ML20006B112
| ML20006B112 | |
| Person / Time | |
|---|---|
| Issue date: | 03/27/1989 |
| From: | Baker E, Petrosino J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20006B106 | List: |
| References | |
| REF-QA-99900094 NUDOCS 9001310431 | |
| Download: ML20006B112 (17) | |
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ORGANIZATION: MASONEILAN-DRESSER AV0N, MASSACHUSETTS REPORT INSPECTION INSPECT 10ll NO.: 99900094/88-01 DATE: December 12-16, 1988 OH-SITE HOURS: 87 CORRESPONDENCE ADDRESS: Masoneilan North American Operations Dresser Valve and Control Division j
Dresser Industries, Incorporated 85 Bodwell Street Avon, Massachusetts 02322 GRGANIZATIONAL CONTACT: Mr. William T. Allen Ill, Quality Manager TELEPHONE NUMBER:
(508)586-4600 NUCLEAR INDUSTRY ACTIVITY: The Dresser Valve and Control Division of i
Masoneilan North American Operations, Dresser Industries, Incorporated (Masoneilan-Dresser),manufacturesASMESectionIIIvalvesandreplacement parts.
ASSIGNED INSPECTOR:
/
'7/ M e
.2 7'f J. J. Petrosino, Reactive Inspection Section No. I ae (RIS-1)
OTHER INSPECTOR (S): Mr. T. L. Tinkel, Sonalysts, Incorporated Mr. C. J. Carroll, Sonalysts, Incorporated APPROVED BY:
M T[E
'v if E. T. Baker, Section Chiet, RIS-1, Vendor Inspection e
Branch INSPECT 10ll BASES AND SCOPE:
A.
BASES:
Appendix B to 10 CFR Part 50, Section 111 of the ASME Boiler and Pressure Vessel Code and 10 CFR Part 21.
B.
SCOPE:
This inspection was performed as a follow-up to an October 21, ITELG 10 CFR Part 21 report from Consumers Power Company regarding valve internal replacement parts that were found in Masoneilan-Dresser (HD) valves,'but were not manufactured by authorized MD facilities.
PLANT SITE APPLICABILITY: All sites.
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9001310431 900122 PDR OA999 EMVDRSI 9990009A PDC
.' ORGANIZATION: MASONEILAN-DRESSER AVON, MASSACHUSETTS REPORT INSPECT 10ll NO.: 99900094/88-01 RESULTS:
PAGE 2 of 17 A.
VIOLATIONS:
1 1.
Contrary to Section 21.21, " Notification of failure to comply or L
existence of a defect," it was identified that the MD 10 CFR Part 21 procedure (236-M-174, Revision B, dated May 2, 1987),
requires individual employees to notify their supervisors of deviations or nonconformances only after the individual employees have determined that a " substantial safety hazard" exists. Addi-ticnally, the procedure states an incorrect definition of the 10 CFR Part 21 term " substantial safety hazard" (88-01-01).
ThisisaSeverityLevelVviolation(SupplementVII).
I B.
NONCONFORMANCES:
1.
Contrary to Criterion IV, " Procurement Document Control;" Criterion Vll, " Control of Purchased Material, Equipment and Services " of Appendix B to 10 CFR Part 50; Section 4. " Nuclear Procurement Con-trol" of Revision J of the MD Nuclear QA Manual, and Sections QS2.2 and QS4, " Order Management and Procurement Control " of Revision G of theMDCommercialQAManual(88-01-02):
a.
MD failed to ensure that adequate quality requirements were included or referenced on its P0 documents to the contractors listed below even though the requirements of Appendix B to-10 CFR Part 50 and ANSI N45.2 were-imposed on MD by the applicable licensee P0's listed below, and.
b.
'MD failed to ensure that its measures to control the P0s listed included adequate provisions to use a MD approved supplier, have objective evidence of the quality.of the hardware, and perform receipt inspections of.the hardware.
Consumers Power Carpenter PV-00016 Company 1007-9218-Q Consumers Power flasoneilan-56859 Company France 56846 2003-0106-Q 56964-E
1 ORGANIZATION: MASONEILAN-DRESSER l
AVON, MASSACHUSETTS REPORT INSPECTION NO.: 99900094/88-01 RESULTS:
PAGE 3 of 17 Licensee /PO Vendor MD PO Consumers Power Boston B45-V23119 Company Centerless s
1007-8545-Q Public Service Boston 18279 Gas and Electric Centerless P2-205090 Commonwealth Edison Boston A10-PV22955 427281 Centerless C,
UNRESOLVED /0 PEN ITEMS:
1.
QA Program Control The inspector's observations and discussions with MD personnel appear to indicate that MD has failed to correctl ANSI N45.2 and Appendix B quality assurance (QA) y implement its program require-ments for parts or components that are exempt or outside the scope of Section III of the American Society of Mechanical Engineers (ASME)BoilerandPressureVesselCode(SectionIII). The majority of safety-related internal valve replacement parts are not pressure retaining and are therefore categorized as exempt from or outside the scope of Section III (e.g., valve stems, seat rings, cages and l
pins).
For those components and parts within the sco)e of Section III the NRC has accepted Section III as meeting tie intent of Appendix B.
However, nuclear safety-related parts and components exempt from or outside the scope of Section III are, required to be manufactured and controlled under a QA program that meets the intent of Appendix B to 10 CFR Part 50. MD does not appear to be in compliance with this requirement. However,.NRC inspectors-did not complete their review of this issue. Therefore, this issuewillbecategorizedasunresolveditem(88-01-03).
2.
Valve Actuator Sizing l
The NRC inspectors briefly reviewed the methodology by which MD sizes its automatic valve actuators with emphasis on accounting for friction between the valve stem and the' stem packing. Since this review was not completed, this issue will be categorized as an unresolveditem(88-01-04).
j ORGANIZATION: MASONEILAN-DRESSER-AV0N, MASSACHUSETTS
{
1 REPORT INSPECTION NO.: 99900094/88-01 RESULTS:
PAGE 4 of 17 s
D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
3 Not reviewed during this inspection.
E.
INSPECTION FINDINGS AND OTHER COMMENTS:
1.
Entrance and Exit Meetings The NRC inspection team informed the MD staff of the scope of the inspection during the entrance meeting conducted on Decenber 12, 1988 and summarized its findings and concerns at the December 16, 1988 exit meeting. The scope.of the inspection included:
review of the circumstances re 21, 1988 Consumers Power Company (CPC) garding the October a.
10 CFR Part 21 report; b.
review of the MD valve distributcr network; reviewoftherelationship(withsub-tiermanufacturerssuchas c.
Control Valve Specialties CVS)andCor-Val;and d.
obtaining information-regarding differences that may be found between spare parts from the original equipment manufacturer versus secondary sources, and MD's manufacturing methodologies and controls.
===2.
Background===
The CPC 10 CFR Part 21 report, dated October 21, 1988, identified sus)ect MD valve internal replacement parts that were found in a MD tur)ine bypass valve installed at CPC's Palisades nuclear plant facility. The CPC report identifies approximately 65 valve trim-parts that were manufactured by vendors not' recognized by MD as being authorized to manufacture MD valve trim parts., The circum-stances of this matter are discussed in more detail-in NRC InformationNotice(IH)88-97.
On December 16, 1988, the inspectors became aware of additional information that CPC identified to the Region III NRC staff which was submitted by CPC as supplemental information to the 10 CFR Part 21 report on December 22, 1988. The supplemental information stated, in part, that 6 of 97 valve pins examined were nonconforming in that they have undersized expanded diameters.
ORGANIZATION: MASONEILAN-DRESSER AVON, MASSACHUSETTS REPORT INSPECTION NO.: 99900094/86-01 RESULTS:
PAGE 5 of 17 Five of these items were supplied by Masoneilan's Houston, Texas facility and the remaining item was supplied from H. H. Barnum, a previously authorized Masoneilan distributor.
Additionally,
)
7 of 51 seat rings examined were nonconforming regarding manufacturing tolerances.
The manufacturer of five of these items has not yet been identified. The two remaining, purchased in 1978, were manufactured by CVS. CVS was an authorized MD manufacturer and distributor in 1978.
3.
10 CFR Part 21 Implementation Py MD a.
The inspector reviewed MD Procedure Number 236-M-174, Revision B, " Compliance with Federal Regulation 10 CFR Part 21," dated May 5, 1987.
Some noted inconsistencies are as follows:
(1) Part 21 defines the term, substantial safety hazard, as "a loss of safety function to the extent that there is a major reduction in the degree of protection provided to public health and safety for any facility or activity licensed... pursuant to...."
The procedure incorrectly defined
" substantial safety hazard" as "Possible exposure of personnel to 25 rems or more of radiation, and/or the release of radio-active material in concentrations which over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would exceed allowable limits." While these two examples are listed in NUREG-0302 under the definition of substantial safety hazard, other more pertinent examples are also listed under the definition, i.e., exceeding a safety limit as defined in the i
facility technical specifications; (2).The procedure requires l
individual employees to notify their supervisors of defects or noncompliance only after the individual employee has determined that a substantial safety hazard exists. This rioes not address the situation where an employee cannot make that determination and the deviation must be referred to the customer for evalua-tion; and (3) The procedure does not address Section 21.31,
" Procurement Documents," of 10 CFR Part 21 (i.e., assuring that P0s issued by MD, specify 10 CFR Part 21 if applicable).
l The inspector concludes that the MD 10 CFR Part 21 implementing procedure is inadequate to assure that potentially reportable deviations are identified to management or that a potentially reportable problem is identified to the customer or licensee so that they may cause an evaluation to' be performed.
Violation 88-01-01 was identified in this area.
ORGANIZATIONS MASONEILAN-DRESSER AV0N, MASSACHUSETTS REPORT INSPECTION NO.: 99900094/88-01 RESULTS:-
PAGE 6 of 17 i
4.
Purchased Material The inspection team review of procurement packages for safety-related valve internal replacement parts and discussions with MD personnel identified seme inconsistencies in the method in which MD implements its program.
Discussions with MD quality assurance / quality control (QA/QC) personnel revealed that QC does not perform receipt inspection activities on bar stock material that may be used for the fabrication of safety-related parts and components with the exception of bar stock designated for'Section III use.
It was of heat code numbers (personnel are not involved in the transferi.e., materia also noted that QA/QC stock cutting process or verification of the transfer, with the exception of material identified as-Section Ill valve-body or bonnent material. The review of this area was not completed during the inspection and will be reviewed in more detail during a future inspection. As a result unresolved item 88-01-03 was identified.
Another inconsistency was that MD fails to pass on QA requirements of Appendix B to 10 CFR Part 50, ANSI N45.2, or Section III requirements imposed on them when purchasing either material to fabricate valve internal parts or to purchase safety-related valve internal replacement parts.
It was noted that HD neither passes on nor requests any specific quality. assurance program l
requirements from its sub-tier vendors or requires that the sub-tier vendor be on the MD approved supplier list. As discussed above, MD does not require its QA/QC personnel to perform receipt inspections or test materials that are received with the exception of material ordered for use in Section 111 valve body and bonnet fabrication.
Several PO packages (listed below) were identified for safety-related -
parts that were not processed in accordance with Appendix B to 10 CFR Part 50 although Appendix B was imposed by the customer.
As a result Nonconformance 88-01-02 was identified during'this part of the inspection.
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I ORGANIZATION: MASONEILAN-DRESSER AVON, MASSACHUSETTS PEPORT INSPECTION NO.: 99900094/88-01 RESULTS:
PAGE 7 of 17 i
Licensee /PO Vendor MD PO Footnote Consumers Power Co.
Carpenter PV-0016 1007-9218-Q (July 31, 1987)
Consumers Power Co.
Masoneilan 56859 1
2003-0106-Q France 56846 1
(December 8,1987) 56964 1
Consumers Power Co.
Boston B45-V23119 2
1007-8545-Q Centerless (June 24,1987)
Public Service Boston 18279 Gas and Electric Centerless P2-205090 (April 8, 1967)
Comonwealth Edison Boston A10-PV22955 4
427281 Centerless (March 30,1987) t 5.
QA Program Review MD has established and uses two types of QA manuals (QAMs) to control the operations at its Avon facilities. -For Section III work activities, MD uses its nuclear QAM (NQAM), while non-Section III activities are covered by the MD comercial QAM (CQAM). Additionally, MD has a "near-nuclear" (NN) program which i
l uses portions of both QAM's.
I I
The nuclear program is currently governed by Revision J of the NQAM, I
dated June 1, 1987. The NQAM appears to comply with ASME Section III I
TherewasnoobjectiveevidencethatMD(France)wasanapprovedsupplier.
Also, the P0 document used to obtain the material was not available for review. The MD engineer stated that this document would not be retained.
2 The plug, stem, and pin were not ordered by the Consumers Power Co., P0.
However, MD supplied t:- additional parts and certified them to the P0 requirements. MD's P0 to Boston Centerless was not available because it was a commercial order and therefore not retained.
i
ORGANIZATION: MASONEILAN-DRESSER AVON, MASSACHUSETTS REPORT INSPECTION NO.: 99900094/88-01 RESULTS:
PAGE 8 of 17
)
for Code items (i.e., pressure retaining as defined by the ASME 1
Code). When Appendix B of 10 CFR Part 50 is imposed without the requirements of Section 111, the NQAM states that Appendix L, ANSI N45.2 and ASME controls are implemented for manufacturing safety-related non-Code parts as agreed upon by MD and the purchaser.
The NQAM states that non-Section 111 material for use in safety-related items is controlled by the CQAM.
Addendum 1 to the NQAM defines the MD NN QA program. Addendum I states that the NH QA program is used to manufacture safety-related items required to meet Section III requirements with the exception of applying the "h" stamp.
Under the NN QA program, the provisions of the NQAM (less requirements for "N" stamp certification) are used to control the manufacture of pressure retaining parts. Addendum I also states that the non-pressure retaining parts are supplied in accordance with the CQAM.
However, it should be noted that Noncon-formance 88-01-02 indicates failures by MD to effectively implement a portion of its CQAM. Unresolved item 88-01-03 also discusses deficiencies in the overall MD program control.
The coninercial quality assurance program is currently governed by Revision G of the CQAM, dated July 1, 1988. The previous revision of the CQAM, Revision F, is dated December 2, 1985. Revision F states that the commercial QA program meets the requirements of Appendix B to 10 CFR Part 50, ANSI N45.2, MIL-Q-9858A, and MIL-I-45208A for safety-related com)onents as agreed upon by HD and the purchaser.
Revision G of tie CQAM does not state that it meets any QA standards or specifications, i
In conclusion, it appears that MD has either relaxed, removed, or has not adequately imposed Appendix B type QA program controls over the MD activities regarding procurement, receipt inspection, l
and manufacturing processes for components that can be used in l
nuclear safety-related applications other than items designated I
asSection III pressure boundary items.
Unresolved item 88-01-03 addresses this issue in part.
6.
Secondary Source Manufacturers The October 21, 1988, 10 CFR Part 21 report from CPC identified several secondary source manufacturers.
One such manufacturer that was identified to the NRC was CVS of Houma, Louisiana.
CVS was licensed by and contracted to MD from approximately September 1, 1975 until September 14, 1980 as an authorized manufacturer and I
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ORGANIZATION: MASONEILAN-DRESSER AV0N, MASSACHUSETTS REPORT INSPECTION l
NO.: 99900094/08-01 RESULTS:
PAGE 9 of 17 supplier of MD products. MD stated that.it terminated all business relations with CVS in the 1980 time period and requested that all of its component drawings be returned. MD also stated that CVS did not return all of the MD drawings as requested. However. it was noted by the inspectors that MD hes been routinely procuring components from CVS after the 1980 contract termination date, and is currently procuring carbide tipped valve plugs from CVS. Approximately eight orders were placed with CVS by MD in 1988. These orders appear to be all nonsafety-related.
i The following is a summary of some of the information provided by HD to the inspection team regarding CVS:
a.
In the mid-1970's, MD experienced some difficulty meeting required delivery schedules for customer spare parts due to many large orders in-house and because material was in short supply. CVS was apparently contracted as a licensed distri-butor and service representative for MD from September 1, 1975 until termination of the agreement on September 14, 1980 and was allowed to manufacture spare parts on an emergency basis for Masoneilan valves.
l b.
The MD Midwest Regional Sales Manager stated the primary l-function for CVS was to provide replacement valve parts for the petro-chemical industry located in the Texas-Louisiana area.
CVS was not authorized to manufacture and sell valve parts to the nuclear power industry.
Further, MD. sales representatives were not authorized to buy replacement valve parts from CVS for the nuclear power industry.
(Note: MD was not able to find a copy of its agreement with CVS. Therefore, the NRC inspector has not reviewed any of the contractual requirements discussed here),
c.
The MD Sales Manager elso stated that on some occasions MD gave tacit approval to MD sales representatives to buy replacement valve parts from secondary sources. This-occurred when MD could not provide parts within the time required by the customer. MD l
sales representatives were then allowed to obtain parts from other sources.
d.
As a result of the CPC 10 CFR Part 21 report, MD has initiated a l
plan to audit MD sales representatives to identify instances l
where parts were procured from secondary source manufacturers
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ORGANIZATION: NASONEILAN-DRE.SSER AV0N, MASSACHUSETTS REPORT INSPECTION N0.: 99900094/88-01 RESULTS:
PAGE 10 of 17 and supplied to nuclear power plants. The QA Manager stated that he will notify the NRC of any problems similar to those identified in the Part 21 report.
7.
MD Valve Trim Component Identification / Control a.
Identification - The folicwing information was obtained'during discussions with the MD personnel regarding identification of_
-its valve internal replacement parts (valve trim):
(1) Each MD valve assembly is identified by a unique serial number. This serial number corresponds to a P0 number, which tracks the specifications and requirements for the original valve.
If the first two. numeric digits of the order number are 44, the order was processed under the commercial QA program.
If the first two numeric digits are 40, the order was processed under the near-nuclear QA program.
Order numbers starting with an N indicate the order was processed under the nuclear QA program and met the requirements of Section 111 or the draft pump and valve code.
(2) MD does not need a customer name to identify a part number to provide a replacement part.
The correct-replacement-4 -
part number can be identified by MD if they know the origi-nal valve serial number and the part name or description.
4 b.
Part Number Control - The following MD policy and procedures regarcing part number control were discussed:
l (1) Policy and Procedure - The MD procedure for revising l
engineering documents, entitled " Revisions-Basic Practice,"
DMR-3-3, Revision E, dated July 27, 1982 was reviewed.
i The procedure is applicable to revising engineering documents such as drawings and associated parts' lists.
The term revision is applied to any change after offi-cial release of an original drawing, parts list, or com-puterized method to generate the particular documents.
4 i
The basic policy is that any change to any part or assembly that affects form, fit, function, or process that forces the part to be non-interchangeable with previous parts requires assignment of a new part number.
Parts are m
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ORGANIZATION: MASONEILAN-DRESSER 1
AV0N, MASSACHUSETTS j
-1 4
REPORT INSPECTION NO.: 99p00094/88-01 RESULTS:
PAGE 11 of 17 1
considered to be interchangeable if they possess such i
functional and physical characteristics as to be equivalent in performance and. durability and capable of being exchanged one for the other without alteration of the items themselves.
(2) Part Numbering Systems - An attempt was made to obtain some historical perspective about the part numbering systems used by MD since-the late 1960's. No procedure describes i
the system but, the following information was obtained from a MD Nuclear Product Engineer who has been with MD for.
over 30 years:
(a) MD part numbers consist of 12 digits. The last three digits represent the material code for the part. The material codes for comercial parts (i.e., no special
~
requirements) are represented by combinati.ons of three numeric digits. The material codes are explained-in a MD Material Code-Index.
(b)
In the late 1960's, MD_ began using material code-numbers 779 and 780 to distinguish parts that were i
subject to special requirements and controls. A 779 code identifies a comercial part that is subject to additional special requirements. This code means,
" refer to the parts list." Depending on the require-ments, the parts might be handled in accordance with either the nuclear or comercial-QA programs. A 780 code identifies a comercial part that is subject to additional special requirements and is handled in accordance with the near-nuclear quality program.
(c) With the introduction of ASME Section III, MD adopted material code 781. This code is used-for items pro-duced ir accordance with the nuclear QA program and l
Section III for both N stamp and non-N stamp items.
Note:
These "special requirements" are usually not identified outside of MD.
(3) Alpha-Nutheric Codes - In 1983 MD adopted an alpha-numeric material code for special material and material require-4 ments not covered by the MD Material Code Index. This system replaced the previously used codes 779, 780, and 781.-
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ORGANIZATION: MASONEILAN DRESSER AVON, MASSACHUSETTS REPORT INSPECTION NO.: 99900094/88-01 RESULTS:
PAGE 12 of 17 The system for using three nuatric digits for commercial part material codes was not changed. The alpha-numeric j
material code systeu is explained in E.S. 420, dated December 16, 1903. This document states:
(a) Alpha-numeric material codes are assigned to special material, special material requirements, i
non-destructive examinations, special welding procedures, mercury free processing, customar approval of weld repair, acid spot testing, and chemi:a1 and physical documentation not covered by the material code index.
(b) Comercial requirements have an alpha code in the l
10th position of the part number (1st digit of the materialcode).
l (c) Nuclear requirements have a numeral in the 10th position followed by an alpha character in either the lith or 12th position of the part number (2nd and3rddigitofthematerialcode).
(4) Parts List - The parts list Revision D, for a 20,000 5eries,4-inch,900-psi,valvewasexaminedtoreviewan example of the implementation of the current MD part number system. Tie parts list identified various part numbers, drawings numbers (for Section !!! parts), pcrt descriptions, quantities, and material specifications for each of the items in the valve assembly. The following parts were identified with an asterisk indicating material shall be manufactured and certified in accordance with the requirementsofArticleNC-2000(Class 2)forSection111.
Body Body Studs and Nuts Plug Bonnet and nipple l
The external valve parts were identified with a nuclear l
alpha-numeric material code.
The remaining parts were identified with a three digit numeric material code l
indicating the parts are to be comercial grade.
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OR(,ANIZATION: MASONEILAN-DRESSER AV0H, MASSACHUSETTS REPORT INSPECTION j
NO.: 99900094/88-01 RESULTS:
PAGE 13 of 17
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i 8.
Differences between Original Equipr.ent Manuf acturer (OEM) and l
5econdary Source Parts i
One issue reviewed during the inspection was whether technical and/
or quality differences exist between commercial grade parts manu-factured by the OEM for nuclear power applications and commercial grade parts manufactured by secondary sources. This particular concern is currently limited to secondary source comercial parts that may find their way into nuclear power plants.
Differences can exist depending on how the original valve was procured and how the current replacement parts are being ordered.
l However, sufficient information is not currently available to eval-unte the impact of these differences on valve operability or plant i
safety. The following comments apply:
a.
For a secondary source to have the capability of correctly pro-ducing a comercial grade part for a MD valve in a nuclear application, three basic items are required. First, the second-ary source needs to have sufficient technical information (e.g.,
detailed drawing, and design tolerances) to produce the com.
mercial grade part. Because of MD's prior relationship with i
i CVS and because MD occasionally uses sub-tier vendors for machin-ing comercial parts some secondary source manufacturers may have copies of the original HD drawings.
Next, the secondary source needs to know what supplemental requirements were applicable to the original nuclear valve order and whether these requirements are applicable to the particular part te be made.
Information on the original valve order is controlled by MD and may not be generally available to the power plant or the secondary source.
Third, the secondary source would have to implenient a quality program that is equal to or better than the one used by the OEM.
b.
During the inspection, the NRC inspectors looked for specific examples of supplementary requirements that could result in differences between a comercial grade part that could be used in a nuclear application and the same comercial grade part used in a comercial application.
A few specific examples identified during the inspection include: Seat rings for commercial applications were typically used as is but for nuclear applications the seat rings were subjected to NDE and sometimes hard facing.
Plugs for strictly comercial applications were used as is, for nuclear applications the plugs are subjected to NDE.
ORGANIZATION: MASONEILAN DRESSER AVON, MASSACHUSETTS j
REPORT INSPECTION NO.: 99900094/88-01 RESVLTS:
PAGE 14 of 17 i
c.
Some QA/QC differences also arise from requirements invoked in the original equipment specifications or may be the inherent result of the quality program being used.
The requirements leading to quality differances may not i
be available to secondary source manufacturing, such as:
}
Requirements to provide written certification of compliar.ce with specification requirements, j
Requirements to use materia'l from qualified (or approved) suppliers with documented certi-fied material test reports from sub-tier vendors.
Requirements for receipt inspection and material control and identification during manufacture and stocking.
Procedures for order entry and processing that involve review of original equipment s>ecifica-l tions for requirements applicable to tie current I
order.
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d.
One last consideration is that some secondary source manu-facturers may be using reverse-engineered drawings (i.e.,
drawings prepared by measuring parts manufactured by the OEM or other secondary source spare parts). Reverse engineered drawings can lead to differences, especially for dimensional tolerances. Design tolerances cannot usually be identified by a single inspection of a finished part.
9.
Review of MD Contracts l
The inspectors conducted a review of MD's contract with their industrial sales representatives, their marketing releases, and executive correspondence concerning sales of nuclear products or sales for use in nuclear power plants. The contract currently-in effect was instituted in 1986 shortly after Dresser Industries acquired Masoneilan f rom McGraw-Edison. There were no copies available of contracts which were in effect prior to 1986; therefore, a review could not be performed.
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. ORGANIZATION: MASONEILAN-DRESSER AV0N, MASSACHUSETTS REPORT INSPECTION NO.: 9990D094/88 01 RESULTS:
PAGE 15 of 17 1
The current contract does not procedurally specify an explicit method to be used when processing a nuclear plant order. The MD QA manager stated that the sales representatives were instructed to pass all orders from nuclear power plants on to MD's Avon facility to determine if the part was nuclear or commercial grade.
l He provided two MD memorandums that were transnitted to MD's sales representatives:
I
~
a.
Memo ASM-24-80-DF, dated May 8, 1986. This memo states, in part:
"All inquiries and orders', REGARDLESS of product type, for Nuclear related parts and/or complete equipment are to be directed to Avon Contract Administration.*
b.
Memo ADM-25-880, dated August 15, 1988. This memo states, in part:
- All inquiries and orders, REGARDLESS of product type i
or that requires delivery, for nuclear related parts and/or complete equipment are to be directed to AVON Contract Administration and clearly marked "NUCLEAF l
The MD memorandums specifically state that nuclear related part orders should be passed to the Avon facility. However, the exact I
definition of nuclear related parts is open to interpretation.
The Midwest sales manager when questioned, stated that it was possible for an experienced MD sales representative to feel capable of determining if a part order from a nuclear plant was for a safety-related system himself.
He might then decide to fill the order fron his stock which could contain non-authorized substitute replacement parts. Therefore, whether a nuclear plant receives an authentic MD part or a secondary source part is dependent in part on the MD sales representative's handling of that order.
Another contractual aspect reviewed was whether MD sales representatives were required to carry exclusively MD products or if they could carry competitors products or secondary source parts. A review of the contract identifies that it does not in itself preclude the MD representative from dealing with competitors or secondary source suppliers.
In conclusion, it is possible for an NRC licensee to receive non-genuine MD parts from an authorized MD sales representative.
The responsibility of assuring the adequacy of purchased material and their conformance to the procurement documents therefore, rests with the NRC licensee, n
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- . ORGANIZATION: KASONE!LAN-DRESSER l
AVON, KASSACHUSETTS 1
REPORT INSPECTION NO.: 99900094/68 01 RESULTS:
PAGE 16 of 17 t
- 10. A{ditionalMPinformation The followir.,
-ere noted during discussion between MD and NRC n
personnel, i
a.
The MD Avon, MA facility is one of several located around the country and arcund the world. Other fecilities within the United States include the MD Instrument Division in Canton, KA, a MD warehouse / valve refurbishment fetility and distri-t bution center in Houston, TX, and another HD manufacturing facility in Montebello, CA.
The Montebello f acility is engaged in Air force and NASA work.
b.
MD has been providing equipment to the commercial nuclear power industry for about 25 years. MD valves are used in a wide variety of safety-related and nonsafety nuclear applications.
i Masoneilan's 21.000 Series, 40,000 Series, and 41,000 Series sliding stem valves are useo in nuclear power plants, c.
MDmaintainsNandNPTstamps(Nos.1836and1837), currently expiring August 1989. These stamps are used when ASME certi-fication of valves or replacement parts is requested by a 11D customer. HD also supplies valves that meet ASME Section Ill without ASME N stamp certification.
d.
Prior to the introduction of Section 111, MD supplied commercial valves (usually with some type of uagrade) to nuclear power plants.
These valves were used in soth safety-related and nonsafety-related applications.
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ORGANIZATION: MASONEILAN-DRESSER AVON, KASSACHUSETTS REPORT INSPECTION NO.: 99900094/88-01 RESULTS:
PAGE 17 of 17 i
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PERSONNEL CONTACTED:
NAFE TITLE
- P. H. Sanford Manager, Massachusetts Operations
- W.
T. Allen, !!!
Quality Manager R. Brundy Service Representative C. A. Canestrari Senior Buyer A. Deci.ellis Final Tester D. Ellis Service Representative K. Juncewicz Regional Manager
'J. A. Kerr QA Engineer i
E. Krarer Nuclear Product Engineer i
E. 11eagher Receipt Inspector J. Powell QC Supervisor J. Raveri Material Receiver / Handler i
R. Rohm Yalve Assembly Supervisor i
- present during exit necting i
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