ML20147C608

Notice of Deviation from Inspec on 780410-13

ML20147C608
Person / Time
Issue date:	05/22/1978
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20147C480	List: ML20147C474 ML20147C496 ML20147C577 ML20147C608 ML20147C616
References
REF-QA-99900017 NUDOCS 7810130061
Download: ML20147C608 (7)

Text

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O Dravo Corporation Docket No. 99900017/78-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on April 10-13, 1978, it appears that certain of your activities were not conducted in full accordance with NRC requirements as indicated below:

A. A Dravo corrective action response letter dated November 23, 1977, states in part with respect to item I.D.3.a.(1) of IE Report No. 77-01,

. . . The welding foremen have been instructed and trained to include all variables over which a welder can exercise control on the Weld Joint Data card before giving to the welders . . . ."

Contrary to the above, the inspector observed that all variables over which a welder can exercise control were not being included by the welding foremen on Weld Joint Data cards supplied to the welders, as illustrated by the following examples:

1. The Weld Joint Data card applicable to the gas tungsten arc welding operation on Weld B, Job No. 3002, Sketch 427, did not specify the required maximum interpass temperature, the required purge gas flow rate, polarity to be used or reference the method of initial and interpass cleaning to be used.

2. The Weld Joint Data card applicable to the gas tungsten arc welding operation en Weld E, Job No. 3000, Sketch 218, referenced two (2) unidentified shielding gas flow rates of 25-50 cfh and 0-10 cfh.

Examination of the applicable welding procedure specification, 1-1-W 6104-LS, Re/ision 6, showed three (3) stipulated argon flow rates, i.e. for the torch, for the hot wire feed device and for the inside purge. It was further noted that the flowmeter ,

l for the hot wire device had been removed from the equipment.  !

B. l A Dravo corrective action response letter dated November 23, 1977,  !

states in part with respect to item I.C.3.a.(1) of IE Report No. 77-02,

". . . Dravo will prepare a General Welding Specification on or before February 28, 1978, incorporating shop standards for all welding processes to be used for tacking . . . ."

Contrary to the above, the inspector was advised on April 12, 1978, that the general welding specification had not been finalized.

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C. A Dravo corrective action response letter dated flovember 23, 1977, states in part with respect to item I.C.3.a.(3) of IE Repcrt No. 77-02,

". . . This item will be included in our audit check list of production activities by 3/31/ 78 . . . . "

Contrary to the above, the inspector was advised on April 12, 1978, that the item had not yet been included in an audit checklist of production activities.

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 and accomplished . . . using qualified procedures Paragraph NA-4451 in the ASME Section III Code (1974 Edition) states in part, ". . . Measures shall be established to assure that processes including welding . . . are accomplished . . . using qualified proce-dures."

Contrary to the above, measures were not established with respect to certain welding power sources e.g. Hobart S/N 66773, which would assure conformance of amperage output with the requirements of applicable welding procedure specifications, in that:

1. No method or means of correlating dial settings with amperage output was at the work station.

2. The QA Manual does not specifically require welding foremen to perform any checks of electrical parameters used by welders relative to procedure requirements, nor is equipment assigned to them to perform such functions.

3. Procedure GWS-6, Revision 1, which defines requiremants for inde-pendent surveys of production welding operations by Welding Engineering, utilizes a random selection basis for operations witnessed and has no provisions to assure that all qualified welders are progressively surveyed to verify compliance to proce-dure requirements at a specified frequency.

4. Review of Welding Engineering survey records dating from June 1973, for a sample of twelve (12) welders taken from a qualified welders list, showed two (2) shielded metal arc welders who had never been surveyed. The inspector also observed two (2) additional welders, who were listed as qualified for all Dravo active processes, that had never been surveyed for any process, The inspector was informed that the latter two were actually welding foremen, for whom until recently it had been the Dravo practice to maintain welding qualifications.

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E. A Dravo corrective action response letter dated November 23, 1977, states in part, with respect to item II.C.3.a.(1) of Report No. 77-02, "A manual revision will be made and issued prior to fiarch 31, 1978, which will clarify this commitment so as to allow recording of the information to occur anytime prior to final inspection."

Contrary to the above, a menual revision to clarify this ommitment was not issued prior to March 31, 1978.

F. A Dravo corrective action response letter dated November 23, 1977, states in part with respect to item II.C.3.a. (4) of IE Report No. 77-02,

. our QA Manual will be revised prior to March 31,1978, to include a requirement for the recording of the procedures and revision letters on the speci fic back-up shop documents . . . ."

Contrary to the above, the QA Manual was not revised prior to March 31, 1978, and the applicable revision to correct this deviation had not j been issued as of the date of this inspection.

G. A Dravo corrective action response letter dated November 23, 1977, states in part with respect to item II.C.3.a.(5) of IE Report No. 77-02,

. A new procedure will be written to specifically delineate this commitment. This procedure ES-DOC-3 will be written and implemented prior to 1/1/78. . . ."

Contrary to the above, a new procedure ES-DOC-3 was not written and implemented prior to 1/1/78 but was written on 4/10/78, over three (3) months later.

H. 10 CFR 50, Appendix B, Criterion IX, states in part, " Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing are controlled . . . in accordance with applicable codes, standards, specifications, criteria and other special requirements."

Section V, Article 6, of the ASME Code, paras,raph T-630, states in part, "When using penetrant examination methods for nickel base alloys the penetrant materials shall be analyzed for sulfur content . . ..

The total sulfur content shall not exceed 1% by weight . . . . When examining austenitic stainless steels . . . . The total halogen content of the residue shall not exceed 1% by weight." ,

Contrary to the above, it cculd not be verified that the total sulfur and halogen content of the residue did not exceed 1% by weight for the penetrant materials used to examine nickel base alloys and austenitic stainless steels, in that, the containers used to dispense bulk penetrant materials contained a residue of an unknown substance.

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4 I. 10 CFR 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances Paragraphs fib, flC and fiD-5521 of ASME Section III Code (1977 Edition) state in part, " Certification of Level III nondestructive exami-nation personnel by examination technical competency is required.

The procedure used for examination shall be described in the written practice which is required by SNT-TC-1 A-1975. .. "

The above requirement was mandatory as of October 1,1977, with the expiration of Code Case N-138 (1769-1).

Contrary to the above, the procedure used for examination of Level III nondestructive examination personnel is not described in the Dravo written practice, ESM-QA-2, which is required by SNT-TC-1 A-1975.

J. A Dravo letter of corrective action dated November 23, 1977, states in part with respect to item III.D.3.a. of IE Report flo. 77-02, ". . .

Furthermore, a procedure has been written and imposed for the control of vendor audits. . . ."

Contrary to the above, although the specified procedure was found to be in a rough draf t stage, the provisions of the draf t were not being imposed.

K. Criterion XVIII of Appendix B to 10 CFR 50 states in part, "A com-prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The audits shall be performed in accordance with the written procedures or check lists Section 17 of the Quality Assurance manual, paragraph 3.5, states,

" Audits performed in accordance with written checklists shall be made periodically during the year." Also, Section 17 of the Quality Assurance flanual, paragraph 3.5.1, states, "Each such checklist shall be completed at least once a year."

Contrary to the above, certain audits had not been performed once a year, in that the corresponding written checklists had not been com-pleted once a year. Examples : Weld Engineering and Production Welding, Purchasing department, and Inspection department.

A similar deviation was previously identified and reported in Report flo. 77-01 and in Report No. 77-02.

I' L. Criterion XVIII of Appendix B to 10 CFR 50 states in parts ". ..

Audit results shall be documented and reviewed by management having responsibility in the area audited . . . ."

Section 17 of the Quality Assurance Manual, paragraph 3.3, states, "Results of the audits shall be distributed to the General Manager, Chief Engineer / Quality Assurance Manager, Quality Assurance Supervisor, Manager of Operations, Chief Inspector, Authorized Inspector, and other appropriate management personnel having responsibility in the areas audited."

Contrary to the above, a sample revealed that results were not distributed to the Chief Inspector in one instance, and to the Authorized Inspector in another instance.

M. Criterion III of Appendix B to 10 CFR 50 states in part, ". . . The verifying or checking process shall be performed by individuals or groups other than those who performed the original design . . ..

Section 3 of the Quality Assurance Manual, paragraph 4.2, states, "To insure accuracy the sketches shall be checked, initialed, and dated by one other individual in Engineering prior to issuance."

Contrary to the above, a sample revealed that sketches were not checked, initialed, or dated by one other individual in Engineering. Examples:

E-2803-143, E-2803-159, E-2803-155, E-2803-143, E-2803-15, E-2803-4, E-2803-5, E-2803-76, E-2803-546, and E-2803-548.

A similar deviation was previously identified and reported in Report No. 77-02.

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Section 3 of the Quality Assurance Manual, Revision 3, paragraph 4.6, states, " Sketches are submitted for customer approval when required by contract."

Contract specification 10855-P-201(Q), paragraph 9.3.1, states in part, "The following drawings shall be submitted and approved prior to start of fabrication:

(a) Spool detail sheets for class 1 and class 2 piping; class 3 piping that is seisgic category 1; and class 3 piping with a design temperature exceeding 21 F or a pressure exceeding 150 psig . . . " Also, the same specification page 12 of 17 under the paragraph " RELEASES" states in part, ". . . Seller is released to commence fabrication upon receipt of Code I status spool sketches."

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Contrary to the above, a sample revealed that certain spool details sheets for class 2 piping had been released for fabrication, even though prior approval had not been obtained. Examples: E-3035-G, E-3035-22, E-3035-20, E-3035-28, E-3035-32, E-3035-34, E-3035-37, E-3035-40, E-3035-41, E-3035-46, and E-3035-54.

A similar deviation was previously identified and reported in Report No. 77-02.

O. Section 14 of the Quality Assurance Manual, paragraph 3.2.7, states, "The ANI shall be given the opportunity to review the disposition on all Code items and nonconformances and to establish mandatory hold points."

Also, paragraph 3.2.7.1 of the same section states, " Completion of such review shall be indicated by his initialing and dating the NCR prior to returning it to Quality Assurance."

l Contrary to the above, certain nonconformance reports (NCR) had not been presented to the ANI as required. Examples: NCR E-3035-QA 33, E-3035-QA 23, E-3035-QA 17, E-2803-QA 61, E-2803-QA 53, E-2803-QA 49, and E-3000-QA-15.

A similar deviation was previously identified and reported in Report No. 77-01.

P. Criterion XV of Appendix B to 10 CFR 50 states in part, " Measures shall be established to control matericls, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation . ...

Section 14 of the Quality Assurance Manual, paragraph 3.1, states in part, "Nonconformances are defined as ' items that, because of deficiency in characteristic, documentation or procedure render the quality of the item unacceptable or indeterminate'.

Section 7 of the Quality Assurance Manual, paragraph 11.5, states,

" Rejected material shall be physically separated, when practical, from acceptable material." Also, paragraph 11.5.1 of the same section states in part, "It shall be marked by both a red tag and trouble tag . . . ."

Contrary to the above, the following materials with discrepant CMTR's were not red tagged or trouble tagged. Examples: E-3036 CMTR#43, E-3035 CMTR#139, E-3035 CMTR#142, and E-3035 CMTR#275.

A similar deviation was previously identified and reported in Report No. 77-02.

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Q. Criterion XII of Appendix B to 10 CFR 50 states, " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits."

Section flCA 4134.12 of the ASME Code states in part, ". . . Calibration shall ce against measurement standards which have known relationship to national standards . . .

Contrary to the above, certain masters are not traceable to the national standards, in that they have been removed from the calibration control program. Examples: Gage Blocks, Dead weight tester weights, Dead weight tester, and Radius Gages.

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