ML20138E328
| ML20138E328 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20138E319 | List: |
| References | |
| REF-QA-99900861 NUDOCS 9705020157 | |
| Download: ML20138E328 (4) | |
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NOTICE OF NONCONFORMANCE DuBose National Energy Services,lnc.
Docket No.: 99900861 Clinton NC Based on the results of an inspection conducted on January 21 through 24,1997, it appears thet certain of your activities were not conducted in accordance with NRC requirernents.
i A.
Criterion V, " Instructions, Procedures and Drawings," of Appendix B to 10 CFR Part 50 requires, in part, that activities affecting quality shall be
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prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings.
1 Paragraph NCA-3861(b) states that the Material Organization shall transmit all certifications received from other Material Organizations or approved suppliers to the purchaser at time of shipment.
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Paragraph NCA-3862.1(b) of Section lli of the ASME Code states that l
"When required chemical analyses (including mill heat analysis), heat l
treatment, tests, examinations, or repairs are subcontracted, the approved l
supplier's certificatior 'or the operations performed shall be furnished as an identified attachment to the Certified Material Test Report."
The following examples demonstrate failure to comply with the above requirements and constitute Nonconformance 99900861/97-01-01 1.
Contrary to the above, DuBose Certified Material Test Report (CMTR) for material supplied to San Onofre Generating Station (SONGS),
under Purchase Order (PO) 6N236016, certified that this material was supplied in accordance with their ASME Quality Systems Certificate l
(QSC), but did not reference or include the mill heat analysis as an j
identified attachment.
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Contrary to the above, DuBose CMTRs for material supplied to Union Electric Co. under PO 094006, dated June 24,1996, and to Carolina Power & Light Co. (CPL), under PO 8M1717 CJ, dated November 1, 1996, certified that the material was supplied in accordance with their j-OSC, but did not reference or include certifications from approved suppliers as identified attachments to their CMTRs.
i 9705020157 970429 PDR GA999 ENV*****
99900861 PDR m
B.
Criterion Vil, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50, requires, in part, that purchased material conforms to procurement documents.
Paragraph 10.3.1.4 of DuBose quality systems program (OSP) requires, in part that QA will review the vendor documentation against requirements of the PO, material specification, and, when required, the ASME Code. When unacceptable documentation is received, the material will be segregated until proper documentation can be obtained.
Paragraph 2.3.4.1 of DuBose QSP requires, in part, that POs shall require certification that the material was furnished under a program accepted by DuBose.
The following examples demonstrate failure to comply with the above requirements and constitute Nonconformance 99900861/97-01-02 1.
Contrary to the above, DuBose accepted material supplied under PO 2284-63, dated February 5,1993, without the starting material supplier being identified on the CMTR as required by this PO.
2.
Contrary to the above, DuBose accepted material under POs 2284-63 and 1546-63, dated February 5,1993, and August 24,1992, respectlyely, without documented evidence that all requirements of the matdrial specification (macroetch test) had been completed.
3.
Contrary to the above, DuBose accepted material under POs 11645-66 and 10612-62, dated December 9,1996, and December 12, 1996, respectively, without certification that the material was i
furnished under a quality program accepted by DuBose.
C.
Criterion IV, " Procurement Document Control," of Appendix B to 10 CFR
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Part 50 requires, in part, that requirements necescary to assure adequate quality are included in the documents for procurement of material.
Paragraph 2.3.4.1 of the DuBose QSP requires, in part, that POs shall require certification that the material was furnished under a program accepted by DuBose.
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Contrary to the above, DuBose issued POs 11495 61, and 10649-68, dated November 11,1996, and November 15,1996, respectively, without including a requirement that the material must be furnished under a program accepted by DuBose. These POs had been reviewed and approved by DuBose QA on November 12,1996, and November 18,1996, respectively.
(Nonconformance 99900861-01-03)
D..
Criterion Vil, " Control of Purchased Material, Equipment, and Services," of Appendix B to 10 CFR Part 50 requires, in part, that the effectiveness of the l
control of quality by contractors and subcontractors shall be assessed at intervals consistent with the importance, complexity, and quantity of the product l
Paragraph 7.4.1 of DuBose QSP states, in part, that evaluation (of vendor)is l
performed to adequately evaluate the quality and technical capability of the vendor.
l Paragraph 2.4.3 of DuBose QSP states, in part, that the approved vendor's list (AVL) shall be compiled on the basis of a site evaluation of the vendor's quality program and Paragraph 2.4.2 states that the AVL shall show the scope of activity approved with any limitations.
1 Paragraph 2.3.2 states that quality related material and services shall only be purchased { rom vendors appearing on the AVL.
The following examples demonstrate failure to comply with the above requirements and constitute Nonconformance 99900861/97-01-04.
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Contrary to the above,.DuBose audit of Colonial Machine Company on April 11,1996, did not document that all areas of the AVL approved scope of activity had been evaluated and determined to be adequately controlled. Specifically, the audit documentation did not describe what was reviewed in the areas of NDE, heat treatment, upgrading of unqualified source material, and control of suppliers of source material and weld repair activities were not addressed.
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Contrary to the above, DuBose audit of Capitol Manufacturing i
Company on February 13,1996, did not document that all areas of l
the AVL approved scope of activity had been evaluated and were j
adequately controlled. Specifically, the audit documentation did not i
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l describe what was reviewed in the areas of material testing and NDE, and did not address heat treatment and the upgrading of unqualified source material, j
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Contrary to the above, on November 11,1996, and on November 15, 1996, DuBose issued POs 11495-61 and 10649-68, respectively, to Marmon/ Keystone Corporation for material that was not included in the product scope of the AVL.
Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Chief, Special Inspection Branch, Division of Inspection and Support Programs, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance. This reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should include for each nonconformance: (1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed.
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l Dated at Rockville, Maryland this day of 1997 i
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