ML20055F728
| ML20055F728 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20055F726 | List: |
| References | |
| REF-QA-99900031 EA-90-122, NUDOCS 9007190099 | |
| Download: ML20055F728 (3) | |
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APPENDIX A L
Sulzer Bingham Pumps, Inc.
Docket No.: 99900031/90-01 Portland Pump Division EA-90-122 Portland, Oregon L
DuringaninspectionconductedatSulzerBinghamPumps,Inc.(SBPI), Portland Pump Division, Portland, Oregon facilit 5-8, 1990, three violations L
of Nuclear Regulatory Commission (NRC) y on February 1
requirements were identified.
In accordance 3
L' with the General Statement of Policy and Procedures for NRC Enforcement Actions,"
~
10 CFR Part 2, Appendix C (1990), the violations are listed below:
A.
Section 21.21, " Notification of failure to comply or existence of a defect," of 10 CFR Part 21, requires, in part, that each individual or -
other entity subject to the regulations evaluate deviations or form the licensee or purchaser of the deviation in order that the h. nsee or purchaser may cause-the deviation to be evaluated.
l Contrary to the above, the following five examples were identified where SBPI either failed to perform an adequate evaluation or failed to notify purchasers so they could cause an evaluation to be performed. (90-01-01)
I 1.
1.
SBPI failed to adequately evaluate the impeller material failurs at l
Diablo Canyon Nuclear Power Plant, Unit 2.
In October 1988, the l
licensee of-the Diablo Canyon Nuclear Power Plant issued Licensee l
Ever: "
.ER)88-029, notifying the NRC of abnormal 1
deten a Wun of safety-related auxiliary salt water pump impellers due *o
- .ojequate heat treatment and failure of the vendor (SBPI) to l
con' < ol special nrocesses. Based upon metallurgical analysis l
per; rmed on M impeller material, the licensee determined that the L
imp. %s d% e aceive adequate. solution annealing heat treatment J
whim eu M in accelerated intergranular corrosion (IGC).
l Ale aW tou 'ied Crystal River Unit 3 of the deviation, SBi bn m F srmed an evaluation of the deviation, in accordance L
with QP, m a. ares, to support its conclusion that the deviation D
was i.x
,, S.able to other facilities with the same impeller material in environments subject to IGC.
2.
SBPI failed to provide notification to all licensees of the applicable nuclear power plants with pumps subject to shaft sleeve L
failures. SBPI informed the owners of Beaver Valley Power Station, L
Hillstone Nuclear Power Station, Palo Verde Nuclear Generating Station (PVNGS)andSouthTexasProjectElectricGeneratingStation (STPEGS) in a notification dated May 4, 1988 of failed wrought l
stainless steel center and throttle shaft sleeves. The notification was issued as the result of shaft sleeve failures due to l
intergranular stress corrosion cracking / hydrogen embrittlement (IGSCC/HE) at PVNGS and STPEGS. However, the notification failed to 9007190099 900711 O
.PDR QA999 EMVSULZB 99900031 PDC
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., ;. include Catawba Nuclear Station, which subsequently experienced a similiar. failure of;a shaft sleeve in an auxiliary feedwater system L.s pump as reported in LER 89-007, dated March 30, 1989.
1 3.
SBPI failed to adequately ey;1uate a deviation concerning pump impeller'weer ring failures. The initial failures occurred at Peach MMw Atomic Power Station and Browns Ferry Nuclear Plant in restfad hett removal (RHR) system pumps and were the subject of NRC Infortatics Notice No. 86-36 dated May 20, 1986. Based upon motnibygical examinatich performed on the wear ring fracture y
g surfaces, the licensees deterMned the presence of IGSCC. Although SBPI informed the owners of Peach Bottom Atomic Power Station, o,
l, Browns Ferry Nuclear Plant, Cooper Nuclear Station, Pilgrim Nuclear Power Station, and Vermont Yankee Nuclear Power Station regarding the failed stainless steel impeller wear rings, SBPI limited their L
evaluation to pumps used in only the RHR systems and as of February 8,1990 had not considered the adequacy of the source supplying the wear ring material or uses of the failed material in
.other environments where an IGSCC mechanism exist.
4.
SBPI did not adequately process deviations, which were handled as i
Technical Bulletins (tbs), pursuant to the provisions of 10 CFR Part 21. Numerous tbs (See paragrah 3.1.4 of Inspection Report 99900031/90-01) were reviewed wherein SBPI dispositioned issues that were deviations, as defined in 10 CFR Part 21, and as of February 8, 1990 had not evaluated the deviations, or provided notification to the applicable licensees.
5.
_SBPI-did not adequately process licensee notifications of deviations.
Problem notifications from licensees entered SBPI through one of two 1
points of contact; the Field Services Engineer or the Pump Parts i
Order Manager. As of February 8, 1990 neither individual in charge of these areas had received training in the requirements for processing deviations. -As a result, SBPI had not evaluated deviations or made notifications to licensees as required by 10 CFR L
Part 21.
This is a Severity Level III violation (Supplement VII).
B.
Section 21.31, " Procurement Documents," of 10 CFR Part 21, requires, in part, that each corporation shall assure that each procurement document for a basic component' specifies, when applicable, that the provisions of 10 CFR Part 21 apply, i
Contrary to the above, the following three purchase orders (P0s) are examples where SBPI failed to invoke the requirements of 10 CFR Part 21 h
in safety-)related P0s to subvendors of basic components or materials:
(90-01-02 1.
SBPI P0 No. 1-201290, issued to PED Manufacturing for safety-related impeller castings for STPEGS.
s 2.
SBPI PO No. 630648, issued to Action Arc Incorporated, and SBPI PO No. 630372, issued to Air Products, for welding electrodes used in welded repairs to safety-related impe11ers for the Diablo Canyon Nuclear Power Plant.
This is a repeat of Violation A.1 identified by the NRC during the previous inspection and documented in Inspection Report 99900031/84-01.
ThishasbeenclassifiedasaSeverityLevelIVviolation(SupplementVII).
-C.
Section 21.21. " Notification of Failure to Comply or Existence of a Defect," of 10 CFR Part 21, requires, in part, that each individual, corporation or other entity subject to the regulations adopt a)propriate procedures for either evaluating deviations or for informing tie licensee or purchaser of-the deviation.
Contrary to the above, SBPI Procedure A14.0, " Procedure for Reporting of Safety Related Noncompliance and Defects to Meet 10 CFR Part 21,"
Revision 6, dated January 26, 1990, did not (1) ensure that licensees or purchasers were informed of deviations so that the deviation may be evaluated regardless of contractual requirements; (2) ensure that product deviations were evaluated to determine whether a particular deviation could create a substantial safety hazard; and, (3) ensure that the bases for SBPI determining reportability, including the scope of the problem, was documented in the required evaluation package. (90-01-03)
This has been classified'as a Severity Level IV violation (Supplement VII).-
Pursuant to the provisions of 10 CFR 2.201, SBPI is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Chief, Vendor Inspection Branch, Division of Reactor-Inspection and^ Safeguards, Office of Nuclear Rec:: tor Regulation, within 30 days of the date of the letter transmitting this Notice of Violation.
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1)thereasonfortheviolation, or, if contested,-the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.
Dated at Rockville, Maryland this lith day of July 1990.