ML20137N259
| ML20137N259 | |
| Person / Time | |
|---|---|
| Issue date: | 04/22/1985 |
| From: | Conway J, Merschaff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20137N250 | List: |
| References | |
| REF-QA-99901002 99901002-85-01, 99901002-85-1, NUDOCS 8601310214 | |
| Download: ML20137N259 (4) | |
Text
..
ORGANIZATION:
ROBERT-JAMES SALES, INC.
BUFFALO, NEW YORK REPORT INSPECTION INSPECTION NO.: 99901002/85.01 DATE(S):
3/25-28/85 ON-SITE HOURS:
56 CORRESPONDENCE ADDRESS: Robert-James Sales Inc.
ATTN: Mr. Robart Boker Presideist 269 Hinman Avenue Buffalo, New York 14216 ORGANIZATIONAL CONTACT: Mr. Robert Boker, President TELEPHONE NUMBER:
(716) 874-6300 PRINCIPAL PRODUCT: Pipe, tubing, flanges, fittings, and valves.
NUCLEAR INDUSTRY ACTIVITY: Less than 0.1 percent of the FY 1984 sales.
ASSIGNED INSPECTOR:
1-$4 h-18 8f
(.yT.Conway,Reactv Inspection Section (RIS)
Date l
OTHER INSPECTOR (S):
J. J. Petrosino, RIS APPROVED BY:
Wb
$~
E. W. Merschoff, Chief, RI6, Vendor Program Branch / Date INSPECTION BASES AND SCOPE:
l A.
BASES:
10 CFR Part 50, Appendix B and 10 CFR Part 21.
B.
SCOPE: This inspection was made as a result of the receipt of an allegation pertaining to remarking foreign fittings and selling them as domestic fittings.
l PLANT SITE APPLICABILITY:
Part 21 requirements:
Nine Mile Point (50-220),
Fermi 2 (50-341), and James A. Fitzpatrick (50-333).
10 CFR 2.790 INFORMATION HAS BEEN DELETED 8602320224 e50509 j99ENVR I.
01
O ORGANIZATION: ROBERT-JAMES SALES, INC.
BUFFALO, NEW YORK REPORT ~
INSPECTION NO.: 99901002/85-01 RESULTS:
PAGE 2 of 4 A.
VIOLATIONS:
1.
Contrary to Sections 21.6 and 21.21 of 10 CFR Part 21:
a.
Copies of 10 CFR Part 21 and Section 206 of the Energy Reorganization Act were not posted.
b.
Appropriate procedures to evaluate deviations or inform the licensee or purchaser of the deviation did not exist.
2.
Contrary to Section 21.31 of 10 CFR Part 21, it was noted that purchase order (PO) Nos. 132-47, J-141-362, and J-141-383 from and P0 No. 91190 from to Robert-James Sales (RJS) specified 10 CFR Part 21 as an applicable requirement, but RJS P0s to (No. 6581),
(No. 6561),
(No. 6582),
(No. 6555),
(No. 3232), and (Nos. 3156, 3233, and 3924) did not similarly specify that 10 CFR Part 21 would apply.
B.
NONCONFORMANCES:
None.
C.
UNRESOLVED ITEMS:
None.
D.
OTHER FINDINGS OR COMMENTS:
1.
Compliance with 10 CFR Part 21 Requirements - An inspection of the shop area noted that RJS had not complied with the posting require-ments of 10 CFR Part 21 (see Violation A.1.a).
In addition, RJS had not developed a procedure for reporting defects and noncompliances (see Violation A.1.b).
2.
Documentation Packages - Two hundred eight-nine documentation packages for pipe, flanges, fittings, and valves ordered by utilities and manu-facturers were reviewed.
The orders were for fiscal years (FY) 80 (36), 81 (37), 82 (48), 83 (80), 84 (60), and 85 (28). Documenta tion packages consisted of customer P0s; P0s to suppliers / manufacturers, work orders, shipping invoices, and Certificate of Conformance (CC);
and CCs and/or Certified Material Test Reports (CMTR) from suppliers /
manufacturers.
~
10 CFR 2.790 INFORMATION HAS BEEN DELETED
ORGANIZATION: ROBERT-JAMES SALES, INC.
BUFFALO, NEW YORK REPORT INSPECTION NO.: 99901002/85-01 RESULTS:
PAGE 3 of 4 The majority of the 209 nonnuclear orders were for fossil type electrical generation facilities, and the 80 nuclear orders were for (60),
(15),
(3),ar.d (2). A review of the 80 nuclear orders revealed the following:
a.
Seventy-six orders were for non safety-related items and referenced ANSI or ASTM for the material specification.
b.
P0s J-141-362 and J-142-383 dated August 31 and September 7,1982, respectively, were the only P0s that referenced the requirements of Section III of the ASME Code.
c.
P0s 132-47 dated October 10, 1980 and J-141-362 and J-141-383 from were the only P0s that specified the requirements of 10 CFR Part 21.
^
d.
PO 91190 dated November 28, 1979, from was the only P0 that required RJS to have a QA program meeting the requirements of Appendix B to 10 CFR Part 50.
In addition, the P0 was stamped
" Note: This is an order for Safety Related Materials...All requirements of NRC Regulation 10 CFR 21 apply as outlined in draft letter #1 August 10,-1977."
August 10, 1977 letter to RJS states, in part, "... inform subtier vendors that they must inform you of defects and deviations from procurement documents."
RJS ordered the items for the customer P0s(3 from and one from
) identified above from six material suppliers and manufacturers.
It was coted that applicable P0s 3924 (December 10, 1979), 31o6 (September 7, 1982), and 3233 (September 16, 1982) to
- 6561 (October 10,1980) to 6581 (October 14, 1980) to
- 6582 (October 14, 1980) to 6555 (October 14, 1980) to
- and 3232 (September 20, 1982) to did not identify the applicability of 10 CFR Part 21 (see Violation A.2).
It was also noted that RJS P0s did not include or reference QA program requirements (e.g., Appendix B to 10 CFR Part 50) or indicate that the material would be used on a nuclear project. There was no indication that the P0s had been reviewed and approved by a QA representative.
l 10 CFR 2.790 INFORMATION HAS BEEN DELETED
ORGANIZATION:
ROBERT-JAMES SALES, INC.
BUFFALO, NEW YORK l
REPORT ~
INSPECTION NO.: 99901002/85-01 RESULTS:
PAGE 4 cf 4 The fittings designated as Section III/ Class 2 on P0s J-141-362 and J-141-383 were ordered from on P0s 3233 and 3156 and on P0 3232. At the time of the orders both and were holders of an ASME Quality System certification (Materials).
In addition, all the items on the 3 P0s were shipped directly from the manufacturer's facility to the Fermi-2 nuclear site. The safety-related items for P0 91190 were also shipped from facility direct to the Nine Mile Point 1 facility.
3.
Allegation - In April 1983, an individual alleged to the NRC Region I Office that RJS was remarking foreign fittings and selling them as domestic fittings. The allegation did not specifically address any material that may have been furnished to a nuclear facility.
The NRC inspector toured RJS's warehouse facility at various times during the inspection.
It was noted that stainless steel pipe, flanges and fittings were segregated according to size and alloy type. A visual inspection of markings on both foreign and domestic <
fittings showed no indication that original markings were altered or changed. The inspector also reviewed approximately 290 P0s from utilities and suppliers / manufacturers of items to the nuclear industry from FY 1980 to the present. Only 80 P0s were for items that were ordered for nuclear facilities.
Of the 80 P0s only 4 P0s were for items considered " safety related" in that Section III and/
or Part 21 requirements were imposed upon RJS.
As noted in D.2 above, all the items on the 4 P0s were produced by domestic qualified manufacturers, and all the items were shipped directly from the manufacturer's facility to the nuclear site.
Based upon the inspector's review of nuclear orders from FY 1980 to the present and an indepth evaluation of stored items in the warehouse, the inspector could not substantiate the allegation.
a 10 CFR 2.790 INFORMATION HAS BEEN DELETED
.