ML20127F218
| ML20127F218 | |
| Person / Time | |
|---|---|
| Issue date: | 08/14/1984 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20127F188 | List: |
| References | |
| FOIA-85-81, REF-QA-99900840 IEIN-84-52, NUDOCS 8506250081 | |
| Download: ML20127F218 (3) | |
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UNITED STATES
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E. W. Merschoff, Section Chief Reactive Inspection Section Vendor Program Branch
SUBJECT:
MEETING WITH REPRESENTATIVES OF CARDINAL INDUSTRIAL PRODUCTS CORPORATION (CIPC) ON AUGUST 3, 1984 Attendees:
M. Donovan, CIPC D. Noll, CIPC M. Dianond, CIPC R. Lindquist, CIPC R. DeYoung, NRC J. Taylor, NRC N. Grace, NRC J. Partlow, NRC J. Liebernan, NRC J. Axelrad, NRC G. Zech, NRC U. Pctapovs, NRC E. Merschoff, NRC
Purpose:
The meeting was held at the request of CIPC in order to provice them with an opportunity to describe the corrective actior progrur.
CIPC has developed in response to inspection fircir;s made by the Vendor Program Branch in Inspection Report Number 9990C640/83-01 and to inform the NRC of the financial impact this inspecticr.
report and IE Information Notice 84-52 " Inadequate Material Procurement Controls on the Part of Licensees and Vendors" has had on CIPC.
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AUG 14 884 CIPC Presentation:
During the course of the meeting, Messrs. Donovan and Knoll of CIPC provided a brief history of CIPC's involvement as a nuclear supplier and provided an overview of the corrective action plan developed by CIPC in response to findings made in NRC inspection report 99900840/83-01. The details of this corrective action plan can be found in two letters from CIPC to the Chief, Vendor Prograa Branch, dated April 12, IEE4 and June 13, 1984.
Following this overview of CIPC's corrective action plan, Messrs. Donovan and Knoll explained that the findings in the NRC inspection report, the discussion of problems with the implementation of CIPC's (among other's) quality assurance program in IE Information Notice 84-52, and unsubstantiated innuendos regarding the quality of CIPC products from unnamed NRC inspectors have adversely impacted their nuclear business, to the point where they are currently losing a substantial amount of money per month.
At this rate, Messrs.
Donovan and Knoll feel that there is a real possibility that CIPC will be forced to go out of business and, consequently, will be unable to complete the corrective action plan described earlier.
Messrs. Donovan and Knoll stated that a solution to this problem, from CIPCs perspective, would be for the f:RC to provide some form cf notification to the ruclear industry that CIPC's current quality assurance program is satisfactory and that the corrective action plan developed in response to past problems is acceptable to the NRC.
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" NRC Response:
Mr. DeYoung responded to the points made by CIPC by pointing out that the mechanism currently in place for dealing with Vendor responses to inspection findings would appropriately deal with CIPC's concerns regarding the acceptability of their corrective action plan.
Specifically, as stated in the NRC Vendor Program Branch letter to CIPC dated July 23,198a; further informetion 9 needed to complete the evaluation of CIPC's ccrrective cc ion plan as described in their June 13, 1984 cnd April 12,1:'"
letters. When CIPC provides the additional information requested in this letter, the NRC will provide a letter to CIPC which clearly states the NRC's position on CIPC's corrective action plan, and CIPC is free to do with this letter as they see fit.
k'ith regard to CIPC's concerns that unnamed NRC inspectors were damaging CIPC's reputation with misleading statements and innuendo to their customers, Mr. DeYoung provided CIFC with the opportunity to provide names and facts.
- Mcwever, CIPC declined to provide any specifics preferring to leave this issue as a general statement of concern.
Cecisions Made:
IE agreed to review CIPC's response to the Vendor Prograt Branch Chief's letter of July 23, 1984 (when it is receivec),
and provide a written ?!RC response as is the normal policy when the NRC deals with Vendors in situations such as this.
However, in light of CIPC's clain that they have incurred a significant economic impact due to this situation, IE a geec to complete this review and provide the formal response as expeditiously as possible.
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Ellis W. Merschoff, 5 ction Chief Reactive Inspection Section Vendor Program Branch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement cc:
R. C. DeYoung J. M. Taylor J. N. Grace J. G. Partlow J. Lieberman J. Axeirad G. Zech E. Merschoff U. Potapovs M. Diamond, CIPC
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i Docket No. 99900870/84-01 Cardinal Industrial Products Corporation ATTN:
Mr. Michael J. Donava t
Chairman H
3827 W. Oquendo Las Vegas, Nevada 89118 i
Gentlemen:
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Thank you for your lette-4, 1985, and your revised Action Plan Interim Report No.
/ 31, 1985, in response to our letter of August 29, 1984.
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.se discussion with you during a tele-phone call on February ening your Action Plan Interim Report No. 1, dated January ".
and the revisions to your Action Plan acceptable.
As discuss, se telephone conversation, we understand that on page eight, parag
,ardinal will add a statement clarifying that only one piece from e.
.ibination will be tested.
We have no further questions comments at this time and will review your I
implementation of the Action Plan, during a future inspection.
Sincerely, ORIGINAL SIGNED BY:
GARY G. ZECH Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance Safeguards, and Inspection Programs Office of Inspection and Enforcement t
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$11 RV AN l'L AT A Df88 6'l S Ulli 10f' ARLINGTON TE X AL W "1 MAY 18, 1984 Docket No. 999 0040/83-01 Cardinal Industrial Products Corporation ATTN: Mr. D. Fielder President 3827 W. Oguendo Las Vegas, NV 89118 Gentlemen:
Thank you for your letter of April 12, 1984, in response to our letter dated February 29, 1984. As a result of our review, we find that additional information is needed with respect to the following items in the Notice of Violation (NOV) and Notice of Nonconformance (NON):
General - With respect to paragraph 3 on page 2 of your letter, please hotify which of the identified nonconformances contained in the NON have been submitted to your customers for determination of 10 CFR Part 21 reportability.
NOV, Item B - From our review of your response, it would appear that compliance with requirements of 10 CFR Part 21, when initially procuring comercial grade items, is contingent upon fully satisfying the requirements of NCA-3867.4(e) prior to sale of fastener items for nuclear safety-related applications.
No further response is required at this time with respect to your stated position in that the subject of compliance with NCA-3867.4(e) is separately addressed in Item D in the NON.
N0f?, Iter. A - Please provice a copy of the applicable welding prccedure spuifi-ca:ic, procecure cualificetion rettid, 6rd welder perfcrc:..,:e c;clific: i.-
ii. tu.; tr.ese oacur..ents could not be locatec 4r our re,ier curirs :ne ;E inspection.
NON Item B.1 - In that the companies cited in this nonconformance were also identified in NON B.3 as having survey / audit checklists which contained no supporting evidence with respect to questions checked off as being acceptable, we have no means for verifying your response. Accordingly, you are requesteo to furnish to us a copy of the quality assurance manuals for the referenced vendors in order that we may have them translated and evaluated with respect to compliance with subarticle NCA-3800 requirements.
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CerM. ration f@N, Item B.2 - With respect te vende.r 2, please provide the date of your last conducted business.
You have failed to provide the requested corrective actions in that available records do not indicate that a meaningful survey / audit has beer performed of vendor 3, with respect to analytical services.
NON, item B.4 - Please provide a copy of the instruction and the date on which Cardinal Industrial Products Corporation (CIPC) instructed the vendor to subcontract the perfonnance of Charpy V-notch impact tests.
The NRC inspection indicated that the performance of Izod impact testing by this vendor was generic to all CMTRs furnished in that you have reported Izod impact values as representing Charpy V-notch impact values on your CMTRs. We are concerned as to the awareness of this condition by your customers.
Accordingly, please clarify what notifications have been made and identify the status of CMTR corrections, f,0N, Item B.5 - Additional response is not recuired at this time with respect to vendor 1.
An additional review of the AVL status for this vendor will be performed in a subsequent NRC inspection.
For vendor 3, your referenced response (i.e., contained in response to B.2) fails to appropriately respond to the stated nonconformance. This vendor was acting in a material supplier capacity and was on the CIPC AVL without the NCA-3800 required survey / audit being performed.
NON, Item B.6 - You have failed to address the stated nonconfonnance in regard to approval of the Phoenix facility of this vendor after the auditor had identified that the vendor had not performed the required internal audits.
NON, Iter E.7 - This item will be reviewed c'ering e subsecu=~ incr+c-W.
'c vrtner response is requirec at this tin.
NON, Item C.1 - You have failed to appropriately address the stated nonconformance.
You reference procedure CSP 4.002 which requires compliance with the vendor's audited, surveyed, and approved quality assurance program; however, as you have stated previously, procedure CSP 4.002 did not become effective until January 9,1984. Examples were identified throughout the NRC inspection report which established that CIPC supplied items as meeting ASME Code requirements for which CIPC perform the required ASME Code upgrading.
Therefore, please provide your corrective actions, measures to preclude recurrence, and the dates these actions will be accomplished.
NON, Item D - In order for us to evaluate your response, it will be necessary for you to clarify the differences between your current and past QA program requirernents for upgrading of stock materials with the provisicns cf TCA-3867.4(e).
(crcir.cl iricustrici I recuc t s (c rpt. rat it r; h0t., Item E :
General - Your response did not provide any requested actions with respect to the specific nonconformance; i.e., the failure of QA perscnnel to identify noncompliance of vendor documentation with respect to invekeo codes, standards, and/or specifications.
NON, Item E.1 - The results of our evaluation of your respons': are detailed above in NON, item B.4.
NON, Item E.2 - This example was written with respect to the procurement of ASTM A-193 Grade B7 materials for which stress relief is a mandatory specifi-cation requirement after cold drawing. Accordingly, please provide the measures which were requested by our letter of February 29, 1984.
NON, Item E.3 - Supplement No. I to Arkansas Power & Light Co.'s purchase order No. 73555 dated September 3, 1E82, with Attachment 1000.11A, item 8 states,
" Proof Load on SA-194 nuts per SAe194 (55)." Accordingly, please provide the measures which were requested in our letter of February 29, 1984, and also clarify your response in regard to the statenents made in ycur response h0h, Item F.6.
NON, Item E.4 - Your response does not provide the measures requested by our letter of February 29, 1984. This example pertains to a material manufacturer (i.e., performing material heat treatment) not attesting to the use of his surveyed and approved QA program on his CMTR.
NON, Item E.6 - The applicability of 10 CFR Part 50, Appendix B, in proturement is not germane to the cited example (NRC Inspection Report, paragraph D.I.b.(1)),
which pertains to the failure to identify that a vendor had not complied with the testing requirements of 3 material specification.
Please provide the re;uested actions with respect to this specific eraGle, f.Gi It'em F.1 - We tuil to understand your res;cnse with respect tc ycar apparent claim of nonapplicability of the customer invoked material specifica-tion for these studs.
Please clarify what was the intended meaning of your general response to Item F.1.
The NRC inspection, as documented in paragraph D.3.a of the inspection report, identified the apparent failure to comply with processing requirements contained in customer specification N-P0H16(h). Similar requirements are additionally contained in the applicable material specification, SA-540.
Your response with respect to the stated nonconformance does not provide requested actions in our letter of February 29, 1984, or in most cases, acknowledge deviation from customer specification requirements.
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Co r ai r.c i Ir.cust ric i Frecutti corporatior: fi0fi Item F.2 - This itera will be reviewed during a subsequent inspecticri ano no further response is required at this time.
N0fi, Item F.3 - This item will be reviewed during a subsequent inspecticr ard no further response is required at this tine.
NON, Item F.5 - With respect to Item A, please identify the basis for actions taken in regard to instructions that are in apparent violation of the ASME Code.
With respect to Item B, please clarify your response in regard to your statement that bolts were MT examined when the order pertained to li" nuts.
With respect to Item C, please identify what specific corrective actions have been taken in regard to the specific cited example.
Your response should specifically include customer notification status and date.
With respect to Item D, your response does not alleviate our underlying concerns regarding the furni.shing of critical safety-related bolting without any apparent QA review to assure that CMTR statements, with respect to ASME Code required nondestructive examination, were both true and complete.
Please provide details of the actions that have been taken to assure that issued CMTRs fully represent the examination and test status for furnished items.
Your response should specifically include customer notification status and date.
NON Item F.6 - Our review of revision 4 of Form No. 1000.11A, page 4, an attachment to Supplement 1 of the customers purchase order, shows no basis for your statements in regard to acceptance of proof load testing in lieu of tensile tests of nut starting materials.
Please submit the documentation that provides the basis for your response statement.
f.0f; Itet G - Le have no further questions with respect to the ver d r's '_r.e: III f.[E exariner.
C" r concc" with respect to the Level II racicprar - re
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as a Le' vel II by an examiner who was not a Level III at the tiu cf tris certification. We, therefore, do not consider that the certification can be idered valid and request that you provide an appropriate response ccnsistent the requirements of our letter of February 29, 1984.
< 4 g item H - Your response is not acceptable in that it fails to recognize that
?1 examination is an NDE discipline under ASME Code rules.
Refer to the a
icable article in Section V of the ASME Code.
i C urt inel Incustr lei i r ecu;tt (crporation itCA-3C64.2(b) states tnat, "All nondestructive exah.ination personnel sr.c11 be qualified in accordance with parograph 5521 of the applicable Subsection."
NX-5521 addresses those NDE methods not covered by SNT-TC-1A documents, ar.d requires that personnel shall be qualified to comparable levels of competency by subjection to comparab;? examinations on the particular method involved.
Please provide the requested measures of our letter dated February 29, 1984.
NON Item I - Please provide the basis for your statement that you were acting as a Material Manufacturer as defined by NCA-3812; i.e., what operations does CIPC perform or supervise and directly control, when procuring finished heat treated nuts and other fastener items?
NON Item J - Your response did not address the stated nonconformance with respect to NCA-3867.4 CMTR heat treating reporting requirements.
Please provide appropriate measures to preclude recurrence of this nonconformance.
Please provide the additional infonnation within 25 days of the date of this letter.
Sincerely, l
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Uldis Potapovs, Chiqf Vendor Program Branch
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Dc e;:e t o. C090006L/57-01
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Petapers:
Cardinal Industrial Products C:rporation hereby neti:icns :ke
';uelear Reculatory Co-'=ission in accordance wi th 10 CTR 2 7 T.', trat the ocrission vithhold f r r r.' filing in its Public Decunent Beer, and fr:= any c:her public disclosure, any doeutents disc 1 sinc -ke neres End ic0ation* Cf I?:-din?.l's Custoners, Ven' Ors and sDDContric* rF.
An ps.:.culer. Ce rr'inal wou lc r e c.v e s t ei;her (1) that D-pert N.
r p, 0 0.:.?:') '0 '.. n 1 es,:ropc sed have the n a r,c s nd locations of its ersto ers. vende rs and suheentractors <ielated therefrom er in se-a
(.-) that the Repert ie ewritten so as te delet-
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'en be listed en a s?purt sched de t o h e :rtein ic in e d in the n r-r.hlic files cf the C =missi-.
The ??ndersigned properly cnf t i m e l y n e r i i c r' the Cerrissien t--
Tele ' re en.'farch 0,
1.C S L of Ca rdinals inte.: to file t'is app 3i-
- ction.
The Report.nroposed to be filed in Nuclear Beruir.tery Cernissinn's Furlie Docur.ent Roc centains the nares end adt: e= se s of et's t ore rs, vendo:3 and subcont.-re:rrs of Cerdinal, which a-s and lists comprised thereof constitute'cenfidential inforretier ceintained by Ca rc'inal a s cenfidential and as a trade-secre:. Th::
infer.atien is held in ecnfidenec by Cardinal. The di=elesure to Cardin+1's corpetitors of the i r'. e n t i t y s n d l o c a t ie.n rf such vand:rs a.d sub e :n t ra c t r. re s sources..oald substantially injure C e rc ir n ' * :-
current c o- :pe t it ive "osition :. n the rerker, and.ould pe r-it it-competitors to contact seid venders and subc n:ractors and ebrei.
iSc a r' van t a c e ou s terns that Cardinal currently enjrys. The dis-clesure of Ca rdinal's customers would per-it ee petiter.= to terre-r its cus ocers for solicitction.
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M... C1 dis Potapovs March 23,1984 Che identity of Cardinal's customers, vendors and subcontractors was r.ade available to the Commission frc= its internal records, and n:: from public sources, and was provided to the Commission inspectors in c:nfidence in order to permit the Co=.ission's investigators to re tie - Cardinal's files pursuant to their recen: on-site inspection.
Cardinal has expended a great deal of time and ef fort 'in locating r_r.d identifying its vendors and subcontracters, and developing its cust:mer base, and the injury resulting from disclosure thereof would hate severe negative economic repercussions to Cardinal, and would inju e Cardinal's competitive position in the marketplace.
Very truly yours, I
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,...a Mr. Uldis Potapovs, Chief Vendor Program Branch 4
Division of Quality Assurance, APR I 61984 Safeguards and Inspection Programs Nuclear Regulatory Commission l-Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Re:
Cardinal Industrial Products Corporation
. Docket No. 999000840/83-01 4
Dear Mr. Potapovs:
Following up on our telephone conversation this morning, this firm represents Cardinal Industrial Products Corporation ("CIPC").
Under separate cover, CIPC is sending to you today their Responses to the Notice of Violation and Notice of Nonconformance dated February 29, 1964.
It is CIPC's desire to promptly and amicably resolve all concerns that the NRC may have with respect to its operations.
I believe that your investigators will conclude, based on the information contained in the
'onses, that CIPC is in compliance with all regulations.
1-
.tional information is required, or if your office desires <
.ional confirmation of the statements and/or references containec in CIPC's Responses, we would l
be pleased to meet with you and/or the appropriate inspectors, j
either at your office in Arlington, Texas, or at our client's
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facilities in Las Vegas, Nevada.
I believe that a meeting at our client's facility would be more productive, as all of our client's records are kept there.
Please call me if there are any questions with regard to the Responses, or if I can be of any assistance to you in providing s
additional information or explanations.
Thank you,-
your assistance.
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May 4, 1984 Certified Mail - Return Receiot Reouested
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Docket Nc. 99900540 Mr. D'ennis Fielder President Cardinal Industrial Products 3873 West Oguenda Las Vegas, Nevada 89118
Dear Mr. Fielder:
This is in reference to your letter of March 23, 1984 in which you petitioned the NRC not to di'sclose the names and locations-of Cardinal Industrial Products Corporation (CIPC) customers, vendors and subcontractors referenced in NRC Inspection Report 99900840/83-01 dated February 29, 1984.
As a result of your request, we have reviewed the report and considered your petition.
With regard to the disclosure of names and locations of the customers, I do not intend to Withhold that information.
The findings of our inspecticn as contained in the inspection report, even allowing for the disagreements contained in your April 12, 1984 letter, raise significant questions concerning the adequacy of CIPC's implementation of its quality assurance program.
Components manufactured by CIPC are used in safety-related systems. Their failure to conform to codes anc standards could impact the operability of such systems under accident conditions and, therefore, could have an adverse impact on the public health and safe y.
Nuclear customers that nave received or may receive products either directly from CIPC, through a distributor, or from another nuclear project need to be aware of the types of problems that may exist with CIPC supplied components in order for these users to take appropriate corrective action.
I am planning to issue an Information Notice covering nonconforming components supplied by CI?C and,other companies.
I am also considering issuing a Bulletin which would direct holders of construction permits and operating reactor licenses to determins if they possess CIPC components in safety-related systems and to take whatever corrective action is necessary.
The discicsure of the customers referenced in the report is necessary to permit licensees to perform an adequate review.
Therefore, I have determined that the potential acverse impact resulting from the possible use of nonconforming CIPC fasteners in safety-related applications takes priority over your stated proprietary interest in withholding the identity of your customers.
Accordingly, I am not addressing the question of whether the names were, as you stated, given in confidence to the NRC.
With regard to disclosing the names and locations of CIPC vendors and'subcon-tractors, it does not appear at this time that releasing this information is necessary to protect the public health and safety.
Therefore, this information will be withheld pending further evaluatior, of Ine effect of withholding it en the ability of licensees to take appropriate corrective action.
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9 Mr. Dennis Fielder A copy of inspection report 99900840/83-01 and the cover letter with all enclosures will be released to the public and placed in the public document room 14 days from the date of this letter. The names and locations of CIPC vendors and subcontractors will be masked on all copies released to the public.
Should our position change cor.cerning the identity of your vendors and subcontractors, I will contact you prior to release.
A copy of the in-spection report with the masked portions noted above is enclosed.
Should you nave any questions on this matter, please contact Gary Zech at (301) 492-9663.
Thank you for your cooperation in this matter.
Sincerely,
- 0rtstnal signed Bz R.C.DeYoung",,
Richard C. DeYoung, Director Office of Inspection and Enforcement
Enclosure:
As stated DISTRIBUTION:
DCS NRC PDR VPB Reading OASIP Reading RCDeYoung JMTaylor JNGrace JGPartlow GZech EMerschoff JLierberman, OELD UPotapovs
- See previous copy for concurrences
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INDUSTRIAL PRODUCTS CORPORATION ITOLL 78tEll 800 634 6861 3873 WEST OQUENDO
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PHONE INEV AD AB 702 739 9966 LAS VEGAS. NEVADA 89118
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April 12, 1984 h_b b
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Mr. Uldis Potapovs, Chief APR ) 3 24 i 1 Vendor Program Branch Division of Quality Assurance, b.
Safeguards and Inspection Programs QUL Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Re:
Cardinal Industrial Products Corporation Docket No. 999000840/83-01
Dear Mr. Potapovs:
i This letter is written in response to the y tice of Violation and Notice of Nonconformance dated February 27, 1984.
As you are aware, concurrently with the Nuclear Regulatory Commission ( " NRC" )
inspection that occurred last year at our facility in Las Vegas, Nevada, ASME was conducting a certification inspection.
As a result of the ASME inspection, Cardinal Industrial Products Corporation
("CIPC") received certification both as a Material Manufacturer and a Material Supplier.
Copies of our certificates are enclosed herewith.
With* the assistance of the ASME certification team, CIPC revised many I
of its record keeping and other practices, and adopted formal written procedures to assure continued compliance.
With respect to the specific findings of the NRC, many resulted l
from the NRC's inspection team not reviewing all applicable documents which exist in CIPC's files.
(Details as to specific items are set forth in our formal Response enclosed herewith.)
Other findings relate to older record keeping procedures of CIPC which had been revised prior to the inspection or were revised as a result of the ASME certification process.
We believe that CIPC's current pro-cedures are in full conformity with NRC and ASME requirements, and CIPC's practices follow its written procedures.
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<NE v&D A. 70 2 13 9196 A LAS VEGAS NEVADA 89118 AUGUST 8, 1984 ACTION PLAN I.
SUBCONTRACTOR VALIDATION AND ON-GOING MONITORING / SURVEILLANCE PROORAM PURPOSE:
To insure that previous surveys / audits addressed the scope of services provided and to docunent that current and, to the extent possible, that previously used quality programs comply with the applicabla requirements of NCA-3900, 10CFR50 Appendix B, and ANSI N45.2.
SCOPE:
The programs / practices of selected overseas subcontractors will be validated on a one time basis to assure accuracy of CMTR data.
The validation will consist of a survey and evaluation of results for impact on supplied material.
The priority for validation will be established in the f ollowing order:
(a) applicability to prcJects with immediate schedule requirements, and (b) subcon-tractors who have processed large amounts of material for CIP and/or are currently processing material for CIP.
Products covered will include (1) alloy bar (melting, hot rolling, cold drawing, heat treating, and mechanical testing)
(2) carbon and alloy nuts (melting, hot rolling, forming, heat treating, tapping and mechanical testing) (3) carbon steel washers (melting, rolling, stamping, heat treating, and mechanical testing) (4) small stain-less nuts (melting, cold drawing, heat' treating, machining and mechanical testing). If the validation process reveals problems with a subcontractor's quality assurance progran in certain areas the number of subcontractors to be validated will be broadened to include those who would likely have similar problems by virtue of
PACE 2 AUCUST 8, 1984 comparable products, operations or programs.
If large numbers of deviations are found through the certification review process (see section III) for a subcontractor their program will also be validated.
This activity will include establishment of ongoing monitoring / surveillance for subcontractors performing heat treat-ment to assure compliance as applicable to CIP approved or supplied procedures.
METHOD:
The valadation will be conducted employing checklists to be determined by the scope of operations / services which the subcontractor performs.
All portions of the checklists will be completed including N/A entries for those attributes determined to be not applicable.
Objective evidence will be reviewed and documented.
Procedures and/or practices for heat treating and testing will be recorded, revieued and approved by CIP.
Additionally, subcontractors will be required to submit procedure /
practice changes to Cardinal for approval prior to use on current and future orders.
This will be verified during the CIP i
monitoring / surveillance program.
Concurrent with the validation survey an audit will be conducted.
This audit uill focus on the historical data in the quality program uhich may impact status of j
previous CIP surveys / audits.
The audit uill also concentrate on subcontractors where certification variances from purchase order j
requirements were found by CIP.
PERSONNEL:
CIP personnel performing validations will be Cardinal 's Senior Vice President of Quality Assurance and our Manager of Admini-stration (see CIP GAM for details on job descriptions).
CIP will,also retain a third party inspection agency (Hartford Steam i
Boiler Inspection and Insurance Company) to lead the validation team.
A degreed metallurgical engineer or other equivalent i
approved party will oversee the monitoring / surveillance program of overseas subcontractors.
l i.
GUALIFICATION:
The validation team leader from Hartford and Cardinal's Sr.
V. P.
are qualified in accordance with ANSI 45.2.23 and the Manager of
' Administration is an auditor-in-training to said standard and will work under the direct supervision of the survey team leader.
Gualification records are on file at CIP.
The monitor /sur-veillance personel wf11 be appointed by the Senior Vice President of Guality Assurance based on his review of their Qualifications.
PAGE 3 AUGUST 8, 1984 4
II.
AGENCY FORMALIZATION (TRADING COMPANIES)
BACKGROUND:
It is customary that many of Cardinal's overseas subcontractors work thru agents who perform administrative functions, but are not allowed to change the technical and quality requirements contained in the CIP order.
These trading companies do not take physical possession of the material.
PURPOSE:
To insure that subcontract work conducted thru agents is better controlled and that CIP procurement requirements are properly transmitted thru the agents to the appropriate CIP app-roved subcontractors.
SCOPE:
All overseas agents will be evaluated for placement on the CIP Approved Agents List (AAL).
Only approved agents will be utilized for future procurement.
METHOD:
Materials which are regularly procured thru agents will be divided into logical groupings by size, shape or type.
Each I
grouping will receive a designated' agent and approved subcontractors prior to issuance of a purchase order.
Each approved subcontractor will be designated by product and/cr services to be provided.
The combination of agent and specific subcontractors for a particular type of product will be called a
" channel" and must be qualified and approved by CIP.
CIP purchase orders will be issued to a designated agent who will transmit the procurement requirements thru the approved channel.
All agents utilfred by CIP will be qualified by an evaluation which uill include a survey and detailed discussions defining their mode of operations.
Upon satisfactory completfon of this process the approved agents will be added to the CIP Approved Agent List.
The i
" channels" will be documented; approved by GA and included in the Purchase order.
Each CIP P.O.
uill have an agent acknowledgement
'that will be signed and returned to CIP when the procurement i
information has been passed thru the channel (subcontractors in the channel will not be changed without CIP prior approval and/or designation of a change).
Subcontractor monitoring /surveill-ance will verify that procurenent information has been passed I
I PAGE 4 AUGUST B, 1984 thru the " channel" by the agent.
PERSONNEL:
CIP's Senior Vice President of Guality Assurance or his designee will approve agents and channels.
GUALIFICATION:
If the Sr.
V. P.
G. A.
uses a designee he shall be appropriately qualified and the qualification will include sufficient experience at CIP to have a good understanding of CIP procure-ment, quality requirements and practices.
III.
CERTIFICATION REVIEW BACKGROUND:
Because of the NRC notice of violation and nonconformance and related customer concerns, CIP determined that it was advisable to verify that materials shipped to customers for nuclear applications i. e., ASME Section III, NCA-3SOO, NA-3700, 100FR50 Appendix B, ANSI N45.2, or 10CFR21, met applicable specification, code and purchase order requirements.
It was determined to focus l
on the content and accuracy of Cardinal's certifications so that i
the customers use of the material 19 not suspect after CIP has reviewed the certification and determined compliance with the specifications, codes and/or standards referenced there in.
Sup-porting documentation that CIP utilized as a basis for issuing it's certification will be reviewed.
Subcontractor supplied data will.be reviewed for material and/or services provided by the subcontractor to Cardinal.
PURPOSE:
To insure that the materials shipped by Cardinal conferm to the specified quality (or code) requirements and that supporting quality verification documentation is on file to substantiate the CIP certification.
1 SCOPE:
4 Cardinal will review for accuracy all of the certifications it has issued to customers for nuclear application.
Certifications which do not reference one or more of the following require-ments will be excluded:
ASME Section III, NCA-3800, NA-3700,
PAGE 5 AUGUST 8, 1984 1
10CFR50 Appendix B, ANSI 45.2 or 20CFR21.
Ilhen CIP has performed in-house manufacturing operations on material the supporting quality verification documentation will be reviewed to determine accuracy of the data on the certification. When operations on materials were performed by a CIP approved subcontractor the data in the CIP subcontract purchase order file utll be reviewed.
The results of this review shall be documented.
Uben the applicable code is ASME Section III, Div. I Cardinal's ASME approved Quality Assurance Manual will serve as the acceptance criteria / standard.
When the referenced code is 10CFR21 APP B or ANSI N45.2 the acceptance criteria vill be Cardinal's approved manual as modified by attached Standard Practice CSP 8.003 uhich excludes criteria that are concerned only with ASf1E and incorporates acceptance criteria for 10CFR50 APP B and ANSI N45.2.
When none of the above standards apply for the specific order, the material specification will be the criteria for acceptance.
The material specification will also be the acceptance criteria for ASME Section III size excluded materials (NX 2600).
1 METHOD:
-Document results of review, including variances, in accordance with procedure outlined as follows:
j 1.
The data base will be established.
-Data will be entered enabling CIP to sort and review cert-l ifications by customer, heat #,
Cardinal PO#, and/or CI#.
This will establish'a current status of review and ident-ification of variances.
2.
The review process a.
Selection
-CMTR's attesting to any one of the requirements refer-enced in the scope of this section shall be selected, b.
Review Shall consist of subcontractor certifications and applicable in-house records.
3.
Review Criteria Verify that all quantative and qualitative data recorded on CIP CMTR's is accurate and supported by adequate Documentation as follows:
a.
Verify visual inspection prior to May 1983 by assuring CNR has proper 0.A.
final inspection sign-off After May 1983 visual inspection reports are on file per CSP 11.003, b.
Verify NDE, when applicable, was performed by an app-roved subcontractor and the appropriate sample was examined, and accepted.
i PAGE 6 AUGUST B, 1984 i
Y c.
Verify heat treatment, when applicable, that times, temperatures, cooling media and heat treated condition are recorded.
i d.
Verify Charpy impact tests, when applicable, have been performed by code or specification requirements and that coupon location and orientation are substantiated.
To i
meet NX 2300 when required.
e.
Verify that up grading, when applicable, to Section III of the Code has chenistries performed on each piece l
used and' sufficient mechanical tests were performed for each heat lot.
When continuous or batch processing is not documented on heat treat certification the most severe sample plan will be used to deternine the number of tests.
f.
Verify that years for Code and Addenda or ASTM spec-ifications which are recorded are accurate and in cases where years an Addenda were not required the material will meet latest year at the time of certification.
3.
Dispositioning findings
-When variances are discovered, as a result of the above, they shall be documented.
Cardinal shall notify i
customer (s) of variance per Cardinal Standard Practice, CSP # 17.003 and/or customers unique reporting method (e.g.
Bechtel SDDR), as applicable.
a.
Documentation of findings - both acceptable and not acceptable (in data base) b.
Evaluation of findings on hardware.
The applicable criteria of the governing standard and/or project requirements shall be considered uhen evaluating for acceptance.
c.
When additional testing is required samples will be pulled from CIP stock, When available, or provided by by the customer, d.
Close out of findings by changing N to Y on data base, Reporting of deviations for any veristion that can not e.
j be closed out will be per CSP 17.003.
4.
Records a.
Corrections if necessary, by ammending CMTR which will be recorded in the computer system.
The new CMTR will reference the old CMTR number.
b.
Customers will be sent ammended CMTRs that records results from the review.
PERSONNEL:
Sort and data entry performed by personnel under the direction of the Manager of Administration.
Acceptance review performed by
PAGE 7 AUGUST 8, 1984 the Guality Verification Documentatifon Review Team,(that group chartered with the responsibility for performing CMTR Review) under the direction of the Director of Guality.
TRAINING AND OUALIFICATION:
Training will encompass: (1) method for performing quality verification documentation review as outlined above, and (2) to the specific requirements of this Corrective Action Plan.
Training shall be documented, and shall serve as a basis for qualification.
Training and qualification records shall be on file at CIP.
Approved by:
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AUGUST 8, 1934 CSP 8.003 CARDINAL INDUSTRIAL PRODUCTS CORP.
STANDARD PRACTICE This Standard Practice will appig to procurement which invokes Cardinal's Guality Assurance Program and either 10 CFR 50 Appendix B or N45.2 but does not invoke Section III, of the ASME Boiler and Pressure Vessle Code.
A.
PURCHASING Parts and/or materials may be purchased from surveyed and approved vendors as prescribed in the Guality Assurance Manual. As an alternate, vendors may be qualified thru other means such as evaluation of Guality program or product verification as outlined in "D"
below at time of receiving inspection.
B.
INSPECTION Per Quality Assurance Manual.
C.
CERTIFICATIONS Vendor Certification: Vendor certifications will not require a Guality Statement but must consist of a Mill-Sheet, certified Material Test Report (CMTR) or a Certificate of Compliance (C of C).
In the case of a C of C, heat numbers need not be known if product verification as delineated below is followed.
Cardinal Certification: The Cardinal Certification for material provided under this standar practice shall bear the statement that the certification is issued subject to the provisions of this supplement as approved by the customer.
Other data required by the purchase order will be given in the certification except Cardinal will not provide its OSC number.
D.
PRODUCT VERIFICATION Raw Material: For carbon steel raw material, Cardinal wi11' determine that the material is ferro-magnetic and that the hardness range is as expected for the grade of carbon steel. For all other raw materials, Cardinal will additionally verify the chemical content of one piece of material and required mechanical testing and record such verification in the vendor certification file.
Finished Product: If carbon steel finished products are procured, Cardinal will verify that the material is ferro-magnetic and that the product meets the, hardness.
and mechanical properties of the invoked material spec-Page 1 of 2
.o GAM SUPPLEMENT Page 2 of 2 fication. The number of pieces tested will be as re-lived by the referenced finished product specifi-ntion. In the case of procurement for all other types of finished materials. Cardinal will additionally per-form a verification of chemistry on one piece of material This data will be included in the vendor certification file.
E.
MARKING All finished products will be marked in accordance with applicable customer and specification requirements. In cases where Cardinal procures finished products which are properig marked, no additional marking will be applied. If product requires additional marking this will be applied by Cardinal prior to shipment.
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s JUNE 20, 1984 REV, AUGUST 7, 1984 REV 2 AUGUST 9, 1984 ATTACHMENT 1 MATERIALS WHICH WERE IZOD TESTED A193 & SA193 B7 ALL THREAD STUDS SIZE AFFECTED HEATS (4)
(1)
(1)
(5) 1 1/8-8:
4525B
,6882D
,9121E
,X107E, X605D
& X606D (1,3)
(1)
(1,4) 1508E & B724B 1 1/4-8:
5450B, 5408B, 3454A, 7536B
,9723D (4)
(1) 1 3/8-8:
3454A, 5408B, 5450B, 6409B, 5785D, 7212E
,9723D (1)
(1) 9423E
& 9814D (1) 1 1/2-8:
N589B, 9525B, 7157D, 9106D & 8724B (1,4)
(1) 1 5/8-8:
9233E, 9423E
, 9106D (4)
(1) 1 3/4-8:
9425E
& 380E (2 PO'S)
(1)
(1)
(1)
(1,4)
(1) I
, 7238D
,7762E
,8724B 1 7/8-8:
9892D
, 9526B (4) 2-8:.95265 (1,4)
(2) 2 1/4-8:
D552B
& 7315A (2)
(2)
(2) 2 1/2-8:
7315A
, N825D
& N630B NOTES:
1 '- Tested at O Deg F per NX2300 with Charpy V-notch. Heat passed.
2 - Tested at 10 Dog F per NX23OO with Charpy V-notch. Heat passed.
3 - Tested at 20 Dog F per NX23OO with Charpy V-notch. Heat passed.
4 - Tested at 68 Dog F per NX23OO with Charpy V-notch. Heat Passed.
5 - Material being tested at O Deg F per NX23OO with Charpy V-notch.
6 C a rdin al INDUSTRIAL PRODUCTS CORPORATION (toll saisti 300.e34.es41 3873 wtST OQvtNoC +
P=o%t a,viv&o As 702 739 1908 LAS VEGAS. NEVAoA 89118 REPORT TO OUR CUSTOMERS This report has been prepared to update our customers as to the current status of our Quality Assurance Program as it relates to products supplied to nuclear customers. Over the past seven years, as interpretations of the ASME Boiler Pressure Code have evolved, Cardinal's Quality Assurance Manual has been updated to reflect these changes. Our Guality Assurance Manual.has under-gone three revisions and two editions. We believe that, in its current form, our Quality Assurance Manual is one.of the most effective in the bolting industry. In recognition of our current Quality Assurance Program, on January 9,
1984, ASME certified Cardinal as a " material manufacturer" and a " material supplier" I
We have also been the subject of frequent customer surveys and/or audits. During the past five years, well over one hundred customers have reviewed our Guality Assurance Program, with an approval rate in excess of 98%.
In the fourth quarter of 1983, concurrent with the ASME certification process, the Nuclear Regulatory Commission in-spected selected portions of our Gualieu Assurance System and prepared detailed reports. The NRC's findings fell in three categories:
1.
Items that have already been resolved by Cardinal taking corrective action, e.g., the posting of additional statutory and regulatory material and providing customers with notices of cer-tain specific potential non-compliancess 2.
Items that were resolved by providing additional informa-tion to the NRC4 and 3.
Items which will be the sub ject of an internal review program that will be discussed below.
Frankly, after having been approveo by so many customers over the past years, we are surprised that the NRC was able to find any problems with our prior Guality Assurance Programs. Please be advised that, with very limited exceptions, all of the areas of concern raised by the NRC related to prior Quality Assurance Programs and not to our current ASME approved Quality Assurance Program.
{
__-------_-----------------------------------------------------J
D While we are confident that Cardinal has provided quality products to the nuclear industry over the past years, in order to assure our customers of the quality of those products, we have commenced an internal rev.ew program which will review all i
certifications issued by Cardinel to the nuclear industry. Since well over 20,000 certifications must be reviewed to determine if any non-conformances exist, this process will take several months. The general areas of review will include the following:
1.
The NRC found an isoleted number of instances where our test records did not confirm that non-destructive tests had been performed on a small number of pieces from certain groups of material. We will review our records to determine if any other instances existed and, if s o, notify tne customer.
- 2. The NRC has interpreted the stress relief requirements for cold drawn A193 and SA193 D7 and D16 materials differently than Cardinal. Cardinal has received an informal confirmation of its interpretation from ASTM committee members involved in writing the standard. Cardinal is currently seeking formal confirmation, and if received, it will clarify that no problem exists. Otherwise, appropriate notice will be given.
3.
Four purchase or.ders-were identif'ied where SA193 B7 mate-rial was cross-certified to SA320 Grade L7, where the required Charpy impact tests, performed by the mill, used Charpy Irod rather than Charpy V-Notch type. tests. Empirical test data and i
informal metalurgical opinions indicate that the values reported for " lateral expansion" may, in fact, be more conservative using the Izod rather that the V-Notch methoo. In any event, we have listed on Attachment 1,
those heat numoers which would be affected under subsection NX23OO. You will note from Attachment 1 that we have already re-tested many of these heats with the V-Notch method, and in each case the material passed. We are currently completing the re-testing of all of the listed heats, and will re-certify them where they have been used in nuclear applications. Additionally, we are reviewing our records to determine, as to Charpy tests performed by Cardinal, whether we may hav'e cut coupons, too close to the end of the material. To the extent we find any such instances, we will either re-test and re-certify the material or notify the customer. So far, all re-tested material has conformed to specifications.
4.
We found isolated instances under prior Cardinal customer approved quality programs, where stock materials were either in-advertently used for code applications without proper upgrade, or where goods were furnished from vendors who were not surveyed and/
or audited until after the material supplied had been produced.
Those instances which were discovered have been reviewed with the appropriate customers. If we discover any further such cases, we will advise the affected parties.
-g-
We believe that Cardinal's Quality Assurance Program as currently constituted is an excellent one. Our goal has been and will continue to be to provide the highest guality parts to the nuclear industry. Moreover.une believe that the NRC's input into Cardinal's Quality Assurance Program has been of significant benefit.
We are delighted that Cardinal is the first organi-ration to gear our program fully to current NRC interpretations.
We will continue to stay abreast of such interpretations to in-sure that all products certified by Cardinal will meet or exceed the standards of the NRC, ASME, our customers and Cardinal.
We welcome these inputs into the bolting industry as we have long believed that such oversight is necessary to bring the in-dustry into full code and statute compliance, for the ultimate benefit of you the nuclear bolting user.
If you have any questions or need additional information, please call me or Norm Henderson. We trust that we can count on your cooperation and support.
Additionally, we are attaching, for your review, copies of a supplement to our Quality Assurance Manual which will apply to procurement which invokes:our Quality Assurance Program and either 10 CFR 50 Appendia D or N45.2 but does not invoke Section III of ASME Boiler and Pressure Vessel Code.
t Sincerely,
'uvwS3 4L Dennis C.
Fielder President 4
I i.
r JUNE 20, 1984 ATTACHMENT 1 MATERIALS WHICH WERE IZOD TESTED A193 & SA193 B7 ALL THREAD STUDS SIZE AFFECTED HEATS (4)
(1)
(5) 1 1/8-8; 4525B
.6882D
.9121E,X107E
,X605D & X606D (3)
(4)(5)
,1 1/4-8:
54508, 54088, 3454A, 7536B
.9723D, 1500E & 8724B (4) 1 3/8-8:
3454A, 54088, 5450B, 64099, 5785D, 7212E
.9723D 9423E & 9814D 1 1/2-8; N5899, 9525D, 7157D, 9106D & 87249 (4)
(5) 1 5/8-8:
9233E..9423E
,9106D (4)'
(5) 1 3/4-8:
9425E
& 380E (5)
(5)
(4)(5)
(5) 1 7/8-8:
9892D, 9526D, 7238D.9526D,7762E
,8724D (4) i 2-8:
9526D (4)(5)
(2) 2 1/4-8:
D5528
& 7315A (2)
(2)
(2) 2 1/2-8; 7315A N825D
& N630D NOTES:
1 - Tested at O Deg F per NX2300 with Charpy V-notch. Heat passed.
2 - Tested at 10 Dcg F per NX2300 with Charpy V-notch. Heat passed.
3 - Tested at 20 Deg F per NX2300 with Charpy V-notch. Heat passed.
4 - Tested at 68 Deg F per NX2300 with Charpy V-notch. Heat Passed.
5 - Material being tested et O Deg F per NX2300 with Charpy V-notch.
JUNE 20,1934 SAM SUPPLEMENT CARSINAL INDUSTRIAL PRODUCTS CORP.
P:s3 8 cf D tan guPPLEpENT supplement to Cardinal's evality Assurance Manual. This supplement E.
MANNING will apply to procurement which invetes Cardinal's Guality All finished products will he marked.in accordance with Assurance Program and either 10 CFR SO Appendia 3 or N45.2 88#1188818 C#8%8**P 8#8 #P8Cification retvirements. In hzt does not invene Section III. of the ASME Boiler ang cases where Cardinal procures finished products which Presacro Vessle Code.
8F# PF898P1g markede ne addittenal marking will be 888 '
8'*888
tU1F88 #dditional marking this A'
PURCHASING wi 1 he applied by Cardinal praer.to shipment, Parts and/ec' materials may be purchased from surveyed and approved venders as prescribed in the Guality Assurance Manual. As an alternate. vendors may be qualified thru other means such as evaluation of Guality program er product verification as outlined in "D" below at time of receiving inspection.
3.
INSPECT!DN Per Guality Assurance Manual.
C.
CERTIFICATIONS Vendor Certification: Vendor certifacations will not require a Suelity Statement but must consist of a Mill Sheet. Certified Material Test Report (CMTR) or a Certsficate of Compliance (C of C3.
In the case of a C of C.
heat numbers need not be known if product verification as delsneated below is followed.
a Cardinal Certification-The Cardinal Certification for material provided under this supplement shall bear the statement that the certificatson is issued subject to the provisions of this supplement as approved by the customer.
Other data required by the purcnase order will be given in the certafication except Cardanal will not provsde its OSC number.
D.
PRODUCT VERIFICATION Qaw Material: For carben steel raw material. Cardinal will determine that the maternal is f erro-magnet te and that the hardness range is as espected for the grade of carbon steel. For all other raw materials, Cardinal will addittenally verify the chemical content of one piece of material and required mechanical testing and record such vertficetton in the vender certification file.
Finished Product: If carbon steel finished products are procured. Cardinal will verify that the material is ferro-magnetic and that the product meets the hardness and mechanical properties of the invoked material spec-afication. The number of pieces tested will he as re-guired by the referenced fanished product specif1-cation. In the case of procurement for all other types of finished materials. Cardinal will addittenelly per-form a verification of chemistry en one piece of material This data will be included in the vender certification l
- ile.
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UNITED STATES
k NUCLEAR REGULATORY COMMISSION
$ ;,y,.
I WASHINGTON, D. C. 20555 s,
August 10, 1984 Docket No. 99900840/83-01 Cardinal Industrial Products Corporation ATTN: Mr. M. J. Donovan Chairman of the Board 3827 W. Oguendo Las Vegas, Nevada 89118 Gentlemen:
/
/
/
Thank you for your)etters of April 17, 1984, June 13, 1984, August 8 1984, and August 9,1984, in response to our letters of February 29d84, May 18,1984, and July 23 A 984.
We have reviewed your reply as described in these letters and find it responsive to the concerns raised in our Notices of Violation and Nanconformance.
Additionally, your letters describe an extensive quality reverification program which, if implemented as described, will adequately address the NRC's concerns and should resolve any questions that may have been raised regarding the quality of products supplied by Cardinal.
We will review implementation of your corrective actions during a future inspection.
Sincerely, Richard C. D ung, O ector Office of I
.ction and Enforcement cc. D. Fielder, President 9
P' l
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Docket iso. 99900840/83-01 August 10, 1984 Cardinal Industrial Products Corporation ATTN: Mr. M. J. Donovan Chairman of the Board 3827 W. Oquendo Las Vegas, Nevada 89118 Gentlemen:
Thank you for your letters of April 12, 1984, June 13, 1984, August 8, 1984, and August 9,1984, in response to our letters of February 29, 1984, May'18, 1984, and July 23, 1984.
We have reviewed your reply as described in these letters and find it responsive to the concerns raised ir. our Notices of Violation and Nonconformance.
Additionally, your letters describe an extensive quality reverification program which, if implemented as described, will adequately address the NRC's concerns and should resolve any questions that may have been raised regarding the quality of products supplied by Cardinal.
We will review implementation of your corrective actions during a future inspection.
Sincerely,
'o: icinal P.:neW.
R. C. DcYo=s' Richard C. DeYoung, Director Office of Inspecticn and Enforcenent l
[
cc. D. Fielder, President DISTRIBUTION:
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Letter to Material Licensing Branch
[
Page 2 July 22, 1980
'1 The BetaART Series 6000 uses the Ohmart Model BAL source holder which has been approved previously.
(See approval request letters dated July 25, 1978 and May 5, 1980.)
1 1.1 Typical Environmental Conditions:
Temperature: ' Ambient, Lab environment i
Pressure Atmospheric Impact Accident only I
Vibration Zero to mild Corrosion Zero to mild Fire Unlikely Explosion Unlikely 1.2 Accident Conditions 1.2.1 Fire In a fire where the temperature is above the melting point of lead j
(3270C), the lead will melt and reduce the shielding, but the source capsule will be retained in the body of the source holder.
i For fires where the temperature is above the melting point of alumi-num (6590C), the body of the source holder will melt, but the source 4
j capsule will be retained in the source holder housing in all configu-rations of intended use.
Since the early 1960's, Ohmart has distributed several hundred beta gages.
None of these have been involved in a fire.
j 1.2.2 Explosion i
Ohmart has no history of beta gages involved in an explosion.
i However, analysis of the design of the various gage configurations indicates that the source capsule would be retained in the gage if the gage was involved in an explosion-2.0 Identification g
i l
This gage configuration will be identified as the Ohmart BetaAkT Series 6000 Profiler.
3.0 Radioactive Sealed Sources j
Sealed sources used in this device will be:
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A-35950 Kr-85 titanium capsule - round i
A-36058 Kr-85 titanium capsule - rectangular A-33766 Kr-85 titanium capsule - round p'.q g j; j
A-36553 Kr-85 titanium capsule - rectangular l
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Letter to Materials Licensing Branch Page 3 July 22, 1980 The American Atomic sources are included because we have been advised that American Atomics has sold the sealed source part of their busi-ness and that these sources will be available again soon.
All of the sources except A-36553,have been approved, previously.
Letters from American Atomics and the Arizona AEC are enclosed covering the source shown in drawing A-36553.
4.0 Radiation Profiles Radiation profiles were measured with a Victoreen Model 440 survey meter recently calibrated with a radium source traceable to an NBS st.andard.
For measurement of beta dose rates, no absorbers were used on the survey meter.
2 For measurement of gamma dose rates, a 300 mg/cm tissue equivalent absorber was added to the front and sides of the ion chamber on the survey meter.
4.1 Radiation Surveys Radiation surveys were made with the source ON and 0FF (shutter open and closed), with the hinged shield open and closed, at 5 cm and 30 cm, and for beta and gamma dose rates.
The enclosed data sheets pre-sent the data for the various conditions.
4.2 Maximum Activity Permissible Since there is no definite guideline for laboratory devices of this type, we will limit the source activity to a value that would result in a whole body dose of not more than 0.5 rem / year.
It is unlikely that an operator's body will be within 30 cm of the device more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per day.
Assuming a work year of 50 weeks, 5 days per week, the operator could be within 30 cm of the gage for 1000hourn/ gear.
Thus, the permissible whole body dose rate (gamma) wouldbefh60 Examination of the data sheet for 30 cm, gamma, source ON, shield open or closed shows that the dose rate is, essentially, background - i.e.
0.05 mr/hr.
Even at 5 cm the gamma dose rate is a maximum of 0.25 mr/hr for the same conditions.
Since the data was obtained using a 65 mci Kr-85 source, we request a maximum acitivty permissible of 200 mci of Kr-85.
Approval for use of other radioisotopes is not requested at this time.
Ollf5I8 i
Letter to Materials Licensing Branch Page 4 July 22, 1980 5.0 Details of Construction Details of construction are shown in the enclosed photographs.
The source holder is the standard Ohmart Model BAL which has been approved previously.
The shutter is operated by a keylock switch. Lights on the front of:the device indicata whether the shutter is open (source ON, red light) or closed (source OFF, green light).
6.0 Labeling Labels attached to the device are:
1)
" Caution - Radioactive Material" - Stainless steel, etched and painted yellow background with purple CAUTION and propeller, attached with drive screws - copy enclosed.
2)
" Caution - Keep Hand Out of Air Gap" - actual label enclosed.
3)
" Source ON" and "0FF" located adjacent to red and green lights.
4)
" Keep Shield Closed Except To Insert Or Remove Sample" located on hinged shield.
5)
Provisions of General License for general licensees only - stain-less steel, etched and painted yellow background, attached with drive screws - copy enclosed.
7.0 Prototype Testing The Model BAL source holder was tested thoroughly at the time of it's submission for approval.
8.0 Quality Control 8.1 Sealed sources:
Examination of vendor source certificate for proper activity and leak test results.
Incoming wipe test before placing source in inventory.
Wipe test of complete device prior to ship-ment.
Wipe testing equipment can detect less than 0.005 uCi of acti-vity on the wipe.
This is to check for contaimination other than Kr-85.
8.2 Radiation Field Intensity:
Measure radiation field intensity of completed device prior to shipment to assurc that the gamma dose rate does not exceed 0.5 mr/hr at 30 cm fro.t the surface of the device, source ON, with the hinged shield either open or closed.
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Letter to laterials Licensing Branch Page 5 July 22, 1980 9.0 Installation Devices distributed to General Licensees will be installed by Ohmart personnel or other specifically licensed persons.
10.0 Wipe Test and 0FF/0N Mechaniam Test Interval Since only Kr-85 will be used in the device, no periodic wipe testing is required.
The standard 6 month interval is requested for testing of the OFF/0N mechanism and indicators.
11.0 Radiation Safety Instructions A new radiation safety section in the instruction manual for devices distributed to General Licensees has been written for the Ohmart Beta-ART Series 6000 Profiler.
A copy of the Section RS-109 is enclosed.
12.0 Servicing The Ohmart Corporation offers a full range of services to its custo-mers including:
Start-up supervision, radiation surveys, leak tests, leak test kits, OFF/0N operational check, training classes at the user's plant or the Ohmart factory and disaster assistance.
Sincerely, O
H.
L. Cook Vice President, Engineering Enclosures HLC:wl