ML20202A953

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Rev 3 to Procedure WEI-1, Procedure for Random RT Welder Surveillance. Related Info Encl
ML20202A953
Person / Time
Site: Comanche Peak  
Issue date: 07/30/1984
From: Wright B
BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:
Shared Package
ML18052B537 List: ... further results
References
FOIA-85-59 WEI-1, NUDOCS 8607100162
Download: ML20202A953 (70)
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BROWN & ROOT, INC.

PROCEDURE EITECTIVE CPSES NUMBER REVISION DATE PAGE i

JOB 35-1195 1 of 5 J7/30/84 WEI-1 3

I 7MPi ORIGINATOR:

DATE TITLE:

7 7[27/ f l

REVIEWEDBY:ft OATE PROCEDURE F(R RANDOM

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B&R @

RT WELDER SURVEILLANG

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APPROVED BY

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[ 38 CONSTRUCTION PROJECT MANAGER DATE/

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o.1 TABE OF CONTENTS h

1.0 INTRODUCTION

2.0 PURPOSE 3.0 SCOPE Y

4.0 DEFINITIONS

  1. 'A 5.0 CENERAL REQUIREMENTS Fg 5.1 IMPLEMENTATION 5.2 MAINTENANG 5.3 WELD SEM CIION Selection of Class III Shop and Field 5.3.1 5.3.2 Selection of BOP Class V Welds 5.4

'ACGPTANG CRITERIA 1.0 INrRODUCTION 2.0 PURPOSE is the purpose of Random RT Welder Surveillance Program to_

2.1 It the welders employed utilize radiography as a means to insure that GSES are capable of maintaining the same level of proficiency atunder field production conditiona as they have previously demon-strated during qualification testing.

.ep 8607100162 860630 PDR FOIA GARDE 85-59 PDR

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s BROWN & R00I, INC.

PROCEDURE EFFECT IVE

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CPSES NUMBER REVIS ION DATE PAGE J05 35-1195 WEI-1 3

07/30/84

'2 of 5 2.2 This program is not intended to be used to evaluate weld joint integrity. Weld joint integrity is to be determined by the NDE methods designated by design specifications in accordance with the applicable codes. NDE as prescribed by this specification is performed The and interpretated by certified Quality Control Inspectors.

Random RT Welders Surveillance Program is not applicable to those systems that require volumetric inspections or SWA's (System Work Authorization's) to perform modifications after inital installation and acceptance by the Owner.

3.0 S COPE 3.1 The following text provides instructions which apply to the implemen-tation and maintenance of the Welder Surveillance Program. E f fect ive this date the Welder Surveillance Program shall be implemented and maintained as follows:

4.0 Iir,e INITIONS a.

RT - Radiographic Test b.

Defects - All defects identified and recognized by the appli-cable code utilizing radiography.

De fect Charge - De fect(s) assigned to applicable welder or c.

weldirg operator by the FWTC.

d.

WTC - Field Weld Technical Center Iot - Twenty (20) consecutive Class III and V welds.

e.

f.

Group - Consists of one (1) or more lots.

WDCC - Weld Data Control Center.

g.

h.

WyrC - Welding Qualification Technical Center i.

WPC - Welding Performance Coordinator f

5.0 GENERAL REQUIREMENIS 5.1 IMPLEMENTATION The Welding Engineering Department shall be responsible for the

__ implementation of the Welder Surveillance Program., The completed Class III weld docunentation shall be brought to the WTC. On a daily basis the WTC will log all completed Class III welds and j,

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t BROWN & ROOT. INC.

PROCEDURE EFFECTIVE

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CPSES NUMBER REVISION DATE PAGE JOB 35-1195 07/30/84 3 of 5 WEI-l 3

The notify the Pipe Department of all welds selected for RT.

Pipe Department will initiate all requests for radiography of these welds a,nd submit them to QCRT, who interpret the film Af ter RT has been per the acceptance criteria o f Paragraph 5.4. film and the RT inspectio completed, the The Welder Performance to the Welder Per formance Coordinator.

Coordinator will be provided with the pink copy of the RT resultsis of each weld containing the welder (s) symbol to whom the defect to be charged.

5.2 MAINTENANCE p U.d A record listing the ASME Class III and BOP Class V pipe q'

a.

welds made by individual welders shall be maintained by gj L

the Welding Engineering WPC.

Welds for each welder shall be listed in lots of twenty (20).

1.,

(5) Lots or one-hundred (100) welds equals one(l)

,( l' b.

Five

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group.

IP A minimum of one(l) weld from each lot (5%) shall be selected c.

by the WPC for RT.

d.

If a welder is charged with a reject, two(2) additional welds from the same lot shall be selected for RT.

If at any time a welder is assigned two(2) rejects in any e.

the welder's certification for the velding one(1) lot,

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procedure shall be evaluated by the Project Welding Engineer

,10 as to whether the welder's certification should be suspended -

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,h' fV or revoked.

y D-r If a welder's certification is suspended or revoked a memo shall be forwarded to the Pipe Department indicating the f /

f.

specifics of the revocation or suspension. A copy of the same memo shall be sent to WDCC, WQTC, QC and all Rod Shacks.

Upon reinstatement of a welder's certification a memo shall l

be sent to all parties on distribution of the memo referenced g.

in 5.2. f.

An interim authorization memo shall also be given to the welder by the WQTC.

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BROWN & R00I, INC.

PROCEDURE EFFECIIVE CPSES NUMBER REVISION DATE PAGE JOB 35-1195 WEI-1 3

07/30/84 4 of 5 5.3 WELD SELECTION Welds designated as Class III and BOP Class V shall be selected for RT by the Welder Performance Coordinator in accordance with the folicwing:

g Welds accomplished by only one(1) welder shall be given

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a.

first priority for selection.

b.

Welds accomplished by two(2) or more welders shall be given second priority for selection.

All other selections are assigned third priority.

c.

d.

If one(1) selected weld, accomplished by two(2) or more welders passes RT, it will count as one(1) acceptable weld for each participating welder, Welders making only tack welds shall not be counted in the e.

Welders Surveillance Program.

f.

Repair welds shall not be selected for the Welder Surveillance Program.

5.3.1 Selection of Class III Shop and Field Weld Data Cards for Class III welds completed in the shop a.

and field shall be transmitted to the PFG in the norma q'[ b l

ma nner. These cards shall be reviewed by the Welder ', 6 Performance Coordinator. A copy of the weld data card for those welds telected shall be forwarded to the Pipe Department RT Coordinator by three part memo. The original l

weld data card shall be placed in an "RT Hold File" in the PFG.

j b.

The Pipe Department RT Coordinator shall notify the area foreman and submit the RT request to QCRT stamped " Random".

5.3.2 Selection of BOP Class V Welds A list of completed BOP Class Y welds which do not require a.

L 100% RT shall be submitted to the Welder Performance g/

Coordinator on a regular basis by the C.I.T. group.

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4 EFFECTIVE PROCEDURE BROWN & ROUI INC.

REVISIQ4 DATE PACE NUMBER 6

CPSES JOB 35-1195 WEI-I 3

07/30/84 5 of 5 The Pipe Department RT Coordinator shall be notified of b.

the welds selected by three part memo and shall notify the foreman and submit an RT request in the normal manner.

area A copy of the list provided by the C.I.T. group shall be returned to this group with the welds selected for RT indicated.

NOTE:

The Welder Per forma ce C d nator shall be provided with a copy of all Random RT requests.

Any velds selected which have not been requested within three working days of notification shall be followed up with a three part memo to Piping Supervision.

5.4 ACCEPTANCE CRITERIA The acceptability of welds examined by radiography shall be determined as follows:

fusion or penetration Any type of crack or zone of incomplete a.

shall be unacceptable.

Non-metallic inclusions (slag) chall be unacceptable if b.

the length of any such indication is greater then 2/3 T where T is the thickness of the thinner section being joined.

If two(2) or more indications within the above limitations e xist in a line, the weld shall be judged acceptable if the sun of the longest dimensions of all indications is not more than T in a length of 6T or proportionately for welds less than 6T and if the longest indications considered are separated by at least 3 L where L is the length of accep-table indications of 3/4 inch (.750").

Any such indication less than 1/4 inch (.250") shall be acceptable for any weld thickness.

factor in the acceptability of welds c.

Porosity is not a selected for this program.

Surveillance of welders welding on ASME ass 1 & 2f' NOTE:

systems will be accomplished by monitor og the ra iographs required by code /'for these-ystems.

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  • - ALLllATIDtd 0K0 0P Mi cdMilh l hn li VIhl16 (ATHblY hl0. 2 5 r r wr w= i:.:u.::--;:;f.% : ma A mixMm unqual.F OA c, personne( -f v tacida decumenft g

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The 'aneger nad been made a supervising documentation clerk, a position the alleger did not consider Me 14ger to be qualified for on the basis of experience or education."

h o" 8 ' ' f ovAy) m n' ell, it was people working cut of procecures and people being unexnerienced,_ like ten years ago they was doing stuff that was very dangerous on tne North Carolina joo Decause they didn 't know anythina about any tyDe of construct; ion work, much less nuclear, and I thought after ten years eney should learn a little better and they come on this job here doing the same type OM.nvu W

.or. stuff.

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Tdl A LLL G AiO x WAJ IME dl4 A rt t 2Y THE L:itih2 offill of ftWtSTilhit02 (0145)

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fl Allegation a.,

as originally received and as further amplified during a.

the interview, could neither be substantiated nor refuted.

Based upon the District Attorney's description of the alleger's background, it appears that the alleger may have been over qualified for the position rather than under qualified.

The matter of responsibility coupled with authority is also a very sub,Sctive area.

The alleger's responsibilities were derived responsibilities actually vested in the Chief Welding Engineer while the authority for rigorous adherence to the random radio' graphic program is largely vested in the Mechanical Department General Superintendent or even in the Brown & Root Project Construction Manager.

The authorities and responsibilities are so substantial as to make it difficult for the RRI to envision that they could reasonably be vested in a sing 1,e, largely clerical, position such as that occupied by the alleger. '

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Comanche Peal (Jpen Issue Action Plan jyt4dj{} //ii I l llUlb Tas6: l'ncua l i f i ed f!d h w el bn we l d i rn dot ument t. ?f2l'$5 g!g/p',/M (s () UI W /l0fk'Y Ref. no. Aa:-c, Aw-7 l Cha rac te r iza t ion tpcu,411typr far iyytf(tpntT6 ion. ClassEj / // Initial Assessrent of Si g r,i f ic anc e: C l a ',' t a rn;e r 'wo . lief / in[r./ Sou rce: t'ec ne n ic a l F. Pi;.ing, Ca tegory T Apprcect. tc F9 solo

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a 2. Peview resul ts of involved p?rsonnel worf and evaulate ccncerns acainst recui re" er t s. 4

efer esa ples of wrongdoing or < ignificant deficiencies to IRI r e r a r.e r.

Evaluate allegntions for generic / se te ty irilications. f. Poinri en re',u l t ' of revien/ evaluation of ellegations. 7. ivalua te cera rir /sof ety ir plicat ions or d p tent ial sioletions. CC 12

Category !;o. 28 Related Open Issue Identificatiori: S ta tu s : Not stated

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Civil /t'echanic al, J.

H. f'a l onsort G r ari-days 4 Retourter Est ic a te: Estir cte

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Fevie,.ed ty: IRT Leader

i l I*,' L l SSER - AQW-27 DCP2 11/2/84 i SSER 1. Allegation Group: flechanical and Piping Category No. 29 2. Allegation f; umber: AQW-27 a 3. Characterization: A routine NRC Region IV inspection on September 4 7-10, 1982 found that improperly certified liquid penetrant materials had been used. q h .I CASE also informed the ASLB on May 18, 1983 that they had learned that certain uncertified liquid penetrant (LP) materials had been used. A review of the CASE allegation showed it was related to the same nonconforning condition. 4. Assessment of Safety Significance: NRC Region IV inspection reports IR 82-18 and 82-09 reported that pen and ink changes were made to date and batch number of the certified test report for (developer) Batch 82-C-068. Inspections performed during the later period of 1982 (documented in IR 82-11) also reports altered certified test reports for other batches of liquid penetrant 2xamination material. IR 82-11, F0lA-85-59 R m

F. fs g-s 6 f r / Appendix A, includes a Notice of Violation requesting TUEC to submit a ,/ written statement or explanation of these altered reports to Region IV (1) the corrective steps which have been taken and the including: results achieved; (2) the corrective steps which will be taken to avoid such violations in the future; and, (3) a date when full compliance will be achieved. The NRC Technical Review Team (TRT) determined that TUEC investigated the reported violation and fcund that the certified test results were altered by the jobber / supplier from when the material was purchased. The TRT also learned that in response to the request for corrective actions, as detailed in IR 82-11 Appendix A, TUEC issued stopwork order No. 28 to prevent use of the materials until proper Further corrective identification and certifications were provided. action was accomplished by the issuance of five TUEC nonconformance This action corrected the receiving inspection reports (HCRs). reports (RIR) to show the identification of the naterials and obtaining the material manufacturer's (magnaflux) original, unaltered The TRT determined that this certified material test reports. corrective action provided documented evidence of the integrity and In acceptability of the liquid penetrant examination material used. addition, TUEC obtained valid manufacturer's material test reports to support their acceptance of the liquid penetrant examination The test reports are included in the record package. material. ,.,,,.r_-- ,..c.-v

s' s \\ ' TUEC took additional corrective action on the cited violation by Revision 5 revising the receivin$ r.spection procedure (CP-QAP-8.1). i of the procedure implemented a detailed receiving inspection checklist to ensure that liquid penetrant materials were properly identified (marked) and that material certifications were originals and were not altered. The TRT 'ound that to prevent a recurrence of the problem with altered certifications, TUEC discontinued the practice of procuring liquid penetrant examination materials from jobbers and instituted a policy TUEC also of purchasing directly from the material manufacturers. removed the jobber who had altered the ce'rtified test report for Batch 82-C-068, from the approved v ndor list. Following their implementation of corrective action, TUEC issued purchase crders (P0s) 10470, 10565, 10707, 11444, and 11685 to the material manufacturer (tiagnuflux). The TRT reviewed receiving 21313, 21627, 22414, 23579, and 24271 for material inspection reports on the above listed P0s, and verified that the penetrant examination material was procured directly from the manufacturer and the receiving inspection conformed to Procedure CP-QAP8.1 requirement for use of the detail checklist. During this review, the TRT also noted that the checklist included in RIRs 21313 and 24271 did not conform to the procedure because an j l f

1

incorrect checklist was used. TUEC corrected the RIRs on July 20, 1984, and the TUEC receiving inspection supervisor conducted a documented training session. The TRT verified both the corrected reports and training documentation on July 30, 1984.

IR 83-10 Appendix Page 3, para. 2 documents that the Region IV inspector verified that TUEC completed corrective action for the stopwork order and the NCRs, that the receiving inspection procedure was revised and implemented, and that the receiving inspectors were trained. The item is considered closed. IR 83-15, page 13, contains a detailed explanation of the inproper certifications. The condition is also cited in a " CASE" letter to the ASLB dated May 18, 1983, which identifies the use of the materials as a potential problem. The TRi noted that pages 11 and 13 of the " CASE" letter refer to the condition vaguely as: "The Atchinson Matter." The TRT determined that IR 83-15 reports the item as closed and that the violation was reported and TUEC completed corrective action which was verified by the Region IV inspector, prior to the date of the CASE letter. 5. Conclusion and Staff Position: Based on the documents reviewed, the TRT concurs with the allegation that improperly certified liquid i penetrant examination materials were used at CP. 1

_ However, TUEC initiated, implemented, and maintained effective corrective action to provide documented evidence for traceability and acceptability of the material in conformance with code, QA procedures and program requirements after this problem was detected. Since TUEC implemented effective corrective action, the TRT concludes that there is no problem or potential prcblem with the liquid penetrant examination materials used at CPSES. Accordingly, this allegation has neither safety significance nor generic implications. 6. Actions Required: None. 8. Attachments: None. l 9. Reference Documents: 1. Receiving Inspection Procedure, CP-QAP-8.1. 2. Liquid Penetrant Examination Procedure, QI-QAP-10.2.1. 3. NRCs f14438, M4339, M4340, M4484 (Rev. 1), and M4050. 4. NRC irs - 82-09 82-04, dated July 6, 1982. 82-18 82-09, dated October 1, 1982. 82-11 82-10, dated December 18, 1982. 83-10 83-05, dated March 10, 1983. 83-01 ---, dated March 24, 1983. 83-24 83-15, dated August 24, 1983. I

r 4 10. This statement prepared by: J. H.11alonson Date Reviewed by: Group Leader Date Approved by: Project Director Date

IY o a 5 / e \\ i. 1 s SSER - AQW-27/CP2A Draft 11/13/84 SSER 1. Allegation Group: Mechanical and Piping Category No. 29, Improperly certified liquid penetrant material 2. Allegation Numbers: AQW-27 i 3. Characterization: During a routine inspection on September 7-10, 1982, the NRC Region staff found that improperly certified liquid. penetrant materials were used at Comar.che Peak Steam Electric Station I (CPSES). l On May 18, 1983, the Citizens Associations for Sound Energy (CASE) informed the ASLB that they had learned that certain uncertified liquid penetrant (LP) materials had been used at CPSES. A review of the CASE allegation showed it to be the same batch of LP material found earlier by RIV. I 4. Assessment of Safety Significance: During a routine review of the i Brown & Root (B&R) liquid penetrant program, the NRC inspector noted that the certified test report (CTR) for a batch of LP materials contained " pen and ink" changes. Inspection reports (irs) 82-09 and 82-18 cover the initial licensee notification of the unresolved item F0lA45-59 cch2

. IR 82-11, Appendix A, " Notice of Violation," requested that Texas Utilities Electric Company (TUEC) submit a written statement or explanation of these altered reports including: "(1) the corrective steps which have been taken and the results achieved; (2) the corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. '/ The NRC Technical Review Team (TRT) determined that TUEC investigated the reported violation and found that the certified test results were altered by the jobber / supplier from whom the material was purchased. The TRT also found that in response to the request for corrective actions as detailed in IR 82-11, Appendix A, TUEC issued stopwork order No. 28 to prevent use of the materials until proper identification and certifications were provided. Further corrective action was acccmplished by issuing of five TUEC nonconformance reports (NCRs), which resulted in correcting the receiving inspection reports (RIRs) to show the correct identification of the materials and obtaining the material manufacturer's original (unaltered) certified material test reports. The TRT determined that this corrective action provided documented evidence of the integrity and acceptability of the liquid penetrant examination material used. In addition, TUEC obtained valid manufacturer's material test reports to support their acceptance of

the liquid penetrant examination materials. The TRT found that these test reports were included in the liquid penetrant record package. TUEC took additional corrective action on the cited violation by revising receiving inspection procedure CP-QAP-8.1. Revision 5 of this procedura implemented a detailed receiving inspection checklist te ensure that liquid penetrant materials were properly identified (marked) and that material certifications were unaltered originals. To prevent a recurrence of the problem with altered certifications, TUEC discontinued the practice of procuring liquid penetrant N examination materials from jobbers and instituted a policy of purchasing directly from the material manufacturers. TUEC also removed the jobber who had altered the certified test report from the approved vendor list. Since the implementation of the corrective action, TUEC has issued purchase orders 10470,10565,10707,11444 and 11685 to the material manufacturer for additional penetrant material. Receiving Inspection Reports (RIRs) 21313, 21637, 22414, 23579, and 24271 were prepared to cover the receipt of this material. The TRT reviewed the RIRs to verify that the new requirements had been met. The TRT found that the penetrant material had been purchased directly from the manufacturer and that a receiving inspection checklist had been used at the site.

. The TRT also reviewed the Appendix to IR 83-10 (page 3, para. 2) which stated that the Region IV inspector verified that TUEC completed corrective action for the stopwork order and the NCRs, that the receiving inspection procedure was revised and implemented, and that the receiving inspectors were trained. During this review, the TRT noted that a checklist included in RIR 21313 and 24271 did not conform to Procedure CP-QAP-8.1, which was a violation of the procedure. TUEC corrected the RIRs thereby eliminating the violation on July 20, 1984. The TRT learned that the department supervisor subsequently conducted a training session for receiving inspection department personnel. The TRT verified the corrected reports and documentation of the training on July 29, 1984. 5. Conclusion and Staff Position: Based on the documents reviewed, the TRT concurs with the allegation that improperly certified liquid penetrant examination materials were used at CPSES. However, after detection and reporting of the violation by the Region IV inspector, TUEC initiated, implemented, and maintained effective corrective action to provide documented evidence for traceability and acceptability of the material in conformance with code QA procedures and program requirements. Since TUEC implemented effective corrective action, the TRT concludes that there is no problem or potential problem with the liquid penetrant examination materials used.

[ D -S-Accordingly, this allegation has neither safety significance nor ge'neric implications. 6. Actions Required: None. 8. Attachments: None. i. 9.

References:

l 1. Receiving inspection checklist, penetrant materials. 2. B&R interoffice memo, part of disposition of NCR M4484, dated November 23, 1982. 3. Memorandum, transmittal of material manufacturers ~ certs to vault, part of disposition of NCR M4484. 4. Memorandum, documentation of receiving inspector training. 5. Training record receiving inspectors. 6. Stop Work Order 28. 7. TUEC Nonconformance Reports M4338, M4339, M4340,'M4484RI, and M4050, 8. TUEC Receiving Inspection Reports 19011, 19240, 21313, 21627, 22414, 23759, and 24271. 9. TUEC Purchase Orders 10470, 10565, 10707, 11444, 11685 NCR M4338, M4439, M4340, M4484 (Rev. 1) and M4050. l

5 . 10. NRC irs 82-09 82-04, dated July 6,.1982; 82-18 82-09, dated October 1, 1982; 82-11 82-10, dated December 18, 1982; 83-10 83-05, dated March 10, 1983; 83-01 --- , dated March 24, 1983; 83-24 83-15, dated August 24, 1983.

11. Receiving Inspection Procedure CP-QAP-8.1.
12. Liquid Penetrant Examination Procedure, QI-QAP-10.2.1.
10. This statement prepared by:

J. Malonson, Date TRT Technical Reviewer Reviewed by: L. Shao, Date Gr6up Leader Approved by:

y. noonan, Date Project Director

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F SSER - AQW-27/CP2A Draft - 11/13/84

SSER, 1.

Allegation Group: Mecha,nical and Piping Category No. 29, Improperly certified liquid penetrant material 2. Allecation Nunibers: AQV-27 3., Characterization: During a routine inspection on September 7-10, ~ l j 1982, the NRC Region staff found that improperly certified liquid penet. M ". ~ rant materials were used at Comanche Peak Steam Electric Station (CPSES). s t

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~ "On*May 18, T983, the Ci ize~ns Associ4tions.for Sound Energy (CASE) ~ informed the ASLB that they had learned that certain uncertified liquid penetrant (LP) materials had been used at CPSES. A review of the CASE allegation showed it to be the same batch of LP materia)., .ae found earlier by RIV. ~ ~ ~ "?g w ~ ~4. Assessment of Safety Significance: During a routine review of the ~ Brown & Root (B&R) liquid penetrant program, the NRC inspector noted that the certified test report (CTR) for a batch of LP materials contained " pen and ink" changes. Inspection reports (irs) 82-09 and 82-18 cover the initial licensee notification of the unresolved item. j

. IR 82-11, Appendix A, " Notice of Violation," recuested that Texas Utilities Electric Company (TVEC) submit a written statement or p ~expNtion of these altered reports including: "(1) the corrective ~ steps which have been taken and the results achieved; (2) the corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. 'I 1 The NRC Technical Review Team (TRT) determineo that TUEC investigated the reported violation and found that the certified tgresults were ~ altered by the jobber / supplier from whom the material was purchased. The TRT also found that in response to the request for corrective r actions as detailed in IR 82-11, Appendix A, TUEC issued stopwork* 4 = order No. 28 to prevent use of the gt.er,iagntil giroper ~ ~ ' identification and certifications were provided. Further corrective p' actiog was ac~compl.ished by issuing of five TUEC nonconformance reports - ~ * (NCRs), which resulted in correcting the receiving insgection reports I (RIRs) to show the correct identJfication of the materials and obtaining the material manufacturer's original (unaltered) certified material test reports. ~ A i As The TRT determined that this corrective action provided documented evidence of the integrity and acceptability of the liquid penetrant + examination material osed. In addition, T0EC obtained valid manufacturer's material test reports to support their acceptance of I i 4 i

= e . the liquid penetrant examination materials. The TRT found that these test reports were included in the liquid penetrant record package: .RJEC took additional corre'ctive action on the cited violatio.n by _4 revising receiving inspection procedure C,P-QAP-8.1. Revision 5 of this procedure implemented a detailed r.eceiving inspection checklist to. ensure that liquid penetrant materials were properly identified (marked) and that material certifications were unaltered originals. To prevent a recurrence of the problem with altered certif'ications, TUEC discontinued the practice of~ procuring liquid penetrant . examination I:iaterialMrom~ jobbers and instituted a policy of ~~ purchasing d.irectly from the material manufacturers. TUEC also removed the jobber who had altered the certified test repor't fr ~ t e l* approved vendor list. ~ i 4 Since the implementation of the corrective action,,TUEC has issu,ed purchase orders 1470,10565,10707,11444 and 11685 to the material -o. manufacturer for additional penetrant mater.ial.. ~ Rece4v.ing> Inspection ~ } Reports (RIRs) 21313, 21637, 22414, 23579*, and 24271 were prepared to cove'r the receipt of this material. Th8 TRT reviewed the RIRs to . verify that the new requirements hap been net. The TRT found that the l penetrant mat ef al had been purchased directly from the manufacturer ~ and that a receiving inspection checklist had been used at the site. f 1

Z r The TRT also reviewed the Appendix to IR 83-10 (page 3, para. 2) shich _ stated that the Region IV inspector verified that TUEC completed t' . ~. corrective action for the stopwork order and ths NCRs, tha't the e receiving inspecti,og prjceduce was revised and imp.lemented, and *that - Duringth.v.,revgw,,theTRT is the receiving inspectors were trained. e noted that a checklist included in RIR 21313 and 24271D,not.corl ornip.5* f -k* to Procedure CP-QAP-8.1, which was a violation of the procedure. TUEC corrected the RIRs thereby eliminating the violatio.n on July 20, ~ 1984. The TRT. learned that the departme'n,t supervisor subsequently condu,cted a training session for receiving inspection department e, p'ersonnel. The Titi verified the corrected reports and documentation MO ~ .. w. of the training on July 29, 1984. J -..~ - s...- ^~ G* ** g.y'4. 5. Conclusion and Staff Position: Based on the documents, reviewed., the, _q .s. i TRT concurs ~with the allegation that improperly certified liquid penetrant examination materials were used at CPSES. However, after detection and reporting of the violation by the Region IV inspector, TUEC initiated, implemented, and maintained effective corrective action to prov,ide documented evidence for traceability and Tceptability of the material in conformance with code,QA. procedures and program requirements. Since TUEC implemented' effective correctiv action, the TRT concludes that there is no problem or potential problem with the liquid penetrant examination materials used. I l

pr -S-Accordingly, this allegation has neither safety significance nor -9 generic implications. 6. Actions Reouired: None'. ~ 8. Attachments: None. ~d ~ 9.

References:

f

  • -3',

x. 1. Receiving inspection checklist, pen.etrant7sa:crisTs., e y- ~ 2. B&R int"fr*f fice mono, par,t. of dispos.Qion gf.UCR M43fsi,, dat'ed November 23, 1982. 3., Memorandum, transmittal of material masu.fytur,, ors. certs to vault, part of disposition of NCR M4484. .p s 4. Memorandum, documentation of receiving inspector training. 5. Training record receiving inspectors. 6. Stop Work Order 28. i.;. TUEC Noncon,formance' Reports M4318, M4339,.M434 W M4484RI, 7. ~ and M4050. 8. TUEC Receiving Inspection Reports 19011, 19240, 21313, 21627, 22414, 23759, and 24271. 9. TUEC Purchase Orders l0470,10565,10707,11444,11685 NCR M4338, M4439, M4340, M4484 (Rev. 1) and M4050. ~

5 '. 1 I

10. NRC 1Rs 82-09 82-04, dated July 6, 1982; 82-18 82-09, dated gTctober 1,1982;881182-10,' dated December 18, 1982; 83-10 83-05, dated Mar,ch.

1983; 83-01 --- , dated March 24, 1983; 83-24 1 83-15, dated August 24,*1983. i 11. Receivind Inspection Procedure CP-QAP-8.1. 12. Liquid Penetrant Examinat9bn Procedure, QI-0AP-10.2.1. i i

10. Jhis statement prepared by:'

J. Malonson, Date TRT Technical Reviewer i e e 1 . e-g l Revie @d by: MS ~~ L. Shao, Date

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. sdmeup Leader j 4 s ee**.. 4 Approved by: j V. hoonan, Date Project Director i I m 4 i l

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Gs.,1?-rdn T. Innnti&n Administrative Writeup integrated into SEER ___________ Potential Violations to Region IV___________ Workpackage File Complete ______________ Workpackage Returned to Group Leader __________ F0lA-85-59 l cc zy

s, s 4 DCP2 - SSER - AQW-27 l 12/11/84 SSER 1. Allegation Group: Mechanical and Piping Category No. 29 l 2. Allegation Number: AQW-27 3. Characterization: A routine NRC Region IV inspection on September 7-10, 1982 found that inproperly certified liquid penetrant materials were used at Comanche Peak Steam Electric Station (CPSES). The Citizens Association for Sound Energy (CASE) also informed the ASLB on May 18, 1983, that they had learned that certain uncertified i liquid penetrant (LP) materials were used. A review of the CASE allegation showed it was related to the same nonconforming condition, j l 4 Assessment of Safety Significance: NRC Region IV inspection reports J IR 82-18 and 82-09 reported that pen and ink changes were made to date and batch number of the certified test report for (developer) Batch 82-C-068. Inspections performed during the later period of 1982 (documented in IR 82-11) also reported altered certified test reports for other batches of liquid penetrant examination material. IR 82-11, i i Appendix A, includes a Notice of Violation requesting TUEC to submit a

4 written statement or explanation of these altered reports to Region IV including: (1) the corrective steps which have been taken and the results achieved; (2) the corrective steps which will be taken to avoid such violations in the future; and, (3) a date when full compliance will be achieved. The NRC Technical Review Team (TRT) determined that TUEC investigated the reported violation and found that the certified test results were i altered by the jobber / supplier from whom the material was purchased. i The TRT also learned that in response to the request for corrective actions, as detailed in IR 82-11 Appendix A, TUEC issued stopwork order No. 28 to prevent use of the materials until proper identifi-cation and certification were provided. Further corrective action was l accomplished by the issuance of five TUEC nonconformance reports (NCRs). This action corrected the receiving inspection reports (RIRs) to show the correct identification of the materials and obtained the material manufacturer's (Magnaflux) original (unaltered) certified material test reports. The TRT determined that this corrective action provided documentation for the integrity and acceptability of the ~ l liquid penetrant examination material used. In addition, TUEC obtained valid manufacturer's material test reports to support their acceptance of the liquid penetrant examination material. The test reports are included in the record package. 1 l

\\ e TUEC took additional corrective action on the cited violation by revising the receiving inspection procedure (CP-QAP-8.1). Revision 5 of the procedure implemented a detailed receiving inspection checklist to assure that liquid penetrant materials were properly identified (marked) and that material certifications were originals and were not altered by mark-up. t The TRT found that to prevent a recurrence of the problem with altered certifications, TUEC discontinued the practice of procuring liquid penetrant examination materials from jobbers and instituted a policy of purchasing directly from the material manufacturers. TUEC also removed the jobber who had altered the certified test reports from the I approved vendor list. Following implementation of corrective action, TUEC issued purchase orders (P0s) 10470, 10565, 10707, 11444, and 11685 to the material nanufacturer(Magnuflux). The TRT reviewed receiving inspection l reports 21313, 21627, 22414, 23579, and 24271 for material on the above listed P0s, and verified that the penetrant examination material was procured directly from the manufacturer and the receiving inspection conformed to the Procedure CP-0AP8.1 requirement for use of the detail checklist. During this review, the TRT also noted that the checklist included in 4 l RIRs 21313 and 24271 did not conform to the procedure because an i

1 incorrect checklist was used. TUEC corrected the RIRs on July 20, 1984, and the TUEC receiving inspection supervisor conducted a documented training session. The TRT verified both the corrected reports and training documentation on July 30, 1984. i i 1' IR 83-10 Appendix Page 3, para. 2, documents that the Region IV { inspector verified that TUEC completed corrective action for the stopwork order and the NCRs, that the receiving inspection procedure E was revised and implemented, and that the receiving inspectors were trained. The item is considered closed, j IR 83-15, pages 13 and 14, contain a detailed explanation of the I alleged improper certifications and Region IV follow-up to assure that i TUEC performed effective and acceptable corrective action. The IR states that the matter is consider >d closed. TilX rLwoc<w]! A6-Wt)ft il6&tLetow F t iAt 0A/9C ~pVG l Crpteo f.9 $~6 M g d a'n A O 5, 5. Conclusion and Staff Position: Based on the documents reviewed, the TRT concurs with the allegation that improperly certified liquid penetrant examination materials were used at CPSES. However, af ter this problem was detected, TUEC initiated, implemented, and maintained effective corrective. action to provide documented i evidence for traceability and acceptability of the material in conformance with code, QA procedures and program requirements. Since TUEC implemented effective corrective action, the TRT concludes that i i

y . there is no problem or potential problem with the liquid penetrant examination materials useo at CPSES. Accordingly, this allegation has neither safety significance nor generic implications. 6. _ Actions Required: None. 8. Attachments: None. 9. Reference Documen__t_s: s 1. Receiving Inspection Procedure, CP-QAP-8.1. 2. Liquid Penetrant Examination Procedure, QI-QAP-10.2.1. 3. NCRs M4438, M4339, M4340, M4484 (Rev.1), and M4050. 4. NCR irs 09 82-04, dated July 6, 1982. 82-18 82-09, dated October 1,1982. 82-11 82-10, dated December 18, 1982. 83-10 83-05, dated March 10, 1983. 83-01 ---, dated March 24, 1983. 83-24 83-15, dated August 24, 1983. l l

10. This statement prepared by:

J. H. Malonson Date i TRT Technical Reviewer ) Reviewed by: L. Shao Date Group Leader Approved by: V. Noonan Date Project Director

DCP2 SSER - AQW-27 2/25/85 SSER 1. Allegation Group: Mechanical and Piping Category No. 29 2. Allegation Number: AQW-27 3. Characterization: NRC Region IV (RIV) inspection report IR 82-18 and 82-09, which cover RIV inspections performed in September 1982, reported that pen and ink changes were made to the date and batch number on the certified test report for (liquid dye penetrant) developer batch 82-C-068. RIV IR 82-11, which covers RIV inspections performed in November 1982, also reported altered certified test reports for other batches of liquid penetrant examination material (which was used in the construction of 'he Comanche Peak Steam t Electric Station (CPSES)). An RIV IR 83-24 and 83-15, which covers RIV inspections performed during March through July of 1983 reported that the Citizens Association for Sound Energy (CASE) also informed the ASLB on May 18, 1983, that they had learned that certain uncertified (sic) liquid penetrant (LP)materialswereused. An (RIV) review of the CASE allegation showed it was related to the same nonconforming condition (pen and ink changes reported in the above irs). l t0lA-85-59 celu

, a 4 4. Assessment of Safety Significance: The NRC Technical Review Team i i (TRT) reviewed the RIV irs (noted above) and found that IR 82-11 \\ issued a notice of violation dated November 24, 1982, to the Texas Utilities Generating Company (TUEC) which requested that TUEC submit a written statement or explanation of these altered reports to Region IV i including: (1) the corrective steps which have been taken and the i results achieved; (2) the corrective steps which will be taken to I j avoidsuchviolationsinthefuture;and,(3)adatewhenfull compliance will be achieved. l The TRT found that TUEC responded to the Region IV notice of violation in a letter TXX 3603 dated December 12, 1982. This letter detailed a the TUEC action that was initiated and implemented to correct the i condition cited and to prevent a recurrence of the violation. l I The TRT determined that TUEC investigated the reported violation and I found that the certified test reports were altered by the 1 jobber / supplier from whom the material was purchased. 1 l l The TRT also learned that in response to the request for corrective actions as detailed in the RIV notice of violation, TUEC issued stopwork order No. 28 to prevent use of the improperly certified materials until proper identification and certification were obtained. Further TUEC corrective action was accomplished by the issuance of five TUEC nonconformance reports (NCRs). This action corrected the i j receiving inspection reports (RIRs) to show the correct identification 1 2

. of the materials, and provided the material manufacturer's (Magnaflux) original (unaltered) certified material test reports. The TRT verified that the acceptable manufacturer's certifications (test reports) provided documentation for the integrity and acceptability of the liquid penetrant examination material used. The TRT found that the test reports are included in the QA record package. TUEC took additional corrective action on the cited violation by revising the receiving inspection procedure (CP-QAP-8.1). This revision 5 of the procedure implemented a detailed receiving inspection checklist to assure that liquid penetrant material containers were properly identified (marked) and that material certifications were originals and were not altered by mark-up. The TRT found that to prevent a recurrence of the problem with altered certifications TUEC discontinued the practice of procuring liquid penetrant examination materials from jobbers and instituted a policy P of purchasing directly from the material manufacturers. TUEC also removed the joboer who had altered the certified test reports from the approved vendor list. Following implementation of corrective action, TUEC issued purchase orders (P0s) 10470, 10565, 10707, 11444, and 11685 to the material manufacturer (Hagnuflux). The TRT reviewed receiving inspection reports 21313, 21627, 22414, 23579, and 24271 for material on the above listed P0s, and verified that the penetrant examination material

. 2 was procured directly from the manufacturer and the receiving inspection cor. formed to the Procedure CP-QAP8.1 Revision 5 requirement for use of the detail checklist. During this review, the TRT found that the checklist included in RIRs 21313 and 24271 did not conform to the procedure because an incorrect checklist was used. TUEC corrected l the RIRs on July 20, 1984, and the TUEC receiving inspection supervisor conducted a documented training session for the receiving 4 inspector who had used the incorrect checklist. The TRT verified both the corrected reports and training documentation on July 30, 1984. ~ IR 83-10 Appendix Page 3, para. 2, documents that the RIV inspector verified that TUEC completed corrective action for the stopwork order 1 and the NCRs, that the receiving inspection procedure was revised and implemented, and that the receiving inspectors were trained. The item 4 i (cited in the RIV notice of violation) is considered closed. 1 IR 83-15, pages 13 and 14, contain a detailed explanation of the j alleged improper certifications and Region IV follow-up inspection to j assure that TUEC performed effective and acceptable corrective action. 1 The IR states that the matter is considered closed. The TRT found I that RIV inspections detected and reported the violation and, by j inspection, verified the completion of TUEC's corrective action by j March 10, 1983 (IR 83-10, 83-05) which is prior to case's notification i to the ASLB by the CASE letter dated May 18, 1983. ? The TRT assessed a related allegation in QA/QC Category 7 allegation ) i i 1 AQ-113. l i

). ! f 4 - 5. , Conclusion and Staff Position: 8ased on the documents reviewed, the ) TRY concurs with the allegation that improperly certified liquid j penetrant examination materials were used at CPSES. However, after this problem was detected, TUEC initiated, implemented, and maintainec effective corrective action to provide documented evidence for l traceability and acceptability of the alleged improperly certified dye penetrant material that was used at CPSES. Since the TRT verified that TUEC implemented effective corrective action, the TRT concludes { that there is no problen with the proper certification of the dye I i penetrant examination materials which were used at CPSES. 1 Accordingly, this allegation has neither safety significance nor i generic implications. I 6. Actions Required: None. J / I S. Attachments: None. ( i 9. Reference Documents: i 1. Receiving Inspection Procedure, CP-QAP-8.1. 1 l 2. Liquid Penetrant Examination Procedure, QI-QAP-10.2.1. 3. NCRs M4438, M4339, M4340, M4484 (Rev.1), and M4050. 4. hRC RIV irs: 82-18/82-09, 82-11, 83-10/83-05, 83-24/83-15. 5. SSER QA/QC Category 7, AQ-113.

. 10. This statement prepared by: J. Malonson Da te TRT Technical Reviewer Reviewed by: L. Shao Date Group Leader Approved by: V. Noonan Date Project Director G

o 1 / { u N O., } -7 I koM hF{ i SSER 1. Allegation Group: Mechanical & piping. Category No. 29 I= properly certified liquid penetrant material 2. Allegation Numbers: AQW-27 3. Characteri=ation: It is alleged that i= properly certified liquid penetrant examination materials were used. 4 Assessment of Safety Significance: NRC Region IV inspection reports t IR 82-18 and 82-09 reported that the certified test report for (developer) Batch 82-C-068 contained pen and ink changes to the date and batch number. IR 82-11 for inspections performed during the later period of 1982 reports altered certified test reports for other batches of like materials. IR 82-11 Appendix A, Notice of Violation requests that TUEC submit a written statement or explanation in reply including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and f3) the date when full compliance will be achieved. ( Subsequent TUEC investigation of the reported violation revealed that the certified test results were altered by the obber/su, lier from whom the material was purchased. m

i . ( ve In response to the request for correctiee-act, ions as detailed in IR the y issuadef stopwork 82-11 Appendix A TUEC :::icr r:: ir.it*-*=d k order 28 to prevent use of the materials until proper identification and certifications were provided. Further corrective action was accomplished by the issue of five TUEC uonconformance reports M4338; M4339; M4340; M4484, Revision 1; and M4050. TUEC action, as a ed t (RxR ), result of the NCRs, correct 4*e the receiving inspection repo hror d the +eceeet identification of the materials and obtained the material manufacturer's (magnaflux) original (unaltered) certified material sa test reports. TUEC completed corrective action provided documented evidence for the integrity and acceptability of the liquid penetrant examination material that was used. Valid manufacturer's material test reports were obtained to support acceptance. The test reports are included in the record RIR/NCR package. Further TUEC corrective action en the cited violation revised the receiving inspection procedure CP-QAP-B.lg Revision 5 implemented the use of a detailed receiving inspection checklist to assure that liquid penetrant materials are properly identified (marked) and that material certifications are original - not altered by markup. l (

(, O ( To prevent a recurrence of the problem with altered certifications, TUEC discontinued the practice of procuring liquid penetrant examination materials from jobbers and instituted a policy to purchase directly from the material manufacturers. The jobber was removed from the approved vendor list. After TUEC implementation of corrective action. TUEC purchase orde 10565; 10707; 11444; and 11685 were issued to the caterial manufacturer - Magnuflux. The TRT reviewed receiving inspection reports 21313, 21627, 22414, 23579, and 24271 for material on the above listed P0s to verify that the penetrant examination material was procured directly from the manufacturer and that the receiving inspection activity was in conformance with the Procedure CP-QAP8.1 requirement for use of the detail checklist. During this review, the TRT noted that the checklist included in RIRs 21313 and 24271 did not conform to the procedure because an incorrect checklist was used. The RIRs were corrected by TUEC on July 20, 1984, and a documented training session was conducted by the TUEC receiving inspection supervisor, corrected reports and training o documentation was verified by the TRT on July 29, 1984. l (- l

\\..- .. ( IR 83-10 Appendix Page 3 para. 2 documents that the Region IV inspector verified that the TUEC corrective action for the stopwork order and the NCRs is complete; the receiving inspection procedure was revised and implemented; and that the receiving inspectors were trained. The item is considered closed. IR 83-15, page 13 contains a detailed explanation of the improper certifications. The condition is cited in a " CASE" letter to the ASLB dated May 18, 1983, wherd((in" CASE"identifiestheuseofthe materials as a potential problem. It is noted that pages 13 and 14 of the " CASE" letter refers to the condition vaguely as: "The Atchinson Matter." The TR 83-15 also reports the item as closed. Please note that the violation was reported, corrective action was completed by TUEC, and verified by the Region IV inspector. Prior to the date of the CASE letter. 5. Conclusion and Staff Position: Based on the review of documents identified in the assessment Section 4 above, the TRT concurs with the allegation that improperly certified liquid penetrant examination materials were used at CP. (

. ~. e a I After detection and reporting of the violation by the Region IV inspector, TUEC initiated, i=ple=ented and =aintained effective corrective action to provide docu=ented evidence for traceability and acceptability of the caterial in conformance dith code,QA procedures,, and progra= require =ents. In the assessment (Section 4 of this report) the TRT has provided the background infor=ation as clarification for an understanding of the allegation. The docu=ents identified in Section 4, and the narrative, explain the detail and the results of the TRT review activity to a support the following conclusion: Since effective corrective action wasi i=ple=ented by TUEC,the TRT concludes that there is no proble= or potential proble= with the liquid penetrant exa=ination =aterials used, er pr ccatly ir uce ct. -GF,- The allegation has neither safety significance nor generic i=plications. 6. Actions Recuired: None g l 1

(, . 8. Attachments: Sample - Receiving inspection checklist penetrant materials Sample - B&R interoffice memo dated November 23, 1982 - Part of disposition of NCR M 4484 Sample - Longhand memo - transmittal of material manufacturers certs to vault - Part disposition of NCR M 4484 Sample - Longhand memo documentation of receiving inspector training Sa=ple - Training record receiving inspectors Stop k'ork Order 28 TUEC Nonconformance Reports M4338, M4339, M4340, M4484RI, M4050 TUEC Receiving Inspection Reports 19011, 19240, 21313, 21627, 22414, 23759, 24271 TUEC Purchase Orders 10470, 10565, 10707, 11444, 11685 NRC IR - 82-09 82-04 July 6, 1982 82-18 82-09 October 1, 1982 82-11 82-10 December 18, 1982 83-10 83-05 March 10, 1983 83-01 March 24, 1983 ( 83-24 83-15 August 24, 1983

9. Reference documents: Receiving Inspection Procedure CP-QAP-8.1 Liquid Penetrant Examination Procedure QI-QAP-10.2.1 10. This statement prepared by: J. H. Maldnson Date Reviewed by: Group Leader Date Approved by: Project Director Date ( ,v.

1 l ) l L..L h LF.I'li UI l>ULot1i IJ'l L I H i t hlit.'t.:t it i i i Deli I.1 f_@d _,5 T N _@N_% _ A I VI E.r cup _, iil 1 Li,s O1 1 on _, _wffgC.f)/2fX _ f a_ ft., f}lJif!K/_Q({ _ _ _,. _,.. t,ut.,1 rc t o4 (ij 1 c ca.t 1 ori 14unibe r e j9 (g)W - 2_2,,,, _ _ __ ____ [ k.,_,jf&f.rfjf Afg_,_,, _ __. _,, _.., _ _ i,ut hur : 1h sheet an } } be t r.1 t 2 n i ed L.y each r e vi eut r. Ii - t c. . w2 i b.- ! ' r e v-) ui uns to the S';;L' l-wr i t e:up arid iser vet. et : rout 2 tree ar ect r evi t-u r et or d. It w2}} be f a ] eri : ti t h t-wari p o c ! c.o r when iht wr 1

  • rur a r votil a r.t.ed.

Dr6it IJunit>cr Draft 1 2 3 4 5 [ [d n i4 hn-r.- r.,. n i r,.- s...- Tech. E d 2 t or rene i .i. s...,1 1..r r ti-i i nne 13 t r-Revi si on Number F2nal 1 2 3 4 5

p.., n nr Tech. Editor C,roun Leader J.

r,.,1, ran r T..,..1, 4 n Admi ni str at i ve Writeup integrated into SSER___________ Potential Violations to Region IV_____,______ Wortpackage File Complete ______________ Workpackage Returned to Group Leader __________

~ ~ i /' \\ /[]JHM \\ lf l' l \\ $< ", Q U ,\\ n j' I \\ SSER f g*m. 97 ..y ~L & c. v} cd. l &,,I Mechanical & piping, Category No. 29 1. Allegation Group: Improperly certified liquid penetrant caterial l 2. Allegation Nu=bers: AQi='-27 ty( $. fle%%'. !.7&~'Q 3-4V c M TT LD M RU'S 'X: f 4 " (' A- [Gn-P': v 7 dM?oa ~ S& D r 2 'so,i9 8 & i~MT' Ivv1 pr.c D tWm c cr yv~1 t=-1 G+2 g,, I tA 0&< Mt4 y I Mo e.w uSGD, L ' (pu i D /M L 6 7% d v 4 W D LLS w c 2 Cae , oco-m As ea w % > z, a 32 tim ltM' IP'c< D LMJM W

c. Wrt' O

(% m E r>'e # 6 b e cc! 1 v t> c 64 n r, c-c y ga v i c W 6G&LI V.S G C. 0 /2-Eul04) cf-77+'5 CAS6 a , ta+1 n ~~~ f24-LMCA 7o TM-6-- f 4+vtb W Cr-Cf s'wLP'w" w nm v :s mm n,,vc;u cx v f $F_,$ rv1M C6 CC#C% /QC&C4. (e Of G >w as o t' Dv oun n anopue t'g' uo a a) on Scc r (%) eiyow psa-wa (Mc csw, rsa-au , <, s o-v- - n W T' tWC ttr (c. Ti'--} c) F (+ 'S ic.-r-co.!- c f-- L0 u ?!' i $,1 t,Y, $'U & ,,, $'l0 ( {WWfy /.\\ CTZcru /4c-fx&rs (/ /C,) 8 2-09 pjs< t ;.2 - f 6 c.z y 6 +< / JUJ(): l/C d-v ] & & m/U C.v '-.a M ivo7tsr?frcr*At' tw ,wC 7;u.& ,ati r-FGlA-85-5W

f?0h ~ _ n -~ IR 82-11 Appendix A. 'otice of Violation p v z _ e z; TWEC submit a e,s 7uote A ro* Leo M '8"I written statement or explanation ir g;17 including: (1) the g corrective steps which have been taken and the results achieved; (2) y$ corrective steps which vill be taken to avoid _;;;i : vio . &mM, t3) g m ense date when full compliance vill be achieved. TPe w u12c. 76ea<. e c4 4. (L6vi GW W {TnX) O & oucFD m <( U - c=-t TUEC investigatb the reported violation M $$Iat the certified test"results were altered by the jobber / supplier from whom the material was purchased. s MWW W) y G in response to the request for correctiee-actions as detailed in IR 49 82-11 Appendix A TUEC t h t ' M '

  • d 5-issuedd stopvork f

g No. order,28 to prevent use of the materials until proper identification and certifications were provided. Further corrective action was 6 accomplished by the beve of five TUEC nonconformance reports (D C iS 3 u tt' M12 S; F'23"; w'2'^; P0', 2;.ici:: M y 1; d ^t.036. TUte action, a m o - a . e the receiving inspection repo gr>. reenle af ek- "D . ccrre::i:: 70 I" d r"' ospu un k4 of the :::cct f rMemo identification of the materials and ;t; id the material manufacturer's (sur#gp>fith6) original (unaltered) certified material ew test r2 ports.

T.n t~ TILT %WW IUM2 Tb 4 Y T* ' I g TUE % a ' corrective action provided docu=ented evidence 6er the integrity and acceptability of the liquid penetrant exa=ination s u Ano mom, rutec o.en wedL, caterial t4een asse used. kValid manuf acturer's material test reports g twtyy,a f, veTe-obeetnad to support, acceptance ( or Tw uVv*o esrrmi The test reports are included in the record Rttk/&Mr package. W.yprt p u nw C# W M 1 , W rW i V PM### Wp# Further TUEC corrective action on-the7ited vicistica revised -the 6 psy merWA receiving inspection procedure CP-QAP-B.lgr,WgM &ic&$ yremented the use of a detailed receiving inspection checklist to assure that liquid penetrant materials are properly identified (marked) and that material certifications are original - not altered.$4astyyp. cc Te prevent a recurrence of the proble: with altered certifications, TUEC discontinued the practice of procuring liquid penetrant examination materials fro: jobbers and instituted a policy to purchase TUFC M50 Mb directly fro = the material manufacturers. 4The jobber W f rom the approved vendor list. w p 940 # C64.nAGo M T W S ^1CA #f j fGLu da 'yML yM isSu&A \\ A4e===S416Csimplementation of corrective action TUEC purchase 3 (Por orders 470; 10565; 10707; 11444; and 11685 wo,e=4essed to the caterial manufacturer he reviewed receiving

rm Ma "s+ ffw's

\\/ inspection reports 21313, 21627, 22414, 23579, and 24271 '-- --*~iel l Au0 v&+tdtM on the above listed Pos t: :::ify that the penetrant examination material was procured directly from the manufacturer and thet the Co m oo To receiving inspection activity "- ,v

-'" the Procedure CP-QAP8.1 requirement for use of the detail checklist.

. \\ S Th@ IR 83-10 Appendix Page 3, para. 2 doommenee that the Region IV -rg. Ci n de v ets $ edtowroc, M inspector verified that 1st TUEC corrective action for the stopvork WM &k6#/,'; W, the receiving inspection procedure was T' order and the NCRs ': _ j revised and implemented $and that the receiving inspectors were trained. S - 4*-- 1 : rrid : d cl ;;d. IR 83-15, page 13,contain etailed explanation of the impre er Thecondition\\scitedina"CAS\\ cert a tica_s. i ter to the ASI.B \\ l \\ 18, 1983,/ e"in"C?SE"identif \\ dated May the us6 of the materials as a potential probi It is note that pages 13 and 14 of \\ \\ \\ j the " CASE" letter refers to th onditiongguely as: The Atchinson \\ u \\ Matter." i "## 9R 83-15 o reports the item as 'ased. ?!^rr- -*- \\ \\ l rivat Ee iolat was reported, horrective action was leted by \\ \\ TUECyan eri ied by the Region KV ins-lector9 pP aa or to the dare of t CASE letter. I wasW n .,a. -.r 5. Conclusion and Staff Position: .eviev fg::---ta ..._om s.. Y iden+1f1-A in d.:

----an* *-etic" '> 6:: 7 the TRT concurs with the allegation that improperly certified liquid penetrant examination materials were used at CP.

s rl@ After detection and reporting cf thc violation by the hegion IV n inspector, TUEC fr.itiated, i=plemented and caintained ef f ective corrective action to provide docu=ented evidence for traceability and acceptability of the caterial in confor=ance with code,QA proceduresj and progra= requirecents.. n the assess =ent (Section 4 of this report) the TRT has provided the f i \\ backgrcund infornation as clarificat,itn for an understanding of'. the I Q allegation. The documents idepti.ied in Section 4, and the narrative, I h \\ explain the detail and the results of the TET revi,ep setivity to \\ k/ support the fol$9ving conclusion:V n)E-C $ M 0LC+1 Gsu TH Since ef fective corrective action ve;_ ',1 r = & $ R,the TRT concludes that there is no proble= or potential problem with the liquid penetrant exa=ination caterials used, er ; cently ir uce ct-CF,- The allegation has neither safety significance nor generic implications. 6. Actions Required: None Lee 8

I e J I l,

/ 0 8. Attachments: @r AN M W Sample - Receiving inspection checklist penetrant materials Sample - B&R interoffice memo dated November 23, 1982 - Part of disposition of NCR M 4484 Sample - Longhand memo - transmittal of material manufacturers certs to vault - Part disposition of NCR M 4484 Sample - Longhand me=e documentation of receiving inspector training Sample - Training record receiving inspectors Stop k'ork Order 28 TUEC Nonconfermance Reports M4338, M4339, M4340, M4484RI, ~4050 TUEC Receiving Inspection Reports 19011, 19240, 21313, 21627, 22414, 23759, 24271 TUEC Purchase Orders 10470, 10565, 10707, 11444, 11685 M Ctl M 4bb O 's m4379,M 43YO,M44 M (4&v I)ttM YO S OMM NRC IR - 82-09 82-04 July 6, 1982 lowse 82-18 82-09, October 1, 1982 82-11 82-1 ecember 18, 1982 83-1083-[5 reh 10, 1983 ) fIrch24,1983 83-01 83-24 83-1 August 24, 1983

y. \\ L4Lefbr_eh Receiving Inspection Procedure CP-QAP-8.1 Liquid Penetrant Examination Procedure QI-QAP-10.2.I 10. This statement prepared by: J. B. Maldnson Date f Reviewed by: Group Leader Date i Approved by: Project Director Date i i I 1 I s s wwn,-- c

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ptil i i t.:ied. Dr e-i t iJunit ccr c A o Dr a.4 t 1 [ /// (4. 4 b nr r,,- r. :,,. # r. ri r..- 1 ec.h. Ecia t or o r n4 i j,

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) I r. ir.! i t r. hevi si on Npmber i Final 1 2 3 4 5 ( 1 f.., y. e.r Tech. Editor C,e ou o Leader J_ r .,1, . c can T i c. m e.1 i 4 r. Administrative Writeup integrated into SEER ___________ Fotential Violations to Region I V _ _ _ _ _ _, _ _ _ _ _ Wor kpaci;c,ge Fil e Complete ______________ Wort. pact: age Returned to Group Leader __________ F0lA-85-59 C.C 2J

mie sm-s 39' i i b 3 L0 ,1) / AiLug e;cG i e ""# "aparling of 'he-violatien-by-the-Region-tv ,y/ t C W b ip TUEC initiatedgi=ple=ented and naintained ef fective / / corrective action to provide documented evidence for traceability od acceptability of the =aterial in confor=ance with cod QA procedureig and progrs= require =ents, k' In the assess =ent (Section ' a# *e report) the TRT has rov 4 be / background infor=at. a larificati or an understanding of the i 0 allegation. The docu- ..s identified.:r-Secion 4, and the narrative s e etail and the results of the T:I review actg1:Q \\ support the following conclusion: .\\ N Since effective corrective at TJ G-C IMC& &swd ion wee i=ple;x.;d Lj T'J.T. the TRT ) concludes that there is no proble= or potential proble= with the

c. 9.5 cTJ.

liquid penetrant ex.a=ination r :erials used, A.T-c:

17 5 ucc--er

-07,- The allegation has neither safety significance nor generic i=plications. 6. Actions Recuired: None

t!' I 714t-TT2T C & 'u 010 MT T1+153 7#9 - n _;1-t 4 orrective action provided documented evidence fyr the integrity and acceptability of the liquid penetrant examination s u troosito u, TV6C 0 6Tn w& material th : ;;.: used. NValid manufacturer's material test reEnno"*%& arts TW54 ' ra toqueo ps1verwr e MI M ~ weee-ebee6eed to support acceptance ( The test reports ase included in ^ the record 3Rs@C(f package. gW g 3-Fmpelmar TUEC corrective action on the cited violation r the 3 FCIW b

-.=,=
=

^ receiving inspection procedure -QAP-5. Revision 3:, implemented the TM M a detailed receiving in pection c cklist to assure that liquid tff- & penetrant materials properl identified (=arked) and that material g ~iginalgot altered br/d*Aq. ff, / r ~S/ certifications aee I To fprevent a recurrence of the problem with altered certifications, TUEC discontinued the practice of procuring liquid penetrant of wG examination materials from jobbers and instituted a policy me purchasec TO L'<. 4-do a w so; directly from the material manufacturers.6e jobberg;;; ;;_;;:d w e n-tA O r% LTam M ' the approved vendor list. g,. p, ^ p ~ ^. CoLleweMG T%d-< L a nu go Asw Tvi;C implementation of corrective action, TUICgurchase C or) / CP ordersr10470( 10565( 10707( 11444( and 11685 rx i_a to the material manuf acturer -cWabfudQ. The TRT reviewed receiving inspection reports 21313, 21627, 22414, 23579, and 24271 for material iWe vSee W on the above listed P0s te verify that the penetrant examination material was procured directly from the manufacturer and tduet the Cen) W 69 CD receiving inspection -hiry 22: in cenfe--~e rith the (3 _ % = : Procedure CP-QAP8.1 requirement for use cf the detail checklist. Ce. tW

. s Ve In response to the request for correctiee-act, ions as detailed in IR j 4t issuadefstopwork 82-11 Appendix A, TUEC ::ti:n :: init*-*=d k-was order 28 to prevent use of the materials until proper identification r HEP o and certifications were provided. Further corrective action was accomplished by the issue of five TUEC nonconformance reports M4338; M4339; M4340; M4484, Revision 1; and M4050. TUEC action, as a ed L (RxR ), result of the NCRs, correct 6ve the receiving inspection repoh r ,/ ~ 1he ::::::: identificaties of the materials and obtained the material manuf acturer's (magnaflux) original (unaltered) certified material se test reports. ya '70&' g gr$ t P A'" 'O TU26 completed corrective action provided documented evidence gyr the 4 integrity and acceptability of the liquid penetrant examination w 6.cd e material that'ves used. Valid manufacturer's material test reports w Y.4-were obtained to support acceptance. The test reports ase included in the record RIR/NCR package. Further TUEC corrective action on the cited violation revised the receiving inspection procedure CP-QAP-B.1, Revision 5 implemented the 6 use of a detailed receiving inspection checklist to assure that liquid penetrant materials a.c #re properly identified (marked) and that material d certifications & Vsee original - not altered by markup. (

i . To prevent a recurrence of the problem with altered certifications, TUEC discontinued the practice of procuring liquid penetrant examination asterials from jobbers and instituted a policy to purchase directly from the material manufacturers. The jobber was removed from the approved vendor list. i After TUEC implementation of corrective action. TUEC purchase orde 10565; 10707; 11444; and 11685 were issued to the material manufacturer - Magnuflux. The TRT reviewed receiving inspection reports 21313, 21627, 22414, 23579, and 24271 for material I on the above listed P0s to verify that the penetrant examination material was procured directly from the manufacturer and that the receiving inspection activity was in conformance with the gzgvubw M Procedure CP-QAP8.1 requirement far use of the detail checklist. [Duringthisreview,theTRTnotedthatthechecklistincludedin f i> RIRs 21313 and 24271 did not confom to the procedure because an ( incorrect checklist was used. The RIRs were corrected by TUEC on July ) eddhdocumentedtrainingsessionvasconductedbytheTUEC

\\

A r48 20, 1984, p k receiving inspection supervisor, rected reports and tutstatag 1 o documentation was verified by the TRT on July 29, 1984. } ( f r* AY 6 l 0

4 _4 ,no IR 83-10 Appendix Page 3, para. 2 documente tljat the Region IV /s.) inspector verified that the TUEC corrective action for the stopwork yt cM4u9ft N O V 6 5 & " Cla i & order he NCRs ir ri,' rt a receiving inspection procedure was revisedandimplementedpand the receiving inspectors were trained. The item is considered closed. IR-4-3-157 pige 13 containra detailedwlanaticu ci i.im 1-ysuper G rificationsv -The condition is cited in a " CASE letter to the ASLB ,7 dated May 18, 1983, whe'rCin " CASE"'i[entifies the use of the 'N materials as a potential probl'em. It is noted that pages 13 and 14 of the " CASE" letter refe s to the c ition vaguely as: "The Atchinson a N Matter." 'DFW 9R 83-15 also reports the item as '.ose. P1 ere_nne d s that hiolation-ws. sogwited, cer-ective-a\\ r-- / ctiuss... ce ylei..J by i Od D .e 10 "p Orp-O-%lltd acc vi th: Of.SE letter. T W Il& W 5. Conclu'sion and Staff Position: Based on the review of documents 3 1 N is th; ::cere =

  • Sectien A 25 ::7.the TRT concurs & E i_

a4EEiesEEn that improperly certified liquid penetrant examination materials were used at CP. (

g _. _ t, 3)N After, detection and reporting of the violation by the Region IV inspector,TUECinitiatedgieplementedand=aintainedeffective corrective action to provide docu=ented evidence for traceability and acceptability of the material in confor=ance with cod QAprocedurep and program requirements. i In the assessment Mactier ^ af thicasport) the TRT has rov he background informaticu-as clarification' or an understanding of the ~ a allegation. The documents identified'l'n-Saction 4 and the narrative, explain the-detail and the results of the TFT review act'ivitQ i support the following conclusion: Since effective corrective at ion 'was i=ple:ented by TUEC the TRT concludes that there is no problem or potential proble= with the liquid penetrant exa=ination t :erials used, er yccati; in ucc-ct- -GF,- l The allegation has neither safety significance nor generic implications. l l I j 6. Actions Required: None f i 4

i = Ii O 8. Attachments: @u_AN % W Sample - Receiving inspection checklist penetrant materials Sample - B&R interoffice meno dated November 23, 1982 - Part of disposition of NCR M 4484 l Sample - Longhand memo - transmittal of material manufacturers certs to vault - Part disposition of NCR M 4484 j Sample - Longhand memo documentation of receiving inspector training Sample - Training record receiving inspectors Stop Work Order 28 TUEC Nonconfermance Reports M4338, M4339, M4340, M4484RI, '4050 TUEC Receiving Inspection Reports 19011, 19240, 21313, 21627, 22414, 23759, 24271 TUEC Purchase Orders 10470, 10565, 10707, 11444, 11685 i NRC IR - 82-09 82-04 July 6, 1982 82-18 82-09 October 1, 1982 82-11 82-10 December 18, 1982 83-10 83-05 Karch 10, 1983 83-01 Karch 24, 1983 83-24 83-15 August 24, 1983 4

w l ; C .f L 'hefbr_e h h Receiving Inspection Procedure CP-QAP-8.1 Liquid Penetrant Examination Procedure QI-QAP-10.2.1

10. This statement prepared by:

J. H. Maldnson Date .i 4 Reviewed by: Group Leader Date 4 ( l Approved by: Project Director Date 4 9 e i I o (e .,-.-w,. .,, _,=,

35-11 5 Q pI }AG, 4 $ -(f, / jownf5 Root.inc. AffY f AQo' l Q'y/ j INTEROFFICE MEMO I N VG Gt IO b IM # 24,577 jf Y h-TO: Distribution DATE: 11-23-82 FROM: E.P. Opelski Site NDE Level III

SUBJECT:

Penetrant material batch numbers authorized for release to fiel'd. As part of the disposition of NCR No. M-4484 I have reviewed and found acceptable the certificates of compliance for the batch E numbers listed below. By copy of this memo, receiving inspection is hereby authorized to release this material to the field. The receiving inspector is to compare the batch nu=ber marked on each can to the batch numbers listed below. The batch numbers released ' are to be recorded on the Material Requisition and a copy of the MR is to be forwarded to the undersigned. Spotcheck Developer Spotcheck Penetrant Spotcheck Cleaner l l 80J065 7H151 80H096 80K023 79D125 78A136 7K076 79C113 80J069 79B001 82B097 7K071 82D097 78M113 79D057 .m 82E041 7 81LO71 79E010 C"3 82C068 82B035-82E067 82B009 82B058 82D112 r 82C090 7G071 82A004

  • I 82D055-81 LOO 7 81K154 Ci 82D058 80A032 82D006 E

N ~ y 82C068 81LO71-82B085' 81JO98 79J110 81L008-7 81K141 81G068 7 81J098 81H066 7 81K141 81G017 r 81B014 81B012 b 79L004 81D054 .I 81B012 81A051 79J0837 79K015 78C089' { 78C050 ee 31 m ot

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