ML20012F496
| ML20012F496 | |
| Person / Time | |
|---|---|
| Issue date: | 03/29/1990 |
| From: | Brach E Office of Nuclear Reactor Regulation |
| To: | Valli P BW/IP INTERNATIONAL, INC. (FORMERLY BYRON JACKSON |
| References | |
| REF-QA-99900030 NUDOCS 9004160020 | |
| Download: ML20012F496 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION a
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WASHING TON, D. C. 2MM
'5 m 29, 1990 l
1 Docket No. 99900030/89-01 Mr. Peter C. Valli, President and i
Chief Executive Officer l
BW/IP International, Incorporated i
200'Oceangate Boulevard l
Suite 900 Long Beach, California 90802 l
Gentlemen:
l Thank you for your letter of February 22, 1990, in response to our letter dated January 12, 1990. We have reviewed your reply to our Notice of Violation l
and Notice of Nonconformance and have the following concerns related"to your response.
Regarding the Notice of Violation,'your letter states on page 2 that BW/IP discussed its evaluation of a deviation regarding the improper positioning of the valve disc within your swing check valve with TV Electric on June 2,1989.
During the NRC's inspection of. your facility in September 1989, BW/IP was unable to provide documetttation to support that evaluation which is required under 10 CFR Part 21.
Further, despite having knowledge of the existence of a i
deviation, BW/IP did not immediately notify other customers so that they~ could l
evaluate the deviation pursuant to'10 CFR 21.21. Your notification to affected customers on September 22, 1989 appears to have been initiated as a result of the NRC inspection findings which were discussed with BW/IP representatives during the exit meeting held on September 14, 1989. Additionally, your response to our Notice of Violation states on page 3 that BW/IP reported the deviation i
regarding the broken cast swing arm to the NRC on October-2,~1989. Again, this j
notification was initiated as a result of our inspection efforts and may not have occurred otherwise. However, since notification of the deviations was made to affected customers, the NRC has no additional concerns at this time.
i Regarding the Notice of Nonconformance, the NRC staff has the following concerns related to your response.
Nonconformance 89-01-02.
BW/IP's dedication process reviewed during the inspection for the eight cast swing arm's supplied to the Comanche Peak Steam Electric Station was inadequate to assure satisfactory performance in a safety-related swing check valve.
As such, the NRC requests BW/IP to review its commercial grade dedication program. NRC's endorsement of 1
the Electric Power Research Institute's report NP-5652 (NCIG-07) in l
Generic Letter 89-02 recognizes several methods which, if implemented properly, should constitute an acceptable dedication program.
It should be noted that the NRC's endorsement'of NCIG-07 was not meant and should not be construed to imply any new requirements.
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Mr. Peter C. Valli 2-m 29, W Nonconformance 89 01 03. Your response to this item states that imple.
mentation audits are not required of ASME Quality System Certificate (QSC) holders, as confirmed by the NRC in September 1989. This informa-tion is not correct. NRC Information Notice 86-21 states that QSC holders may be placed on the approved vendor list however, prior to utilization, the purchaser is responsible to assure implementation of the vendors quality assurance program.
Regarding your statement concerning the submission to BW/IP of a material sample from QSC holders used during the preceding year, the NRC staff does not recognize this'as an effective method of controlling unaudited sub.
suppliers who furnish items to BW/IP for use in nuclear safety-related applications. There is no correlation or assurance that the material sample supplied to BW/IP is traceable to that furnished previously.
This practice should be reevaluated for its compliance to the provisions of 10 CFR 50, Appendix B, Criterion VII.
Nonconformance 89-01-04. Your audit findings,. documented in RCA 89-17 for the ACME Casting Company, identified several deficiencies within the implementation of ACME's quality program which included, for example,<
1mproper identification, segregation and control of nonconforming material; and inadequate documentation of inspection and testing personnel training and qualification records.
Based on these. deficiencies, BW/IP is requested to review previous purchase orders placed with ACME to identify where
.i potential nonconforming material may have been used and notify customers accordingly.
In addition BW/IP should identify, review and evaluate previous ACME nonconformance reports for possible deviations that may be reportable to the NRC: pursuant to the requirements of 10 CFR Part 21.
l Nonconformances 89 01 05, 06, 07 and 08. At this time, the NRC staff has no concerns with BW/IP's response to these items.
Please provide the additional information requested above within 30 days of the date of this letter.
Sincerely, Origirmi sised 4:
b N Brach, Chief l
Vendor Inspection Branch Division of Reactor Inspection and Safeguards I
Office of Nuclear Reactor Regulation DISTRIBUTION iCentral Files:
VIB Reading DRIS Reading PDR BKGrimes EWBrach GCwalina RPettis Previously concurred.
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- R15-1:VIB:DR15 :AC:RIS-l:VIB :C:VIB:DR15:NRR:
NAME :RPettis:nrp*
- GCwalina*
- EWBrach*
DATE
- 03/28/90
- 03/28/90
- 03/28/90 i
OFFICIAL RECORD COPY Document Name: VALLI LETTER l
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