ML20198D487

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Partially Withheld Assessment of Allegation AQ-5 to Allegation Category Qa/Qc 5E, Matls Re Lack of Traceability for safety-related Matls & Components
ML20198D487
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Watson V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59, FOIA-85-89 NUDOCS 8605230299
Download: ML20198D487 (5)
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1. Allegation Category: QA/QC SE, Materials
2. Allegation Number: AQ-5
3. Characterization: It is alleged that lack of traceability for safety-related materials and components has occurred.
4. Assessment of Safety Significance: The NRC Technical Review Team (TRT) reviewed the Brown & Root (B&R) Quality Assurance Manual, Section 8.0, dated May 17, 1978. Paragraph 8.2 of the manual requires that if material with material traceability identification is cut into more than one piece, the identification (or heat numbers) shall be transferred to the other pieces before cutting. A QC inspector shall then verify that heat numbers have been transferred. Section 8.0 of this B&R manual, in the revision dated August 14, 1981, continued to require verification of heat numbers by a QC inspector prior to subdividing material. Quality instruction QI-QAP-11.1.28, Revision 25, required QC verification of material heat

' numbers prior to subdividing and also required that this heat number re-main distinguishable until the fabrication and installation of component supports were accepted by QC inspectors.

The TRT also reviewed an ASME Boiler and Pressure Vessel Code survey con-ducted at CPSES on October 12-14, 1981. Because of the many deficiencies identified by the survey team in the B&R QA program, ASME delayed B&R's recertification until appropriate corrective action was taken. Some of the deficiencies identified by the ASME survey team were:

1. Control of material salvaged from vendor-supplied components was inadequate.
2. B&R's survey and qualification of vendors was inadequate.
3. B&R divided material and transferred the material identification incorrectly.
4. B&R did not verify the transfer of material identification.

ASME conducted another survey after B&R took the necessary corrective action.

l The following were among the corrective actions taken:

1. B&R's appointment of a new quality assurance manager on November 6, 1981.
2. TUEC obtained fabrication records from two vendors, ITT Grinnell and Nuclear Power Services Incorporated (NPSI). The records contained certified material test reports (CMTRs) and other fabrication data thaf provided the necessary material control information. TUEC incorporated this data into the record packages for those cases in which B&R had used salvaged material to fabricate component supports.
3. B&R received procurement documentation and issued interoffice memoranda
- which documented material reclassification.

.g !860512 0-193

( . GARDE 85-89. PDR..

4. TUEC procurement documents specified that material be purchased with CMTRs. Therefore, purchase orders were issued with standard paragraphs requiring material traceability. This allowed B&R to review procure-ment documents and verify that the material* was acceptable for reclassification.

S. TUEC reviewed approximately 17,600 data packages, reinspected material where necessary, and scrapped material unacceptable for reclassification.

6. In February 1982, B&R initiated a program to review all hanger packages to confirm acceptability of material. The review identified that ASME Class 2 and 3 material had been installed in 45 Class I component sup-ports, as documented on NCRs M-3033, Rev. I and M-3258, Rev.1. As a result of this review and subsequent reinspection, some material was identified as unacceptable and was scrapped.

The ASME conducted another survey in January 1982 and recommended acceptance of the QA program.

Based on a review of records and interviews with craft, inspection, and engineering personnel, the TRT determined that since the identification .

and correction of the deficiencies reported by the ASME survey team, the QA program for material control has been maintained.

5. Conclusion and Staff Positions: Based on its review, the TRT concludes that the allegation that TUEC failed to maintain material traceability for safety-related material for numerous hardware comperients prior to October 1981, was substantiated. TUEC did have procedures for material traceability, as required by 10 CFR 50, Appendix B, Criterion VIII; how-ever, TUEC did not follow these procedures, resulting in a partial break-down in the QA program. Although corrective actions were taken and were l

documented (NCRs M-3033 and M-3258) in accordance with TUEC QA procedure CP-QAP-8,5, TUEC failed to report this partial breakdown to the NRC per 10 CFR 50.55(e) requirements.

A meeting was held with the alleger on December 10, 1984, and the TRT's findings and conclusions were presented. No new concerns or allegations were identified.

M 0-194

7. Attachments: None.

Reference Documents:

1. Procedure CP-QAP-8,5, Rev. 4, dated June 11, 1984.
2. B&R QA Manual, Section 8.0.
3. A-5 letter, dated March 7, 1984.
4. Interoffice Memorandum (IM) 26, 407, SIS 367-B; IM 26, 589 SIS 369, SIS 369-B, IM 26, 729.
5. A-5 meeting December 10, 1984, p. 99.
6. Procedure QI-QAP-11.1-28
7. Procedure CP-QP-16.1, Rev. 4, dated September 11, 1981.
8. Results of AMSE B&PV Code Survey, dated November 23, 1981.
8. This statement prepared by: ($ww W. dA V. Watson, TRT

(,/(,/PS-Uat6 Technical Reviewer Reviewed by: / r w cu

[H.Livermore, d Y Date Group Leader Approved by:

V. Noonan, Date Project Director 9

l 0-195

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e 0-196

-- - ~- - _ . . - - -

Document N:me:

AQ-5 SSER Requestor's ID:

LAVERNE Author's Name:

Posiusny Document Comments:

5/31/85 QA/QC SE AQ-5 thru QA/QA 6 AQ-55 & AQ-78 pgs 193-228

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