Bulletin 83-06: Nonconforming Materials Supplied by Tube-Line Corporation Facilities at Long Island City, New York; Houston, Texas; and Carol Stream, Illinois

                                                         SSINS No.: 6820   
                                                         OMB No.: 3150-0011 
                                                         IEB 83-06         

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555
                                     
                                July 22, 1983

IE BULLETIN NO. 83-06:   NONCONFORMING MATERIALS SUPPLIED BY TUBE-LINE 
                         CORPORATION FACILITIES AT LONG ISLAND CITY, NEW 
                         YORK; HOUSTON, TEXAS; AND CAROL STREAM, ILLINOIS 

Addressees: 

For action: 

All nuclear power reactor facilities or fuel facilities holding an operating 
license (OL) or construction permit (CP). 

Purpose: 

Power reactor and nuclear fuel facilities received initial notification of 
nonconformities with materials supplied by Tube-Line Corporation (T-L) in 
Information Notice No. 83-07 dated March 7, 1983. This bulletin is being 
issued as a result of the findings from Region IV Vendor Program Branch 
inspections at the T-L facilities at Long Island City, New York; Houston, 
Texas; and Carol Stream, Illinois. It was concluded from these inspections 
that there are potential generic safety implications at plants which either 
have received direct shipment materials furnished by T-L (i.e., pipe 
fittings and flanges) or receive piping subassemblies and other components 
from holders of ASME Certificates of Authorization which incorporate these 
materials. Therefore, we ask all recipients of this bulletin to review the 
information herein for applicability to their facilities and: (1) to take 
appropriate actions to confirm the adequacy of affected components for 
intended service; or (2) submit reports stating that T-L materials received 
from the referenced manufacturing locations will not be used in 
safety-related systems at their facilities. 

Description of Circumstances: 

1.   On December 6, 1982, Capitol Pipe and Steel Products Company (CPSP 
     Co.) sent a letter to the NRC which identified nonconformities with 
     certain materials that they had obtained from T-L and furnished to 
     their customers. In this letter, CPSP Co. identified the customers who 
     had received the T-L materials and stated that the customers had been 
     notified in regard to the material nonconformities. The products 
     identified by CPSP Co. were carbon steel pipe fittings (caps, tees, 
     and elbows) and flanges. The nonconformities identified were shipment 
     from an unapproved nuclear source, failure to 



8306270408 
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     perform required heat treatment, and failure to perform nondestructive 
     examinations in accordance with the applicable provisions of the ASME 
     Code. 

2.   A 10 CFR Part 21 report dated January 10, 1983, was received from the 
     Babcock & Wilcox Company (B&W) which additionally addressed T-L carbon 
     steel materials that had been furnished by CPSP Co. This report stated 
     that certain materials furnished to B&W had been supplied by the 
     Houston, Texas, facility of T-L which was not an approved nuclear 
     supplier per NCA-3800 requirements. It was additionally stated that 
     B&W had performed mechanical testing of four heats of received 
     fittings and flanges and had found that the strength properties in two 
     heats of flange materials were lower than shown on the material 
     certifications; one heat was below the minimum requirement in the 
     procurement specification. Subsequent testing initiated by Carolina 
     Power & Light Company has further identified strength properties in 
     fittings (caps) that were below material specification requirements 
     and differences in chemical analysis from that reported on the T-L 
     Certified Material Test Report. 

3.   Direct inspections by the Region IV Vendor Program Branch have 
     identified discrepant conditions at both the, T-L carbon steel 
     facilities in Long Island City, New York; and Houston, Texas; and the 
     stainless steel facility in Carol Stream, Illinois. Known and intended 
     recipients of these materials are listed in Table 1 - Carbon Steel 
     (see Attachment 2) and Table 2 - Stainless Steel (see Attachment 3). 

4.   As a result of the inspections performed by the Region IV Vendor 
     Program Branch, the following additional pertinent information has 
     been obtained in regard to materials furnished by T-L: 

     a.   Certain carbon steel materials were procured from unsurveyed 
          sources and improperly certified to CPSP Co. and Dravo 
          Corporation, Marietta, Ohio, as having been manufactured in 
          accordance with the quality program which CPSP Co. and Dravo 
          Corporation had audited and approved as meeting the requirements 
          of NCA-3800 in Section III of the ASME Code. Similarly, certain 
          stainless steel materials were procured from unsurveyed sources 
          and improperly certified to customers as having been manufactured 
          in accordance with the requirements of NCA-3800 and referencing 
          the T-L (Carol Stream) ASME Certificate of Authorization No. 
          QSC-435. It was additionally established at T-L (Carol Stream) 
          that the basis for approval of some vendors of materials and 
          services (i.e., heat treatment, NDE, mechanical testing, and 
          chemical analysis) was a self-evaluation form filled out by the 
          vendor. 

     b.   Numerous instances were observed at T-L (Long Island City) in 
          which commercial carbon steel materials (i.e., materials procured 
          solely in accordance with a material specification) had been 
          procured and manufacturing had been completed before the 
          establishment of the T-L quality program. These materials were 
          then furnished to CPSP Co. and Dravo Corporation and improperly 
          certified as being both in accordance with specified Section III 
          of the ASME Code requirements and as having been manufactured in 
          accordance with the quality program 
.

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                                                              July 22, 1983 
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          which these companies had audited and approved as meeting the 
          requirements of Section III of the ASME Code. Similar procurement 
          and certification of commercial stainless steel materials was 
          identified by direct inspection at T-L (Carol Stream). 

     c.   Several 3", 600 lb. ASTM A105 carbon steel weld neck flange 
          forgings (e.g., 362 from T-L Heat Code EUUA and 1480 from T-L 
          Heat Code EKP) which have not been appropriately heat treated 
          have been shipped to various customers (both nuclear and 
          non-nuclear). Similarly, the NRC has been notified that 
          documentation was not available to demonstrate that approximately 
          530 SA-182 stainless steel flanges received the required solution 
          annealing heat treatment. These flanges have been shipped to 
          various customers. 

     d.   Direct inspection has resulted in the current identification that 
          T-L (Carol Stream) furnished 521 stainless steel fittings welded 
          with filler metal to various customers and that vendor 
          documentation for these fittings does not indicate compliance 
          with Section III of the ASME Code requirements in regard to: 

          (1)  Manufacture by a holder of a ASME Certificate of 
               Authorization for an NPT symbol using the ASME accepted QA 
               program. 

          (2)  Use of welders and welding procedure specifications which 
               have been qualified in accordance with the requirements of 
               Section IX of the ASME Code. 

          (3)  Inspection during manufacture by an Authorized Nuclear 
               Inspector and certification by issue and signing of a 
               Partial Data Report Form NM-1. 

     e.   Foreign material manufacturers were surveyed and approved by T-L 
          (Long Island City) representatives as having documented quality 
          assurance programs which were in compliance with the requirements 
          of NCA-3800 in Section III of the ASME Code. Interviews and 
          examinations of available survey/audit records established, 
          however, the following: 

          (1)  Certain manufacturers were approved although they did not, 
               in fact, have documented quality assurance programs. 

          (2)  Other manufacturers were approved although their documented 
               quality assurance programs were not available in the English 
               language and the auditors were unable to read the applicable 
               quality assurance manuals. 

          (3)  Certain manufacturers were maintained on the Qualified 
               Supplier List after identification that previous 
               surveys/audits had improperly stated that the documented 
               quality assurance programs were in full compliance with the 
               requirements of NCA-3800 in Section III of the ASME Code. 
.

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                                                              July 22, 1983 
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     f.   Materials were procured for T-L (Long Island City) without 
          specification of the applicable nondestructive examination (NDE) 
          requirements contained in Section III of the ASME Code. 
          Subsequent purchase orders to NDE subcontractors referenced 
          either that only commercial NDE was required or specified that a 
          paragraph in section III of the ASME Code was applicable without 
          reference to or assuring use of an approved NDE procedure. 
          Failure to assure use of approved subcontractor NDE procedures 
          was also identified at T-L (Carol Stream). It was further 
          established that T-L (Carol Stream): (1) failed to have records 
          demonstrating that UT and PT was performed; (2) had no records of 
          eye examinations being given to their level II examiner; (3) 
          failed to have qualification records of their NDE subcontractor's 
          personnel; and (4) did not address acceptance criteria in their 
          PT procedure. 

5.   Tube-Line Corporation representatives, in a letter to Region IV dated 
     April 8, 1983, stated they would send letters to all identified 
     end-users of their carbon steel products in nuclear facilities. The 
     letters would request meetings with the affected end-users to 
     determine whether the products met the necessary requirements, or to 
     determine whether upgrading or replacements are necessary. 
     Additionally T-L, in letters to Region IV (dated April 25, April 27, 
     May 3, May 6, and May 13, 1983), stated they would send letters to the 
     identified end-users of their stainless steel products of concern. 

6.   The information available to date indicates that T-L started supplying 
     ASME Code components to the nuclear industry in 1981. 

Actions To Be Taken by Holders of Operating Licenses or Construction 
Permits: 

1.   Review the lists of purchasing and receiving companies given in 
     Attachments 2 and 3 and determine if any T-L supplied ASME Code 
     materials have been furnished to your facility. The lists of 
     purchasing and receiving companies given in Attachments 2 and 3 have 
     been developed based on correspondence from T-L and inspections at 
     T-L; however, NRC has not verified the completeness of these lists. 

2.   For ASME Code materials furnished by T-L which are either not yet 
     installed in safety-related* systems at your facility or are installed 
     in safety-related systems of plants under construction, the following 
     actions are requested: (Perform action a and either action b or c) 

     a.   Provide a list of T-L supplied materials and identify the systems 
          in which these materials are/will be installed. 


*For the purpose of the applicable actions of this bulletin "safety-related" 
constitutes those systems covered by the definition given in 10 CFR Part 
100, Appendix A Sections III.(c)(1), III.(c)(2), and III.(c)(3). In 
assessing the impact of T-L supplied materials in other systems at their 
facilities, licensees should consider the provisions of GDC 1 to 10 CFR Part 
50 Appendix A. 
.

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                                                              July 22, 1983 
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     b.   Implement a program which provides assurance that received 
          materials comply with ASME Code Section III and applicable 
          procurement specification requirements, or which demonstrates 
          that such materials are suitable for intended service. This 
          program should include specific verification that received 
          austenitic stainless steels are in a nonsensitized condition. 

     c.   Replace fittings and flanges with materials which have been 
          manufactured in full compliance with ASME Code Section III and 
          the applicable procurement specification requirements. 

3.   For ASME Code materials furnished by T-L which are installed in 
     safety-related* systems in operating plants, the following actions are 
     requested: 

     a.   Provide a list of the T-L supplied materials and identify the 
          systems in which the materials are installed. 

     b.   Implement a program as discussed in 2b or 2c above. 

     c.   Provide a basis for continued plant operation if the program 
          requested by Item 3b has not been completed by the time of the 
          bulletin response. 

4.   Provide a written report within 120 days of the date of this bulletin 
     that either: 

     a.   States that no T-L supplied materials have been furnished for 
          your facility for use in safety-related systems. 

     b.   Provides the results of those actions taken in response to Items 
          2a, 2b, and 2c above, as they apply to materials not yet 
          installed and to materials installed in plants under 
          construction. The report should include your plan and schedule 
          for completing actions 2b and/or 2c. 

     c.   Provides the results of those actions taken in response to Items 
          3a, 3b, and 3c above, as they apply to materials installed in 
          operating plants. The report should include your plan and 
          schedule for completing item 3b and your basis for continued 
          operation if item 3b has not been completed. 

     Although the specific details involving the nonconforming materials 
     supplied by T-L may not directly apply for your facility, you are 
     requested to review the general concerns expressed in the bulletin for 
     applicability at your facility. Your response should describe the 
     results of the review, and if the general concerns apply, you should 
     describe the short-term and long-term corrective actions to be taken 
     and the schedules thereof. 


*For the purpose of the applicable actions of this bulletin "safety-related" 
constitutes those systems covered by the definition given in 10 CFR Part 
100, Appendix A Sections III.(C)(1), III.(c)(2), and III. (c)(3). In 
assessing the impact of T-L supplied materials in other systems at their 
facilities, licensees should consider the provisions of GDC 1 to 10 CFR Part 
50 Appendix A. 
.

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                                                              July 22, 1983 
                                                              Page 6 of 6  

The written reports required by Items 4a, 4b and 4c above shall be submitted 
to the appropriate Regional Administrator under oath or affirmation under 
the provisions of Section 182a, Atomic Energy Act of 1954 as amended. In 
addition, the original copy of the cover letters and a copy of the reports 
shall be transmitted to the U.S. Nuclear Regulatory Commission, Document 
Control Desk, Washington, D.C. 20555 for reproduction and distribution. 

This request for information was approved by the Office of Management and 
Budget under clearance number 3150-0011. 

Although no specific request or requirement is intended, the following 
information would help the NRC evaluate the cost of implementing this 
bulletin: 

1. Utility staff time to perform requested inspections and evaluations. 

2. Radiation exposure attributed to requested inspections. 

3. Utility staff time spent to prepare written responses. 

If you have any questions regarding this matter, please contact the Regional 
Administrator of the appropriate NRC Regional Office, or the technical 
contact listed below. 


                                   Richard C. DeYoung, Director 
                                   Office of Inspection and Enforcement 

Technical Contact:  J. R. Fair, IE
                    (301) 492-4509

Attachments:
1.   List of Recently Issued IE Bulletins
2.   Table 1 - Listing of known and intended recipients of Tube-Line
     Corporation furnished carbon steel materials
3.   Table 2 - Listing of known and intended recipients of Tube-Line
     Corporation furnished stainless steel materials