ML20132E108
| ML20132E108 | |
| Person / Time | |
|---|---|
| Issue date: | 12/13/1996 |
| From: | Gallo R NRC (Affiliation Not Assigned) |
| To: | Pedritti D ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| Shared Package | |
| ML20132E112 | List: |
| References | |
| REF-QA-99901297 NUDOCS 9612230048 | |
| Download: ML20132E108 (1) | |
Text
Dec a.ber 13, 1995 Mr. Don F. Pedritti, President & General Manager ABB-Electro Mechanics 150 John Downey Drive New Britain, CT 06050-0750
SUBJECT:
ABB-ELECTR0 MECHANICS SEPTEMBER 16 AND NOVEMBER 26, 1996, PEPLIES TO NOTICE OF NONCONFORMANCE 99901297/96-01-01 (NRC INSPECTION REPORT NO. 99901297/96-01)
Dear Mr. Pedritti:
Thank you for your September 16 and November 26, 1996, letters in response to our subject Notice of Nonconformance (NON).
In your September 16, 1996, letter, you indicated that ABB-EM plans to revise its Quality Assurance Procedure (QAP)-215, "Non-Conforming," and other appropriate procedures to require customer rejections to be documented.
In your November 26, 1996, letter, you provided us a copy of the revised QAP-215.
We have reviewed your letters and find that your response to the NON is responsive to our concern.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC's Public Document R<
.PDR).
Sincerely, Original sinned by:
Robert M. Gallo, Chief Special Inspection Branch Division of Inspection and Support Programs 9ffice of Nuclear Reactor Regulation j
Docket No. 99901297
Enclosures:
1.
ABB-EM letter dated September 16, 1996.
2.
ABB-EM letter dated November 26, 1996, and attachment QAP-215.
Distribution:
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l September 16,1996 U.S. Nuclear Regulatory Commission Artn: Document Control Desk Washington, D.C. 20555-001 cc: Chief, Special Inspection Branch Division ofInspection and Support Programs Office of Nuclear Reactor Regulations Washington, D C. 20555-001 REPLY TO A NCrflCE OF NON-CONFORMANCE DOCKET NO: 99901297 (99901297/96-0l)
==
Introduction:==
ABB Electro-Mechanics ( ABB E-M) was cited in the subject NRC Inspection Report for failure to take proper corrective actions to prevent a recurrence of deSciencies noted by customer final inspection results. The spectfic orders reviewed were two replacement part orders with RG&E for the Ginna Station. The deficiency cited by the NRC Inspection Report is that EM failed to take adequate corrective action to preclude recurrences of similar deficiencies.
Deteriotion of steps that were taken to ccrrect non-conformances.
- 1. Regarding the first order, there was no immediate corrective action taken by A3B E-M at the time of the surveillance inspection during witich the non-conformance was noted. RG&ti issued NCR 92-100 (per RG&E Quality Release form) to facilitate action at Ginna Station, to resolve the non-conformance.
- 2. Subsequent to the R&GE's General Supplier Audit conducted in June 1993, ABB EM modified its internal methods for processing RG&E orders including the issuance of a formal company procedure (e.g. EMOF-126, Contract Control Requirements General Procedural Guidelines), to insure that RG&E purchase order requirements are incorporated to the satisfaction of RG&E prior to the point of release for shipment. This procedure involves the formal submittal, via Request for Review /Approwl (RAR) form, of certain ABB EM order processing documents to RG&E for their comment and approval to insure agreement on how order requirements will be met prior to completion of the order.
- 3. The noted deficiency related to the second order involved the disapproval on an RAR submitting various process documentation for comment / approval. RG&E's concerns were similar to the issues raised on the first order. ABB EM addressed RG&E's concerns and resubmitted the documentation by RAR. The revised RAR and documentation were approved on 06/03/96 and the equipment was shipped.
ABB Electro-Mechanics A 0+s on of Comeustion Engineenng inc PO Bom 750 Teiephone (860) 826-4100 150 xhn Ocaney Dnve Fan (8Ec) 826 4115 Ne.s enta n CT 06C50-0750
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Descrintion of stens that will be taken to correct non-conforrn=c~
l ABB E-M Quality Assurance Procedure QAP-215 "Non-Conforming" items will be revised to include customer discovered non-conformance's as follows
- 1. Customer Rejections ofitems found to be in non-conformance during surveillance inspections shall i
be documented on Problem Disposition Report forms (PDR) per QAP 221 and dispositioned in
[
accordance with the procedures as indicated in the referenced QAP.
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- 2. The PDR's generated during the surveillance inspections for a particular customer will bejointly reviewed by ABB EM Contracts, ABB EM Engineering and ABB EM Quality Assurance, as a minimum, on receipt of order from that customer. The intent of that review is to insure that the specific requirements of their order wi'l be met. ABB EM will revise the appropriate QA procedures to accomplish and document these reviews.
Qat.ej corrective actions and preventive measures will be completed.
Changes to Procedures as defined above will completed on or before December 2,1996.
Yours truly, (11$Y Donald F. Pedretti ABB E-M General Manager l
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A EB ED 7%BDED November 26,1996 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-001 cc: Chief, Special Inspection Branch Division ofInspection and Support Programs Office of Nuclear Reactor Regulations Washington, D.C. 20555-001 Reference To Notice of Non-Conformance Docket No.: 99901297 (9991297/96-01)
Dear Sirs:
In the ABB Electro-Mechanics reply of September 16,1996 to the notice ofnon-conformance on the reference docket we committed to revision ofour document QAP 215. Attached to this correspondence is the revised document for your file.
Yours truly,
, Peter A. $erwerda Quality Assurance Manager cc:
J. W. Davis A.A.Oja D. F. Pedretti
. W. J. Waylan d S. L. Packard W. L. Iladovski ABB Electro-Mechanics A D4
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QAP 215 SHEET 1 CON'T ON 2 REVISION DATE: 11/25/96 QUALITY ASSURANCE PROCEDURE QAP 215 NON-CONFORMING ITEMS REFERENCE QAM 200 SECTION 15
'f APPROVED /s/ Peter Ferwerda DATE 12/14/90 QUALITY ASSURANCE MANAGER APPROVED /s/J. W. Davis DATE 12/14/90 DIRECTOR OF OPERATIONS py20'!%
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%EF Ntw Britain, Conneewat 06051 QAP 215
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I SHEET 2 CON'T ON 3 l
NON-CONFORMING ITEMS PEVISION DATE REVISION RECORD APPROVAL l
12/14/90 1.
Revised to obtain new management
/s/ Peter Ferwerda i
approval and computer control.
/s/J. W. Davis 2.
Revised Section 3 for references.
3.
Added Section 4 (old Section 3).
l 6/3/96 1.
Refonnatted procedure.
/s/ Peter Ferwerda
/s/J. W. Davis A
11/25/96 1.
Added paragraphs 4.3 & 4.4.
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ABB El ctra-M:chanics S
N:s Britain, Connocucut 06051 QAP 215 SHEET 3 CON'T ON F 1.
SCOPE This procedure specifies the measures to be followed in processing non-conforming items.
2.
GENERAL Items acquired or intended for use which do not meet the requirements of the prescribing document will be identified and processed as required to prevent inadvertent use.
3.
REFERENCES 3.1 QAP 210 Inspection 3.2 QAP 220 Work Orders 3.3 QAP 221 Problem Disposition Reports 4.
PROCEDURE 4.1 Non-conforming items will be identified and processed in accordance with the following procedurns, as applicable:
QAP 210 Inspection QAP 220 Work Orders QAP 221 Problem Disposition Reports 4.2 Non-conforming items will be separated from normal production items unless prohibited by size, weight or other considerations, in which case suitable identification will be attached to prevent inadvertent use.
4.3 Customer rejections of items found to be in nonconformance during surveillance inspections shall be documented on Problem Disposition Report Form F249 per QAP 221 and dispositioned in accordance with
,rocedures as indicated in the referenced QAP.
4.4 The Problem Disposition Reports generated during the surveillance inspections for a particular customer will be jointly reviewed by ABB EM Contracts. ABB EM Engineering and ABB EM Quality Assurance, as a minimum, on receipt of the order from that customer. The intent of that review is to insure that the specific requirements of their order will be met.