ML20059L432
| ML20059L432 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1990 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Hanner R PLANNED MAINTENANCE SYSTEMS |
| Shared Package | |
| ML20059L434 | List: |
| References | |
| REF-QA-99901101 EA-90-062, EA-90-62, NUDOCS 9009260318 | |
| Download: ML20059L432 (3) | |
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NUCLEAR REGULATORY COMMISSION 5
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September 13, 1990 i
Docke' Nc. 99901101/88-01 Enforcement Action No.90-062 Mr. Rodney C. Hanner, President Planned Maintenance Systems 1002-1004 Main Street i
Mount Vernon, Illinois 62864 i
Dear Mr. Hanner:
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This letter addresses the inspection of your facility at Mount Vernon, Illinois, led by Mr. J. J. Petrosino of this office on May 9-12, 1988.
i
.The NRC inspection focused on the concerns expressed in a 10 CFR Part 21 report that was transmitted to the NRC on April 1,1988 by the Wolf Creek Nuclear J
OperatingCorporationregardingthevalidity)ofCertificatesofCompliance (C0Cs) that Planned Maintenance Systems (PMS provided for safet"-related
' equipment. This inspection consisted of an examination of procedures and representative records, interviews with personnel and observations by the inspectors. The areas inspected, specific findings and references to the pertinent requirements are identified in the enclosures to this letter.
The inspection found that the implementation of your quality assurance (QA) 1 program failed to meet certain NRC requirements. The inspection findings
' included the following nonconformances:
the failure to perforin contractually required hardware qualification activities specified ir Standard 323 of the 1
institute of Electrical and Electronics Engineers (IEEE), the failure to l
adequately deliMate many of the IEEE 344 requirements to test laboratories, L
and the failure to maintain adequate records for quality-related activities involving safet/-related hardware supplied to customers.
The inspection also i
L revealed violaSiow by,PMS of the requirements of 10 CFR Part 21, specifically, PMS neither perirrmed an evaluation of deviations nor informed customers of the deviations as required by 10 CFR Part 21.
Further, PMS had inadequate pro-cedures to imple.nent 10 CFR Part 21 and failed to invoke 10 CFR Part 21 on subseopliers as required.
The most significant inspection finding was the identification of PMS-supplied L
C0Cs that incorrectly certified that PMS had satisfar.torily performed the required IEEE testing.
Furthermore, yuu made false statements to the NRC regarding the authenticity of Gould and Westingnouse C0Cs. You subsequently t
L admitted to falsifying thme COCs to make it appear that these products were qualified nuclear-grade cuponents even though you had full knowledge that the products deviated from the technichi requirements of the applicable procurement documents.
The violations described in the enclosed Notice of Violation havt been L
classified in accordance with the " General' Statement of Policy ancl Procedure-y CU bk.b hbh @l;f i
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Mr. Rodney C. Hanner "
Enforcement Action No.90-062
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forNRCEnforcementActions,"10CFRPart2AppendixC(1988). The Severity Level of Violation 2 has been escalated from a Severity Level III to a Severity l
Level 11 because a responsible officer of PMS, in this case the President of PMS, willfully modified documents and fraudulently misrepresented safety-related equipment to nuclea. power plants.
If an appropriate evaluation had been performed as required, a 10 CFR Part 21 report to the NRC may hav6 been required regarding the failure to perform the required IEEE-323 actioni and the fraudulent representation of comercial-grade products as safety-related.
The NRC strongly condemns such acts.
Furthermore, PMS failed to evaluate the md tiple failures to comply with the contractual requirements and knowingly and <,ntentionally modified COCs to fraudulently represent the comercial-grade products as safety-related products.
i A response tetailing your corrective actions for the violations is required.
However, the NRC understands that PMS is no longer conducting business activities with NRC licensees. Therefore, the required response is being held in abeyance until such time as PMS or Mr. Rodney C. Hanner plans to recomence business activity with any NRC-licensed facility.
If a reply is necessary, the
' reply should be submitted 60 days prior to Mr. Rodney C. Hanner or PMS under-taking any business activity with any NRC-licensed facility. When submitted, the reply should be clearly marked as a "Repiy to a Notice of Violation" and should include the folicwing:
(1) the reason for the violation, if admitted, (2) the corrective steps that have been taken and res"; x. hieved, (3) the corrnctive steps that will be taken to avoid further
.ns, and (4) the w id be addressed date when full compliance will be achieved. The rest - e to the US Nuclear Regulatory Comission, Attn: DocuL
't i v rol Desk,
- tion Branch.
Washington, D.C. 20555 with a copy to the Chief, Vendo.
Normally, you would also be requested to submit a.imil:r written statement for each item that appears in the enclosed Notice of Nonconformance. However, this request is also being deferred until such time as you or PMS recomence business with NRC licensees.
In accordance with 10 CFR Part 2.790 of the Comission's regulations, a copy of this letter and its enclosures will be placed in the NRC's Public Docuant Room.- The responses requested by this letter are not subject to the cleart.nce l
procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
l IL
SEPTFXBER 13, 1990 Mr. Rod 4y C. Henner
-3 Enforcet.ent Action No. 90 062 i
Should you have ee questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
/
C i
/
Q i
William T. Russell, Associate Director for Inspection and Technical Assessment
.e Office of Nuclear Reactor Regulation
'nclosures:
1.
Appendix A. Notice of Violation 2.
Appendix B. Notice of Nonconformance 3.
Appendix C. Inspection Report No. 99901101/88-01 cc: Mr. W. A. Alexander, Esquire Trout, Alexander, Popit and Warner 105 North Main Street Post Office Box 548 Benton, Illinois 62812 DISTRIBUTION:
- Central Tues?%
'PDR BKGrimes EWBrach JJ Petrosino (3)
KSullivan, BNL
'CVanDenburgh JTaylor BNL WRussell VIB R/F
+
Docket Files 99901101/88 01 DRIS R/F
- see previous concurrence s
OFC
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NAME :JJPetrosino:jh* :CVanDenburgh* :EWBrach*
- BKGrimer
- JLieberman:JGoldberg:WRussell
~DATE :06/).2/90
- 06/14/90
- 06/15/90
- 08/ /90
- 06/25/90 :08/ /90 : { /13/90
- EDO:
JTaylor-08/ /90 0FFICIAL RECORD COPY DOCUMENT: PLANNED MAINTENANCE !.ETTER
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