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CENTER FOR NUCLEAR WASTE REGULATORY ANALYSES

CORRECTIVE ACTION REQUEST

CAR No. 91-03 Associated AR-SR-NCR NO. AR 91-1
PART 1: DESCRIPTION OF CONDITION ADVERSE TO QUALITY
In accordance with the CQAM, Paragraph 12.4.3(1), thermometers are excluded from the
calibration requirements. However, the listing of Commercial Devices in ANSI/ASME
NQA-1 does not exclude thermometers from calibration and control. ASTM Standard E77-89,
Standard Test Method for Inspection and Verification of Liquid-in-Glass Thermometers,
clearly indicates the need for periodic verification of thermometer accuracy.

Initiated by: R. M. Weber Date: 7/26/91

PART 2: PROPOSED ACTION Responsible Element Manager: H. Garcia
a) Root Cause:
Action Party: B. Mabrito

See Attached.

b) Corrective Action to Preclude Recurrence:

See Attached.

/ i.
for Completion: 9/30/91

Date: 8/1/91
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Comments/Instructions: Bloc

Director of Q
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PART 4: VERIFICATIO FACTIN
ECTIVAIN IMPLEMENAIN
IMPLEENTATIN

Verified by: / Date: !/O/

CNWRA FORM QAP 14-0

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Attachment to Corrective Action Request (CAR) No. 91-03

Associated with AR 91-1

PART 2: PROPOSED ACTION

a) Root Cause:

The Center expanded the generally accepted list of equipment not requiring
calibration to incluoe "ASTM g;,de laboratory (mercury) thermometers." In doing
so, the Center took c>'ANSI/ASME NQA-1, since the listing of Commercial
Devices in ANSI/ASME NQA-1 does not exclude them. This position was taken
because the Center believed that the purposes for which these items are being
used in its nuclear waste work differ significantly from the nuclear reactor
applications addressed in NQA-1. Further evaluation of this position is needed.

b) Corrective Action to Preclude Recurrence:

An evaluation will be conducted to determine (a) the degree of similarity of

operating conditions and concerns which led to the requirements of NQA-1 for
liquid-in-glass thermometry and (b) the specific requirements of ASTM E77-89 for
periodic calibration (as opposed to certification and/or incoming inspection).
Based on the results of such evaluations, it may be necessary to revise the noted
paragraph of the CQAM and/or to issue a procedure for calibration of such
devices.
 UPDATED RESPONSE TO CAR 91-03

After further investigation, the Center QA staff concurs with the audit finding
that the exclusion of thermometers from calibration requirements may present a
risk to measurement validity. The corrective action shall be to delete the
exclusion for thermometers in CQAM Section 12, paragraph 12.4.3 (1). The target
date for completion is 9/15/91.
The use of thermometers in Center experimental activities has been limited to
parameter (temperature) control of reactions, in which the accuracy tolerance is
+ 2 degrees C or more. After calibration, if any thermometers are found out of
tolerance by an amount greater than 2 degrees C, Nonconformance Reports shall be
initiated to determine the disposition of affected experiments on an individual
basis.

Proposed by Date_ _

Approved by Date 2169/

Director of QA