ML20024E670

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QA Program Insp Rept 99900834/83-01 on 830614.Noncompliance Noted:Failure to Post 10CFR21,Section 206 of Energy Reorganization Act of 1974,procedures Adopted Pursuant to Regulations & Notice Describing Regulations
ML20024E670
Person / Time
Issue date: 07/22/1983
From: Barnes I, Ellershaw L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20024E664 List:
References
REF-QA-99900834 NUDOCS 8308160354
Download: ML20024E670 (7)


Text

_

'0,RGANIZATION:

E. D. GIBERSON & COMPANY, INC.

NORTH BRUNSWICK, NEW JERSEY REPORT INSPECTION INSPECTION N0.

99900834/83-01 OATE(S) 6/14/83 ON-SITE HOURS:

16 CORRESPONDENCE ADDRESS:

E. D. Giberson & Company, Inc.

ATTN:

Mr. A. T. DePowell, Vice President and General Manager 1330 Livingston Avenue North Brunswick, New Jersey 08902 ORGANIZATIONAL CONTACT:

Mr. A. T. DePowell, Vice President and General Manager TELEPHONE NUMBER:

(201) 246-8500 PRINCIPAL PRODUCT:

Pipe, tubes, and fittings.

NUCLEAR INDUSTRY ACTIVITY:

Less than one percent.

1 hn ASSIGNED INSPECTOR: N kh

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(. E. Ellershaw, Reactive and Component Program Date Section (R& CPS)

OTHER INSPECTOR (S):

D. E. Norman, R& CPS APPROVED BY:

v" M-7-2 2. -R3 I. Barnes, Chief, R& CPS Date INSPECTION BASES AND SCOPE:

A.

BASES:

10 CFR Part 21 and 10 CFR Part 50, Appendix B.

B.

SCOPE:

This inspection was conducted as a result of NRC's initiation of inspections of material manufacturers and material suppliers in order to determine compliance with NRC and ASME Code requirements pertaining to procurement activities.

PLANT SITE APPLICABILITY:

Not identified.

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8308160354 830729 PDR GA999 ENV*****

99900834 PDR

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0,RGANIZATION:

E. D. GIBERSON & COMPANY, INC.

NORTH BRUNSWICK, NEM JERSEY i

REPORT INSPECTION NO.-

99900834/83-01 RESULTS:

PAGE 2 of 4 A.

VIOLATIONS:

1.

Contrary to Section 21.6 of 10 CFR Part 21, E. D. Giberson &

Company, Inc. (GIBCO) had not posted:

(1) a copy of 10 CFR Part 21, (2) Section 206 of the Energy Reorganization Act of 1974, (3) procedures adopted pursuant to the regulations, or (4) a notice describing the regulations and procedures, including the name of the individual to whom reports may be made.

2.

Contrary to Section 21.21 of 10 CFR Part 21, GIBC0 had not adopted procedures to provide for:

(1) evaluating deviations, (2) causing deviations to be evaluated, or (3) assuring that a director or responsible officer is informed if a basic component fails to comply or contains a defect.

B.

NONCONFORMANCES:

None C.

UNRESOLVED ITEMS:

None D.

OTHER FINDINGS OR COMMENTS:

1.

General:

This inspection was made as a result of NRC's initiation of inspections of material manufacturers and material suppliers in order to determine comoliance with NRC and ASME Code requirements pertaining to procurement activities.

GIBLO, a material supplier, is a wholly owned subsidiary of DB Orban Company, primarily an importer of commercial grade piping, tubing, and fittings.

GIBC0 does not hold an ASME Quality System Certificate (Materials).

The procurement of foreign materials used by GIBC0 is performed by DB Orban Company.

Domestic materials are purchased directly by GIBC0.

It was established during this inspection that less than one percent of GIBCO's sales are nuclear-related.

In addition, i

approximately 70 percent of their sales is to other material suppliers.

l 2.

Quality Control Program Status:

The GIBCO Quality Control Manual, l

dated June 14, 1978, was written to comply with the material supplier l

provisions contained in Section III of the ASME Code, Sub-Article l

HCA-3800.

Since GIBC0 is not an ASME Certificate Holder, records I

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' 0,RGAN'IZATION:

E. D. GIBERSON & COMPANY, INC.

NORTH BRUNSWICK, NEW JERSEY MPORl 1NWto tuh NO.:

99900834/83-C1 RESULTS:

PAGE 3 of 4 were reviewed to determine acceptance of the program by customers who had purchased to ASME Code specifications for possible domestic nuclear applications.

Records of two such customers were reviewed.

A letter dated January 3,1980, from Custom Alloy Corporation provided approval of the manual as meeting the provisions of NCA-3800.

A reaudit was performed by Custom Alloy on January 13, 1981, with one deficiency being identified.

The deficiency was subsequently corrected by GIBCO.

Several purchase orders (PO) placed by G&W Taylor Forge Stainless, Gulf & Western Manufacturing Company (TFS) were also reviewed; however, no evidence of audits or quality program acceptance was available.

Within this area of inspection, no nonconformances or unresolved items were identified.

3.

Procurement Control:

A review of GIBC0 customers since 1978 provided a list of eight which were known to be involved in the commercial nuclear industry.

A review of over 300 P0s from these 8 customers revealed just 1 (TFS) had imposed ASME Code Section III requirements on a total of 5 P0s.

All others were commercial type orders.

GIBCO P0s to their vendors for materials to be supplied against the five P0s referencing ASME, were reviewed to assure that the customer requirements had been passed on.

The particular vendors involved were on GIBCO's Approved Vendor List by virtue of their being an ASME Certificate Holder or their having been audited and approved by GIBC0 or GIBCO's customer.

In no instance was it found that materials for nuclear application had been purchased from an unapproved source or that customer requirements were not included in GIBCO's P0s.

The vendors' CMTRs for the material were reviewed and were found to address the ASME Code, Sections II and III requirements.

Within this area of the inspection, no nonconformances or unresolved items were identified.

4.

10 CFR Part 21 Compliance:

During review of purchase orders, it was established that 10 CFR Part 21 had been imposed by one customer (TFS) on four P0s for ASME Section III application and on one P0 l

l l

ORGANIZATION:

E. D. GIBERSON & COMPANY, INC.

NORTH BRUNSWICK, NEW JERSEY REPORT INSPECTION NO.-

99900834/83-01 RESULTS:

PAGE 4 of 4 in which ASME was not referenced.

It was subsequently determined during an inspection at TFS, that the end use for the products on the one P0 not referencing ASME was non-nuclear.

As a result of the imposition of 10 CFR Part 21 requirements on GIBCO, a review was co'nducted to establish compliance.

This review resulted in the identification of Violations A.1 and A.2.

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Purchase Order

1. Sequential Item No.

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Internal Memo

2. Type of Document :

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Letter

3. Date of Document 4 QA Manual 8.

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