ML20056F215
| ML20056F215 | |
| Person / Time | |
|---|---|
| Issue date: | 07/16/1993 |
| From: | Norrholm L Office of Nuclear Reactor Regulation |
| To: | Bilanin A CONTINUUM DYNAMICS, INC. |
| Shared Package | |
| ML20056F216 | List: |
| References | |
| REF-QA-99901265 NUDOCS 9308260197 | |
| Download: ML20056F215 (4) | |
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1 July 16, 1993 l
l Docket No. 99901265 i
Dr. Alan J. Bilanin, President Continuum Dynamics, Inc.
P.O. Box 3073 Princeton, New Jersey 08543
Dear Dr. Bilanin:
SUBJECT:
NOTICE OF VIOLATION AND NOTICE OF NONCONFORMANCE 5
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(NRC INSPECTION REPORT NO. 99901265/93-01)
This refers to the inspection conducted by Messrs. R. L. Pettis, Jr.,
i K. R. Naidu and Ms. A. E. Cubbage of this office, and Mr. U. S. Rohatgi of Brookhaven National Laboratory on May a-5,1993.
The inspection included a review of activities authorized for your Princeton, New Jersey facility.
On June 4, 1993,, follow-up inspection was performed by Messrs. R. L. Pettis, Jr., and R. K. S. ahm, Jr., at the Electric Power Research Institute's)(EPRI's)'m Nondestructive Examination Center, located in Charlotte, North Carolina.
This was riecessary since the actual test configurations tested by Continuum Dynamics, Inc. (CDI) were assembled at this facility. At the' conclusion of the Princeton, New Jersey inspection, the findings were discussed Mit:i those members of your staff identified in the enclosed report. We also acknowledge receipt of your letter dated May 10, 1993, which provided additional information relating to the inspection.
The inspection was conducted to determine whether tests conducted by CDI, in support of the Boiling Water Reactors Owners Group (BWROG) Reactor Water Level Monitoring (RWLM) Long Term Program, were performed in accordance with your quality assurance (QA) program and applicable purchase order requirements, including 10 CFR Part 21 and Appendix B to 10 CFR Part 50 (Appendix B).
l Areas examined during the inspection are identified ir the_ report. This inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspectors.
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Dr. Alan J. Bilanin,
Based on the results of this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice of Violation (Enclosure 1).
Specifically, CDI's procedures for implementing 10 CFR Part 21 (1) did not adequately address evaluation and reporting requirements, (2) as written, may preclude the reporting of potentially safety significant deviations by employees, and (3) did not contain provisions to ensure that all affected licensees or purchasers are informed of deviations that cannot be evaluated by CDI.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice of Violation when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice of Violation, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In addition, during this inspection it was found that the implementation of your QA program failed to meet certain NRC requirements, as specified in the enclosed Notice of Nonconformance (Enclosure 2).
Specifically, CDI did not assure that calibration services for instruments, used to perform safety-related tests for the BWROG RWLM Long Term Program, were suitable for such applications and complied with the requirements of Appendix B, which were imposed on CDI by contract with EPRI. Additionally, CDI accepted calibrated instruments from two vendors without performing any assessments or surveys to verify that the suppliers' commercial quality programs and controls were effectively being implemented for the types of items / services purchased. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter.
Please provide us within 30 days from the date of this letter a written statement in accordance with the instructions specified in the enclosed Notice of Nonconformance. Note that our June 10, 1993, letter from Mr. Rossi requested that, prior to issuance of the final test report to EPRI, CDI evaluate the impact the above findings may have had on the test data obtained.
In your response to the NRC, please included the results of your evaluation.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
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Dr. Alan J. Bilanin "
The responses directed by this letter and the enclosed Notices are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Public Law No.96-511.
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eif J. Norb olm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation i
Enclosures:
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Notice of Nonconformance 3.
Inspection Report No. 99901265/93-01 cc:
Mr. Paul Blanch 135 Hyde Road West Hartford, CT 06117 Mr. Earnest Hadley 414 Main Street P.O. Box 3121 Wareham, MA 02571
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hh Dr. Alan J. Bilania July 16, 1993
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The responses directed by this letter and the enclosed Notices are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Public Law No. 96.511.
Sincerely, Leif J. Norrholm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation
Enclosures:
e 1.
Notice of Nonconformance 3.
Inspection Report No. 99901265/93-01 cc:
Mr. Paul Blanch 135 Hyde Road West Hartford, CT 06117 Mr. Earnest Hadley 414 Main Street P.O. Box 3121 Wareham, MA 02571 DISTRIBUTION: L il ' II.
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