ML20046C017
| ML20046C017 | |
| Person / Time | |
|---|---|
| Issue date: | 08/02/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20046B982 | List: |
| References | |
| REF-QA-99901103 99901103-88-01, 99901103-88-1, EA-92-101, NUDOCS 9308090120 | |
| Download: ML20046C017 (3) | |
Text
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NOTICE OF NONCONFORMANCE R.E.C.
Corporation Docket No.
99901103/88-01 Mount Vernon, New York EA 92-101 Based on the results of an NRC inspection conducted October 25 and 26, 1988, it appears that certain of your activities were not conducted in accordance with NRC requirements.
A.
Criterion VII, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50 states, in part, that measures shall be established, as appropriate, for source evaluation and selection and inspection at the contractor or subcontractor source.
Subsection 3.6,
" Vendor Surveys and Qualifications," of Section V,
" Control of Operations and Materials," of R.E.C.
Corporation's (REC's) Nuclear Quality Assurance Manual (QAM), Revision 11, dated December 20, 1985, states, in part, that qualified auditors shall perform annual audits of REC's vendors to ensure that all items and services conform to the American Society of Mechanical Engineers (ASME),
Boiler and Pressure Vessel Code (Code).
Contrary to the above requirements, REC failed to produce documented evidence to substantiate that audits of its vendors were performed with the frequency sp.ecified in its QAM during the period from January 1986 to the date of this inspection, October 1988 (99901103/88-01-04).
B.
Criterion III, " Design Control," of Appendix B to 10 CFR Part 50 states, in part, that measures shall be established for the selection and review for suitability of application of material, parts, and processes that are essential to the safety-related functions of the components.
The ASME Code is the basis for demonstrating suitability of l
application for studs and nuts supplied to Northeast Nuclear Energy Company (NNEC) for NNEC purchase orders (Pos) that imposed ASME Code requirements.
Paragraph NCA-3867.4(e) of Section III of the ASME Code states, in part, that the material manufacturer, who certifies material made from stock material produced by a manufacturer whose quality system program has not been qualified under the provisions of NCA-3800, may accept the certification of the requirements of the material specification, which must be p<rfoceed during the melting and heat analysis, from the i
manufacturer of the stock material provided the material manufacturer performs (1) all other requirements of the material specification on each piece of stock material and 7
(2) a product analysis to verify the chemical composition of each piece of stock material.
9308090120 930802 PDR GA999 EMV*****
99901103 PDR
Notice of Nonconformance
-2 Contrary to the above requirements, for four NNEC POs issued to REC during the period of May 1987 through February 1988, REC failed to perform the required testing of the stock material supplied to NNEC (99901103/88-01-05):
C.
Criterion III, " Design Control," of Appendix B to 10 CFR Part 50 states, in part, that measures shall be established for the selection and review for suitability of application of material, parts, and processes that are essential to the safety-related functions of the components.
The ASME Code is the basis for demonstrating suitability of application for studs and nuts supplied to NNEC for NNEC POs that imposed ASME Code requirements.
Paragraph j
NB/NC-2610(b) of Section III of the ASME Code states, in part, that the requirements of NCA-3867.4 and NCA-3866.6 shall be met, however the other requirements of NCA-3800 need not be used by the material manufacturer for small products (defined in NX-2610(c) (2) for bolting as studs, nuts, and bolts of 1-inch nominal diameter and less) furnished with a certificate of compliance (COC).
For these small products, the ASME Certificate Holder shall assure that the material is furnished in accordance with the material specification and with the applicable ASME Code requirements.
Contrary to the above requirements, for six NNEC Pos issued to REC during the period of February 1987 through December 1987, REC supplied small products to NNEC with COCs that certify that the material complies with the requirements of 1
ASME Code,Section III without an ASME Certificate Holder assuring the material met the requirements of the material specification or ASME Code (99901103/88-01-06).
Before REC resumes business with the nuclear industry, REC is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washirgton, D.C.
20555 with a copy to the Chief, Vendor Inspection Branch, Division of Reactor Inspection and Licensee Performance, Office of Nuclear Reactor Regulation.
This reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should include for each nonconformance:
(1) a description of steps that have been or will be taken to correct these items, (2) a description of cteps that have been or will be taken to prevent recurrence, and (3) the dates your corrective actions and preventive measures were or will be completed.
Dated at Rockville, Maryland this 2" day of August, 1993
i l
SYNOPSIS "On January 19, 1989, the Executive Director for Operations, Nuclear Regulatory Commission (NRC), requested the Office of Investigations (OI) conduct an investigation to determine if R.E.C. Corporation (REC) had sold fasteners that were falsely certified as complying with the requirements of Section III of the American Society of Mechanical Engineers (ASME) Code, to an NRC licensee.
It was additionally alleged that REC had altered related material test reports provided to the licensee, Northeast Nuclear Energy Company (NNECO).
The Office of Investigation determined that REC knowingly and deliberately provided a false Certificate of Conformance (CoC) to NNECO.
REC accepted NNECO POs requiring 10 CFR 21 procedures when REC knew such requirements were not met by the supplier, i
REC deliberately provided, to NNECO, at least one false certification knowing this certification to be false.
REC accepted NNECO POs which required ASME,Section III, standards.
REC deliberately provided, at least 10 false CoCs to this NNECO PO requirement knowing this requirement could not be met by REC.
REC accepted NNECO POs requiring REC QA procedures detailed in the REC QA manual, Rev. 11.
REC deliberately provided, at least 10 false CoCs to this NNECO PO requirement knowing this requirement could not be met by REC.
The evidence obtained in this investigation did not substantiate the allegation that falsified Certified Material Test Reports (CMTRs) had been provided by REC."
Case No. 4-90-004