Text

Nuclear Regulatory Commission Vendor Inspection Report of Laboratory Testing, Inc., No 99902064/2018-201
	ML18261A375
Person / Time
Site:	99902064
Issue date:	10/11/2018
From:	Kerri Kavanagh; Division of Construction Inspection and Operational Programs
To:	Faia J; Laboratory Testing Inc
	Torres E, NRO/DCIP
References
	EPID I-2018-201-0042 IR 2018201
	Download: ML18261A375 (20)
	v • d • e

October 11, 2018 Mr. Jonathan Faia Director of Quality & Improvement Laboratory Testing, Inc.

2331 Topaz Drive Hatfield, PA 19440

SUBJECT:

NUCLEAR REGULATORY COMMISSION VENDOR INSPECTION REPORT OF LABORATORY TESTING, INC. NO. 99902064/2018-201

Dear Mr. Faia:

On September 4-7, 2018, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at Laboratory Testing Inc.s (hereafter referred to as LTI) facilities in Hatfield, PA.

The purpose of this limited-scope routine inspection was to assess LTIs compliance with provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, and selected portions of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.

This technically-focused inspection specifically evaluated LTIs implementation of the quality activities associated with testing and calibration services provided for safety-related materials and equipment in support of operating nuclear power plants. The enclosed report presents the results of the inspection. This NRC inspection report does not constitute NRC endorsement of LTIs overall quality assurance (QA) or 10 CFR Part 21 program.

Based on the results of this inspection, the NRC inspection team found the implementation of your QA program met the requirements imposed on you by your customers or NRC licensees.

No findings of significance were identified.

In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRCs Rules of Practice, the NRC will make available electronically for public inspection a copy of this letter and its enclosure through the NRC Public Document Room or from the

J. Faia NRCs Agencywide Documents Access and Management System, which is accessible at http://www.nrc.gov/reading-rm/adams.html.

Sincerely,

/RA/

Kerri A. Kavanagh, Chief Quality Assurance Vendor Inspection Branch-2 Division of Construction Inspection and Operational Programs Office of New Reactors Docket No.: 99902064 EPID No.: I-2018-201-0042

Enclosure:

Inspection Report No. 99902064/2018-201 and Attachment

ML18261A375 *via e-mail NRO-002 OFFICE NRO/DCIP NRO/DCIP NRO/DCIP NAME THerrity JOrtega-Luciano* YDiaz-Castillo*

DATE 10/02/2018 10/10/2018 10/10/2018 OFFICE NRO/DCIP NRO/DCIP NAME ETorres KKavanagh DATE 10/10/2018 10/11/2018 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NEW REACTORS DIVISION OF CONSTRUCTION INSPECTION AND OPERATIONAL PROGRAMS VENDOR INSPECTION REPORT Docket No.: 99902064 Report No.: 99902064/2018-201 Vendor: Laboratory Testing, Inc.

2331 Topaz Drive Hatfield, PA 19440 Vendor

Contact:

Mr. Jonathan Faia, Quality Director Email: jfaia@labtesting.com Phone: (215) 716-3824 Nuclear Industry Activity: Laboratory Testing, Inc. (LTI), provides testing and calibration services for safety-related materials and components in support of nuclear power plant operations.

Inspection Dates: September 4-7, 2018 Inspectors: Edgardo Torres NRO/DCIP/QVIB-1, Team Leader Yamir Diaz-Castillo NRO/DCIP/QVIB-1 Thomas Herrity NRO/DCIP/QVIB-2 Jonathan Ortega-Luciano NRO/DCIP/QVIB-2 Chantal Gélinas Canadian Nuclear Safety Commission/Observer Approved by: Kerri A. Kavanagh, Chief Quality Assurance Vendor Inspection Branch-2 Division of Construction Inspection and Operational Programs Office of New Reactors Enclosure

EXECUTIVE

SUMMARY

Laboratory Testing, Inc.

99902064/2018-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a vendor inspection at the Laboratory Testing Inc. (hereafter referred to as LTI) facility located in Hatfield, PA, to verify that it had implemented an adequate quality assurance (QA) program that complies with the requirements of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. In addition, the NRC inspection team also verified that LTI implemented a program under 10 CFR Part 21, Reporting of Defects and Noncompliance, that met the NRCs regulatory requirements. The NRC inspection team conducted the inspection on September 4-7, 2018. This was NRCs first inspection at LTIs facilities, in Hatfield, PA.

This technically-focused inspection specifically evaluated LTIs implementation of quality activities associated with calibration and testing services (i.e., material, chemical, and non-destructive evaluations (NDE)) being supplied to the current nuclear power plant operating fleet.

Specific activities observed by the NRC inspection team included:

Liquid penetrant inspection of a cast pump impeller

Magnetic particle inspection of a 5 inch elbow LR45 80S

Calibration of a 1.00015 inch plain ring gage master

Calibration of a 0 to 24 inch Digimatic caliper

Calibration of a thread plug gage G/NG 1/2 - 13 unified national coarse (UNC)-2B

Charpy V-Notch testing of a 10-inch by 3-inch Schedule 100, test blank for material SA 106 Grade B These regulations served as the bases for the NRC inspection:

Appendix B to 10 CFR Part 50

10 CFR Part 21 During the course of this inspection, the NRC inspection team implemented Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated January 27, 2017; IP 43004, Inspection of Commercial-Grade Dedication Programs, dated January 27, 2017; and IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 13, 2012.

The NRC inspection team determined that LTIs QA policies and procedures comply with the applicable requirements of Appendix B to 10 CFR Part 50 and 10 CFR Part 21, and that LTIs personnel are implementing these policies and procedures effectively. No findings of significance were identified.

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REPORT DETAILS

1. 10 CFR Part 21 Program

a. Inspection Scope The NRC inspection team reviewed LTIs policies and implementing procedures that govern LTIs 10 CFR Part 21, Reporting of Defects and Noncompliance, program to determine compliance with the regulatory requirements. In addition, the NRC inspection team examined the 10 CFR Part 21 postings and a sample of LTIs purchase orders (POs) for compliance with the requirements of 10 CFR 21.21, Notification of Failure to Comply or Existence of a Defect and its Evaluation, and 10 CFR 21.31, Procurement Documents. The NRC inspection team observed that LTIs nonconformance and corrective action procedures provides a link to the 10 CFR Part 21 program.

The NRC inspection team reviewed LTIs procedure to perform 10 CFR Part 21 evaluations to determine if it addresses the requirements for evaluating deviations and failures to comply. The NRC inspection team reviewed only the procedures because at the time of the inspection LTI had not performed any evaluations under 10 CFR Part 21.

The NRC inspection team also discussed the 10 CFR Part 21 program with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b. Observations and Findings No findings of significance were identified.

c. Conclusion

The NRC inspection team concluded that LTI is implementing its 10 CFR Part 21 program in accordance with the regulatory requirements of 10 CFR Part 21. Based on the limited sample of documents reviewed, the NRC inspection team also determined that LTI policies and procedures are adequate to implement the regulatory requirements 10 CFR Part 21.

No findings of significance were identified.

2. Oversight of Suppliers

a. Inspection Scope The NRC inspection team reviewed LTIs policies and implementing procedures that govern the implementation of its oversight of contracted activities to determine compliance with the requirements of Criterion IV, Procurement Document Control, and Criterion VII, Control of Purchased Material, Equipment, and Services, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.

The NRC inspection team reviewed a sample of purchase orders (POs) to determine that the POs included, as appropriate, the applicable technical and quality requirements. In addition, the NRC inspection team reviewed a sample of receipt inspection records (e.g.,

Certificates of Calibration), to determine that these records (1) had been reviewed by LTI 3

for compliance with the requirements of the POs, and (2) the records contained the applicable technical and regulatory information. In addition, the NRC inspection team reviewed a sample of external audits for qualification of Appendix B suppliers and verified that the audit reports included an audit plan, findings were identified and dispositioned, documented with adequate objective evidence of compliance with the applicable requirements, and were reviewed by LTIs responsible management. Furthermore, the NRC inspection team reviewed LTIs approved suppliers list (ASL) to determine that the suppliers listed had been qualified in accordance with LTIs specifications and that the ASL was being kept up to date.

The NRC inspection team also discussed the supplier oversight program with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b. Observations and Findings No findings of significance were identified.

c. Conclusion

The NRC inspection team concluded that LTI is implementing its oversight of suppliers in accordance with the regulatory requirements of Criterion IV and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that LTI is implementing its policies and procedures associated with the oversight of suppliers. No findings of significance were identified.

3. Commercial-Grade Dedication

a. Inspection Scope The NRC inspection team reviewed LTIs policies and implementing procedures that govern the dedication of commercial-grade services for use in safety-related applications to determine its compliance with the applicable regulatory requirements of Criterion III, Design Control, and Criterion VII of Appendix B to 10 CFR Part 50.

The NRC inspection team observed that LTIs commercial-grade dedication activities are limited to qualifying commercial calibration service suppliers in accordance with the requirements of the International Standard Organization (ISO)/International Electrotechnical Commission (IEC) 17025, General Requirements for the Competence of Testing and Calibration Laboratories, in lieu of performing an on-site commercial-grade survey.

Specifically, LTI implements this process in accordance with the conditions imposed on the NRCs approval of the International Laboratory Accreditation Cooperation accreditation process documented in the Arizona Public Services safety evaluation dated September 28, 2005 (Agencywide Documents Access and Management System Accession No. ML052710224).

The NRC inspection team observed that LTIs use of software is limited to the software contained in the equipment used to perform calibration and testing. The software is used to record data, calculate calibration results based on acceptance criteria, and produce data for calibration reports. The software is verified and validated by LTI when the equipment is 4

purchased, through conducting hand calculations in parallel with use of the equipment and the results are compared. LTI has a process in place to ensure that each software version is validated prior to use and if a discrepancy is identified during validation or during the use of the software, LTI will initiate a nonconformance report. LTI has not received any error notices, nor have they had any failures with the software associated with the equipment used.

The NRC inspection team also discussed the limited scope commercial-grade dedication program with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection

b. Observations and Findings No findings of significance were identified.

c. Conclusion

The NRC inspection team concluded that LTI is implementing their limited scope commercial-grade dedication program in accordance with the regulatory requirements of Criterion III and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that LTI is implementing its policies and procedures associated with the commercial-grade dedication program. No findings of significance were identified.

4. Control of Special Processes

a. Inspection Scope The NRC inspection team reviewed LTIs policies and implementing procedures that govern the control of special processes to determine compliance with the regulatory requirements of Criterion IX, Control of Special Processes, of Appendix B to 10 CFR Part 50, Section V, Nondestructive Examination, of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel (B&PV) Code, 2015 Edition; and the American Society for Nondestructive Testing (ASNT) SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing.

The NRC inspection team reviewed for adequacy the procedures used for nondestructive examinations (NDE) and observed that they contained the applicable technical information and addressed the quality requirements. In addition, the NRC inspection team selected a sample of NDE reports for safety-related components and observed that the NDEs were performed by qualified personnel, using qualified procedures in accordance with the requirements of Section V of the ASME B&PV Code and ASNT SNT-TC-1A, and used calibrated equipment.

The NRC inspection team reviewed LTIs procedure for certification and qualification of magnetic particle (MP) and liquid penetrant (LP) examination personnel and observed they were consistent with the latest revision of the ASNT SNT-TC-1A. The NRC inspection team reviewed the light meters used during MP and LP examinations and observed that they were identified with a calibration sticker and that the calibration records were current and within the specified range and frequency.

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The NRC inspection team reviewed the training and qualification records for three of LTIs NDE Level III inspectors. The NRC inspection team observed that the inspectors records indicate that the individuals had been trained and qualified in accordance with LTIs procedures, ASNT SNT-TC-1A, and the ASME B&PV Code. The NRC inspection team also reviewed all NDE personnels annual vision test records and noted that they were current.

The NRC inspection team also discussed the control of special processes program with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b. Observation and Findings No findings of significance were identified.

c. Conclusion

The NRC inspection team concluded that LTI is implementing its control of special processes program in accordance with the regulatory requirements of Criterion IX of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that LTI is implementing its policies and procedures associated with the control of special processes program. No findings of significance were identified.

5. Test Control

a. Inspection Scope The NRC inspection team reviewed LTIs policies and implementing procedures that govern LTIs testing activities to determine compliance with the regulatory requirements in Criterion XI, Test Control, of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed a sample of test plans and laboratory procedures which showed that applicable customer specifications were translated correctly into test plans, procedures or instructions. The NRC inspection team reviewed a completed tensile, hardness, and chemical test for a carbon steel forged material; and a chemical composition analysis for stainless steel material. The NRC inspection team observed that the tests were performed in accordance with the test procedures and applicable standards.

The NRC inspection team also discussed the test control program with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b. Observations and Findings No findings of significance were identified.

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c. Conclusion

The NRC inspection team concluded that LTI is implementing its test control program in accordance with the regulatory requirements of Criterion XI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that LTI is implementing its policies and procedures associated with the test control program. No findings of significance were identified.

6. Control of Measuring and Test Equipment

a. Inspection Scope The NRC inspection team reviewed LTIs policies and implementing procedures that govern the measuring and test equipment (M&TE) program to determine compliance with the requirements of Criterion XII, Control of Measuring and Test Equipment, of Appendix B to 10 CFR Part 50.

For a sample of M&TE, the NRC inspection team observed that the M&TE had the appropriate calibration stickers and current calibration dates, including the calibration due date. The NRC inspection team also noted that the M&TE had been calibrated, adjusted, and maintained at prescribed intervals prior to use. In addition, the calibration records reviewed by the NRC inspection team indicated the as-found or as-left conditions, accuracy required, calibration results, calibration dates, and the due dates for recalibration.

The NRC inspection team performed a walk-down to observe that M&TE was labeled, handled, and stored in a manner that indicated the calibration status of the instrument and ensured its traceability to calibration test data.

The NRC inspection team discussed the M&TE program with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b. Observations and Findings No findings of significance were identified.

c. Conclusion

The NRC inspection team concluded that LTI is implementing its M&TE program in accordance with the regulatory requirements of Criterion XII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that LTI is implementing its policies and procedures associated with the M&TE program. No findings of significance were identified.

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7. Corrective Action/Nonconformance

a. Inspection Scope The NRC inspection team reviewed LTIs policies and implementing procedures that govern the nonconformances and corrective action programs to determine compliance with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed a sample of nonconformance reports (NCRs) to verify that LTI: (1) dispositioned the NCRs in accordance with the applicable procedures, (2) documented an appropriate technical justification for various dispositions, and (3) took adequate corrective action with regard to the nonconforming items. The NRC inspection team also verified that NCRs provide a link to the 10 CFR Part 21 program.

The NRC inspection team also reviewed a sample of corrective action reports (CARs) to determine if conditions adverse to quality were promptly identified, corrected and provided a link to 10 CFR Part 21. The NRC inspection team observed that the CARs provided: (1) a description of the conditions adverse to quality, (2) an analysis of the cause of these conditions and the corrective actions taken to prevent recurrence, as applicable, (3) direction for review and approval by the responsible authority, and, (4) a description of the current status of the corrective actions.

The NRC inspection team also discussed the corrective action and nonconformances with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b. Observations and Findings No findings of significance were identified.

c. Conclusion

The NRC inspection team concluded that LTI is implementing its corrective action and nonconformance programs in accordance with the regulatory requirements of Criterion XV and Criterion XVI of Appendix B to 10 CFR Part 50. Based on the documents reviewed, the NRC inspection team also determined that LTI is implementing its policies and procedures associated with corrective actions and nonconformance programs. No findings of significance were identified.

8. Audits

a. Inspection Scope The NRC inspection team reviewed LTIs policies and procedures that govern the external and internal audits to determine compliance with the requirements of Criterion XVIII, Audits, of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed a sample of internal and external audit reports and observed that the audits were performed by qualified auditors by reviewing a sample of training and qualification records of LTIs lead auditors and that auditing personnel had 8

completed all the required training and had maintained the applicable qualification and certification in accordance with LTIs policies and procedures. In addition, the NRC inspection team reviewed a sample of internal audit reports to determine if the reports included: an audit plan, any findings identified, adequate documentation of objective evidence of compliance with the applicable requirements, and a review by LTIs responsible management. Furthermore, the NRC inspection team observed that the internal audits were performed by personnel not having direct responsibilities in the areas being audited. The NRC inspection team noted that audit findings were dispositioned and corrective actions were implemented to correct the issues identified.

The NRC inspection team also discussed the audits program with LTIs management and technical staff. The attachment to this inspection report lists the documents reviewed by the NRC inspection team.

b. Observations and Findings No findings of significance were identified.

c. Conclusion

The NRC inspection team concluded that LTI is conducting its external and internal audits in accordance with the regulatory requirements of Criterion XVIII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed and interviews conducted, the NRC inspection team determined that LTI is implementing its policies and procedures associated with internal audits. No findings of significance were identified.

9. Entrance and Exit Meetings On September 4, 2018, the NRC inspection team discussed the scope of the inspection with Mr. Michael McVaugh, Chief Executive Officer/President, and other members of LTIs management and technical staff. On September 7, 2018, the NRC inspection team presented the inspection results and observations during an exit meeting with Mr. McVaugh, and other members of LTIs management and technical staff. The attachment to this report lists the attendees of the entrance and exit meetings, as well as those individuals whom the NRC inspection team interviewed.

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ATTACHMENT

1. ENTRANCE/EXIT MEETING ATTENDEES Name Title Affiliation Entrance Exit Interviewed Laboratory Chief Executive Michael McVaugh Testing, Inc. X X Officer/President or (LTI)

Brandon McVaugh Director of Operations LTI X X Machine Shop Brad McVaugh LTI X X Manager Jonathan Faia Director of Quality LTI X X X Business Development Eric Baum LTI X Manager Quality Assurance Sherri Scheifele LTI X X X (QA) Specialist QA Coordinator/Lead Heather Heathwood LTI X Auditor Rick Gaynor Metrology Manager LTI X Destructive Testing Lee Dilks Manager/Chemistry/ LTI X Metallography Edward Deeny QA Manager LTI X X X Calibration Technician Jay Kohr LTI X Level II Calibration Technician Donna Schooner LTI X Level II Calibration Technician Bob Hall LTI X Level I Level II Liquid Don Myers Penetrant (LP) Testing LTI X Supervisor Level II Magnetic Rick Stuart Particle (MP) Testing LTI X Supervisor Mechanical Testing Steve Fretz LTI X Technician Name Title Affiliation Entrance Exit Interviewed Manufacturing Tyler Snyder LTI X Engineer Chemistry & Corrosion Ashley Phillips LTI X Coordinator Metrology/Calibration Eva Pellow LTI X Lead Technician Metrology/Calibration Terry Baker LTI X Technician Eddie Phillips Metrology Specialist LTI X Collin Jones IT Support Specialist LTI X Mechanical Lab Paul Szczepaniak LTI X Manager Supervisor Mechanical Andy Giordano LTI X Shop Lenny Flowers Machine Operator LTI X Level II Ultrasonic Steve Walmsley LTI X Testing Edgardo Torres Inspector/Team Lead NRC X X Jonathan Ortega-Inspector NRC X X Luciano Yamir Diaz-Castillo Inspector NRC X X Thomas Herrity Inspector NRC X X Canadian Chantal Gélinas Inspector Nuclear Safety X X Commission

2. INSPECTION PROCEDURES USED Inspection Procedure (IP) 36100, Inspection of 10 CFR Part 21 and Programs for Reporting Defects and Noncompliance, dated February 13, 2012.

IP 43002, Routine Inspections of Nuclear Vendors, dated January 27, 2017 IP 43004, Inspection of Commercial-Grade Dedication Programs, dated January 27, 2017

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED None.

4. DOCUMENTS REVIEWED Policies and Procedures LP-E165, General Procedure for Fluorescent Penetrant Examination in Accordance with ASTM E-165, Revision 6, dated July 22, 2016 LTI-AQMR, Assuring Quality of Metrology Results, Revision 2, dated February 11, 2009 LTI-AQTR, Assuring Quality of Test Results, Revision 1, dated February 23, 2015 LTI-CAR, Procedure for Corrective Action, Revision 15, dated October 18, 2013 LTI-COMP, Resolution of Customer Complaints, Revision 2 dated June 9, 2014 LTI-EXT-AUD, Procedure for Performance of External Audits and Surveys, Revision 6, dated June 4, 2015 LTI-INT-1, Procedure for Performance of Internal Audits, Revision 13, dated September 30, 2016 LTI-LP-TO, Training Outline for Liquid Penetrant Testing, Revision 5, dated September 22, 2010 LTI-MANCTRL, Control of the Quality System Program Manual, Revision 6, dated August 8, 2014 LTI-MP-TO, Training Outline for Magnetic Particle Testing, Revision 5, dated September 22, 2010 LTI-Nonconformance, Procedure for Reporting and Control of Nonconforming Testing and/or Calibration Items, Revision 8, dated January 13, 2015 LTI-Procedure, Preparation of Documents, Revision 9, dated May 18, 2016 LTI-QUAL-NQA1, Qualification and Certification of Inspection and Testing Personnel, Revision 4, dated February 29, 2012 LTI-SAMPLING, Procedure for Sampling, Revision 0, dated March 17, 2010 LTI-SCS-RAL, Subcontracted Calibration Services from Recognized Accredited Laboratories, Revision 5, dated January 30, 2014 LTI-SWQA-1, Procedure for Validation of Computer Software, Revision 4, dated September 30, 2010 LTI-QUAL-NQA1, Qualification and Certification of Inspection and Testing Personnel, Revision 4, dated February 29, 2012 LTI-VT-TO, Training Outline for Visual Inspection, Revision 1, dated April, 9, 2007 CP-PHM-1, Calibration Procedure for pH Meters, Revision 1, dated June 1, 2018 CP-PR-PP-1, Calibration Procedure for Plain Cylindrical Plugs and Rings, Revision 3, dated May 11, 2015 CP-STP-1, Procedure for Calibration of Straight Thread Plug Gages (Working Plugs and Setting Plugs), Revision 3, dated November 28, 2016 CP-VC-1, Calibration Procedure for Vernier, Dial, and Electronic Calipers, Revision 5, dated May 23, 2017 PI-1, Purchasing Instructions for Materials and Services, Revision 15, dated June 2, 2016 PI-1 Addenda CGD, Commercial Grade Items/Services/Software, Revision 3, dated December 8, 2016 PI-1 Addenda CGD LP Materials, Addenda for Commercial Grade Dedication for the Purchasing of Liquid Penetrant Materials, Revision 1, dated July 7, 2017 PI-1 Addenda Quality PO, Procedure for Creating Quality Purchase Orders for Procurement of Reference Standards, Outside Services, Calibration and Repair Services, Revision 0, dated September 6, 2011 PQ-AUD-1, Procedure for Qualification and Certification of Auditors and Lead Auditors in Accordance with ASME/ANSI N45.2.23 and ASME/NQA-1, Revision 2, dated December 13, 2011 PQ-MAS-1, Procedure for Personnel Qualification, Revision 12, dated February 1, 2013 PQ-NDT-1, Nondestructive Examination Personnel Qualification and Certification Written Practice in Accordance with SNT-TC-1A, ASME Section III, V, VIII and T9074-AS-GIB-010/271, Revision 28, dated October 5, 2017 PQ-410-1, Nondestructive Examination Personnel Qualification and Certification Written Practice in Accordance with NAS-410, Rev.4, Revision 22, dated October 3, 2017 QC-MTL-NDT, Material Control and Maintenance of Traceability for Nondestructive Testing of Pipe, Tube, Bar, Plate, etc., Revision 3, dated August 11, 2015 RI-1, Procedure for Receiving, Order Entry, Identification, and Traceability, Revision 23, dated February 23, 2017 Specimen Preparation - Mechanical Testing Sample Procedure, Revision 15, dated August 5 2016 86-LP-C, Liquid Penetrant Calibration Procedure, Revision 24, dated June 6, 2017 86-MP-C, Magnetic Particle Inspection Equipment Calibration, Evaluation and Quality Control, Revision 22, dated May, 31, 2017 10CFR21 COMPLIANCE, Reporting of Defects and Nonconformance in accordance with 10 CFR 21, Revision 9, dated June 7, 2012 Purchase Orders Purchase Order (PO) No.17-39915-46OS for calibration services of two Rockwell hardness test blocks, dated October 31, 2017 PO No. 18-02156-46OS for calibration services of an 8-inch qwikcheck gage, dated May 8, 2018 PO No. 18-03114-46CAL for calibration services of a Starrett angle block set, dated June 27, 2018, PO No. 18-12380-41OS for ultrasonic testing (UT) reference standards, dated April 14, 2018 PO No. 18-19198-310OS for UT reference standards, dated June 21, 2018 PO No. 10-23-17-45S for chemistry standards, dated October 23, 3017 PO No. 12-15-17-45S for chemistry standards, dated December 15, 2017 PO No. 18-00218-46os for calibration services of a light meter, dated January 16, 2018 PO No. 18-00665-46OS for calibration services of a digital radiometer and a contour probe, dated February 20, 2018 PO No. 18-027640 for Tensile test, Hardness Test and AES Chemical test, dated August 24, 2018 PO No. X-16982, Pressure gage calibration 1500 lbs., dated August 24, 2018 PO No. 18-0727577, Chemical Analysis, dated August 28, 2018 PO No. 0024305, Liquid penetrant, dated August, 24 2018 Certificates Calibration Certificate No. FAI004-17-10-39915-1 for a Rockwell Test Block, Instrument No. 60041077, calibrated on November 6, 2017 Calibration Certificate No. FAI004-17-10-39915-2 for a Rockwell Test Block, Instrument No. 60041079, calibrated on November 6, 2017 Calibration Certificate No. FAI004-18-05-02156-1 for a qwikcheck gage, Instrument No. 60041912, calibrated on May 30, 2018 Calibration Certificate No. DNC001-18-06-03114-1 for a Starrett angle block set, Instrument No. 60012504, calibrated on August 4, 2018 Calibration Certificate No. CMM002-18-01-00218-1 for a light meter, Instrument No. 60023266, calibrated on January 23, 2018 Calibration Certificate No. digital radiometer, Instrument No. 60056003, calibrated on February 23, 2018 Calibration Certificate No. 60056004, Instrument No. 60056004, calibrated on February 23, 2018 Audit Reports LTIs Internal Audit Report, audit performed May 31 - June 1, 2017 LTIs Internal Audit Report, audit performed May 15 - 16, 2018 2017-PH-001, External audit report, dated April 19, 2017 2017-VHG-01, External audit report, dated September 13, 2017 WMTR-16, External audit report, dated May 8, 2016 Training Records Nondestructive Examination Personnel Qualification Record for Level III and Level II personnel.

Certification records for Level I and Level II inspectors.

Miscellaneous Documents Laboratory Testing Inc.s (LTI) Quality Systems Program Manual, Revision 20, dated December 12, 2012 LTIs Approved Vendors List Commercial-grade survey report dated May 21, 2018 Computer Software Validation List Software Validation Forms and associated testing date for the following equipment:

o Tinius Olsen Tensile Machine o ATS Stress Rupture Frame o 250kN Fatigue Frame o Mahr Federal Gage Customer Complaint Report (CCRs)