audit notifications, pre-audit conferences, audit performances, and post-audit conferences.
f.
Review of selective audit reports to verify that they are properly distributed to management and the audited organization; and that follow-up audits to verify corrective action is required.
g.
Review of selective internal and external audit reports to verify the applicable procedures were available to the audit team personnel, and that the audit procedures were properly and effectively implemented.
3.
Findinas_
Within this area of the inspection no deviations or unresolved items were identified.
G.
Special Welding Applications 1.
Objectives
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_g.
The objectives of this area of the inspection was to verify that special welding specifications (cladding, hard surfacing, seal welding, and weld repair without postweld heat treatment) conform with the additional requirements established by ASME Code,Section III and IX, NRC regulations, and the vendor's QA program commitments.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
a.
Review of the ASME accepted QA Manual, Revision 6:
(1)
Section G-16, Welding Quality Assurance, und (2) Section G-17, Heat treating to verify the vendor had established procedures to prescribe a system for the development and qualification of special welding specifications, and for qualifying welders and/or welding machine operators.
b.
Review the WC-G documents, 4-GWP Manual Shielded Metal Arc-Welding (SMAW) Procedure Groove and Fillet Welds Group P-Number 1, Gr. 1 Materials (Quenched and Tempered), to verify the special requirements governing special welding application procedures and performance qualification imposed by ASME Code regarding test sample size, examination of
'a test sample, and special essential variables are satisfied.
c.
Interviews with personnel to verify that they were knowl-edgeable in the procedures applicable to canopy welds.
3.
Findings a.
Deviations See Enclosure Items E, F, and G.
b.
Within this area of the inspection no unresolved items were identified.
H.
Evaluation of Supplier Performance 1.
Objectives The objectives of this area of the inspection were to verify that procedures had been prepare,d and approved by the vendor to prescribe a system for evaluation of suppliers performance which is consistent with flRC rules, Code requirements, and the commitments of the QA Program. Also, to verify that the proce-dures for evaluation of suppliers performance is being properly i
and effectively implemented by the vendor.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
a.
Review of the ASME accepted QA Manual, Revision 6, Section 12, Control of Purchased Material, Equipment and Services, to verify the vendor had established procedures for effecting evaluation of suppliers, that is consistent with NRC rules and Code requirements.
b.
Review of six (6) sets of documents applicable to three (3) suppliers to verify that the procedures, and necessary procurement documents, were available to the persons responsible for performing the quality affected activities, and that the procedures were properly implemented.
c.
Interviews with personnel to verify whether they were knowl-edgeable in the procedures applicable to evaluation of the suppliers' performances.
3.
Findings Within this area of the inspection no deviations or unresolved items were identified.
I.
Exit Interview The inspector met with management representatives (der.oted in para-graph A. ) at the conclusion of the inspection on August 18, 1978.
The management representative acknowledged the statements by the inspector concerning the deviations identified this inspection.
_. DETAILS SECTION II (Prepared by D. E. Whitesell)
A.
Persons Contacted Walworth Company - Corporate Engineering (WC-C)
R. O. Hunt, Director of Quality Assurance Walworth Company - Greensburg Plant (WC-G)
G. J. M. Hill, Manager of Quality Assurance E. M. Petrosky, Nuclear Project Manager Gary Homer, Nuclear Engineer Hartford Steam Boiler Inspection and Insurance Company (HSB)
C. F. Balsley, Regional Manager The assigned ANI was on vacation.
l l
B.
Authorized Nuclear Inspector (ANI) Interface 1.
Objectives
~
The objectives of this area of the inspection were to ascertain whether procedures had been prepared and approved, which describes the system to be implemented for the achievement of interface activities with the ANI, and that the identified activities are consistent with the NRC rules, Code requirements, and the QA Program commitments.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished as follows:
a.
Review of the QA Manual, Section G-8, " Order Review,"
paragraph 2.5; to ascertain whether the system provides for interface with the ANI, and/or the Authorized Inspection Agency (AIA), to review the Design Specification (DS), and provide the inspection services, required by code, of all code items covered by the customer's order and DS.
b.
Review of the QA Manual, Section G-11, " Drawing and Print Distribution and Control;" paragraph 2.4; to verify that e
____-__ - - changes in the customer's design specifications (DS) are reviewed with the ANI to inform him of the status of the inspections and tests of the items when it is removed from the manufacturing pracess, c.
Review of the QA Manual, Section G-12, " Control of Pur-chased Material, Equipment and Services;" paragraph 2.3.1.2; to verify that measures have been provioed to make available for review by the ANI, Material Certifications and the QC Source and/or Receiving Inspection Reports, and that such reviews are documented.
d-Review of the QA Manual, Section G-13, " Material Identifi-cation and Control;" to verify that a system has been provided to maintain the identification of materials, and that tne ientificatiN is transferred when it becomes necessary to di.ide the material, aho, tt
"?#y that the ANI is provided the opportunity to verify uiht the identification of material is properly maintained and documented.
e.
Review of the QA Manual, Section G-14, " Process Control,"
to verify that the program provides for the QCS Check Lists to be reviewed with the ANI so that he may select the operations, inspections, and tests that he will witness.
Also to verify that code parts cannot be processed beyond the ANI hold point until signed-off by him.
f.
Review of the QA Manual, Section G-15, " Welding Quality Assurance," paragraph 3.12; to ascertain whether measures have been established for the ANI to witness any welding procedure and/or any welder performance qualification tests and to verify that he may request the requalification of any procedure or welder.
g.
Review of the QA Manual, Section G-20, " Code Symbol Stamping,"
paragraph 2.3; to verify that the program provides for the application of the code stamp only with the authorization of the ANI af ter acceptable pressure testing, and the certification of the Manufacturer's Data Report, and only in the presence of the ANI.
h.
Review of the QA Manual, Section G-21, " Authorized Inspection,"
to ascertain the designated WC personnel authorized and responsible for maintaining liaison with the AIA and the ANI.
Also to verify that the design specifications (DS),
drawings, and data sheets are made available for review by the ANI to enable him to verify and document that the DS
l l are certified by a professional Engineer (PE), that the size and code class of the component, or part, is within the scope of the certificate of authorization, and that the code jurisdiction is clearly established and identified.
i.
Review of the QA Manual, Section G-22, "Nonconformities and Corrective Actions," paragraph 3.4.3; to verify that the ANI is notified of all rejection, or scrap items, as indicated on Nonconforming Material Report Tag, where the ANI previously participated in acceptance of quality actions.
Also, paragraph 4.3; to verify. that Material Review Board Report, indicating its recommended corrective actions, are made available for review by the ANI and his review is docu-mented.
j.
Design Specification No. DSP-G508-044687-000 was reviewed to verify that the QA program requirements established by paragraph 2.5 of Section G-8, of the QA Manual was being properly implemented.
Also to verify that the specified Nuclear Information Report had been properly completed, and had been reviewed by both the ANI, and the ANIS, and that these reviews were documented.
k.
Review of QCS.918, Order No. PN37653-16AA, and QCS 931, Order No. PN30908-008A, both for 3 inch weld end wedge gat <3 (WEWG), class 3 valves to verify that the requirements of G-14 of the QAM was being correctly implemented.
It was verified that the ANI had reviewed the foregoing documents and had selected his hold points.
m.
Review of Review Board Reports (RBR) Nos. 733 and 736, to verify that as-built conditions are fedback to design for evaluation.
These reports concerned the flange thickness of both the bonnet and body of a 150 pound globe valve, as being less than the dimension and tolerance established by the part drawings.
The Review Board recommended that these parts be "used as is," and had attached copies of the original design calculations which established the minimum acceptable dimensions for the thickness of these flanges, to document that the as-built conditions were acceptable.
Copies of the part drawing had been attached to the appropriate RBR to demonstrate that the drawings had been revised to reflect the as-built conditions.
n.
The Daily Log Book maintained by the ANI was reviewed, and it was observed that he had documented his review of the above mentioned RBR.
It was also observed that
__ he identifies his review of DS, drawings, QCS Check Lists, Welding Procedures and Qualifications, and the qualifications of Weldors and NDE technicians, also that he witnesses hydro tests, and the application of the stamp.
3.
Findings The ANI activities as documented in his bound log book, and by documents reviewed, supports a Finding that the vendor is properly implementing its interface responsibilities with the ANI in a manner consistent with the NRC rules, Code requirements and its QA program commitments.
1 1
4 DETAILS SECTION III (Prepared by V. H. Hunter)
A.
Persons Contacted Walworth Company - Greensburg Plant (WC-G)
E. M. Petrosky, Nuclear Project Manager V. G. Taylor, Assembly Area Inspector
+
B.
Manufacturing Process Control - Machining 1.
Objectives The objectives of this area of the inspection were to verify that the machining operations are performed under a controlled system of manufacturing which meets the ASME Code requirements, NRC regulations, and contract requirements, and is effective in assuring product quality.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
a.
Review of the ASME accepted QA Manual, Revision 6, (1)
Section G-10, Quality Planning (2)
Section G-13, Material Identification and Control, and (3) Section G-14, Process Control to verify that procedures had been established to prescribe a control system of operation.
b.
Review these selective specification and WC-G procedures:
(1) SSPC-SP-10-63T titled " Steel Structures Painting Council Surface Preparation Specifications,"
(2) Hydrostatic test procedure, and (3) NDE Procedures
(
~ to verify that they had been prepared by the designated authority, approved by management, and reviewed by QA, and are consistent with NRC regulation, Code requirements, and QA coamitments.
c.
Review these selective documents:
(1)
Engineering Instructions, (2) Drawing log, and (3) Bills of Material to verify that they provide drawing / document control in the shop, and also provides for part identification and trace-ability, in-process and final inspections, identification and segregation of defective items, the resolving of non-conforming items, and that the gages and measuring devices are under a controlled calibration system.
i d.
Examine three (3) representative samples of finished machined l
parts to verify that they were properly, identified and j
machined to conform to the drawings and specifications.
e.
Examined these selective WC-G documents:
(1) Order No.
PD 40331, PN 37653, 30878, PN 30879, PN 31299, and 37653, (2) Quality Checklists QCS-918, QCS 164-5, QCS 328-5, QCs 528-4, and QCS 538-5, and (3) Final documentation packages for all of the above to verify compliance with applicable documentation require-ments.
3.
Findings a.
Deviations See Enclosure, Items A, B, and C.
b.
Within this area of the inspection no unresolved items were identified.
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