ML20058M197
| ML20058M197 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/1993 |
| From: | Norrholm L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Fredkin N NTS (NATIONAL TECHNICAL SYSTEMS) |
| Shared Package | |
| ML20058M199 | List: |
| References | |
| REF-QA-99900912 NUDOCS 9312200193 | |
| Download: ML20058M197 (3) | |
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't UNITED STATES l
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NUCLEAR REGULATORY COMMISSION
- f WASHINGTON D.C. 20555 0001
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December 02, 1993 Docket No. 99900912 i
Mr. N.J. Fredkin, Jr., Vice President National Technical Systems Nuclear Services Group 533 Main Street Acton, Massachusetts 01720
Dear Mr. Fredkin:
SUBJECT:
NOTICE OF VIOLATION AND NOTICE OF NONCONFORMANCE (NRC INSPECTION REPORT NO. 99900912/93-01)
This refers to the U.S. Nuclear Regulatory Commission (NRC) inspection conducted July 6 through 9, 1993, by Messrs S.D. Alexander, G.C. Cwalina, and
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K.R. Naidu and Ms. A.M. Dummer of this office of your facility at Acton, Massachusetts, and to the discussions of our findings with you and members of your staff at the conclusion of the inspection.
Areas examined during the inspection are identified in the report. Within 1
these areas, the inspection consisted of selective examination of procedures and apresentative records, review of technical documentation, interviews with personnel, and observations by the inspectors.
The major areas reviewed l
included (1) implementation of your quality assurance (QA) program based on Appendix B to Part 50 of Title 10 of the Code of Federal Reculations (10 CFR Part 50), (2) implementation of your program for reporting of defects and noncompliance pursuant to 10 CFR Part 21 (particularly as these programs relate to the dedication, including seismic and environmental qualification, of commercial grade items for use in nuclear safety-related applications),
with emphasis on electrical equipment manufactured by K16ckner-Moeller (K-M),
GmbH, of Bonn, Germany, and (3) selected equipment qualification projects and information pertinent to the NRC's ongoing survey of industry and regulatory issues in this area.
l Based on the results of this inspection, certain parts of your 10 CFR Part 21 implementation program appeared to be in violation of NRC requirements, as l
specified in the enclosed Notice of Violation (Notice). The violation of 1
10 CFR Part 21 is related to your procedures adopted pursuant to the j
regulation (1) establishing the threshold for employee reporting so high as to j
preclude in effect such reporting as the procedure was written and (2) not j
containing certain provisions required by the version of the regulation that became effective on October 29, 1991.
It also was noted that your 10 CFR j
Part 21 posted notice as prescribed by your procedures lacked certain items i
required by the regulation.
However, the inspectors found no instances in which your other practices or records were not in accordance with 10 CFR Part 21; nor did the inspectors identify any instances in which potential Part 21 issues were not properly dispositioned. The specific findings and j
references to the pertinent requirements are identified in the enclosed Notice and inspection report. Subsequent to the inspection, we reviewed your draft NTS 00eedpq pk%ub/ des i
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uu2 wa Hwk-r pa s u a u u a m e n Y n os abur m
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N.J. Fredkin December 0 2, 1993 I
revision to QAP-1 and, in conjunction with your answers to certain questions about it by telephone, we found that it addressed our principal concerns.
Also, during this inspection, it was found that the implementation of your QA program failed to meet certain NRC requirements.
Specifically, your procedures for dedication testing of certain K-M molded-case circuit breakers for the North Anna %wer Station did not specify a minimum duration for the full-load hold-in test, and the inspectors learned that the test was apparently conducted for an inappropriately short time.
An unresolved item of concern was the out-of-tolerance tripping of certain K-M overload relays attributed to age.
The inspectors were not able to determine during this i
inspection the basis for the K-M revised trip time tolerances, nor what other installations might be affected oy relays with similar age / shelf-life-shifted i
I performance characteristics.
l You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional l
actions you plan to prevent recurrence. After reviewing your response to the Notice, 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.
You are also requested to respond to the enclosed Notice of Nonconformance, which is based on the deficiencies in the implementation of your QA program as identified in the enclosed report.
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.
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.
The responses requested by this letter and the enclosed Notice 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.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Si
- erely,
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.s gm feifJ.'Norrholm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation
Enclosures:
(1) Notice of Violation (2) Notice of Nonconformance (3) Inspection Report 99900912/93-01
O Q
N.J. Fredkin December 0 2, 1993 i
DISTRIBUTION:
" DOCKET FILES
CENTRAL FILES PDR RIDS CODE IE:09 VIB R/F i
DRIL R/F DSSA/SPLB r
t
- See previous concurrence.
0FFICE RIS2:VIB SC:RIS2:VIB BC:VIB:DRIL D:DFh:NRR NAME Salexander*
Gewalina*
LNorrholm*
M zP DATE 11/22/93 11/22/93 11/23/93 h/5/93
/
7/ /93 COPY YES ((.., k )
YES NO kES' N
YES NO
~
OFFICE RIS2:VIB DSSA:SPLB Tech Editor NAME KNaidu*
ADummer*
DGable*
1 DATE 11/23/93 11/23/93 9/21/93 s
COPY YES YES OFFICIAL RECORD COPY Document Name:
G:\\ALEXANDE\\N1S.IR
)
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