ML20058M209
| ML20058M209 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20058M199 | List: |
| References | |
| REF-QA-99900912 NUDOCS 9312200197 | |
| Download: ML20058M209 (2) | |
Text
,
NOTICE OF VIOLATION National Technical Systems, Incorporated Docket No. 99900912 Acton, Massachusetts Report No. 93-01 During an NRC inspection conducted July 6-9, 1993, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1992), the violation is listed below:
Section 21.21(a) of 10 CFR Part 21, " Reporting of Defects and Noncompliance,"
requires, in part, that each individual, corporation, or entity subject to the regulations in this part adopt appropriate procedures to ensure the proper
~
evaluation of deviations and failures to comply and reporting of defects and failures to comply related to a substantial safety hazard to a director,or responsible officer in accordance with certain time requirements and that an interim report is made to the NRC if the evaluation cannot be completed in the required time.
Section 21.6(b), " Posting Requirements," requires in lieu of posting the regulation and the procedures adopted pursuant to the regulation, that in addition to Section 206 of the Energy Reorganization Act of 1974, a notice be posted that (1) describes the regulation and the procedures, (2) states where they may be viewed, and (3) gives the name of the person to whom reports may be made.
Contrary to the above, as of July 9,1993, the effective revisions of National Technical Systems, Incorporated, (NTS) procedures (Section V of the NTS Quality Assurance Manual and Quality Assurance Procedure QAP-1), adopted pursuant to 10 CFR 21.21, would not, as written, ensure proper evaluation and reporting. The procedures inappropriately required employees to report
" defects that could create a substantial safety hazard in a nuclear power plant," a determination employees could not be expected to make; yet, the procedures did not specifically require employees to report to management deviations from technical procurement specifications (so that they could be evaluated), a determination employees could make. Also, the procedures had not been updated to include certain provisions required by the version of 10 CFR Part 21 that became effective October 29, 1991, which had instituted substantial changes in evaluation and reporting requirements.
In addition, the NTS posted notice, pursuant to 10 CFR 21.6 and prescribed by QAM Section V, did not state where the procedures (specifically QAP-1) could be viewed and did not give the name (or title) of the person to whom reports should be made.
This is a Severity Level V Violation (Supplement VII). 9312200197 931202 99 EECN s
00
I Pursuant to the provisions of 10 CFR 2.201, NTS is hereby required to submit a l
written statement or explanation to the U.S. Nuclear Regulatory Commission, i
ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Chief, j
Vendor Inspection Branch, Division of Reactor Inspection and Licensee t
Performance, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply l
should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, 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 i
given to extending the response time. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
v t
l l';
i l
i e
Dated at Rockville, Maryland this 3 06 day of December 1993.
= _ - -
l NOTICE OF NONCONFORMANCE r
t National Technical Systems, Incorporated Docket No. 99900912 Acton, Massachusetts Report No. 93-01 Based on a Nuclear Regulatory Commission (NRC) inspection conducted July 6-9, 1993, it was found that certain of your activities were not performed in accordance with NRC requirements imposed on you by purchase order contracts l
with NRC licensees or their contractors.
i Criterion III, " Design Control," of Appendix 3 to Title 10 of the Code of Federal Reaulations (10 CFR Part 50), requires that design basis requirements be properly translated into design output documents (i.e., drawings, instructions and procedures).
Criterion V, " Instructions, Procedures and Drawings," of Appendix B to 10 CFR Part 50, states, in part, " Activities affecting quality shall be prescribed by instructions procedures, or drawings appropriate to the circumstances."
l I
Criterion Vll, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50, states, in part, " Measures shall be established to assure that purchased material.... whether purchased directly or through contractors and subcontractors, conform to the procurement documents."
Contrary to the above, procedures, prepared by National Technical Systems, Incorporated, for dedication testing of K16ckner-Moeller molded-case r.ircuit breakers for safety-related service at the North-Anna Power Station, an i
activity affecting quality, were not appropriate to the circumstances and did not properly incorporate design requirements because they did not specify a minimum duration for the full-load hold-in test for the breakers.. There was no documented evidence that the breakers had been adequately verified to conform to the operability specification in the procurement documents with respect to this function and there was evidence that the test had been conducted for an inappropriately short time. (93-01-02)
Please provide 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 Licensee Performance, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should include for each nonconformance:
(1) a.
description of steps that have been or will be taken to correct these items, (2) a description of steps that have been or will be taken to prevent recurrence, and (3) the dates your corrective actions and preventive measures were or will be completed.
Dated at Rockville, Maryland i
this 3 % ay of December, 1993 d
l l
?