ML20046B989
| ML20046B989 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1988 |
| From: | Baker E, Parker L NRC, Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20046B982 | List: |
| References | |
| REF-QA-99901103 99901103-88-01, 99901103-88-1, NUDOCS 9308090093 | |
| Download: ML20046B989 (5) | |
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ORGANIZATI0ti:
R.E.C. CORPORATI0t1 MT. VERti0ti,tiEW YORK REPORT ItiSPECTI0fl IliSPECTI0tt tiO. : 99901103/88-01 DATE:
10/25-26, 1988 Oli-SITE HOURS: 40 CORRESP0i4DEliCE ADDRESS: Mr. Robert S. Brinker, President R.E.C. Corporation Ten Beach Street Mt. Vernon, flew York 10550 ORGANIZAT10tlAL C0f4 TACT: Mr. Robert S. Brinker, President TELEPH0!iE tiUMf!ER:
(924) 699-6000 t4UCLEAR ll4DUSTRY ACTIVITY: Manufacturer and distribution of fasteners.
ASSIGt4ED liiSPECTOR:
[ ct4 M/f7 L. B. Parker,4 etial Projects Inspection Date Section (SPIS OTHERlliSPECTOR(S):
G. Cwalina, Program Development and Reactive Inspection Section (PDRIS)
APPROVED BY:
c B6f.
[
M E. T. Baker, Section Chief, PDRIS, Vendor Inspection Da'te Branch ItiSPECTI0ti BASES AND SCOPE:
A.
BASES:
10 CFR Part 21, Appendix B to 10 CFR Part 50, and Section III of the ASME Boiler and Pressure Vessel Code.
B.
SCOPE: The inspection was conducted to perform an evaluation of the implementation of R.E.C. Corporation's (REC) Quality Assurance (QA) program as it relates to the fabrication and supply of fasteners for the nuclear industry.
PLAfii 511L APFLILADILITY: Itillstone 50-245/336/423,111dland 50-329/330, Watts Bar 50-390/391, Sequoyah 50-327/328, Browns Ferry 50-259/260/296, Palo Verde 50-528/529/530, Fermi 2 50-341, ticGuire 50-369/370, Nine Mile Point 50-220/410, Susquehanna 50-387/388.
9308090093 930802 PDR GA999 EMV*****
99901103 PDR
ORGANIZATION:
R.E.C. CORPORATION f
11T. VERHON, flew YORK
. P.E PORT INSPECTION NO.: 99901103/88-01 RESULTS:
PAGE 2 of 5 i
A.
VIOLAT10fiS:
1.
Contrary to Section 21.6 of 10 CFR Part 21, P.EC had not posted current copies of the Part 21 regulations, Section 206 of the Energy Reorganization Act of 1974 or procedures adopted pursuant i
to the Part 21 regulations.
(88-01-01) 2.
Contrary to Section 21.21 of 10 CFR Part 21, REC had not adopted written procedures to evaluate deviations or inform. licensees or purchasers of deviations and to assure that a director or responsible officer is informed if a basic component supplied by REC contains a defect.
(88-01-02) 3.
Contrary to Section 21.31 of 10 CFR Part 21, a review of purchase orders (PO) to vendors revealed that while 10 CFR Part 21 was imposed on REC, REC did not impose 10 CFR Part 21 requirements on P0s 013428 (April 17, 1986) to Texas Bolt, 013423 (April 15, 1985) to B&G Manufacturing Company Inc., and 013439 (April 24, 1986) to A. Heller Heat Treating Company.
(88-01-03)
B.
NONC0ilFORMANCES:
1.
Cnntrary'to paragraph NCA-3861 of Section III of the ASME Boiler and Pressure Vessel Code (the Code), REC could not_ provide any evidence that their quality assurance (AQ) program had been implemented since April of 1987. (88-01-04) i 2.
Contrary to Subparagraphs NB/NC-2610(a), NCA-3867.4(c) and NCA-3867.4(g), REC supplied and certified fasteners greater than an inch in diameter as complying with Section III of the Code when in fact REC had purchased the fasteners as stock material from unapproved sources and did not perform the testing required by Section III to upgrade the fastners. (88-01-05) 3.
Contrary to Subparagraphs flB/NC-2610(b) and NB/NC-2610(c) of the AS!!E Code, ASME Code Interpretation III-1-83-260R, and paragraphs 3.3.4c and 3.6.5 of REC's QA Manual, REC supplied and certified small products (fasteners 1 inch in diameter and less) as meeting Section III of the Code when in fact the fasteners were purchased
'r s A..pp usu agi ce and REC did r ut inf orn L tustc r.er u.a t the fasteners were supplied under the provisions cf subparagraph NX-2610(b). (88-01-06) b
ORGANIZATION:
R.E.C. CORPORATION llT. VERNON, NEW YORK REPORT INSPECTION NO.: 99901103/88-01 RESULTS:
PAGE 3 of 5 C.
UNRESOLVED ITEMS:
None D.
STATUS OF PREVIOUS INSPECTION FINDINGS:
None, this is the first inspection of the facility.
E.
OTHER FINDINGS AND C0!iftENTS:
1.
10 CFR Part 21 Review REC's compliance with the requirements of 10 CFR Part 21 were reviewed and it was determined that (a) the posting of t
requirements 10 CFR Part 21 had not been implemented (Violation 88-01-01), and (b) REC had not adopted written procedures to evaluate defects (Violation 88-01-02).
2.
Documentation Packages (DP)
The inspectors reviewed approximately 100 REC documentation l
packages. These packages are listed below by year of issuance:
1984 - the inspectors reviewed 9 P0s from Anchor / Darling, 3 P0s from BS&B Safety Systems, 2 P0s from Borg Warner Air i
Conditioning, Inc.,1 P0 from Combustion Engineering (Palo Verde),1 P0 from Daniel Construction Company,1.P0 from Detroit Edison, 4 P0s from GPE Controls, 9 P0s from Gould Pumps, Inc.,
1 PO from Guyen Alloys Inc., 2 P0s from Long Island Lighting j
Company,1 PO from J. E. Lonergan Company, 4 P0s from McJunkin Corporation,1 P0 from Mill-Power Supply Company, 2 P0s from National Valve and Manufacturing Company, 9 P0s from Niagara flohawk Power Corporation, 9 P0s from Northeast Utilities, 5 P0s from Pennsylvania Power and Light Company (Susquehanna), 6 P0s from Public Service Electric & Gas Company (PSE&G), 2 P0s from Stone & Webster (Niagara Mohawk's Nine Mile Point Station), 4 P0s from Westinghouse (Philippine Nuclear Project Unit 1), and 9 P0s from York Engineered Machinery Air Conditioning Group of l
Borg-Warner Corporation; i
19N t he ing tciers revicued 1 PO frou PSUC, 2 P0s from Anchor / Darling, 2 P0s from Gould Pumps, Inc., and 3 P0s from Northeast Utilities; i
1986 - the inspectors reviewed 2 P0s from Northeast Utilities, and 8 P0s from Gould Pumps, Inc.;
I t
ORGANIZATION:
R.E.C. CORPORATION MT. VERfl0fi, NEW YORK i
REFORT INSPECTION N0.: 99901103/88-01 RESULTS:
PAGE 4 of 5 1987 - the inspectors reviewed 24 P0s from Northeast Utilities; and 1988 - the inspectors reviewed 10 P0s from Northeast Utilities.
i Based on the review, REC appears to have implemented an adequate QA program prior to November 1985, which is when they dropped their ASME Quality Systems (Materials) Certificate (QSC).
For j
material purchased by REC prior to giving up their QSC, the t
records indicate that the material was purchased from companies REC had audited and approved as having QA programs that met the requirements of NCA-3800. However, after giving up their QSC, REC's implementation of the QA program declined. The end result being that in 1987 and 1988 REC was purchasing stock material from unapproved vendors, supplying and certifying the material as meeting Section III requirements, when in fact the material aid not meet Section III requirements.
For fasteners over one inch in diameter,Section III, NCA-3867.4(e) requires that each piece of stock material have a product analysis performed on it a verify chemistry. The material for the Northeast l
Nuclear Energy Company (hMEC) purchase orders (fos) listed belo,i was t
purchased by REC as stock material and no evidence of upgrade testing was available.
(Nonconformance 88-01-05) fillEC - P0 - 908798 - 180 SA-194 Grade 2H, 2 inch dianeter nuts, ordered to ASi1E Section III, Class 1, 1980 Edition i
NNEC - P0 - 909692 - 100 SA-194 Grade 8, 1-1/4 inch diameter nuts, ordered to ASME Section III, Class 2, 1980 Edition i
1 NNEC - P0 - 101075 - 50 SA-193, 1-1/8 inch diameter studs, ordered to ASME Section III, Class 2, 1980 Edition, Winter 86 Addenda HNEC - P0 - 107623 - 25 SA-194, Grade 2H nuts, 1-3/4 inch diameter order to ASME Section Ill, Class 2,1980 Ecition for fasteners one inch diameter and less, ASME Interpretation 111 1-83-260R, dated December 5,1986, requires that the purchaser be informed whenever small products are being furnished under the provisions of subparagraph NX-2610(b).
REC's QA Manual, paragraphs 3.. 4 and 3.6.5, require Wt RFC mually audit subtier vendors that supply REC with small products. The material supplied for NNEC P0s listed below was purchased by REC from unaudited, unapproved vendors and REC certified the material as meeting Section Ill requirements without informing NNEC that the material was being supplied under NX-2610(b). (Nonconformance 88-01-06) e
i ORGANIZATION:
R.E.C. CORPORATION MT. VERNON, NEW YORK REPORT INSPECTION N0.:
99901103/88-01 RESULTS:
PAGE 5 of 5 UNEC - P0 - 762377 - dated February 25, 1987 25 - SA-193 B7, 1/2 inch diameter hex head bolts, ordered 1
to ASME Section III, Class II, NCA-3800, and REC's QA
~
Manual, P.evision 11, dated December 20, 1985.
1 NNEC - P0 - 772662 - dated June 24, 1987 200 - SA194, Grade 8, 1/4 inch diameter nuts, ordered to ASME Section III, Class II, REC's QA Manual, Revision 11.
i NNEC - P0 - 778156 - dated September 8, 1987 200 - SA-194, Grade 8MA, 1/2 inch diameter nuts, ordered to ASME Section III, Class II, NCA-3800, and REC's QA Manual, Revision 11 NNEC - P0 - 779668 - dated September 30, 1987 1000 - SA-194, Grade 8, 3/4 inch diameter nuts, ordered to NCA-3800 and REC's QA Manual, Revision 11 i
25 - SA-193 B7, 1/2 inch diameter hex head bolts, ordered to ASME Section III, Class II, NCA-3800, and REC's QA Manual, Revision 11 NNEC - P0 - 101075 - dated November 17, 1987 5000 - SA-194 Grade 8, 3/8 inch diameter nuts, ordered to ASME Section III, Class I, and REC's QA Manual, Revision 11 NNEC - P0 - 102361 - dated December 3, 1987 100 - SA-193 B8, 2 inch diameter studs, ordered to ASME Section III, Class II, and REC's QA Manual, Revision 11 3.
Review of Internal and External Audits REC could not produce any documented evidence that audits had been performed by REC since January 1986. Additionally, REC l
has not had a person specifically assigned to manage the REC QA program since April 1987 and since that time REC's QA program has not been implemented.
(Nonconformance 88-01-04)
F.
PERSONNEL CONTACTED:
- Robert S. Brinker, President
- Attended exit meeting
.