ML20057A605

Responds to 930624 Notice of Violation & Insp Rept 99901260/93-01 on 930112-14

ML20057A605
Person / Time
Issue date:	09/13/1993
From:	Norrholm L Office of Nuclear Reactor Regulation
To:	Dudas N KLOCKNER-MOELLER
References
REF-QA-99901260 NUDOCS 9309150032
Download: ML20057A605 (3)

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UMlVED STATES NUCLEAR REGULATORY COMMISSION g

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j4g WASHINGTON. D C. 20555-0001 September 13, 1993 Docket No.

99901260 Mr. Nicholas Dudas, President Klockner-Moeller Corporation Corporate Headquarters (USA) 25 forge Parkway Franklin, Massachusetts 02038 i

SUBJECT:

RESPONSE TO NOTICE Of VIOLATION (NRC INSPEC.,0N REPORT NO..

99901260/93-01) AND PROPOSED FUTURE INSPECTION This is in reply to your letter of June 24, 1993, in which you responded to the Nntice of Violation and report of the inspection conducted by Messrs.

Stephen D. Alexander and Charles J. Paulk of this office January 12 through 14, 1993.

We found the corrective actions and preventive measures you 1

described to be responsive to our concerns. We have also reviewed your procedures adopted pursuant to 10 CFR Part 21 and found them to be consistent with the requirements of Section 21.21.

Implementation of the corrective actions and preventive measures you described will be reviewed and continued compliance confirmed in a future NRC inspection.

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This letter is also to confirm the telephone conversation on August 22, 1993, between Mr. Stephen Alexander of this office and Mr. Thomas Erskine of your staff, concerning the inspection at the Bonn facility and other facilities in Germany, as appropriate, during the week of September 20-24, 1993.

i As stated in our inspection report, the effectiveness of the reporting interface maintained with the K-M factory in order to support the Part 21 program was of concern to the inspectors.

Although no specific deficiencies were identified in this area during the inspection, the need was apparent to examine further K-M's system for acquiring, handling, and dispositioning failure information from the field in the U.S. as well as from the facilities in Germany.

Whether K-M's (USA) disposition of these issues was in compliance with 10 CFR Part 21 remains unresolved pending resolution of the reporting questions identified above.

Also, technical and linguistic ambiguities in K-M's root-cause analysis of the support lever f ailures need to be resolved.

In addition, we understand that f or f uture sales of K-M electrical equipment to U.S. nuclear utilities as basic components, National Testing Services, (NTS) Acton, Massachusetts, will become the principal (if not exclusive) supplier.

NTS is to maintain an interface with K-M in Germany and/or through you at K-M's U.S. facilities and K-M will be providing technical support to NTS as required to facilitate its commercial grade dedication activities.

Accordingly, NTS is expected to take credit for some K-M factory activities, such as commercial quality controls and some testing, such as interrupting capacity testing of molded case circuit breakers under its Underwriters 9309150032 930913 I%

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Mr. Nicholas Dudas Sept en be.r 13, 1993 Laboratories (UL)-489 or other program.

In dedicating K-M equipment for safety service, such NTS activities constitute or are related to activities affecting quality.

Therefore in addition to resolving the technical and Part 21 issues stated above, the NRC has identified the need to review K-M activities in Germany in support of NT5's dedication orograr during an NRL inspection.

This inspection would of necessity be of limited sc ope and it is our intention to minimize the impact on the K-M staff to the extent we are able, consistent with our ability to resolve the issues in question.

We would also be pleased to have you and/or your representatives present at this inspection if you so desire.

However, in any case, we would appreciate information on the appropriate persons to contact at your German facilities so that we may correspond with them as well.

Your cooperat ion concerning this n'atter will be appreciated.

If your have any question < please contact Stephen Me> ander at (301) 504-2995.

5;ncerely, i

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LeifJ[Norrholm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation 1

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P Niholas Dudad. September 13, 1993

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Laborat ories (UL)-489 or other program.

In dedicating K-M equipment for safety service, such NTS activities constitute or are related to activities f

affecting quality.

t Therefore, in addition to resolving the technical and Part 21 issues stated f

above, the NRC has identified the need to review K-M activities in Germany in i

support of NTS's dedication program during an NRC inspection.

This inspection would of necessity be of limited scope and it is our intention to minimize the impact on the K-M staf f to the extent we are able, consistent with our ability to resolve the issues in question.

We would also be pleased to have you and/or your representatives present at this inspection if you so desire.

However, in any case, we would appreciate information on the appropriate persons to contact at your German facilities so that we may correspond with them as well.

l Your cooperation concerning this matter will be appreciated.

If your have any i

questions please contact Stephen Alexander at (301) 504-2995.

Sincerely, Leif J. Norrholm, Chief Vendor Inspection Branch i

Division of Reactor Inspection l

and Licensee verformance Office of Nuclear Reactor Regulation l

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