ML20148S337

Notice of Deviation from Inspec on 780619-22

ML20148S337
Person / Time
Issue date:	07/21/1978
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20148S181	List: ML20148S269 ML20148S337 ML20148S385
References
REF-QA-99900086 NUDOCS 7812010317
Download: ML20148S337 (5)

Text

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l Hopkinsons Limited Docket No. 99900086/78-01 h NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on June 19-22, 1978, it appeared that certain of your activities 'were not conducted in full accordance with NRC requirements as indicated below:

A. 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 . . . ."

l Paragraph QW-201.1 in 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 nonessential. (See QW-252 through QW-281.)"

Paragraph QW-201.2 in the ASME Code,Section IX, states in part, "The specific facts involved in qualifying a WPS shall be recorded in a form called Procedure Qualification Record (PQR). This form shall document the essential variables of the specific welding process or processes (as listed in QW-252 through QW-281) . . . .

A change in any essential variable shall require requalification, to be recorded in another PQR."

Paragraph QW-281.2(e) in the ASME Code,Section IX, lists a decrease of 100F or more in minimum specified preheating temperature as an essential variable for all hardfacing processes.

Paragraph NB-43S2(b) in the ASME Code,Section III, lists torch type as an essential variable when the oxyacetylene process is used for hardfacing.

Contrary to the above, the inspector observed the following with respect to WPS N6-42, Revision 0, which was used for hardfacing on Operation 7 for Manufacturing Work Order 35/SM 323:

1. The WPS permitted hardfacing with a minimum preheat temperature in excess of 100F below that of the referenced supporting PQR.

2. The WPS did not define torch type to be used for hardfacing opera tions.

B. Criterion V of Appendix B to 10.CFR 50 states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or. drawings . . . and shall be accomplished in accord-ance with these instructions, procedures, or drawings . . . ."

78120103/74

Paragraph 5.2 in Quality Control Procedure No. N9-3, Revision 2, states with respect to heat treatment after hardfacing, "The treatment time shall not be exceeded by more than 25%, nor reduced by more than 10%." Paragraph 7.1 states, "In the event of any deviation from this procedure, a deviation report shall be prepared and submitted to the Material Review Committee for disposition."

Contrary to the above, the required treatment time in Furnace

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' Charge No. TH23 was exceeded by more than 25% and a deviation report was not prepared and submitted to the Material Review Committee for disposition.

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 NB-4334.1 in the ASME Code,Section III, requires weld impact test specimens for procedure qualifications to be located so that the longitudinal axis of the specimens is at least 1/4t -

from the weld surface of the test assembly.

Contrary to the above, Figure 5 (Repair Welding Procedure Test) in Quality Control Procedure No. N6-1, Revision 3, required weld impact test specimens for the procedure qualification to be located at the surface of the test assembly.

D. 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 speci-fied periods to maintain accuracy within necessary limits."

Sub-paragraph (a) in paragraph NA-4133.12 of the ASME Section III Code states in part, " Measures shall be established and documented to assure that tools, gages, instruments, and other examination, measuring, and testing equipment and devices used in activities affecting quality are of the proper range, type and accuracy to verify conformance to established requirements. A procedure shall be in effect to assure that . . . measuring . . . devices used in fabrication . . . activities affecting quality are calibrated . . .

to maintain accuracy within necessary limits . . . ." Sub-paragraph (c) ms. .n_ states in part, ".When discrepancies in examination or testing equipment are found at calibration, the Certificate Holder shali t

_- __, a a,- aa_ a 46 --a -1+ a _,a> -.-- m & - M, determine what corrective action is required. Materials and items previously checked (since the previous valid calibration) with equipment which is out of calibration shall be considered unacceptable until the Certificate Holder can determine that all applicable requirements have been met . . . ."

Contrary to the above, the inspector observed the following with respect to Quality Control Procedure No. 9-1, Revision 3, which was applicable to calibration of furnace instrumentation:

1. The procedure did not define required accuracy limits to be maintained on furnace instrumentation.

2. The procedure required adjustment of incorrect instrumentation without any provisions for consideration of effects of instrument error on previously heat treated materials.

E. 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 . . . using c qualified procedures in accordance with applicable codes, standards, .

l specifications, criteria . . . ."

Paragraph 10.3 in Quality Control Procedure No. N9-2, Revision 8, states in part with respect to furnace calibration, " . . .

i A 4 1/2" solid steel cube shall be placed in the hottest and l coldest positirns in the worst expected typical furnace load . . . ."

Contrary to tae above, furnace calibration, TH8, was performed by placing 4 1/2" steel cubes in an empty furnace and not with the worst expected typical furnace load.

j F. Criterion XVIII of Appendix B to 10 CFR 50 states in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program . . . ."

Section 13.0 of the Quality Assurance Manual, paragraph 13.2.7, states in part, "The frequency of audits shall be scheduled on form No. 60431A so that all Quality functions are covered within a twelve (12.) month period, or more frequently . . . ."

. Contrary:to the, above, the frequency of audits was not scheduled so that all-Quality functions would be covered within a twelve (12) month period... Examples: Organization, Non-conformances and corrective action, training, and audits. -

G. Criterion VII of Appendix B to 10 CFR 50 states in part, " Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents . . . ."

Customer Specification No. 8791-G-QA1 states _in part, "It is the -

responsibility of the supplier to request, review, accept, and retain, as appropriate, a controlled copy of the lower tier supplier's Quality Assurance Program . . . ."

Contrarr to the above, the supplier had not requested, reviewed or apprned a controlled copy of the lower tier supplier's Qualit' ,Assurance Program. Examples: Braman Dow, Industrial Services, Joseph Dyson & Sons, and Hopkinsons Foundry Division.

H. Criterion VII of Appendix B to 10 CFR 50 states in part, " . ..

The effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or services." ,

Section 3.0 of the Quality Assurance Manual, paragraph'3.2.2.

states in part, " . . . Purchasing personnel shall ensure that material is only purchased from vendors who have been approved by the Quali ty Assurance Manager . . . ."

Contrary to the above, the welding materials that were utilized for ASME Code work were purchased from a vendor, Middlesex, who had not been approved.

I. 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 8.0 of the Quality Assurance Manual, paragraph 8.3.7, states,

" Calibration of master gauges shall be made by outside approved sources working to National Standards. Certificates of calibration shall be furnished by all outside sources. These master gauges shall be re-inspected for accuracy, or proven, at established periods and records shall be maintained to the extent and frequency of such inspection." > n Contrary to the abov% the TALYVEL ELECTRONIC LEVEL S/N BT 1023,

-Number 1, .that is used as a master for the calibration of surface r plates has not been calibrated.

J. Criterion XVI of Appendix B to 10 CFR 50 states in part, " Measures shall be e;tablished to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the c'ause of the condition is determined and corrective action taken to preclude repetition Article NCA-4134.16 in Section III of the ASME Code states in part,

"(a) Measures shall be established to assure that significant conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and other nonconformances, are pronptly identified and corrected . . . ."

Contrary to the above, with the exception of nonconforming materials that are submitted to the Material Review Committee, neasures have not been established in order to comply with 10 CFR 50, Appendix B, and Article NCA-4134.16 in Section III of the ASME Code. .

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