ML19260C263
| ML19260C263 | |
| Person / Time | |
|---|---|
| Issue date: | 08/16/1979 |
| From: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Amidon W ITT GRINNELL INDUSTRIAL PIPING, INC. (SUBS. OF ITT |
| Shared Package | |
| ML19260C234 | List: |
| References | |
| REF-QA-99900019 NUDOCS 7912260130 | |
| Download: ML19260C263 (2) | |
Text
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UNITED STATES
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[k NUCLEAR REGULATORY COMMISSION a'
.p REGION IV 611 RYAN PLAZA DRIVE, SUITE 1000 D
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16 AUG 1979 Docket No. 99900019/79-01 s.
ITT Grinnell Industrial Piping, Incorporated Atta: M. W. C. Amidon, President Post Office Box 566 Kernersville, North Carolina 27284 Gentlwn:
Thank you for your letter of July 13,1979, in response to our letter dated April 2,1979. As a result of our review, we find that additional information is needed on the following items:
A.
Your response describes corrective action for the reported finding but fails to provide steps to preclude recurrence, either for the specific cited condition, or, in the more general sense that was requested by the transmittal letter for Inspection Report No. 79-01.
ITT Grinnell was informed by Gibbs and Hill Specification No. 2323-MS-43A that fabrication and testing should be in accordance with Regulatory Guide 1.44.
Paragraph 3.7.3.9 in the same specification additionally required performance of a solution annealing heat treatment, if austen-itic stainless steel was subjected to temperatures above 800 F during fabrication. We therefore cannot accept any premise that ITT Grinnell Industrial Piping, Inc. (GCO) was inadequately informed on Comanche Peak quality requirements with respect to sensitization of austenitic stainless steel.
It is apparent from your response, that the absence of a specific require-ment in the Bending and Forming Section of Specification No. 2323-MS-43A Revision 3, for the perform 4 ace of solution annealing heat treatment on hot bends made to a radius of five (5) or greater pipe diameters, was recognized by GCO. What concerns us greatly i, that the GCO methods and practices for establishing customer quality requirements, would permit, in a matter of potential safety significance, reliance solely on a telephone conversation with your customer.
No information has been provided to us, that indicates at any point prior to the last NRC inspection, you sought formal resolution of this matter with your customer, as provided for by paragraph 3.3 of Specification No. 2323-MS-43A Revision 3.
Your response has not alleviated this concern.
In addition, it is requested that you supply a copy of the customer documentation received by you on February 28, 1979, which you referenced in your response as confirming exemption froa a solution annealing require-ment for hot-bends made to a radius of five pipe diameters and greater.
During the February 26 - March 1, 1979, inspection, the NRC inspector saw no customer documentation, nich clearly exempted CCO from this heat treatment requirement.
616 119 7912 260
ITT Grinnell Industrial 2
Piping, Incorporated B.
Your response provides acceptable corrective action measures for the affected assembly, but fails to provide adequate steps to preclude recurrence, in that:
1.
Your internal corrective actions addressSection III requirements and not the cited failure of personnel to comply with applicable centrnet specification requirements.
2.
Your response does not address the QC acceptance of a furnace chart and load sheet, which was not in conformance with speci-fication requirements.
C.
Please describe hcw the stated instruction of production personnel was docesented, to provide an auditable record of corrective action.
D.
Please provide a date by which determination and submittal of pro-posed corrective actions will be completed.
It is also requested that you clarify your steps to preclude recurrence with regards to mechanism to be used for assuring supply of complete information to
- Quality Assurance and the relevance of purchase orders with respect to internal testing programs.
Please provide th[s $ddItional information within twenty (20) days in order that we may complete our review in a timely manner.
Sincer y,
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l Karl V. Sey Director
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