ML20024E647
| ML20024E647 | |
| Person / Time | |
|---|---|
| Issue date: | 08/11/1983 |
| From: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Duvall D BBC BROWN BOVERI, INC. (FORMERLY BROWN BOVERI CORP. |
| Shared Package | |
| ML20024E648 | List: |
| References | |
| REF-QA-99900740 NUDOCS 8308160287 | |
| Download: ML20024E647 (2) | |
Text
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AUG 111983 Docket No. 99900740/82-01 Brown Boveri, Incorporated Switchgear Systems Division ATTN:
Mr. D. D. Duvall Vice President Norristown Road and Route 309 Spring House, PA 19477 Gentlemen:
Thank you for your letter dated December 20, 1982, in response to our letter dated November 26, 1982.
With respect to your comment that the violation included as Appendix A in our November 26, 1982, letter was classified as failure to prepare a record of evaluation of a deficiency rather than failure to report as classified by our inspector during the exit meeting, we note that all inspection results discussed at the conclusion of the inspection are further reviewed by the regional management.
It is possible that based on these reviews the severity level of adverse findings is either raised or lowered.
Typically, when a finding is reclassified to a higher severity level as a result of such review, the vendor is so advised by telephone prior to the issuance of the Notice of Violation.
If, however, the finding is reduced to a lower severity level as it was in this case, no such notification is made.
In this particular instance, our review of the inspection findings concluded that an evaluation of the described relay deficiency as required by 10 CFR Part 21 should have been conducted by your company to form the basis for reportability decision. While your December 20, 1982, letter summarizes your basis for concluding that the deficiencies identified with Westinghouse Types C0-6 and SA-1 relays were not reported under 10 CFR Part 21, this information was not documented at the time of our inspection.
While we reconsidered the violation as you requested, the discussion that you presented provides no basis for identifying the finding as other than a violation.
The information that you provided supports the finding that
" records of evaluations had not been prepared," as noted in paragraph E.1.b of the inspection report.
During our evaluation of your response, a telephone conversation was held with your Mr. E. W. Rhoads on January 25, 1983, in an attempt to establish whether the proceedings of the evaluation ccmmittee had been documented concerning the findings of this inspection.
This is deemed pertinent because conclusions need to be substantiated by documented activities - not of historical events but focused on the deficiency and its impact.
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Brown Boveri Electric, Incorporated Unfortunately, we received no assurance that there are documents which support the conclusions.
Similarly, our concern regarding the wiring separation deficiency is limited to your responsibility and not problems created by the user. We will review these issues, your corrective actions, and preventive measures during a future inspection.
No additional response is required at this time regarding the inspection findings.
Sincerely, Original Signed B7m Uldis Potapovs Uldis Potapovs, Chief Vendor Program Branch bec:
JTCollins RLBangart JEGagliardo TFWesterman WEFoster DMB-IE:09
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