ML19309F305
| ML19309F305 | |
| Person / Time | |
|---|---|
| Issue date: | 02/22/1980 |
| From: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gussman M MARVIN ENGINEERING CO., INC. |
| Shared Package | |
| ML19309F295 | List: |
| References | |
| REF-QA-99900338 NUDOCS 8004290179 | |
| Download: ML19309F305 (3) | |
Text
_ _ __.
/
'c, UNITED STATES
!t
- i. y j NUCLEAR REGULATORY COM' MISSION 3
REGION IV
- #(
[
611 RYAN PLAZA oRIVE, SUITE 1000
,f ARLtNGToN, TEXAS 76012 2 2 FEE to80 Dockat No. 99900388/79-01 Marvin Engineering Co., Inc.
Aten:
Mr. M. Gussman President 251 West Beach Avenue Inglewood, California 90302 Gentlemen:
Thank you for your letter of January 11, 1980, in response to our letter dated October 25, 1979. As a result of our review, we find that additional information is needed on the following items in the Notice of Deviation:
Item 3.
Please clarify whether your response to this item indicates that all welding operations on Job No. 1805 were signed off for the actual welders by Hung Nguyen, and, that the twenty-eight dis-crepancies observed were the result of errors in perfor=ing this function.
If so, please identify what specific actions were taken to assure this individual was conversant with the documentation requirements of your manufacturing process control system.
Item 6.
Please describe how the referenced meetings were documented, in order to provide an auditable record of corrective action.
Item 7.
Please describe how notification of stop work authority to in-process inspectors was documented, in order to provide an auditable record of corrective action.
Item 9.
Your response fails to provide any specific corrective actions relative to the specific current employees cited in this finding.
Item 16.
Your response states that weld procedure specification (WPS) ME-WP-7 revision 0 was used for operations 50 and 90 of Mo 447 for Job 1805 and the welder was E. Hertel.
Please provide the means by which the above was ascertained in view of the fact the MO states welding was performed by Manule on January 6, 1979, using WPS ME-WP-4, and only 4 welder's daily chics could be found for this job, none cf which were applicable to operations 50 and 90 of MO 447.
Additionally, please provide the status of CE's review / approval of ME-WP-7.
l 800.4290179
Marvin Engineering 2
Item 13.
Your response refers us to your response 12b.1, which. in turn refers us to response 11.1, in which.you state in part, ".
In order to be able to completely ensure the acceptability of Job 1805's six (5)(sic) fuel grapples, MEC is presently going through a completely documented reinspection of the grapples as approved by GE.
Estimated date of completion is February 28, 1980." Response 12b.1 states in part, ".
In order to ensure acceptability MEC will again perform all final NDE vich the re-inspection as stated in response 11.1...."
These responses deal only with Job 1805.
Item 18 addresses Job Nos. 1805, 1349, and 24dOA.
Please advise us as to the means by which you will completely ensure the acceetability of Job Nos.1349 and 2480A, the =ethod of documentation, and the dates by which this will be accomplished.
Further, you did not address the sign-off by 3 unqualified personnel showing performance of NDE on Job 2480A, operation number 400.
Item 23.
Your response indicates that liquid penetrant examination of root passes on Job 2480A are in-house requirements, except for one area per assembly, which is a GE requirement.
Please provide us with a copy of GE requirement which specifies just one root pass area per assembly be liquid penetrant examined.
Item 24 Your response is not totally accurate regarding who is to be notified when Notification Points are reached during fabrication, and GE not providing written vaivers.
GE purchase order 205-AL 709 imposed the following quality re-quirements on MEC: QAR II revision 1; NL 272 AE revision 0, and QA Supplement 28 revision O.
QAR II paragraph 2 states in part, " Buyer - In this document Buyer is the General Electric Company, Nuclear Energy Systems Division.
Customer - In this document, Customer is 3uyer's client."
QA Supplement 28 paragr4. 4 states in part, "... Each notification point will be identified as a '3uyer' or a ' Customer' notification point.... Seller shall notify 3uyer's Quality Control Representat-ive or Suyer's San Jose Quality Control office.
For 'Cuscocer' points, Seller shall also notify 3uyer's Quality Control Office in San Jose, California, by IWX (or equal).
' Customer' notifi-cation and other identified special events shall not proceed without vitness or written vaiver from Suyer's Quality Control."
1 j
Marvin Engineering 3
NL 272A paragraph 1. states in part,
... Customer Events Cannot Proceed Withoet Witness or Written Waiver from Suyer's Quality Control." Paragr:tph 3. states in part, "~'he Specialist, Quality Notifications, will advise seller by return wire.
whether 3uyer's Quality Control Representative (and Utility Customer, as applicable), will witness the event or that witnessing of the event is waived."
Therefore, it would appear that your actions to prevent recurrence will not be adequate if a delineation is not nade to differentiate between buyer and customer notification points.
Please provide the neans by which you will control this different-1ation and the date of implementation.
We have no further questions at this time regarding your responses to the Notice of Violation and items 1, 2, 4, 5, S, 10, 11, 12, 13, 14, 15, 17, 19, 20, 21, 22, 25, 26, and 27 in the Notice of Deviarion.
Please provide this additional information within twenty (20) days in order that we nay complete our review in a timely nanner.
Sincerely,
/
, - fb d L
'r/% Karl 7.(Seyfrit Directed l
l l
I l
l t
l l
_ l