ML20056D966
| ML20056D966 | |
| Person / Time | |
|---|---|
| Issue date: | 06/21/1993 |
| From: | Cwalina G, Naidu K Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20056D965 | List: |
| References | |
| REF-QA-99901266 99901266-93-01, 99901266-93-1, NUDOCS 9308190093 | |
| Download: ML20056D966 (6) | |
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ENCLOSURE ORGANIZATION:
Huron Industries, Incorporated l
REPORT NO.:
99901266/93-01 CORRESPONDENCE ADDRESS:
2301 16th Street P.O.
Box 610104 Port Huron,-Michigan 48060 l
ORGANIZATIONAL CONTACT:
Ms. Debra A. Sullivan, Q.C. Manager (313) 984-4213 NUCLEAR INDUSTRY ACTIVITY:
Manufactures and supplies commercial-grade pipe-thread lubricant and sealant t
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INSPECTION June 2-3,,[$993 CONDUCTED:
TEAM LEADER:
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'! b-K.R. NaidL, Team Leader Date Reactive Inspection Section 2 (RIS-2)
Vendor Inspection Branch (VIB)
OTHER INSPECTOR:
Joseph J. Petgosi o, RIS-2: VIB-dd/ J APPROVAL:
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dregory,C.
Cwalina, Chief Date RIS-2, VIB Division of Reactor Inspection and' Licensee Performance INSPECTION BASES:
10 CFR Part 21 and 10 CFR Part 50, Appendix B INSPECTION SCOPE:
To review licensee purchase orders, related records, and associated activities of Huron Industries, Inc.
PLANT SITE APPLICABILITY:
Numerous j
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1 INSPECTION
SUMMARY
Huron Industries, Inc. (Huron) supplies only commercial grade items to nuclear power plants for which compliance to 10 CFR Part 21 and 10 CFR 50, Appendix B is not required.
2 STATUS OF PREVIOUS INSPECTION FINDINGS.
This is the first NRC inspection at this facility.
3 INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Entrance and Exit Meetings On June 2, 1993, during the entrance meeting, the NRC inspectors discussed the scope of the inspection and the areas to be reviewed with the Quality Control (QC) Manager.
On June 3,
- 1993, during the exit meeting, the inspectors discussed their conclusions with the QC Manager.
3.2 Backaround Huron supplies a line of commercial-grade pipe-thread lubricants and sealants to military, nuclear steam supply system suppliers and nuclear power plants that includes the following:
Pipe-Lubricant Neolube No. 1 (DAG-156).
Acheson Colloidals (Acheson) manufactures this compound and supplies it to Huron in 55-gallon drums.
Huron repackages it in 2 and 8 ounce plastic containers.
Before dispatching the drum (s),
Acheson collects samples of the compound and sends them to an independent testing laboratory to verify that they meet the requirements of Military Specification (MIL)-L-24131B,
" Lubricant, Colloidal Graphite In Isopropanol."
Huron does not recommend the use of Neolube 1 on fittings in areas where the operating temperatures are greater than 400*
Fahrenheit.
Dryfilm Pipe-Thread Lubricant Neolube No. 2 (DAG-154).
Acheson manufactures and supplies a concentrated mixture of j
Neolube No. 2 in 55-gallon drums.
Huron dilutes this with certified alcohol meeting Federal Specification TT-I-735A using a proprietary formula and repacks the mixture in 2, 16, 32 and 128 ounce containers.
Neolube No. 2 is extensively used as an anti-seize lubricant in a variety of applications in commercial nuclear power plants and military applications.
On request, Huron sends samples of this product to an independent testing laboratory to verify conformance to MIL-L-24131B.
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y Neolube Pipe-Thread Sealant No. 100.
Loctite Corporation (Loctite) manufactures and packages one of their products for Huron in plastic tubes as Neolube 100.
This product is light paste sealant which seals threaded pipe, plugs and a
fittings.
In the absence of oxygen, and at above room l
temperature it cures efficiently.
The manufacturer guarantees each batch of this product for a shelf life of one year when stored at the specified temperature.
When a customer requests an extension, the manufacturer retests the sealant and extends the shelf life if the specimen is found to have retained its original properties.
At the bottom of the tube, the manufacturer imprints a code number from which the year and month of manufacture, the manufacturing plant and the batch number can be deciphered.
For example, 3GN468 denotes the products was made in 1993, G the month during which it was manufactured (in July), N the plant where it was manufactured and 468 denotes the batch.
Neolube Pipe-Thread Lubricant No. 650.
Union Carbide manufactures this product in 55-gallon drums and ships it to a packaging company where it is packaged for Huron in small containers and is sold as a high temperature anti-seize paste.
It is composed of graphite and petroleum based carrier.
Huron recommends Neolube No. 650 for use as a lubricant in close fitting threaded joints of two inches and smaller diameter pipe size in service applications where high temperature and high pressure or both are experienced.
Neolube Pipe-Thread Sealant No. 1260.
Union Carbide also manufactures this product in 55-gallon drums and ships it to a packaging company where it is packaged for Huron in small containers and is sold as a high temperature anti-seize paste.
This product is a pipe-thread sealant and is composed of graphite and petroleum based carrier.
Huron recommends Neolube No. 1260 for use in close fitting threaded joints of two inches and smaller, and in service applications where high temperatures and high pressures or both are experienced.
3.3 Review of Huron's Ouality Assurance Procram Huron's QA Manual, Revision 3 of October 27, 1988, has been developed to comply with MIL-I-45208A, " Inspection System Requirements."
The inspection team reviewed the QA program requirements at Huron that were delineated in its QA Manual.
Some of the Sections that were reviewed included the following:
Design control appears to be based on the manufacturer's specifications which in turn have to meet Military Standards.
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1 The manufacturer collects and sends samples of the material
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manufactured to an independent testing laboratory for confirmation that the product meets the relevant Military Specifications (MIL-Specs).
After the test results'are determined acceptable, the material is shipped to Huron.
In addition to these tests, if a purchase order (pO) specifies certification by an independent testing laboratory, Huron
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collects and sends samples to a test laboratory designated i
by the customer.
The team determined that Huron utilizes I
four different laboratories to independently test samples of' lubricants and sealants routinely, and when specifically requested.
j Receipt inspections.
Huron indicated that it inspects incoming material to ascertain if the materials meet the specifications in the PO as documented in the certificate of conformance.
Huron stated that the results of the inspection are documented in receipt inspection reports which identify the item inspected, the number of the PO, batch number, lot size, sample size, quantity, condition, certification and leakage, if present.
Huron personnel also j
apply stickers to the containers of the accepted material for identification and traceability.
The team reviewed the Deficiency Reports in which Huron f
documented conditions adverse to quality.
The inspectors observed that the actions taken to correct the adverse f
conditions were adequate to prevent recurrence.
3.4 Review of Procurement Document Control The inspectors selectively reviewed procurement documents which included licensees' POs to Huron, Huron's internal invoices to specify the respective quality requirements and the required
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certificates of compliance.
The inspectors determined that Huron i
has developed a computer program with controls to ensure compliance with the quality requirements in the POs.
For example, an interlock in the accounting computer program prevents further processing of a purchase order which specified special test and verification requirements.
In such cases, the program reminds the operator of the special requirements.
The operator i
then enters the customer's special requirements in Huron's shop i
order.
3.5 Control of Measurina Eauionent During the visit to Huron's facility in Jeddo, Michigan, where it f
packages sealants and lubricants, the team observed that Huron i
uses an Ohoius Triple Beam Balance to weigh the bottles it fills with sealant or lubricant.
Huron has established internal 4
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controls to verify the accuracy of the balance and stated that it t
has the unit calibrated annually by an outside calibration agency.
3.6 Review of Corrective Action The inspectors reviewed six Deficiency Reports that had been generated between 1989 and 1992 to document conditions adverse to t
quality and noted that Huron had taken actions to correct and l
disposition them.
3.7 Review of Audits Performed The inspectors reviewed the audits performed by Wolf Creek l
Nuclear Operating Corporation, Carolina Power & Light company, j
Gulf States Utilities Company, Niagara Mohawk Power Corporation t
and Entergy Operations, Inc. to qualify Huron as'an acceptable commercial-grade item supplier for their respective nuclear power l
plants.
The audits indicate that Huron's quality assurance program was evaluated and determined to be acceptable.
Therefore it was qualified as a commercial-grade supplier for its lubricantsLand sealants.
Other utilities qualified Huron based on written answers to surveys.
3.8 Stated shelf Life The NRC inspectors conducted discussions with the QC Manager regarding product shelf life and reviewed the Huron technical data sheets for each of their products and the associated certificates of conformance (CoCs).
During this discussion and
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review, the team observed that the stated shelf life in the CoC was different from the manufacturer's recommendations in the technical data sheets for three Huron products, specifically:
Neolube Thread Sealant No. 100; Neolube Pipe Thread Lubricant No.
650; and Neolube Pipe Thread Sealant No. 1260.
The technical data sheet for Neolube Thread Sealant No. 100 stated that the shelf life at 72 degrees-Fahrenheit is 1-year minimum.
However, Huron's CoC stated that the shelf life was 1-year, and that recertification after expiration date is available upon request.
The technical data sheet for Neolube Pipe Thread Sealant No. 650 stated that the shelf life was a minimum of two years from-date of first use.
However, Huron's CoC stated that the shelf life was two years, the material may be satisfactory if soft in tube, and that recertification after the expiration date is available upon request.
The technical data sheet for Neolube Pipe Thread Sealant No. 1260 stated that the shelf life was a minimum of two years from date of first use.
However, Huron's CoC stated that the shelf life 5
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was two years, that the material may be satisfactory if soft in tube, and that the shelf life may be extended after the expiration date by submitting a sample tube for retesting.
The team was mainly concerned with the shelf life that was stated on the technical data sheets because an NRC licensee may file the product CoCs in their QA record filing area and transmit the j
technical data sheets for use by installing organization personnel without the benefit of the CoCs.
Consequently, the difference in the shelf life recommendations that Huron stated in its documents may not be recognized and the installing organization may rely on the more relaxed, less conservative, shelf life that was stated on the Huron technical data sheets.
The team discussed this difference in the characterization of the shelf life with the QC Hanager and 4.ts scenario of possible misuse by licensee rtaff as a result of the differences in stated shelf life.
As a result of the discussion ruron committed to the NRC team to research the manufacturer's min. mum and maximum shelf life recommendations, correct the technical data sheets as required and to send any corrected technical data cheets to all of its affected customers.
The team concluded that Huron's commitment to resolve this matter satisfactorily resolves the NRC inspection team concern.
4 PEREONNEL CONTACTED D. A.
Sullivan, QC Manager L.
Meddaugh, Quality Technician K.
Sexton, Administrative Assistant i
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