ML20010C669
| ML20010C669 | |
| Person / Time | |
|---|---|
| Issue date: | 02/23/1978 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Welch N FEDERAL BUREAU OF INVESTIGATION |
| Shared Package | |
| ML20010C668 | List: |
| References | |
| FOIA-81-120 NUDOCS 8108200293 | |
| Download: ML20010C669 (6) | |
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c&.v FB 2 3 UM Mr. fleil J. Welch Federal Bureau of Investiga tion United States Department of Justice Federal Of fice Building 600 Arch Street Philadelphia, Pennsylvania 19106 Re:
Your File riumber 46-C690RA
Dear Mr. klelch:
The following information is provided in response to your letter of February 15, 1978 concerning the Hayward-Tyler Pump Ccmpany:
Item l_:
The nature of an t!-Stamp and if the Hayward-Tyler Pump Ccmpany, 80 Industrial Parkway, Burlingttn, Ver: cont, has been issued an N-Stamp.
If it has, what regulations and stipulations gcVern its operation and the circumstances under which this ccmpany received i ts t!-Stamp.
Response
The Hayward-Tyler Pump Company at Burlington, Vermont, is the holder of American Society of Mechanical Engineers (ASME) Nuclear Certificates of Authorization flumber N-lS19 for Class 3 Vessels and Pumps, riumber N-1635 for Class 2 and 3 Pumps, flumber tt-1520 for Class 3 Vessel Parts, Pump Parts and Appurtenances, Piping Subassemblies and Ccmponent Supports and Number N-1636 for Class 2 and 3 Pump Parts and Appurtenances.
For background, the ASME is a professional organization who establishes standard rules for the design and construction of nuclear power plant items such as vessels, tanks, piping systems, pumps and valves for use in the nuclear pcwer system portion of power plants.
This set of rules is issued asSection III of the ASME Boiler and Pressure Vessel (S&PV)
Code which is an American f ational Standard.
ASME has established procedures to authorize qualified organizations (e.g., contructors,'
fabricators) to perform various activities in acccrdance with the require-ments of the ASME B&PV Code with the aim to provide reccgnition of organiza tions so authorized.
This recognition is provided by the Society granting these organizations a Certificate of Authorization to use Code Symbol Stamps, e.g., N-Stamp, to mark items fabricated cr constructed by the organization in accordance with the ASME E&PV Code.
Before the Society issues a Certificate of Authorization, the organization must 8108200293 810601 DNLO
-120 PDR
Mr. Neil J. Welch 2
Federal Bureau of Investigation agree to perform applicable activities in accordance with the rules of the Code, have a Quality Assurance Program acceptable to the Society, satisfactorily demonstrate to the Society that it is implementing the rcquired Quality Assurance Program and pay the required fee.
The Society may withdraw the Authorization if the rules of the ASME B&PV Ccde are not met.
Presently, 37 states of the United States and 11 provinces in the Ocminion of Canada have boiler and pressure vessel laws requiring the ASME S&PV Code to be used for nuclear cc.nponents used within their jurisdiction.
Title 10 of the Code of Federal Regulations, Part 50, (10 CFR 50) in Section 50.5Sa., " Codes and Standards Rule", requires nuclear components which are a part of the reactor coolant pressure boundary to meet the requirements for Class 1 components set forth in Section III of the ASME B&PV Code.* Also, by means of conditions placed on the construction permit for a nuclear power plant, the Nuclear Regulatory Comnission requires several plant ccmponents to meet the requirements for Class 2 or 3 components set forth in Section III of the ASME B&PV Code.
The Ccmmission, howaver, does not require the Code Symbol to be applied, but coes require an equivalent inspection process if the ASME inspection process is not employed.
Most states require the Code Symbol to be applied and the ASME inspection process to be used.
Therefore, the " nature of N-Stamps" is that an organization must be authorized by the ASME to use this Code Symbol and components bearing this symbol are certified by the fabricator as having been designed and fabricated in accordance with the rules of the ASME B&PV Code.
Organiza-tions holding an ASME Certificate of Authorization are inspected by a qualified inspector from an " Authorized Inspection Agency"; that is, an agency (usually an insurance company) authorized by the individual s ta te.
Therefore, for ccmponents to be fabricated contrary to Code rules usually requires a failure on both the part of the constructor / fab-ricator and the Authorized Inspector.
The Authorized Inspection Agency for Hayward-Tyler Pump Ccmpany is the Lumbernans Mutual Casualty Company.
The Code recognizes the different levels of importance associated with the function of each ccmponent as related to safe operation of the nuclear power plant.
Reactor coolant pressure boundary ccaponents are considered most important to safe operation and are required by the Nuclear Regulatory Comnission to meet the Code rules established for Class 1 components.
These rules are more stringent than those required for Class 2 or 3 components which are considered to be of lesser importance to safe operation.
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Mr. Neil J. Welch 3
Federal Sureau of Investigation For your further information, our records indicate there is a Hayward-Tyler and Company, Ltd. at Beds, England, who are holders of AS1E Cartifi-cates of Authorization Numbers M-894 and N-895 for Class 1, 2 and 3 Pumps.
Their Authorized Inspection Agency is the Keir.perco Reinsurance Ccapany.
Item 2:
The manner in which the Nuclear Regulatory Ccemission regulates and inspects manufactured parts or systems to be used in the Nuclear Pcwer Plants and, specifically, how these relate to the Hayward-Tyler Pump Company.
Response
A fundamental premise of the Nuclear Regulatory Ccemission's nuclear power plant r:gulation and inspection program is that the licensee is responsible for the proper construction and safe operation of his nuclear power plant.
The total governnent-industry system for the inspection of nuclear facilities has been designed to provide for multiple levels of inspection and verification.
The licensee and his cent. actors and vendors each participate in the inspection process in accordance with requiremants prescribed in the NRC rules and regulations, e.g., the 10 CFR 50.55a, " Codes and Standards Rule," 10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing plants,"
and 10 CFR 21, " Reporting of Defects and Noncompliance." The NRC inspects to determine whether its requirements are being met by the licensee and his contractors.
The total nuclear inspection activity is pyramided, with each layer of activity verified, inspected or audited by those above.
The NRC's position is at tha apex, while the great bulk of the inspection activity is performed by industry within the base.
The firms designing nuclear steam systems, the architect engineering firms doing design work on nuclear pcwer plants, and certain selected vendors are currently inspected on a regular basis by NRC.
Mcwever, tha Hayward-Tyler Pump Ccmpany is not one of the selected vendors since the company is not a major supplier of nuclear components, is a supplier oJ Class 2 and 3 ccmpon:nts which are of lesser safety significance th,an Class 1 cerronents, 'nd is net known nor alleged to have been a supplier of faulty components nor have a faulty quality assurance program.
Mr. Neil J. Welch 4
Federal Bureau of Investigation l
1 A significant part of the NRC's inspection and enforcement ef fort is involved in responding to allegations of improper or unsafe operations.
Although many allegations prove to be of minor significance concerning safe plant operation and may be reviewed during scheduled inspections, some require special response.
In these cases, a special inspection is scheduled or, if appropriate, an imaediate, full investigation is initiated by NRC personnel.
Therefore, if there is reason to belf:ve that the quality of Hayward-Tyler Pump Ccmpany nuclear ccmponents is substandard oc that their quality asst.ance program is not being properly implemented, the Nuclear Regulatory Commission needs to be informed so that the Cornaission may initiate appropriate actions.
Such actions would be consistent with our responsibilities to protect the public health and safety and to cooperate with the Justice Department.
Itcm 3:
Copies of contracts, manufacturing specifications, inspection reports or other documents related to the production of Nuclear Pumps by Hayward-Tyler.
Such information may be used to show
- 1) if the U.S. Government has funds or subsidies involved; 2) if Hayward-Tyler altered or entered incorrect information given to the Nuclear Regulatory Comnission regarding the manufacturing pumps.
Response,:
To the best of our kncwledge, the Ccmmission does not have any of the above documenta tion.
This documentation would normally be held by the purchaser of the component.
Hayward-Tyler Company would, of course, also have copies of the documants.
The Commission does have means to obtain such documentation as indicated in the response to item 4 below.
Item 4:
The names and addresses of nuclear power facility customers of the Hayward-Tyler Company.
Response
We do not have a list of those nuclear power plants in the United States who have purchased Hayward-Tyler nuclear compor.ents.
Hcwever, such a list can be obtained by the Ccmmission through a variety of methods..
The method selected normally depends on the seriousness of any problem upon plant safety.
The time required to develop the list could vary from hours to a few '..eeks depending upon the method selected.
Mr. Neil J. h'elch 5
Federal Bureau of Investigation l
From our preliminary review of the Hayward-Tyler matter, we t.nderstand a concern has been experienced about the proper implementation vf their quality assurance program.
Ccnsequently, we are initiating a review of this matter. We will forward a copy of our report of findings to you when it is completed.
Thank you for your cooperation in bringing this matter to our attention.
If you have further questions on this matter, we would be glad to discuss them with you.
Sincerely, f2s 3Ccgg /. ici:-p/
b[ce H. Grier Director 3
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(w/cy of inccming correspondence)
,d. G. Martin, RI R. T. Carlson, RI N. C. Moseley, IE:HQ J. G. Davis, IE:HQ E.'
Jordan, IE:HQ Director, Regions II, III, IV & y s
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