ML20079J345

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Procedure NPM7, Procedure for Reporting of Defects of Noncompliance on Nuclear Orders
ML20079J345
Person / Time
Site: Mcguire, Catawba, McGuire, 05000000, 05000360
Issue date: 01/13/1984
From:
DUKE POWER CO.
To:
Shared Package
ML20079J318 List:
References
NPM7, NUDOCS 8401240297
Download: ML20079J345 (11)


Text

{{#Wiki_filter:. NELSON ELcCTRIC BM Mo STAXDiF,L3 HeNPM. /

                   $UBJECi PROCEDURE 'iCR REPORTING OF DEFECTS OR NONCOMPLIANCE ON NUCLEAR ORDERS STAND /.RD PRACTICE I. PUPSOSE:                                             -CONTROLLED COPY             9N jg        :                  The purpose of these procedures is to ensure compliance l?         g                with Section 206 of the Energy Reorganization Act of d        1974 and Nuclear Regulatory Commission Regulation 10, CFR M. 7      .is                Part 21, as amended, (the " Regulation").

I

         ;                      II. SCOPE:

I i These procedures apply whenever this Company manufactures and/or supplies a " basic component" for use in any facility l or activity which is licensed or otherwise regulated

         .        I                   pursuant to the Atomic Energy Act of 1954, as amended, or l         l                    the Energy Reorganization Act of 1974                         Such facilities and activities include not only nuclear pcwer reactors, i

but also facilities and activities involving nuclear by-

 . i
        '                             product material, source material, special nuclear material, the packaging of radioactive material for transport and j

fuel cycle facilities, licensed under 10.CFR Parts 30, 40, 50, 70, and 71. I ' I When applied to products manufactured or supolied for use

        ;                              in nuclear power reactors, " basic components means a i                              plant structure, system, component or part thereof, neces-sary to assure:
1. The integrity of the reactor coolant pressure boundry(1) oisTR I
2. The canability to shut down the reactor and maintain it in a safe s.nutdown condition or us. l 1 3. The capability to prevent or mitigate the consequences gP- l  !

of accidents which could result in potential off site

   ?r#                                    -exposures comparable to those referred to in 10 CFR, tev.               _

CH. 1, Section 100.11.(2) i$  ! I tems  ! When applied to products manufactured or supplied for use scas '  ! in regulated facilities and activities other than nuclear eram !  : power reactors, " basic componen t" means a component, struc-ss.  ! i ture, system or part thereof that is directly procured by as i the licensee of such facility or activity and which, if ' Lore l i defective or not in compliance with any applicable regula-

   ;M i                               tian, order or license of the Nuclear Regulatory Cecmission, scac '                             could create a substantial safety hazard. This second on i                 -

definition limits the supplier organizations subject to F? ! Part 21 to these that directly supply the material and fuel fh! w _

                        ,            cycle licensees.
  . T A-                ;            (1)         Appendix A contains the 10 CFR, Ch. I, Section 50.2(v) definition of " reactor coolant pressure boundary".

(2) Appendix B contains 10 CFR, Ch. I, Section 100.11 8401240297 840113 PDR ADOCK 05000369 cr i Atto im.r: ev i cart A m evt: - -: - . S PDR

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.* NELSON ELECTRIC STANDAP.is N?nPs: ~ SUSJECT PROCEDURE FOR REPORTING OF DEFECTS OR NONCOMPLIANCE FOR NUCLEAR ORDEI In all cases, " basic cecponent" includes design, inspection testing or consulting services important to safety that are ii  : associated with the component hardware, whether the service: Ii s are perfor=ed by the component supplier or others.

               !                      A " commercial grade ites" is not a part of a basic componcn:

j until after " dedication". The term " commercial grade item" I means an item that is:

1. Not subj ect to design or specification requirements that are unique to facilities or activities licensed j by the NRC (3) and
2. Used in applications other than facilities or activitie:

licensed by the NRC (3) and , l 3. To be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer's published product description (for example , a catalogue'

        -l          .

Suppliers of commercial grade items are exempt from prov sions of 10 CFR Part 21 to the extent that they supply such items. An item .i.s " dedicated" and reporting obligatio: l beS i n with the organization that designates the commercial grade item for use as a basic component of nuclear appli-cation. III. NOTICE TO EMPLOYEES / POSTING REOUIRE?ENTS The Vice President / General Managers of CPD and PDP shall DISTR. I be responsible for notifying their personnel of the require

. I I ments of Section 206 of the ERA of 1974, 10 CFR Part 21 and
            .es. l    I            these procedures and for their department's compliance with 5            I            these provisions.       The General Managers shall ensure that
            $"F#I I                   all of'their division's sales representativcs are informed rev. I                    about these provisions.

3 I teasl The Quality Assurance department shall be responsible for seas I posting current copies of the following documents in n=1 conspicuous positions, e.g., bulletin boards on all the ssa. I Comnany's premises, including manufacturing plants and

           .a s. I                 offices within the United States where activities subject s.tTol                     to 10 CFR Part 21 are conducted.

ag llcm ;, 1. HRC 10 CFR Part 21

           ' av i                     2. Section 206 of ERA of 1974
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                                                                                                                                           \

(3) Licensed pursuant to 10 CFR, Ch. I, Parts 30,40,50, ut 70 and 71. L"l.;.?;* i at..e::s . avurm ! *act cyt:_ isr t: ev i  : Art 3,. evt: _ 7

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  • NELSON ELECTMC .

STANDA! IDS

                                                    .                                                                   No. Nex750.m SUBJECT                                                                                        4

( PAGE $ PROCEDURE FOR REPORTING OF DEFECTS OR NONCOMPLTANCE FOR NUCLE ^R ORDERS of "l_ III. NOTICE TO EMPLOYEES / POSTING REQUIP.EMENTS (Cont'd)

    ! l[
    ..                              3.      These procedures y                              4.      ilames of Company individuals to contact when ther:                                 '
   .   . .x     ;

are any questions concerning Part 21. i 'IV. NOTICE OF 10 CFR PART 21 PURCHASE ORDERS AND CHANGES I l

                '                   Sales / Marketing personnel shall promptly notify the
       ,                            General Managers whenever they receive a purchase order I                            that specifies that the provisions of 10 CFR Part 21 l-                           are applicable.

1 ' Intnediately upon receipt of the Part 21 purchase order, , the General Managers shall notify the Director of Engin-eering and the Vice President of Manufacturing and the Director of Quality Assurance'of the order and shall 1- deliver a copy of the order to the Director of quality I As sur ance . In addition, if the General Managers believe l that the items to be supplied by the Comcany" are "commer-I cial grade items" and not " basic components subject to Part 21, he should contact the firm issuing the Part 21

                  .                  purchase order (the " Purchaser") to seek the Purchascr's written agreement that Part 21 does not apply to that particular order. Section 206 of the ERA o. 1974, 10 CFR Part 21 and these procedures shall apply to any such Part 21 purchase order unless and until this Company msTn.                                receives the Purchaser's wricten statement that 10 CFR 1                           Part 21 does not apply.
s 1 ~')

Pi The Marketing / Sales department shall be responsible for.

 $i                                   ensuring that Part 21 general orders contain the following
v. I information:

A i uns t 1. Name and address of the Purchaser; Name and address of the ultimate customer / owner; [ st i 2.

3. Name and address of the actual job or facility /
 + i                                          activity where the item will be used or installed;
  . co.1
4. Purchaser's purchase order number and any special

, s markings;

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The ultimate customer / owner's purchase order number av i 1 5. fyr i i and any special markings ;

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6. Appropriate dates, including order entry, shipping, "on site" inspection, etc.;

r^' 7. A complete descriptien of the products on the. purchase order to which 10 CFR Part 21 applies; e,n i g, e I o,n

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sngms NEW nmc 108 JECT b NPM750 PROCEDURE FOR REPORTING DEFECTS OR !!ONC09T T A? re vno NT7ct r a o ORDERS - of IV. NOTICE OF 10 CFR PART 21 PURCHASE ORDERS AND CHANGES (Cont'd) o . B. A list of all engineering and quality control specifi-A

         !      j.                       cations that apply; 4                               NOTE:

I +pNd I N. Special care shall be given to any equip =ent qualification or use testing that is required. (This will commonly be referred to as " Equipment must ecoply with IEEE 323-1974"1 If this testing has not already been done it can be quite expensive and money =ust be included to cover the costs.

9. Notification that 10 CFR Part 21 applies ar.d the
  ,                   ;                  certification of compliance notice;
10. The name, address and telephone number of'the individuals representing the Purchaser and/or ultimate customer / owner
     -                                   who shall be contacted in case of defects or noncompliance or if necessary for evaluation of deviations and any special instructions concerning defects, noncompliance or evaluation of deviations; i                    11. A notation that the -order is to be inspected by the I

Company's Quality Assurance department before shipment;

12. A notation that the order must be shipped directly from the Company, not from any national warehouses unless special arrangements are made with authorization frc=

the Director of Quality Assurance. The Marketing Manager shall ensure that all sales personnel ynx are aware of the above shipping restrictions on Part 21 purchase orders. A copy of the Marketing Manager's notice / 3 directive covering that subject shall be on file with the

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Quality Assurance department, The Vice President of Manufacturing or his designee, shall

  -{[                              ensure:     .(1) that all of the Company's procurement dccuments
    .                              for basic components subj ect to 10CFR Part 21 clearly specify
    ,,                             that "THE PROVISIOliS OF 10 CFR PART 21 APPLY", (2) that all
    .,;'                           of the Company's Part 11 procurement orders contain the infor-mation (items 1-12) above required to be included on Part 21

[, purchase orders, (3) that the Cc=pany's vendors are properly gg i notified to report any defec ts _ (i . e. , a deviation that could 7 , create a subs tantial safety hacard) or noncompliance in basic

   ;4 ;;                           components previously sent to the 'Compant and -(4). that a '
                  ,                lecter in the form of A 7pendix C accompanies each of the p;            l Company's Part 21 procurement orders.

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NELSON ELECTRIC b10NPM750.0i STil(DAns racU suancT eg 19 PROCEDURE FOR REPORTING DEFECTS OR NONCOMPLIANCE FOR NUCLEAR ORDERS , The Director of Engineering shall ensure that all Engineering functions including design, stress analysis, material selec-

           =

tion a'nt any other design area are performed in strict

            ;                                   compliance with all applicable specifications , procedures and
      ; p                                       requirements relative to any nuclear basic component to be f l R "~                                     designed, manufactured and/or supplied.by the Company. This sh 11 include any material qualification documents required
      !                                         by purchase order in reference to IEEE standards.

The Vice President of Manufacturing and the Director of Quality Assurance each shall ensure that the activities of their respective departments are in strict compliance with all specifications, procedures and requirements for the I~ design, manufacture and/or ~ supply of nuclear basic components. I_ . V. REPORT ALL NONCOMPLIANCE AND DEVIATIONS FROM TECHMICAL SPECIFICATIONS /REQU1REMENTS doncompliance refers to any failure to comply with the

       -                                         Atomic Energy Act of 1954, as amended, or any applicable l                                         rule, regulation, order or license of the Nuclear Regualtory Co: mission relating to a subs tantial safety hazard. "Devia-tion" means a departure from the technical requirements included in a procurement document.(4)

It is in the Company's bestThis interest to discover deviations is because the Company's before items are shipped. obligation to report to the U.S. Nuclear Regulatory Con =ission only applies to ccaponents that have been celivered to a I Purchaser. mt. ' i Any employee that learns of or suspects that there has been a Tailure to comply wit.h any URC rules , regulations er crders

 -!                    I or that the design, manufacture or supply of a basic compon-
 -1                    i ent, including already shipped, deviates from technical specifications / requirements or contains a substantial safety i

i l hazard, shall immediately report such deviation or noncom-w pliance to the Director of Quality Assurance or in his absence, si the Director of Engineering. m.I I i t (4) A " procurement document" means a contract that defines

  .70.1 i

the recuirements which basic components must meet in 7: : orcer to be considered acceptable by the Purchaser.

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NELSON ELECTP N o. NPa7 f c . c,. SIAEAm

                                                                                                                              . pSc., e SUS >ECT I    f,e I ou       z.

PROCEDURE FOR REPORTISG DEFECTS OR NONCOMPLIANCE FOR HUCLEAR O __ Ic=ediately upon being notified of any such deviation or noncomoliance, the Director of Quality Assurance or in his absenc'e, the Director of Enginee' ring,' or their designees , [ I' shall prepare a notice of deviation / noncompliance. The the following information:

     '6 f.]" C , notice shall include at least
1. Name, job. description and department of the reporting employee;
2. Identification of the nuclear cower clant or cther regulated or licensed facility' or ac'tivity for which the basic component is being designed, manufactured l

and/or supplied; l_ 3. Identification of the basic component (s) containing the deviation and/or affected by the noncompliance;

4. Nature of the deviation or f ailure to co= ply and the safety hazard which is created or could be created by such deviation or failure to comply;

_I

5. The date on which the information of such deviatica
           ,         3 or f ailure to comply was obtained; l

I 6. The number and location of all such basic cocoonents supplied for or being supplied for'one or more facilities or activities suoject to 10 CFR Part 21; in use at, 1

7. The corrective action which has been, is being or will be taken, the name of the individual and/or department responsible for the corrective action and the length of msu  !

time that has been or will be taken to co=plete the - i

                       '                 corrective action; h
             !         i
8. Any advice related to the deviation or failure to
                        '                cohply that should be given to Purchasers and/or ultimate J[
  • I __ customer / owners.
v. I i 1=nediately upon being notified of cny such deviation or hic noncompliance, the Director of Quality Assurancea or in
   .i i                 !

lensi i the Director of Engineering, shall put hold on

   .zs :                 ;       ab s ence ,                                            that may have a you!                          any      shipments of the basic componentIf the Director of Quality i

de'viation or be noncocplying.

v. i Assurance or in his absence, the Director of Engineering o i determines that the deviation is_present only on itecs still
   ...re.

N t within the Company's control the defect will be corrected in

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accordance with the applicable provisions of the Ccapany's

   -w           :          l Quality Assurance Manual.

1 a:a '  ! If the Director of Quality Assurance or in the his deviation absence,/ the 9F ' 2d'  !' , Director of Engineering, determines thatin or affect prcducts which have C '

                 '          '      nonco=cliance been     shipped,mav be presentch'en he shall ic=ediately convene the Evalu-i      ation Co==ittee pursuant to Section 17.

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M NP m 0.07

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NELSON ELECTRtc' . STARARC3 PAGE 7

                                                                                                                                              ~--

SUSJECT of 10 PROCEDURE FOR REPORTING DEFECTS OR NOHC0!ELIANCE FOR NUCLEAR -f Whenever a deviation or noncompliance is discovered, the Quality Assurance department, in addition to taking steps to correct it, shall take appropriate steps to prevent i= 18 any recurrence of the deviation, including maintaining a uj file of all deviation notices and educating personnel as

      ;UU         '                to the necessity of and procedure for, avoiding recurrence .                                      ,

l~- of deviations. l VI. EVALUATION OF DEVIATIONS / NONCOMPLIANCE l of the ' The Company's Evaluation Co=mittee shall censistthe Director of CPD and General Manager of CPD and of PDP, the Director of Quality Assurance and the PDP Vice President o CPD Manufacturing orof Engineering,f their designees. Within two days af ter the first report a known.or suspected

             ~

deviation or noncompliar.ce pursuant to paragraph V above, the Evaluation Cocmittee shall determine whether the deviation or noncocpliance could create a subs tantial safety hazard. l A " substantial safety hazard" means a loss of saf'ety function to the extent that there is a major reduction in the degree of protection provided to the public health and safety forpursuant any - facility or activity licensed, other than for export,'Acorocriate criteria for - to 10 CFR Parts 30,40,50,70 and 71. 4 determination of the existence of a su'c'stantial safety hazard include: (1) moderate exposure to , or release of, licensed 1 I material; (2) major degradation of essential safety related construc-material; tion, inspection, or (3) major deficiencies involving design, tests or use of li ties.

sTn. I the If the Company's Evaluation Co=nittee determines that i  ! ~

F i i deviationthen hazard, or noncomoliance the Director of could Quality create Assurance a substantial or in his safet'. 1 i i absence, the Director of Engineering, each of whom to Part'Zl,has shall i - I 2 7; executive authority over activities subject for their I contact the General Signal Legal Department Promotly upon receipt hsi i= mediate evaluation and instructions. ki of the Legal Department's evaluation and instructions of but in

  .m.1 no case more than two days                                                    af    ter the the Director of. Quality Assuranceinitial    report t I                                   deviation or in his absence,
                                                             /nonec=pliance,the Director of Engineering, shall report I

could create a substan-To.1 the deviation or noncocoliance the that defect) to either the Director, cial safety hazard (i.e'., i- i J United States

, net                  i Office of Insuection and Enforcement.or to the Director of the Com

, a r i Regulatory Regional Office. Commission,If initial notification to the Cec =ission

 ~$                     1 is by means other than written coc=unication, a written hi                 !

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                                                 .                              HELSON ELECTRIC                         .                     No NPM750.07 4                                                              .

aTINDARDS PAGED Sua>ECT of 19 PROCEDUP2 FOR REPORTING DEFECTS OR NOUCOMPLIANCE FOR NUCLFJ.R ORDERS report (5) shall be submitted to the appropriate office within five days af ter the information is first obtained. Three copies of each report shall be submitted toThe the 2 Director, Office of Inspection and Enforcement. s written report shall include but need not be limited to

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b the following inrormation to the extent known: .

l. dame and adcress ot tne incivicual'or individuals
       '              1                              inferming the Cocaission; I
2. Identification of this Cc=pany as the fir: supplying the essic component which f ails to comply or contains a defect;
3. Nature o.f the defect or f ailure to co ply and the safety h::ard which is created or could be created by such defect or failure to comply; l
         ,                                    4.        Identification of the Huclear Power Plant or other i                                             regulated or licensed facility for which the basic compenent has ',oeen supplied; The date on which the information of such defect or l

5. failure to comply was o'qtained;

6. The number and location of all such basic cc=ponents in use at, supplied for or being supplied for one or more facilities'or activities subject to 10 CFR Part 21;
7. The corrective action which has been, is being or will be taken; the name of the individual or organization responsible for the action; and the length of time "I I I

that has been or will be taken to cocplete the action; L i--- 8. Anv advice related to the defect or failure to T" cohply about the facility, activity or basic ccapon-ent that has been, is being or will be given to

 ,           i           i                                   Purchasers or licensees.

exsi es ! The Director of Quality Assurance or in his absence, the Director of Engineering shall cooperate in supplying sny o ~.1 l additional inf ormation that the U.S. Muclear Regulatory Cc= mission may request relaced to the defect er failure

 ,. I                     i
 <            f           i to comply.                 All such supplemental infor=ation shall be 1

ao:  ; evaluated by the General Signal Corporation Legal Depart-i- 1 i

 .1
 ,                                              cent before submission to the Cc==ission.
v i
y
  ."% i                     u (5)              All written cornunications to the NRC shall be a

sent by registered or certified mail - return teceipt requested. i AppROYtc I DA*!

                                                                    '          OAff0         151UED BY      CATE          ,                                                      ~

I AlpiAC15 3ULLETIN PACE i

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                   *
  • NELSON ELECTRIC uo STANDARDS N . N P M 7 5 0 . 0 ,7 pAgg y 508J E ~.7 of 10
PROCEDURE FOR REPORTING DEFECTS OR MONCOMPLIAUCE FOR NUCLEAR ORDERS . --

If the Evaluation Co==ittee decides that it is unable to i t determine whether the deviation or noncompliance creates i s a substantial safety hazard, it shall first contact the 4 g %g Legal Department for evaluation and instructions and then bd within two days af ter first notice of the deviation / noncom-pliance, the Director of Quality Assurance or in his absence, the Director of Engineering shall give notice of the deviation or noncompliance to the Company's Purchaser and if so instructed by the Purchaser, to the ultimate Customer / Owner of the nuclear power reactor or other I licensed or regulated activity or facility.

                 ~

i VII. INSPECTIONS - The Company shall permit duly authoriced representatives l j of the U.S. Nuclear Regulatory Commission to inspect its records, premises, activities and basic components as necessary to effectuate the purpcse of the Part 21 Regula-tion. The Director of Quality Assurance or in his absence, the Director of Engineering, shall be responsible for coordinating such inspections and for escorting the NRC ,

                        ;                                 representative during his visit to its facilities .

VIII. MAINTENANCE OF RECOP.DS The Quality Assurance Depart:ent shall ensure that records are prepared in connection with the design, manufacture, fabrication, placecent, erection, installation, modifi-s1 I cation, inspection and testing of any basic component I  ! supplied for any licensed facility or to be used in any

licensed activity sufficient to assure cocpliance with
    ' i                                                   10 CFR Part 21. The Quality Assurance Department shall maintain all records involvsag Part 21 co=pliance jobs
                        !                                 including:

i gg e i 1. All purchase order records;

ui 2. Quality Assurance activities and inspections; '
w. i g
3. Design data (if other than standard);

t 4 Manuf acturing data (if other than s tandard);

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5. The Conpany's procurement orders and other purchased material data; j i
    -         !           l                                6.      Any testing data;

'L2 . Any authorized deviations and codifications; l l j, 7. Compliance certificates and notices of defects or I  ! 8. 8 i non' compliance. 4

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                                                                                                                                                                       !o,,f 10 PROCEDURE FOR REPORTIliC DEFECTS OR iiONCOMPLIN4CE FOR MJCLEAR 6RDERS The Quality Assurance Department shall maintain records y{                                  related to compliance with 10 CFR Part 21 for a ceriod P<       o       i                  of five years af ter delivery.                                       Before destruction of
     .,6 0     h'
               .Q                         records relating to evaluations or notificationc to the Commission, such records shall be offered to the Purchaser of the component.                           If such Purchcser determines and notifies the Company in writing that any such records :

I

1. Are not related to the creation of a subctantial l

safety hazard, then upon receipt of the Purchaser's authorization, such records shall be destroyed; or

             -                             2.        Are related to the creation of a substantial safety hazard, the Quality Assurance Department shall ccmply with the Purchaser'.s. request as to the delivery of such documents.

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               .M Q,7 NELSON ELECTRIC 3 .. ........ ... _ ._ _.....,..__..,............. ........

a October 17, 1983 t e John Akers ! Quality Assurance Supervisor j - DUKE POWER COMPANY <- _ P.O. Box 33189 Charlotte, NC 28242 .

Dear Mr.. Akers,

I am forwarding the enclosed copy of Nelson Electric's - procedure, NPM750.07, established for the reporting of defects or noncompliances pertinent to nuclear orders

,                    whenever a purchase order has been received which speci-fies that the provisions of 10CFR Part 21 are applicable and such reporting action becomes prevalent.

When a purchase order has been received by Nelson Electric i from Duke Power Company wherein the requirements of 10 CFR Part 21 do not form a condition of the applicable purchase order, Nelson Electric will continue to assure that Nelson officers and directors are informed of dafects or failures. Subsequently, Nelson Electric will then notify Duke Power Company of such defects or noncompliances. It will be encumbent upon Duke Power Company, after notification by Nelson Electric of pertinent defects or noncompliances to so notify the NRC. All other elements of Nelson Electric's Quality Assurance i Program and Inspection System will continue in implementa-cion in accordance with established procedures and the Q.A. Manual. , 4/ / l Bill Karr t Dire: tor, Quality Assurance cc: W. G. Von Miller

75(E V ' DUKE POWER GOMPANY P.O. nox 33189 CHARLOTOE, N.C. 28942 HAL B. TUCKER res.rruows

              "*""""                                                                       N" July 20, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.      20555

Subject:

Duke Power Company Catawba Nuclear Station Docket Nos. 50-413, -414 McGuire Nuclear Station . Docket Nos. 50-369. -370

Dear Mr. Denton:

j Duke Power Company was recently notified by the General Signal Company, Nelson Electric Division, that they will no longer accept purchase orders which involve 10 CFR Part 21. The decision of Nelson Electric to refuse these purchase orders is based upon the current lack of business activity from the nuclear peser industry coupled with the rising costs of maintaining the QA/QC systems and pro-cedures to ensure compliance with the reportability requirements. This company has fabricated and supplied nuclear safety-related motor control centers, distribution centers, and power panels for the Duke Power Catawba and McGuire Nuclear Stations. It is necessary that Duke Power continue to purchase equip-ment and parts from Nelson Electric for use on the above listed components. In order to meet Duke's procurement needs for these items while ensuring that the intent of 10 CFR Part 21 is satisfied, Duke Power Company proposes to take the following actions:

1. Duke Power will continue to place nuclear safety-related orders with Nelson Electric, but will not reference 10 CFR Part 21.
2. Duke Power will continue to perform audits and surveillance to assure Nelson's QA program meets the purchase specifications.

These QA audit and surveillance visits would be performed as with any other of Duke's approved safety-related vendors and ensure that the existing Nelson QA program or another program acceptable to Duke would continue to be implemented.

3. Duke Power will assume all 10 CFR Part 21 reporting requirements when any Nelson items are delivered for acceptance under our QA program. This will encompass not only material problems, but design problems as well.

W'l:i ifR

4 - Mr. Harold R. Denton, Director Page Two , i h Duke Power feels the above actions will assure compliance with the intent of 10 CFR Part 21 and furthermore foresees no generic industry prob 1' ems since the i subject equipment was fabricated specifically for installation at the Catawba and McGuire Nuclear Stations. It is requested that the above information be reviewed by the appropriate NRC personnel and that a timely response be given to Duke Power concurring with these proposed actions. Very truly yours. Cd f / Hal B. Tucker , JSW:DWD:scs cc: Ms. E. G. Adensam Mr. J. P. O'Reilly, Region Administrator > Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission, RII U. S. Nuclear Regulatory Commission Suite 2900, 101 Marietta St., N.W. Washington, D. C. 20555 Atlanta, Georgia 30303 Mr. R. C. DeYoung, Director Mr. J. T. Collins, Regional Administrator Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission, RIV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Washington, D. C. 20555 Arlington, Texas 76011 Mr. Guy H. Cunningham Mr. Uldis Petapovs, Chief

Office of the Executive Legal Director Vendor Program Branch l U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission, RIV Washington, D. C. 20555 611 Ryan Plaza Drive. Suite 1000 Arlington, Texas 76011 bec
N. A. Rutherford W. O. Henry J. L. Crenshaw G. A. Copp R. O. Sharpe l Group File: CN-811.01 '

Group File: MC-811.01 l

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