ML20236F491

Part 21 Rept on QA Controls Re NDE Records Utilized by Eastern Testing & Insp,Inc During Performance of NDE Svcs at Facility.Names of Individuals Informing NRC & Identification of Basic Svcs Containing Defect Provided

ML20236F491
Person / Time
Site:	Peach Bottom
Issue date:	10/19/1987
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
REF-PT21-87, REF-PT21-87-189-000 PT21-87-189, PT21-87-189-000, NUDOCS 8711020161
Download: ML20236F491 (5)

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' PHILADELPHIA ELECTRIC COMPANY  ;

2301 MARKET STREET 1

P.O. BOX 8699 ]

PHILADELPHIA. PA.19101 taisi ensw' October 19, 1987

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Docket Nos. 50-277 l 50-278' i

Mr. William T. Russell, Administrator  !

Region I l U.S. Nuclear Regulatory Commission {

631 Park Avenue King of Prussia, Pa. 19406 {

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Subject:

Peach Bottom Atomic Power-Station - Units 2 and 3 l 10CFR Part 21 Report {

Hon-Destructive Examination Services Provided  !

By Eastern Testing and Inspection, Inc.  !

DearLMr. Russell:

In accordance with paragraph (3)'of 10CFR 21.21(b), the following information is '

,being provided regarding quality assurance controls pertaining to non-destructive-

-examination records utilized by Eastern Testing and Inspection, Inc. during performance of non-destructive examination (NDE) services at Peach Bottom Units 2 and 3.

'1. Name of individuals informing the Commission Oral-notification was made to J. H. Williams, USNRC, on October 16, 1987 by the following individual: j M. J. Cooney

2. Identification of basic services which contain a defect:

Certification of Non-Destructive Examination (NDE) testing equipment and chemicals, and certification of NDE personnel.

3. Identification of firm supplying the basic component:

Eastern Testing and Inspection, Inc. (ETI) ,

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9220 Collins Avenue  :

Pennsauken, New Jersey 08110 8711020161 871019 p

PDR ADOCK 05000277 i  !

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Mrs William T4 Russel1-October. 19, 1987'

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L 4. , Nature of. defect and the. safety hazard which could be created:

During a Philadelphia Electric Company quality assurance audit of ETI , I three'nonconformances to ETI procedures regarding HDE documentation were.

discovered. 'These findings are summarized below:

A.' Nonconformance with'ETI-Procedure ETI-PT-2000, Rev. 1 Regarding Documentation of Thermometer Calibrations.

Paragraph 4.3.1 of the referenced procedure states the temperature of ,

the penetrant and the part to be examined shall be between 60 and  !

-1250 F inclusive, as measured with a calibrated surface thermometer.. -! ,

Contrary to the above requirements, a review of.ETI calibration records for surface thermometers revealed the following:

1) Calibration Test Report, Lehigh No. 8896A dated January 14, 1987 for thermometer Serial No.'s A-1 and B-1 appears to have had the serial numbers typed in over white-out on a copy of the test report.

2) Several " blank" copies of the test report listed in item (1) j above, were observed in the surface thermometer calibration file with the instrument serial numbers apparently whited-out. All ,

.other data, including the "as-found" calibration data and ]'

signature of'Hugh Horning of Lehigh Testing were left unchanged.

3) In a telecon with Lehigh Testing Laboratories personnel (Don  !

Pelligrino, General Manager) on April 28, 1987, the auditor was l informed that Hugh Horning, whose signature appears on the test j report listed in item (1) above, terminated his employment with j Lehigh on October 17, 1985. j

4) "As-found" calibration data for thermometer serial numbers A-1, B-1, A, B, D, E. F, G H and I dated January 14, 1984, July 13, 1984, and September 7, 1984 are identical on each calibration report.-

B. Nonconformance with ETI Training and Certification Procedure ETI-CP-101 -3 Rev. 3, Regarding Documentation of Annual Eye Examinations. (All methods)

Paragraph 4.5.6 of the referenced procedure states in part, a visual examination shall be administered at least on an annual basis for those personnel who are certified as Level I, II & III. This examination shall be performed by a professional optometrist, a medical doctor or other qualified person. Examination results are to be included as a part of the qualification requirements.  !

Contrary to the above requirements, a review of eye exams for Mr.

William Molineaux, ETI's Level III for Peach Bottom revealed the following:  !

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% w Ms.!WilliamT. Russell- ' October 19,:1987 g

Page 3 of 5 1

Mr.'Molineaux's current visual examination report dated September 16, .

.1986 appears to be a copy of his previous visual examination. report- l dated September 19, 1985. The issued date (September 16,1986),date.  !

'by. eye doctor (September 16,1986) and next-examination due (September 16,1987) are. typed in over his previous report dated September 19, 1985 examination report where the. original dates were apparently '

whited-out.  !

C. Nonconformance with'ETI Procedure Regarding' Documentation of Chemical. j Analysis Results of Penetrant Materials i

Paragraph 3.1.2 of the referenced procedure states in part - Certified

-analysis shall be obtained from the manufacturer for.all liquid penetrant materials used giving manufacturer's brand name and number or type, batch numbers and actual test retained'in accordance with the applicable code.

Contrary to the above requirements, a review of ETI Batch Certification-Test Reports for penetrant materials revealed the following:

1) Several " blank" copies of a Magnaflux Batch Certification Test.

Report for spotcheck developer, type SKD-NF, were observed with,  ;

the report date and-batch number apparently whited-out with the-chemical analysis results for. sulfur'(0.0095%) and-halogen (0.0149%) content and signature of the magnaflux QC Supervisor on the form.

2) Magnaflux Test Reports for spotcheck developer, type SKD-NF, bathnumbers 81K065, 83A008 and 83L053 dated December 7, 1981, 3

January 12, 1983 and January 17, 1983 appear to have had the batch )

numbers' typed in over white-out on a copy of the test report i listed in. item 1) abom. The sulfur and halogen content listed on each of these batch certification reports is identical; sulfur 0.0095% and halogen 0.0149%. j Inaccurate NDE results caused by such nonconformances could result in not I detecting welds that might be deficient. Failure of deficient welds in the i primary system boundary could result in a loss of coolant accident and  !

failure of deficient welds in the emergency core cooling systems could result in their failure to function to mitigate a loss of coolant accident.

5. Date on which the information of such defect was obtained:

The nonconformances were identified on April 27, 1987 by Philadelphia l Electric quality assurance auditors. ETI was notified on August 28, 1987 by {

Philadelphia Electric Company that their responses indicating corrective action taken by them in response to the described nonconformances were I acceptable and that these findings were considered closed. The evaluation l to determine deportability was completed on October 14, 1987.

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Mre, William T. Russell October 19, 1987 ,

i j Page 4 of 5 6.: The number and location of the basic component that contains a defect:  !

Eastern Testing and Inspection performed non-destructive examinations on .

ap' proximately four hundred various primary system boundary and emergency  !

core cooling system welds in the period March 10, 1987 through April 27,  ;

1987 during the performance of modification work on Peach Bottom Units 2 and 3.

7. Corrective action that has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length of time that has been or will be taken to complete the action:

Philadelphia Electric Company's Mechanical Engineering Division and the

' Engineering and Research Quality Assurance Division verified that the nonconformances did not adversely affect the quality of welds non-destructively examined by ETI. The verifications performed and the results are described below.

A review of all ETI Reports for NDE services performed during the period March 10, 1987 through April 27, 1987 was completed and a list of all ETI thermometer serial numbers and surface temperatures of the items examined was compiled.

A review of the list referenced above verified that no thermometers, other than those for which calibration records were reviewed during the April, 1987 audit performed at ETI's Pennsauken, New Jersey facility, were utilized by ETI.

A review of calibration records furnished by ETI for calibrations performed ,

on May 10, 1987 by Schiavonne Labs and Pacific Transducer Corporation on l July 10, 1987 and comparison against the surface temperatures compiled in i the list verified that all examinations performed were within the 1 temperature range of the approved ETI Liquid Penetrant Procedure.

A review of all ETI Reports for NDE Services performed during the period i March 10, 1987 through April 27, 1987 was completed and a list of all ETI 1 HDE' technicians who performed NDE during this period was compiled. This j list was compared against the auditor's checklist used for the original l audit to determine which technicians eye exam records needed to be reviewed as part of resolution of the non-conformance regarding certification of personnel.

Copies of eye exam records for four ETI technicians which were not reviewed I during the April 1987 Philadelphia Electric Company audit performed at ETI's Pennsauken, N. J. facility were requested, received and reviewed. The doctor who performed eye exams for three of the technicians and the 1 technician identified in the nonconformance was contacted via telecon on l July 16, 1987 (with the permission of ETI) and it was verified by comparison l between the eye exam dates in the doctors records and the dates shown on the l ETI Eye Exam Records for the subject technicians that the dates were in agreement.

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Mr>. William T. Russell October 19, 1987 g Page 5 of 5 l

A review of all ETI reports for NDE Services performed during the period March 10, 1987 thru April 27, 1987 was completed and a list of all penetrant material batch numbers was compiled. This list was compared against the auditor's checklist used for the original audit to determine which batch certification records needed to be reviewed as part of resolution of the nonconformance regarding certification of penetrant materials.

Copies of Batch Certification Reports for two batches of Magnaflux cleaner / remover SKC-NF and two batches of developer SKD-NF which were not reviewed during the April 1987 audit performed at ETI's Pennsauken, N. J.

facility were requested, received and reviewed. The subject batch certifications appear to be valid copies with no apparent sign of correction of any entries.with white-out/ correction fluid.

Magnaflux Corp. was contacted and copies of Batch Reports for the penetrant materials identified in the nonconformance finding report were obtained. It was verified by comparison between the reports submitted by ETI and the reports independently obtained directly from Magnaflux that the batch numbers, dates and chemical analyses were in agreement.

l When the nonconformances were identified. ETI was immediately terminated from further NDE activities at Peach Bottom and subsequently, on August 28, 1987, were notified that they had been removed from PECo's Evaluated Suppliers List because of our concerns with the credibility of their Quality Assurance Program relative to control and authenticity of Quality Assurance records.

8. Notification:

The industry has not been notified of these nonconformances in NDE services provided by ETI.

Should you require any additional information, please do not hesitate to contact us.

Very truly yours, Y k cc: Addressee T. P. Johnson, NRC Resident Site Inspector - PBAPS

I l 00T 9 61987 L

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i Mexico l Williams, Reactor trator

)r Engineering Mexico 87131 rator Licensing Section Chief 25, 1987, Mr. John L. Pellet will assume the position and Chief of the Operator Licensing Section in the Division of placing Mr. Ralph Cooley.

s and correspondence formerly sent to Mr. Cooley should now

r. Pellet.

Sincerely, Original Signed By' A. B. Beach

1. L. J. Callan, Director

{ Division of Reactor Projects lexico r, Chief

upervisor bxico 87139 Mexico

, Director 1 Safety lexico 87139 o Environmental Improvement Agency ge) 9

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