ML20100H682

Submits Amer Industrial Technologies,Inc,Conclusion That Cartridge Element & Associated O-Rings May Not Have Been Properly Qualified by Commercial Grade Dedication Activities,Per Bechtel Latest Requirement

ML20100H682
Person / Time
Site:	Calvert Cliffs
Issue date:	02/21/1996
From:	Amer A External (Affiliation Not Assigned)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-PT21-96 NUDOCS 9602270413
Download: ML20100H682 (4)

Text

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AMER  !

-INDUSTRIAL

]JTECHNOLOGIES E INC.

February 21,1996  !

U. S. Nuclear Regulatory Commission Document Control Desk )'

Washington, D.C. 20555 *

Subject:

10CFR Part 21 - Notification re: Bechtel Job 21464  !

Calvert Cliffs Nuclear Power Plant Diesel Generator Project Bechtel P. O. CCDG 0065 and CCDG0767

- Safety Related Fuel Oil Filters -

Bechtel File No. DG80382 - CCDU-96/008

Reference:

Letter - A.E. Amer (A.I.T.) to R.F. Yamrus (Bechtel) dated 2/5/%

Letter - R.F. Yamrus (Bechtel) to A.E. Amer (A.I.T.) dated 2/6/%

Sirs:

Based upon the above referenced letters and our review ofthe A.I.T. procurement documents associated with the oil filter cartridge used in the Fuel Oil Filters, we have concluded that the cartridge element and associated 0-Rings may not have been properly qualified by commercial grade dedication activities as per Bechtel's latest requirement.

We are corresponding with Bechtel and B. G. & E. to determine the best methods to

. accomplish a proper commercial grade dedication.

A.I.T. is also to notifying Baltimore Gas & Electric and Bechtel Power Corporation via letter or fax of this condition.

Point of contact for this action item is A. E. Amer at (302) 652-3900. Should you have any further comments or questions, please refer them to myself.

Sincerely,

. t +w A.E. Amer President AEA:rse cc: N392 File Part 21 File '

QA Chron 9602270413 960221 PDR ADOCK 05000317 - \1 S PDR \

1000 S. MADISON ST., WILMINGTON. DELAWARE 19801 TE L (302) 652-3900 FAX (3o2)652 640o

1 AMER-INDUSTRIAL TECHNOLOGIES INC.

February 5,1996 Bechtel Power Corporation Calven Cliffs Diesel Generator Project Job No. 21464 9801 Washingtonian Blvd.

Gaithersburg, Maryland 20878-5356 Attention: Mr. Ram Yelamanchi

Reference:

Fuel Oil Transfer Filters Specification No. SP-760 Revision 1 Procurement Specification DG-80382 Purchase Order No. CCDG0767 A. I. T. Project 523

Dear Mr. Yelamanchi:

Per the requirements of the above referenced procurement specification DG-80382, A.I.T.

would like to identify the safety-related non-Code part of this contract as the filter cartridges. In accordance with the specifications A.I.T. will identify all steps taken to control the step by step processing of the cartridges A.I.T. issued Purchase Order No. 20808 (copy attached for your review and information) to our vendor requiring strict compliance to the Bechtel Power Corporations procurement specifications, including but not limited to Certificate of Conformation, shelflife of the filter cartridge, engineering information (flow vs DP), storage requirements i.e. temperature, ultraviolet light, etc. Also, A.I.T. will issue their Certificate of Compliance to certify that we furnished these items in accordance with our Q. A. Program, your purchase order requirements and ASME B &

PV Code Section III, Division 1, Class 3,1986 Edition, no addenda,10CFR21 applied.

Please advise A.I.T. of Bechtel's acceptance of this process. Should you have any further questions or comments, please contact me.

Sincerely, ,

AMER INDUSTRIAL TECHNOLOGIES, INC.

9 A.LE. Amer Q- _

President AEA:rse 1000 S. M ADISON ST., WILMINGTON. DELAWARE 198o1 TEL (302) 652 3900 FAX (3o2) 652-6400

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m LOChtel Y W ,,

9801 Washingtonian Boulevard lU Gaithersbutg. Maryland 20878-5356

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b ,e v iA (301) 417 3000 ,

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February 13, 1996 Mr. A. E. Amer Amer Industrial Technologies 1000 S. Madison Street Wilmington, Delaware 19801 D ar Mr. Amer:

Subject:

Bechtel Job 21464 Calvert Cliffs Nuclear Power Plant Diesel Generator Project Bechtel P. O. # CCDG 0065 & CCDG 0767 Safety Related Fuel Oil Filters Bechtel File Nos.: DG80382 CCDV-96/010 Our review of your letter dated February 5, 1996, and the information furnished with the letter, identified the following inconsistencies:

The Amer Industrial Technologies Inc. (AIT) Purchase Order No. 20808 furnished with the above letter does not appear to invoke safety related quality program requirements. Item 3 of Attachment B to the purchase order states that material shall be in compliance with ASME III, Class 3, 1986 Edition. However, the filter cartridges are exempt from the requirements of ASME III, since the filter cartridges are not associated with the pressure retaining function. Item 9 of Attachment B to the purchase order states that 10 CFR 21 applies to the order. Our review indicates that, there is no objective evidence that the sub-supplier had a safety related quality program, and implemented the program in the manufacture of filter cartridges.

Based on the information furnished with your letter, we can not make a determination, that the controls used by AIT in procurement of filter cartridges are acceptable. The only acceptable methods for procurement of safety related filter cartridges are, either to purchase them as safety related parts from an approved supplier with a ANSI N 45.2 (10 CFR 50, Appendix B) quality program, or to purchase them as commercial grade items and dedicate them for safety related application in accordance with EPRI NP-5652.

Further information in the following areas is necessary to detennine the acceptability:

1. Did your sub-supplier, Norman Ultraporous Filters, have a approved safety related quality program?

Bechtel Power Corporation

a..,-

'Mr. A. E. Amer CCDV-96/010.

Page,2.

2. Did Norman Ultraporous: Filters acknowledge your purchase order as a safety related order'and accept the reportability requirements under 10 CFR 21?

3.- Did you procure the filter cartridges as' commercial l grade items?

.4. If the filter-cartridges were procured as commercial grade items, was a dedication. plan consisting of critical characteristics, acceptance criteria and verification methods developed and implemented in accordance with EPRI NP-5652?

5. . Was~Bechtel filter data sheet included with your procurement

- documents?' If it was not included, how did you provide the full range of design conditions including the viscosity to Norman Ultraporous Filters?

We request that you contact Bechtel to discuss the answers to the

above. questions and take the necessary actions to document the controls used in the procurement of filter cartridges in an expeditious manner.

Very truly yours, l C g R. F. Yamrus Project Engineer RY/ry cc:- Mr. C. R. Mahon Mr. E. S. Broczkowski Mr. F. J. Reedy 1

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