ML20138E343

Insp Rept 99900861/97-01 on 970121-24.Nonconformances Noted. Major Areas Inspected:Implementation of Selected Portions of Dubose Natl Energy Svcs,Inc.Qa Program for Supplying Matl Under ASME Code & for Providing Commercial Grade Matl

ML20138E343
Person / Time
Issue date:	04/29/1997
From:	NRC (Affiliation Not Assigned)
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ML20138E319	List: ML20138E313 ML20138E328 ML20138E343
References
REF-QA-99900861 NUDOCS 9705020161
Download: ML20138E343 (15)

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U.S. NbCLEAR REGULATOHY COMMISSION i

OFFICE OF NUCLEAR REACTOR REGULATION j l

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Report No: 9E 900861/97-01 1

Organization: DuBose National Energy Services, Inc. l l

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Contact:

James Dailey, Quality Assurance Manager (910) 590 2151 Nuclear Industry Activity: Supplier of threaded fasteners, bars, tubular products, forgings, plates, flanges, fittings, and other items used l primarily for nuclear applications.

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Dates: January 21 through 24,1997 l

Inspectors: Uldis Potapovs, Senior Reactor Engineer Steven M. Matthews, Quality Assurance Engineer I

Approved by: Gregory C. Cwalina, Chief Vendor Inspection Section Special Inspection Branch Division of Inspection and Support Programs l

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9705020161 970429 PDR GA999 ENV*****

99900861 PDR _

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1 INSPECTION

SUMMARY

During this inspection, the inspectors reviewed the implementation of selected portions of DuBose National Energy Ser$ ices, Inc. (DuBose) quality assurance (QA) program for supplying material i.nder the American Society of Mechanical Engineers (ASME) Boiler and Prensure Vessel Code (Code) requirements, and for providing dedicated com'nercial grade matr, rial. The inspection was focused on the review of DuBese activities related to the supply of nonconforming material to Southern California Edison for use in the San Onofro Generating Station (SONGS)

The inspection bases were: '

e Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reaulations (10 CFR Part 50).

e 10 CFR Part 21, " Reporting of Defects and Noncomplience" e ASME Code, Section lil, Subarticle NCA 3800.

During this inspection, four instances where DuBose failed to conform to NRC requirements imposed upon them by NRC licensees were identified.  :

These nonconformances are discussed in Sections 3.2 and 3.3 of this '

report.  :

2 STATUS OF PREVIOUS INSPECTION FINDINGS This was the first NRC inspection of DuBose at its present location and  :

under the present management. The last NRC inspection of DuBose was conducted on May 21 through 25,1984, at Roseboro, NC. The status of findings from that inspection were not reviewed.

3. INSPECTION FINDINGS AND OTHER COMMENTS 3.1 Descriotion of Facilities and Activities DuBose has been accredited by the ASME as a Material Organization (MO),

supplying a wide range of metallic materials, including bars, threaded I

fasteners, castings, forgings, plates, fittings, flanges, tubular products, structural shapes, and weld filler material. According to DuBose management, approximately 70-80% of sales volume consists of safety related material supplied to nuclear utilities. Of that amount, approximately 50% is sold under their ASME Quality Systems Certificate as complying 4

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l with the requirements of NCA 3800. The company has an on site laboratory facility capable of performing spectrochemical analyses, tensile testing, hardness testing, and hydrostatic testing. No manufacturing operations, other than subdividing of material, are performed.

1 j 3.2 Follow un on Nonconformina material sucolied to SONGS

a. Background On May 10,1996, DuBose issued a Certificate of Conformance/ Compliance /

CMTR (CMTR) to SONGS for forty six 3/4-10 ASME SA-194, Grade 7, heavy hex nuts, supplied as item 2 of SONGS purchase order (PO) 6N23G016. SONGS receipt inspection of these nuts resulted in a nonconformance report (NCR) for failure to meet System 22 dimensional inspection requirements, as specified in the PO. It was also identified that chemical analysis of ten nuts showed that, while they complied with the specification limits, the nuts apparently came from two different heats of material (all 46 nuts were certified as coming from a single heat). SONGS performed a 10 CFR PART 21 reportability evaluation and determined that this event was not reportable.

Review of documentation obtained from SONGS indicated that the material was shipped from T&T Enterprises, Corona California, a supplier qualified by DuBose. DuBose provided the CMTR for this material, referencing their ASME QSC number and certifying compliance with the PO and ASME Code requirements. Attached to the DuBose CMTR was a CMTR from T&T Enterprises, certifying the performance of dimensionalinspection (System l 22), visual inspection, and macroetch (ASTM E-381), in accordance with their DuBose-approved QA program. Also furnished with the material was a CMTR from A&G Engineering'll, Inc. (A&G), dated February 8,1993 and issued to DuBose. The CMTR certified that the material was provided under l A&G's QSC and contained the results of chemical and mechanical tests, apparently transcribed from Korea Bolt Ind. Co., LTD., inspection Certificate, dated October 10,1991, attached to the A&G CMTR. The certifications did not include a CMTR from the producing steel mill, and there was no l indication of who produced the steel.

On September 12,1996, NRC contacted DuBose and requested information concerning the apparent loss of traceability for this material. DuBose

! responded on September 19,1996, by stating that, based on their review l and additional chemical analyses, they determined that there was no I

conclusive evidence to indicate that the nuts were from mixed heats of material. This conclusion was based primarily on the fact that the heat code was forged into each nut by the manufacturer and that the chemical i

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4 overcheck results (15 samples) were within acceptable variance limits of ASTM A-29.

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b. Observations and Findings Documentation available at DuBose for the material discussed above did not contain a CMTR from the producing mill. Also, other than the macroetch that was apparently performed by T&T Enterprises, as discussed above, on a finished nut, there was no indication that macroetch testing was performed as a part of the steel producer's quality procedures, as required by the applicable material specification, ASME SA-194. A macroetch test on a forged nut, performed after the completion of manufacturing is not considered an acceptable method of achieving compliance with the material

specification requirement. With respect to the missing CMTR from the steel producer, the inspector noted that, for material supplied under DuBose's OSC, paragraph NCA 3862.1(b) of the ASME Code requires that certifications of approved suppliers be furnished as identified attachments to the OSC holder's CMTR. In this case, the steel mill was considered an approved supplier, and the mill CMTR, or heat analysis, should have been available, and should have been provided to the recipient of the nuts.

With respect to DuBose's comment, as discussed above, that forging of the

, heat code into each nut during the manufacturing process assures heat traceability, the inspector noted that the forged-in heat markings could not be relied upon to provide full heat traceability for this situation, since a material mixup may have occurred at the producing mill or at an intermediate supplier to the nut manufacturer.

With respect to DuBose atatement that, since the results of their chemical analyses of 15 nuts wem within acceptable product analysis limits of ASTM A-29, there was no conclusive evidence that the nuts were from mixed heats, the inspector noted the applicable variance limits in A-29 were not Intended to verify heat homogeneity, and that multiple analyses of a single heat of material would be expected to show less variability than indicated in

the tables referenced in A-29.

Review of the nonconforming thread issue identified during SONGS receiving inspection showed that DuBose issued Non-Conformance Report (NCR) No.

1039 on June 18,1996, as a result of communication from SONGS. Based on the NCR, a Corrective Action Report was issued to T&T Enterprises on June 19,1996, describing the unsatisfactory condition, and requesting a response by July 19,1996. On September 6,1996, T&T Enterprises provided a response by stating that the internal threads were gaged with GO-NOGO plug gages and GO NOGO cylinder gages which satisfied the I

f functional requirements of System 22. They identified the cause of the nonconformance as unavailability of the cone and vee type internal variable ,

. gages to appraise the values of the internal pitch diameters over the full ,

, length of the thread. The described corrective action was to assure the proper equipment is used to make these measurements on future orders.

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DuBose accepted the proposed corrective action on September 9,1996.  !

The inspector also reviewed several procurement documents related to l DuBose's acquisition of material from A&G, as summarized below:

e The nuts discussed above were purchased as a part of DuBose PO 2284-63, dated February 5,1993 for approximately 85,000 ASME SA-i 194 nuts in sizes ranging from 5/8-inch to 1 1/2- inches. The nuts were l to be provided under A&G's QSC. The inspector noted that PO contained an attached Form D-2. Paragraph 6. of this form stated that "The starting material manufacturer is to be identified on the CMTR produced by your company." Paragraph 7. of the same form stated that the use of foreign starting material is not permitted without DuBose's approval and that, when approvalis given, backup certification is to be provided. The PO was amended on February 8,1993, to allow foreign starting material. All other conditions were to remain the same. There '

was no further explanation concerning " backup certification." The inspector's review of documentation supplied by A&G did not identify any reference to " backup certification," and did not show any evidence .

that the starting material manufacturer had been identified as specified i in the attachment to the DuBose PO for this meterial.

r e On August 24,1992, DuBose issued PO 1340-63 to A&G for 20 tons of threaded rod in accordance with ASME SA-193, Grade B7 in 12-foot lengths, and diameters ranging from 1/2 to 1 inch, to be supplied under A&G's QSC. The A&G CMTR for this material contained apparently '

transcribed results of the required chemical and mechanical tests and certified the material as being provided in accordance with their QSC.

The CMTR did not include certification from the steel mill or include any certifications by approved suppliers. Also, there was no indication that a macroetch test, as required by the material specification, was performed during the steelmaking process.

c. Conclusions As discussed above, the inspectors determined that, for SONGS PO N236016, DuBose did not provide all of the documentation required by the ASME Code provisions governing the application of their QSC when certifying Code material. Specifically, contrary to the requirements of ASME l

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j Code, SC lil, paragraph NCA 3862.1(b), DuBose did not include the producing mill heat anslysis as an identified attachment to their CMTR. This item was identified as an example of Nonconformance 99900861/97-01-01.

The inspectors also determined that, contrary to Paragraph 10.3.1.4 of their QA Manual, A&G certifications for material supplied to fill DuBose POs 2284-63 and 1546-63 were either not reviewed by DuBose OA, or the review was not effective. Specifically, this material was accepted without identification of " starting material manufacturer" on these certifications, as required by Form D-2, attached to the DuBose POs. Additionally, the A&G certifications did not indicate that all of the testing, required by the material specification (macroetch), had been performed. These items were identified as examples of Nonconformance 99900861/97-01-02.

With respect to the mixed heat issue, based on review of the results of DuBose chemical analyses of,15 nuts, it appears likely that more than one heat of material was represented in the sample. However, as discussed above, since none of the samples tested by DuBose or SONGS failed to meet the requirements of the material specification, co-mingling of heats, if it did occur, appears to have been limited to the same grade of material.

Additionally, a July 15,1996, memorandum from the DuBose QA Manager to its President indicates that this material was being moved to the DuBose commercial inventory. The dimensional nonconformance of these nuts apparently resulted from the subcontractor's failure to perform all of the required measyrements, and was dispositioned through the DuBose corrective action process. l l

3.3 QA Proaram imolementation 3.3.1 Proaram Descriotion

• i The DuBose quality assurance program is described in their Quality System Program (OSP) and in Quality Control Procedures (QCPs). Revision 5 of the QSP, dated January 10,1996, was in effect at the time of the NRC inspection. The QSP was written to comply with the ASME Code, Section j lil requirements applicable to Material Organizations, and also indicates  !

compliance with 10 CFR 50, Appendix B, MIL I 45208, MIL Q 9858, NQA 1, ANSI 45.2, And ISO 9002.

Only selected areas of the QA program and its implementation were reviewed during this inspection.

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l 3.3.2 Procurement Control l

a. Inanecdon Scone The inspectors reviewed DuBose approved vendors list (AVL) dated January 21,1997, and selected several suppliers from the AVL to evaluate DuBose capability to qualify vendors for placement on the AVL.

b. Observations and Findinas -

b.1 Approved Vendors According to Section 2.4, " Approved Vendors List," of DuBose QSP, vendors are placed on the AVL either on the basis of a site evaluation of the ,

vendor's QA program in accordance with Section 7.4, " Vendor Surveys and Audits," of the QSP, or on the basis of verification that the vendor has an ASME issued QSC or an N-type Certificate of Authorization. Vendors that are placed on the AVL based on a DuBose site evaluation are qualified to one of two levels: For material traceability only, or as a DuBose qualified MO with QA program meeting the requirements of Subarticle NCA-3800 of Section lll of the ASME Code.

To evaluate DuBose capability to qualify vendors for placement on the AVL as an approved supplier, the inspectors reviewed the following audits:

(1) Marmon/ Keystone Corporation, Charlotte, North Carolina The last DuBose audit of Marmon/ Keystone was performed on October 13,1994. The scope of the audit identified Marmon/ Keystone as a supplier of ferrous and non ferrous, seamless, and welded without filler metal, tubular products. Based on a review of the audit report, the inspectors determined that DuBose had adequately evaluated Marmon/ Keystone, Charlotte, North Carolina, as a supplier of source material with controlled traceability. ,

However, the AVL's approved scope for purchases from Marmon/ Keystone was, "MS - carbon welded tubular products in  ;

accordance with QA manual,1st Edition, Revision 0, dated January 27, l 1988." Therefore, in this instance, the AVL approved scope for l l purchases was inconsistent with the scope of DuBose's audit of  ;

l Marmon/ Keystone since it did not include nonferrous or seamless tubular l l products. i l

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(2) Alloy Rods incorporated The last DuBose audit of Alloy Rods Inc., was performed on April 15, 1994. The scope of the audit was, "MO - ferrous and nonferrous bare and covered wire." On the basis of their review of the audit, the inspectors determined that DuBose had adequately evaluated Alloy Rods Inc. as a qualified MO.

However, the AVL's approved scope for purchases from Alloy Rods Inc. j was, "MO - ferrous and nor: ferrous brazing material, bare and covered ,

flux cored electrodes, and bare wire." Therefore, the AVL's approved <

scope for purchases was not consistent with, and was expanded l beyond the scope of the DuBose audit of Alloy Rods Inc. Specifically, the audit scope did not include brazing material or bare and covered flux cored electrodes. This condition would permit DuBose buyers to procure material that was not included in the audited, and therefore, ,

qualified capability of Alloy Rods Inc.  !

(3) Colonial Machine Company, Inc., Pleasantville, Pennsylvania The last DuBose audit of Colonial Machine Company was performed on April 11,1996. The scope of audit was: "MO - ferrous and nonferrous fittings, flanges and pipe hangers - machining and I processing of DuBose supplied material." However, the Vendor Quality Assurance: Survey / Audit Cover Sheet (Form D-46), also listed additional items including the following:

o bars e plates e seamless fittings' e forgings e flanges e seamless tubing product l e NDE (nondestructive examination) l e HT (heat treatment) e weld repair e material testing o upgrading unqualified source material e approval & control of suppliers of source material l' e approval & control of suppliers of services i

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On the basis of their evaluation of DuBose April 11,1996, audit of Colonial Machine Company, the inspectors determined that the audit report did not contain objective evidence that the audit had adequately evaluated the following areas: l e for NDE, HT, upgrading unqualified source material, and approval & control of suppliers of source material, the DuBose auditor did not document objective evidence of what was audited a weld repair was not addressed e for approval & control of suppliers of services, the DuBose auditor did not document objective evidence that supplier audits were evaluated.

Additionally, the AVL's approved scope for purchases from Colonial Machine Company was, "MO - ferrous and nonferrous fittings, flanges and pipe hangers- machining and processing of DuBose supplied material- welding in accordance with ASME B31.1 Code." Therefore, the AVL's approved scope for purchases was not consistent with and was expanded beyond the scope of DuBose's audit of Colonial Machine Company. Specifically, welding in accordance with ASME B 31.1 Code was not included in the audit scope. This condition would permit DuBose buyers to procure material that was not included in the audited, and therefore, qualified capability of Colonial Machine Company.

(4) Capitol Manufacturing Company The last DuBose audit of Capitol Manufacturing Company was l performed on February 13,1996. The scope of audit was: "MO - l manufacturing carbon and stainless fittings." However, DuBose Form D-46, also listed additional items including:

e seamless fittings e NDE o HT 1 e material testing e upgrading unqualified source material e approval & control of suppliers of source material e approval & control of suppliers of services 4

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On the basis of its evaluation of DuBose February 13,1996, audit of Capitol Manufacturing Company, the inspectors determined that the audit failed to adequately document evaluation of the following areas:

e for NDE and material testing, DuBose did not document objective evidence of what was evaluated e HT was not addressed e for upgrading unqualified source material, DuBose did not document a review of upgrading activities.

b.2 Procurement Document Control '

To evaluate DuBose capability to control procurement documents, the inspectors reviewed the following purchase orders (POs):

(1) PO 11495-61 DuBose issued PO 11495-61, dated November 11,1996, to Marmon/ Keystone Corporation, Charlotte, North Carolina, for 20-feet  !

(ft.), random length,8-inch nominal diameter, schedule 160, A-106 l Grade B, seamless pipe. The PO was reviewed and approved by ,

DuBose QA on November 12,1996. l l

However, the PO failed to impose on Marmon/ Keystone the requirement that material must be controlled in accordance with the quality control system and procedures audited by DuBose. Marmon/ Keystone also failed to provide DuBose certification that the material was furnished under a quality program accepted by DuBose.

Additionally, the AVL approved scope for purchases from Marmon/ Keystone was, "MS - carbon welded tubular products in .

accordance with QA manual,1st Edition, Revision 0, dated January 27, j 1988." Since this PO procured seamless pipe, the PO did not comply with the limitations of the DuBose AVL.

(2) PO 10649-68 DuBose issued PO 10649-68, dated November 15,1996, to Marmon/ Keystone Corporation, Charlotte, North Carolina, for 60-ft.,

5/8-inch outside diameter (OD) x .083-wall x 20-ft., A 269 type 304 l stainless steel tubing. The PO was reviewed and approved by DuBose l QA on November 18,1996.

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However, the PO failed to impose on Marmon/ Keystone'the requirement l that material must be controlled in accordance with the quality control ,

system and procedures audited by DuBose. Marmon/ Keystone also )

failed to provide DuBose certification that the material was furnished l under a quality program accepted by DuBose.

Additionally, the AVL approved scope for purchases from Marmon/ Keystone was, "MS - carbon welded tubular products in accordance with QA manual,1st Edition, Revision 0, dated January 27, .

1988." Since this PO procured stainless steel tubing, the PO did not '

comply with the limitations of DuBose AVL.

(3) PO 11645 66 '

DuBose issued PO 11645-66, dated December 9,1996, to TAD USA, Inc., for one piece of 2-inch, schedule 80 x 10-ft., SA-335, P22, seamless pipe. The PO was reviewed and approved by DuBose QA on December 11,1996.

Even though DuBose imposed on TAD USA the requirement that material furnished must be controlled in accordance with the quality control system and procedures audited by DuBose, TAD USA failed to  ;

provide DuBose certification that the material was furnished under a quality program accepted by DuBose.

(4) PO 10612-62 DuBose issued PO 10612-62, dated December 12,1996, to Castle, f A.M. & Company for one piece of 2 3/4-inch thick x 35-inch wide x 36-inch long, SA-516 Grade *70, plate.

Even though DuBose imposed on Castle, A.M. & Company the requirement that material furnished must be controlled in accordance with the quality control system and procedures audited by DuBose, Castle, A.M. & Company failed to provide DuBose certification that the material was furnished under a quality program accepted by DuBose.

c. Conclusions The inspectors determined that the DuBose material traceability audits of suppliers appeared to be adequate for their intended purpose. -

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j However, the inspectors determined that the audits of DuBose-qualified l NCA 3800 suppliers (MOs) were lacking in detail and programmatic in their conduct and/or documentation. The inspectors identified two instances  !

(Colonial Machine Company, Inc., and Capitol Manufacturing Company)  !

where DuBose audits of its vendors failed to (a) adequately assess the effectiveness of the control of quality by its vendors and (b) compile its  !

AVL, for all vendors, on the basis of an adequate site evaluation of the <

vendors quality program for the AVL's approved scope for purchases. These audits often lacked objective evidence that upgrading and dedication activities were adequately verified or that the implementation of these j activities was evaluated. These findings were identified as examples of j j Nonconformance 99900861/97-01-04. l Additionally, in certain instances identified by the inspectors and described above, DuBose AVL approved scope for purchases was expanded beyond the scope of DuBose's audit and therefore permitted DuBose buyers to procure material that was not included in the audited and qualified capability of the supplier.

i in other instances identified by the inspectors and described above, DuBose procured material form vendors on its AVL that was not included in the AVL approved product scope (POs 11495-61 and 10649-68). These instances were identified as examples of Nonconformance 99900861/97-01-04.

The inspectors; identified two instances (POs 11645-66 and 10612-62) where DuBose accepted material from its vendor without certification that the material was furnished under a quality program accepted by DuBose.

These items were identified as examples of Nonconformance 99900861/97-01-02.

On the basis of its review of the POs described above, the inspectors identified two instance (POs 11495-61 and 10649 68) where Dubose failed to require its vendors to certify that the material was furnished under a quality program accepted by DuBose. These items were identified as examples of Nonconformance 99900861/97-01-03.

3.3.3 Review of Recent Material Sales To NRC Licensees

a. Scone The inspectors reviewed selected documentation packages Wr safety related material recently supplied to NRC licensees under the DuBose's QSP to verify the implementation of the applicable QA program requirements and compliance with 10 CFR 50, Appendix B, provisions.

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b. ' Observations and Findinos Document packages for material supplied to Appendix B requirements, as well as  !

material certified under DuBose OSC, were reviewed. Significant observations and j findings are summarized below, i e Union Electric PO 094006, de,ted June 24,1996, item (2) for twenty  ;

ASME SA-564 Grade 630 studs (3/4-10, 51/2in long), with 1100 F j aging treatment, and 302 BHN minimum hardness. l This material was certified under DuBose OSC as complying with the applicable Code and PO requirements. Appended to DuBose CMTR was a certification from Walker Bolt, a DuBose-qualified supplier. Attached to the Walker Bolt certification was certification from Ugine Savois (French company) containing chemical and tensile test results, satisfactory macroetch statement and statement that the material was l provided in solution treated condition. No quality program statement i was attached to this certification, indicating that Ugine Savois was not an approved supplier and that the material was upgraded by Walker Bolt. However, no test reports, indicating that upgrading of this material was performed were attached to the Walker Bolt certification.

There was also no indication of what organization performed the required aging treatment on this material, or the actual time and  ;

t temperature of the heat treatment, l  :

The inspector noted tha'. Paragraph 3.3.10 of the DuBose QSM section

, on utilization of unqualif!sd source material states that "... the lab test l report shall be attached to the DuBose Certificate of Conformance."

Paragraph 3.3.11 states that the Certificate will contain a statement

" upgraded per NCA 3855.5."

Before the completion of this inspection, Walker Bolt telefaxed an amended certification to DuBose indicating that upgrading tests were performed at their facility and including a certification of the heat treatment.

e Carolina Power & Light Co. PO BM1717 CJ, dated November 1,1996 for thirty four 1-8, 21/2 inch long ASME SA-193, Grade B7 Cap screws.

This rnaterial was certified under DuBose OSC, as complying with the applicable Code and PO requirements. Appended to the DuBose CMTR was a certificate from T&T Enterprises (T&T), a DuBose-qualified supplier, containing chemical analyses, results of tensile and hardness tests, description of heat treatment, visual inspection, and a statement I

Indicating that a macroetch test had been performed with satisfactory results. The T&T certification also contained a quality program statement that all activities had been performed in accordance with their DuBose approved QA program. A Republic Steel Co. CMTR for this heat of material was attached. The Republic Steel certification was sent to Fry Steel Co., a distributor, indicating that T&T obtained this material as unqualified source material and upgraded it.

The inspector noted that, since the starting material was in the form of 1-inch bar, cold or hot heading operations, as well as heat treatment would have been involved in the manufacturing process, requiring the use of approved suppliers. However, no certifications for these operations were in the data package.

e Public Service Electric & Gas Co. PO P2 09029931850 0000 for four 10 gage,4 by 8 foot steel sheets.10 CFR 50, Appendix B QA requirements and 10 CFR Part 21 were invoked by the PO.

DuBose certified this material as complying with their QSP and the PO requirements. DuBose obtained the material from NUCOR Steel Co., a commercial supplier, and dedicated it under their program. The dedication consisted of performing complete chemical analysis on each of the four sheets, and tensile and bend tests on one sheet. The laboratory report, including the test results and the NUCOR Steel Co.

material certification were attached to the Dubose CMTR. The chemical analyses of samples from the four sheets showed close agreement to the NUCOR Steel Co. CMTR, supporting the bases for verifying mechanical properties of only one sample.

c. Conclusions

• Failure to include certifications from approved suppliers as identified attachments to DuBose CMTRs issued to Union Electric (PO 8M1717 CJ) and Carolina Power and Light (PO 8M1717 CJ), were identified as examples of Nonconformance 99900861/97-01-01.

3.4 Entrance and Exit Meetinas in the entrance meeting on January 21,1997, the NRC inspectors discussed the scope of the inspection, outlined the areas to be inspected, and established interfaces with DuBose management. In the exit meeting, on January 24,1997, the inspectors discussed their findings and concerns.

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l PARTIAL LIST OF PERSONS CONTACTED I

l l Carl M. Rogers, President & CEO John Hottel, Vice President James Dailey, Manager, Quality Assurance l Allen Jones, Manager, Sales & Marketing l Laurie Meyer-Dickson, Certification engineer  ;

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 99900861/97-01-01 NON Failure to provide required documentation '

99900861/97-01-02 NON Acceptance of material with incomplete documentation 99900861/97-01-03 NON Inadequate procurement Documents i 99900861/97-01-04 NON Inadequate suppiier audits l 1

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