ML22303A005

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EN 56178 - Tioga Final. LTR-TP-22-29 2021 10CFR Part 21 Improper Notification of NRC
ML22303A005
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 10/24/2022
From: Nichols B
Tioga Pipe
To: Hoc H
Document Control Desk, Office of Nuclear Reactor Regulation
References
LTR-TP-22-29
Download: ML22303A005 (27)
v • d • e


Text

From: Nichols, Bryan To: Hoc, HOO X

Subject:

[External_Sender] Tioga 10CFR Part 21 Date: Monday, October 24, 2022 4:20:44 PM Attachments: image001.png image002.png LTR-TP-22-29 2021 10CFR Part 21 Improper Notification of NRC.pdf Please see attached.

Bryan Nichols Director l Quality Assurance 100 Mort Drive, Easton, PA 18040 Direct 484-546-5613 Office 610-252-7473 Mobile 215-435-2806 Email bnichols@tiogapipe.com tiogapipe.com l CONFIDENTIALITY: This e-mail and any attachments are confidential and may be privileged. If you are not the intended recipient or this was sent to you in error, please notify the sender by reply e-mail immediately and do not disclose the contents to another person, use it for any purpose or store or copy the information in any medium. Thank you for your understanding.

When it has to be right .

f LTR-TP-22-29 October 24, 2022 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Phone: (301) 816-5100 Fax: (301) 816-5151 FROM: Bryan Nichols, Quality Director SUBJECT : Letter to the NRC to notify the improper submittal of a 10CFR Part 21 Report generated on September 2, 2022 On September 2, 2022, Tioga in accordance with its internal 10CFR Part 21 procedure, QSP-115.1, emailed the attached 10CFR Part 21 report to the following email address:

EIE@nrc.gov . Tioga had incorrectly identified this email address as one of the allowable methods of submittal for 10CFR Part 21 reports. This issue was identified by a NUPIC audit team on October 24, 2022 . Tioga is now submitting the 10CFR Part 21 report through the correct method of facsimile at 301-816-5151. Tioga has opened an internal corrective action, N-CAR-22-04, to address this condition. As part of this corrective action, Tioga shall revise its internal 10CFR Part 21 procedure, QSP-115.1, to remove the email address: EIE@nrc.gov as one of the options of submitting a 10CFR Part 21 report. If you have any questions or concerns, please let me know.

Respectfully,

~

Bryan Nichols Quality Director

  • r.oga 100 Mort Drive, Easton, PA 18040 Direct 484-546-5613 Office 610-252-7473 Mobile 215-435-2806 Email bnichols@tiogapipe.com tioga pipe.com Page 1 of 1 File Location: FILESVRl Public FORKS A Lette s and Corres ondences

Nichols, Bryan From: Nichols, Bryan Sent: Thursday, September 2, 2021 3:47 PM To: EIE@nrc.gov Cc: Keiser, Andy; Keiser, David; Kotcher, Bill; Reigel, Glenn; Echols, Shannon; Mandy.Hare@duke-energy.com; Sherry.Andrews@duke-energy.com

Subject:

RE: 10CFR Part 21 Notification and Report Attachments: LTR-TP-21-24 Rev. 1 Mackson-Duke 10CFR Part 21 Notification and Final Report.pdf Good afternoon. Tioga needs to issue a revision to the original 10CFR Part 21 report issued on Tuesday, 8/31/2021. Tioga mixed up two Mackson Nuclear/Duke Energy orders for 6" Sch. 40 that shipped at the same time: Tioga Sales Order 358008 and Tioga Sales Order 354160. Due to this mix up, the following information on the final report was incorrect:

  • 160 total feet of Maxim material supplied to Duke Energy, not 180 total feet
  • 8 total pieces of Maxim material supplied to Duke Energy, not 9 total pieces
  • 60 feet delivered to Duke Energy McGuire Nuclear Station, not 80 feet
  • The last Duke Energy PO listed in the report is 00154619 00967, not 00154619 01012
  • The last Tioga Sales Order listed in the report is 354160, not 358008
  • 40 feet of Walsin, Heat No. 112540, Lot No. 202010-TG-B30 supplied as replacement to Duke Energy, not 60 feet of Walsin, Heat No. 112037, Lot No. 202010-TG-B30 and 202010-TG-E07 The above information has been corrected in the attached revised final report. I apologize for the inconvenience. Please let me know if you have any questions or concerns.

Thank you, Bryan Nichols Director I Quality Assurance 100 Mort Drive, Easton, PA 18040 Direct 484-546-5613 Office 610-252-7473 Mobile 215-435-2806 Email bnichols@tiogapipe.com tiogapipe.com I Im From: Nichols, Bryan Sent: Tuesday, August 31, 20215 :17 PM To: EIE@nrc.gov Cc: Keiser, Andy <akeiser@tiogapipe.com>; Keiser, David <dkeiser@tiogapipe.com>; Kotcher, Bill

<bkotcher@tiogapipe.com>; Nichols, Bryan <bnichols@tiogapipe.com>; Reigel, Glenn <greigel@tiogapipe.com>; Echols, Shannon <SEchols@mackson.biz>; Mandy.Hare@duke-energy.com; Sherry.Andrews@duke-energy.com

Subject:

10CFR Part 21 Notification and Report 1

Good afternoon. The attached letter provides notification and a final report in accordance with

§21.21 concerning the supply of 6" NPS Sch. 40 Seamless Stainless-Steel Pipe to the Duke/

Progress Energy Catawba Nuclear and McGuire Nuclear Stations for ASME Section III, Subsection NC Class 2 2007 Edition, 2008 Addenda applications. Please let me know if you have any questions or concerns.

Thank you, Bryan Nichols Director I Quality Assurance 100 Mort Drive, Easton, PA 18040 Direct 484-546-5613 Office 610-252-7473 Mobile 215-435-2806 Email bnichols@tiogapipe.com tiogapipe.com I tffl 2

When it has to be right.

f LTR-TP-21-24 Rev. 1 September 2, 2021 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Phone: (301) 816-5100 Fax: (301) 816-5151 E-Mail: EIE@nrc.gov

SUBJECT:

Revised Final Report Notification Pursuant To 10 CFR Part 21.21, Regarding Supply Of 6" NPS Sch. 40 Seamless Stainless-Steel Pipe; Manufacturer:

Maxim Tubes Company PVT. LTD.; Heat No: N200309AW01, SR No: 7; 8 pcs; 160 feet total procured as unqualified source material for ASME Section III, Subsection NC Class 2 2007 Edition, 2008 Addenda This letter provides a final report in accordance with §21.21 concerning the supply of 6" NPS Sch. 40 Seamless Stainless-Steel Pipe to the Duke/ Progress Energy Catawba Nuclear and McGuire Nuclear Stations.

Mackson Nuclear, LLC subcontracted Tioga Pipe, Inc. (Tioga Pipe) to supply the pipe.

Tioga Pipe performed utilization of unqualified source material in accordance with ASME NCA-4255.5 on Maxim Tubes Company PVT. LTD. material from Tioga's commercial inventory. While the unqualified source material passed all required tests and examinations in accordance with the requirements of ASME NCA-4255.5, the material was identified with multiple linear indications located on the inside diameter of the pipe.

Further evaluation by Tioga Pipe found these indications to be lap-like and thus, rejectable in accordance with ASME SA999 paragraph 28.12. Please see Attachment 1, "Final Report Notification Information per §21.21", for additional details and clarification.

All material supplied from the same heat and lot number from Maxim Tubes Company PVT. LTD. has been identified by Duke, found not be installed, and returned to Tioga Pipe. At this time, all of the defective material is in Tioga's possession and there is no risk of this defective material being installed into a nuclear facility.

If you have any questions, please feel free to contact me at (713) 512-3569 or our Quality Director, Bryan Nichols, at (484) 546-5613.

Regards, Fell. (A)l:U,J:AM l<'.oi-GM.CR - OJ?~~

William Kotcher J?>~'1Pt>J N"k.1-\C>t.$, CPOAUl:-r'1 1'1.'t2e'-"'t"o'S2_

President Tioga Pipe Inc.

When it has to be right .

f LTR-TP-21-24 Rev. 1 I I

Enclosures:

1) Attachment 1, Final Report Notification Information per §21.21
2) Duke Energy Part 21 Letter to Mackson July 2021
3) Laboratory Testing Inc. Certified Test Report, TPS00l-21-08-24454-1 Cc:

Andrew Keiser, Tioga David Keiser, Tioga Bryan Nichols, Tioga Richard Crowley, Tioga Glenn Reigel, Tioga Shannon Echols, Mackson

,.,liog When it has to be right f LTR-TP-21-24 Rev. 1 Attachment 1 Final Report Notification Information per §21.21 I. Name and address of the individual or individuals informing the Commission:

William Kotcher President Tioga Pipe Inc.

14950 Heathrow Forest Parkway, Suite 390 Houston, TX 77032 II. Identification of the facility, the activity, or the basic component supplied for such facility which fails to comply or contains a defect.

  • 6" NPS Sch. 40 Seamless Stainless-Steel Pipe; Manufacturer: Maxim Tubes Company PVT. LTD.; Heat No: N200309AW01, SR No: 7; 8 pcs; 160 feet total procured as unqualified source material for ASME Section III, Subsection NC Class 2 2007 Edition, 2008 Addenda.
  • 100 feet delivered to the Catawba Nuclear Station on PO 00154619 00971 and 60 feet delivered to the McGuire Nuclear Station on PO 00154619 00978 and 00154619 00967.
  • Tioga Sales Orders: SO 354874 Position 20, SO 355032 Position 20, and SO 354160 Position 50.

III. Identification of the firm constructing the facility or supplying the basic component which fails to comply or contains a defect.

Tioga Pipe, Inc.

IV. Nature of the defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.

Tioga Pipe Inc. purchased unqualified source material from Maxim Tubes Company PVT. LTD. The unqualified source material passed all required tests and examinations in accordance with the requirements of ASME NCA-4255.5 however the material was identified with multiple linear indications located on the inside diameter of the pipe. The indications were discovered by Duke Energy during their pre-fabrication inspection at the Catawba Nuclear Station. The indications ranged from 1/4" to well over an inch in length. This material along with the material with the same heat number at McGuire Nuclear Station was returned to Tioga Pipe for further evaluation. The evaluation found these indications to be lap-like and thus, rejectable in accordance with ASME SA999 paragraph 28.12.

Page 3 of 5 File Location: \\Ell.ESVRl\Public\FORKS\OA\ *~ ~""-"'=n_&!ences

1090 When it has to be right .

f LTR-TP-21-24 Rev. 1 V. The date on which the information of such defect or failure to comply was obtained.

  • Duke Energy notified Mackson Nuclear and Tioga Pipe, inc. of the linear indications on July 21, 2021. At that time, it could not be determined if the linear indications were rejectable in accordance with ASME SA312 and SA999.
  • The material was returned to Tioga for further evaluation on 7/30/2021.
  • A sample of the material containing the linear indications shipped to Tioga's approved supplier of destructive testing, Laboratory Testing, Inc. {LTI) on 8/17/2021 for microstructure examination.
  • The microstructure examination was completed on 8/20/2021.
  • Tioga received the LTI test report, TPSOOl-21-08-24454-1 determining the material to contain defects on 8/30/2021.

VI. In the case of a basic component which contains a defect or fails to comply, the number and location of these components in use at, supplied for, being supplied for, or may be supplied for, manufactured, or being manufactured for one or more facilities or activities subject to the regulations in this part.

(8 pcs) 20 ft long pieces = 160 total linear feet supplied with 100 feet delivered to Catawba Nuclear Station on PO 00154619 00971 and 60 feet delivered to the McGuire Nuclear Station on PO 00154619 00978 and 00154619 00967. All 160 feet have been returned to Tioga Pipe, Inc.

VII. The corrective action, which 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.

Tioga Pipe Corrective Action, N-CAR-21-08 has been generated and Bryan Nichols, Quality Director is responsible for completing and closing this corrective action.

Completed Actions:

1. Extent of condition: The extent of condition is limited to above identified 160 feet and the additional 171 feet in Tioga's commercial inventory.
2. Tioga has replaced the 160 feet supplied to Duke with different material supplied by different mills (120 feet of Salzgitter Mannesmann, Heat No.

350470, Lot No. QL30151841 and 40 feet of Walsin, Heat No. 112540, Lot No. 202010-TG-B30).

3. The 160 feet of pipe returned to Tioga has been quarantined and tagged as nonconforming material.
4. Tioga shall not use any material supplied from Maxim Tubes Company PVT. LTD. for nuclear orders until Tioga has been provided with a sufficient corrective action response from Maxim Tubes Company PVT.

LTD.

Page 4 of 5 Letters and Corre ces

Q When it has to be right.

r LTR-TP-21-24 Rev. 1 Open Actions:

5. Prepare and Issue Final Report to NRC - due August 31, 2021.
6. Tioga shall quarantine and tag as nonconforming material the remaining 171 feet in Tioga's commercial inventory - due September 10, 2021.
7. Issue a supplier corrective action to Maxim Tubes Company PVT. LTD. to have them investigate the cause and provide corrective actions for the laps identified on the inside diameter of the above pipes - due September 10, 2021.

VIII. Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees.

Not applicable. All material from this heat number has already been returned to Tioga Pipe. The returned material has been quarantined and tagged as nonconforming material.

IX. In the case of an early site permit, the entities to whom an early site permit was transferred.

Not applicable .

Page 5 of 5 File Location: ..\.ll....=-=-:"'-"'-'-:.:>..>!--"'-"".,,__,,__,.'--""-'-=~Q8\Letters and Correspo de ces

Catawba Nuclear Station 1f_') DUKE Duke E111rgy ENERGY. CN01VP I 4800 Concord Road York, SC 29745 July 21, 2021 10 CFR 21 Mackson Attention:

Shannon Echols, Quality Assurance Manager sechols@mackson.biz

Subject:

Duke Energy Carolinas, LLC (Duke Energy)

Catawba Nuclear Station, Units 1 and 2 Request for Mackson Determination of 10 CFR 21 Reportablllty Catawba Nuclear Condition Report (NCR) 02388864 Catawba Nuclear Station PO 00154619 Rel 00971 RE: Linear Indications identified on 6" SS ASME SA312, Schedule 40, Piping The purpose of this letter is to formally notify Mackson of a discovery by Duke Energy concerning the above described piping. Material received on PO 00154619 Rel 00971, and issued under Duke Energy CAT 10 149543, was discovered to have linear indications on the ID of the piping during pre-Inspection activities at Duke Energy, Catawba Nuclear Station.

The basic component was delivered for use at CNS and Issued to craft for pre-fabrication activities. The material was intended to be used in the Duke Class C LD System (ASME Class 3), which is QA Condition 1, Safety Related. The piping was purchased under CATID 149543, which is [PIPE, 6", SS, ASME SA312, TP304, PLAIN ENDS, SEAMLESS OR WELDED, SCH 40, ANSI B36.10, 1001C1AF1O0B060, B, ASME SECTION Ill SUBSECTION NC]. The material was identified with multiple linear indications and is associated with Heat

  1. N200309AW01 (Duke Energy UTC 30197705). The indications range from 1/4: to well over an inch. Similar indications were not identified on other material from CATID 149543, with a different Heat#, that was also issued for the same project. It should also be noted that piping from the same heat number (N200309NW01) was also supplied to McGuire Nuclear Station on Duke Energy PO 00154619 Rel 009967 & Rel 00978, This part was procured QA Condition 1 and provided to Duke Energy under the 10 CFR 50 Appendix B quality assurance program. It is possible that 10 CFR 21 may require Mackson, as the supplier, to make a report to the NRC. Therefore, Duke Energy requests Mackson review this issue against the reporting criteria of 10CFR 21 and take appropriate action to assure that Mackson complies with 10 CFR 21 with respect to this issue. Duke Energy requests Mackson provide documentation of its conclusions relative to 10 CFR 21 reportability for our records within 45-60 days of receipt of this letter.

Letter from Duke Energy to Mackson Page2 Please direct any questions to Sherry Andrews, Catawba Regulatory Affairs, at (803) 701-3424.

Q;< ~

Mandy B. Hare Nuclear Support Services Manager Catawba Nuclear Station bxc:

M.B. Hare S.E. Andrews A. Linker J. Stewart C. Jenkins R. Bowman S. Steele RGC Date File

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2450 Wheatsheaf Lane 100 Mort Drive Philadelphia, PA 19137 Easton, PA 18040 ATTN: Bryan Nichols CUSTOMER P.O. CERTIFICATION DATE SHIP VIA 713869 8/20/2021 L Tl DELIVERY DESCRIPTION Quantity: 9 Material: ASME SA312 Grade TP304/TP304L Size: 6" NPS Sch. 40

Description:

Seamless Stainless Steel Pipe Heat No.: N200309AW01 Shop Order#: 354874 / 10 O.A. No.: 12164/7 S/N: 1,2,3 Code Year: ASME Section Ill Subsection NC Class 2 2007 Edition 2008 Addenda; ASME Section II 2007 Edition 2008 Code Year: Addenda MICROSTRUCTURE EXAMINATION APPLICABLE SPECIFICATIONS: Customer's Instructions ETCHANT: As Polished/ 10% Oxalic, Electrolytic MAGNIFICATION: 10X- SOX KEY: C - Conform NC - Non-conformance R - Report for Information KEY SIN, ID# MICROSTRUCTURE FIGURE (C/NC/R) 1 -1 A lap-like indication measuring 0.0179" in depth was observed on the ID surface. 1-2 R 1*2 A lap-like indication measuring 0.0251" in depth was observed on the ID surface. 3-4 R 1*3 A lap-like indication measuring 0.0119" in depth was observed on the ID surface. 5-6 R 1*4 A lap-like indication measuring 0.0247" in depth was observed on the ID surface. 7-8 R Date Completed: 8/20/2021 Procedures/Methods: 90-MICR0-1, Rev. 8, Microexamination of Metals MICROSTRUCTURE EXAMINATION APPLICABLE SPECIFICATIONS: Customer's Instructions ETCHANT: As Polished/ 10% Oxalic, Electrolytic MAGNIFICATION: 100X KEY: C - Conform NC - Non-conformance R - Report for Information KEY SIN, IP# MICROSTRUCTURE FIGURE (C/NC/R}

2 -1 A lap-like indication measuring 0.0097" in depth was observed on the ID surface. 9 - 10 R Date Completed: 8/20/2021 Procedures/Methods: 90-MICR0-1, Rev. 8, Microexamination of Metals Page 1 of 16

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  • FAX: 800-219-9096 HEAT NO. N200309AW01 / SHOP ORDER NO. 354874 / 10 MICROSTRUCTURE EXAMINATION APPLICABLE SPECIFICATIONS: Customer's Instructions ETCHANT: As Polished/ 10% Oxalic, Electrolytic MAGNIFICATION:10X - 100X KEY: C - Conform NC - Non-conformance R - Report for Information KEY SIN, ID# M!£ROSTRUCTURE FIGURE (C/NC/R) 3-1 A lap-like indication measuring 0.0102" in depth was observed on the ID surface. 11 - 12 R 3-2 A lap-like indication measuring 0.0265" in depth was observed on the ID surface. 13 -14 R Date Completed: 8/20/2021 Procedures/Methods: 90-MJCRO-1, Rev. 8, Microexamination of Metals No weld repairs were performed on the referenced items.

The provisions of 10CFR21 , 10CFR50, Appendix Band ASME Section 111, NCA-3800 apply to this order.

The services performed above were done In accordance with LTl's Quality System Program Manual Revision 21 dated 5/1/2019 and 1S0/IEC 17025:2017. These results relate only to the items tested and this report shall not be reproduced, except in full. without the written approval of Laboratory Testing, Inc. The services provided on this certificate have been performed in conformance with the customer's purchase order requirements. LT.I. Is accredited by Nadcap for NDT and Materlals Testing for the test methods and specific services as listed In the Scopes of Accreditation available at www.labtestlng.com and www.eAudllNet.com. The results reported on this test report represent the actual attributes of the material tested and Indicate full compliance with all applicable specification and contract requirements. This Is a shared risk decision rule which the customer also has responsibility for determining acceptance of the results.

MERCURY CONTAMINATION: During the testing and Inspection, the product Sherri L. Scheifele did not come In direct contact with mercury or any of Its compounds nor with QA Specialist any mercury containing devices employing a single boundary of containment.

NOTE: The recording of false, fictitious or fraudulent statements or entries on this document may be punishable as a felony under Federal Statutes. Authorized Signature Page 2 of 16

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