ML20128K235

Notice of Nonconformance from Insp on 850506-10

ML20128K235
Person / Time
Issue date:	06/28/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20128K214	List: ML20128K210 ML20128K235 ML20128K277
References
REF-QA-99900343 NUDOCS 8507240070
Download: ML20128K235 (4)

Text

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APPENDIX A I

Gulfa11oy, Inc. \

l Docket No. 99900343/84-01 ,

NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted on May 6-10, 1985, it appears that certain of your activities were not conducted in accordance with NRC requirements.

Criterion V of Appendix B to 10 CFR Part 50 states: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructinns, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Nonconformances with these requirements are as follows:

A. Section 3.1 of the " Quality Assurance Program Materials Identification and Verification Manual" (QAM) dated September 1983, states, in part, "All sources of nuclear quality materials will be surveyed by the .-

Quality Assurance Department.... They will be surveyed...according to the requirements of the latest Edition and Addenda of the ASME Boller and Pressure Vessel Code,Section III."

Section 5.1 of the QAM states in part, " Materials are to be ordered

...under a Quality System Program as accepted by...Gulfa11oy...."

Subsection NCA-3861(b) of Section I!! of the ASME Code states, in part, "The material supplier shall be responsible for:...(2) surveying, quali-fying, and auditing the Quality System Program of the Material Manu-Jacturer...."

Contrary to the above a review of documentation packages for 20 nucioar urders from Florida Power & Light (FPL) and 2 nuclear orders from Texas Utilities Generating Company (TUCCo) indicated that material on 11 FPL orders and one TUGCo order was purchased by Gulfalloy from the following suppliers / manufacturers who were either surveyed / audited after the purchase order (PO) was placed or who were never surveyed / audited by Gulfalloy:

%f 99900343

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r l Customer Order (date) Supplier / Manufacturer FP&L Delivery & Work Authorization (OWA) 39541 (December 6, 1982) Benko Fittings & Flange (1)

Cardinal Industrial Products (2)

Tube-Line (1) i 38624 (Narch 19, 1982) Ametek(1) l Tube-Line (1)  :

39666 (January 3, 1983) Standard Fittings (1) l Hackey (1)  !

National Flange & Fittings .

Benko Fittings & Flange (1) i l

38625 (March 19, 1982) Tube-Line (1) _

24503C(November 10,1981) GulfSupply(3) '

26398W (January 25,1983) Cardinal Industries Products (4) 28660S(September 3,1981) Gulf Supply (3) 17461A (April 1, 1982) All States Steel (1)

Gulf Supply (3) 17328 (February 5, 1982) All States Steel (1) 17387 (March 3, 1982) All States Steel (1)

TUCCo p0 CPF 1000 - S Copperweld Regal Tubing (4) ,

(1) Never surveyed /audlted by Gulfalloy (2) Surveyed / audited 6 months after P0 date (3) Last surveyed / audited in February 1978 (4) Surveyed / audited 1 month af ter P0 date

, 8. Section 3.3 of the QAM states, in part, "A co be on file as evidence of the qualification."py of the certificate (s) will ,

7 Contrary to the above, there was no documented evidence of a Quality System i Certificate (Material) for Nippon Kokan, Kawasaki Steel Corporation and l Nippon Benkan who are ASMC certificate holders. In 1982, these three i manufacturers supplied pipe and fittings to Gulfalloy through Benko i Fittings & Flange, a sister company of Gulfalloy. Subsequently, Gulfalloy '

sent a number of the items to the Turkey Point nuclear facility for orders '

on DWA 39541 dated December 6, 1982 and DWA 39666 dated January 3, 1983, i C. FP&L imposed Special QA Document (SQAD) 1001 " Quality Requirements for l Items Requiring Nuclear Quality Assurance", Revision 3 and SQA0 1002

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" Defect or Noncompliance Reporting Requirements for Nuclear Related Purchases", Revision 3 on all nuclear safety related P0s which were  !

designated "QL-1."  !

Section 2.5 of the QAM requires the Quality Assurance Coordinator be  !

responsible for certifying Gulfalloy's material test reports and letters '

of compliance.

Subsection NCA-3867.4(c) of Section III of the ASME Code states, in part, l "This certification affirms that the contents of the report are correct I and accurate...."

i Contrary to the above, a review of documentation packages for 20 "QL-1"  !

PCs from FP&L revealed that Gulfalloy certified on Material Test Reports (MTR) or Certificate of Conformances (CC) that the requirements of SQA0s 1001 and 1002 applied to the purchased items, but the manufacturer's ,

Certified Material Test Report (CMTR) did not document this fact. The af fected nuclear orders with improper certifications are as follows:

l DWA/PO No. MTR/CC Date I l

34648 October 26, 1981 i

39641 February 3 and 17, 1983 ., !

January 24, 1983 39541 January 26, 27, and 28, 1983 February 7 and 17, 1983 38617 A April 13 and 20, 1982 38624 8 April 12 and 20, 1982 May 4, 1982 39666 March 3, 1983 May 4, 1983 January 31, 1983 38625 May 13, 1982 April 22, 1982 218345 August 11, 1982 219355 August 11, 1982 276395 January 5, 1984 17461 A April 20 and 23, 1982 i

17328 February 10, 1982 17387 April 20, 1982 I l i

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4 D. Texas Utilities Generating Company (TUGCo), P0 CPF 1000-S dated July 13, 1981 for 2000 ft of A500 Grade B tube steel referenced Section III Class 1 component, Subsection NF, 1974 Edition thru Winter 1974 addenda of the ASME Code.

Section 5.2.2 of the QAM states, in part, " Orders placed on Vendors must show ,,

date of Code Edition and applicable Addenda required by the customer 1

i Subsection NCA-3867.4(c) of Section III of the ASME Code states, in part, l "This certification affirms that the contents of the report are correct  ;

and accurate...."

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Contrary to the above, it was noted that Gulfalloy PO 22-27-22672 dated  !

July 14, 1981, to Copperweld Regal Tubing (CRT) did not reference the code requirements identified on TUGCo's P0; and Gulfalloy's MTR dated September 23, 1981 certified that the material met the requirements of l ASME Section !!!,1974 Edition thru 1974 Winter Addenda, N8-2000 for  :

Class 1 materials", but CRT's CMTR dated September 3, 1981, did not  !

document that the material met the code requirements. -

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