ML20148C092
| ML20148C092 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1988 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Rudis M ROCKWELL ENGINEERING CO., INC. |
| References | |
| REF-QA-99900836 NUDOCS 8803220267 | |
| Download: ML20148C092 (5) | |
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March 17, 1988 Docket No. 99900836/87-01 Rockwell Engineering Company, Inc.
ATTN: Mr. Mark A. Rudis General Counsel 13500 South Wtstern Avenue Post Office Box 58 Blue Island, Illinois 60406-0058 Gentlemen:
Thank you for your letter dated October 30, 1987 which discussed your response to Inspection Report No. 99900856/87-01. We would like to extend our sincerest apologies for not responding to your letter at that time. The inspector who performed the inspection at your facility has since left the NRC and unfortunately your letter was misplaced. We have now reviewed your response and several of the items in your response are considered inadequate and require additional information. These items are discussed below. Additionally, with the cognizant inspector leaving, there are some aspects of yeur response that we need additional information in order to render a decision on your actions.
Your response to the Notice of Violation (NOV) Part A (87-01-01) states that the Rockwell Engineering (RE) Quality Assurance Manual (QAM) Section 11 specifically outlines a 10 CFR Part 21 procedure.
If Section 11 is used as your Part 21 procedure, all requirements identified in 10 CFR Part 21 need to be included as well as those requirements outlined in 10 CFR Part 50, Appendix B.
Section XV, "Nonconforming Materials, Parts, or Components." Section ll, according to your response, provides for the identification ot nonconforming material, notification of the customer, evaluation of the discrepancy b,r Engineering and Supervision, and assuring a responsible officer, the president, is informed by signing Form 11, the Nonconformance Report. Section 11, however, does not provide adequate detail of what actions will be taken if the noncon-formance or deviation is evaluated and detemined to be a defect as defined in 10 CFR Part 21.3(d). Additionally, there is no provision in Section 11 requiring that a responsible officer notify the NRC (10 CFR Part 21.21(b)(1)) when it is determined that a detect exists.
It is a general practice to have a separate procedure to incorporate the requirements of 10 CFR Part 21, however, if Section 11 of the QAM is to be used as your Part 21 procedure, some type of distinction needs to be made between the steps taken for a deviation and those taken for a defect. This was not evident to the inspector during the inspection.
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Rockwell Engineering Company, Inc. March 17, 19f.8 The response to the NOV Part B (87-01-02) states that RE was not required by VEPC0 to pass on the requirements of 10 CFR Part 21 even though VEPC0 had imposed Part 21 on RE.
Please provide a copy of the procedure which states that RE was not required to pass on Part 21 requirements. Also, provide a copy of the VEPCO contract modification which identified Central Steel and Empire Galvanizing as supplying commercial grade material.
If the material supplied by Central Steel and Empire Galvanizing were considered commercial grade, please describe the dedication process performed by RE after receipt of the material.
The response also stated that the requirements of 10 CFR Part 21 had been imposed on Weld Star.
Please provide a copy of the document which imposed Part 21 on Weld Star and a copy of the document which certifies that the material received from Weld Star was certified as 10 CFR Part 21 material, as stated in your response.
In response to the NOV Part C (87-01-03), if Section 11 of the RE QAM is considered your 10 CFR Part 21 procedure, a copy of the procedure, along with a copy of 10 CFR Part 21 and Section 206 of the Energy Reorgaaization Act of 1976 should be posted.
The response to the Notica of Nonconfonnance (NON) Part A (87-01-04) stated that the requirements of 10 CFR Part 50, Appendix B were passed on to sub-tier vendors by audit. Criterion IV of Appendix B specifically requires that contracts to vendors include quality assurance provisions, to the extent necessary.
Passing requirements tu vendors by audit is not acceptable.
Please reassess your response to this nonconformance.
The response to the NON Part B (87-01-05) states that the QA inspector did not have NDE responsibilites and were not required to have current eye examina-tion records.
Personnel perfonning inspection functions, including visual inspection, are required to have annual vision examinations in order to maintain their qualification as inspectors.
If the inspectors had not performed any inspection functions over the time period in question please state so. Your response also needs to address your compliance with the annual vision examination requirements for future work. Also, please provide a copy of the RE procedure "Qualification Training and Testing of Quality Assurance Inspector," RECO 1900-1, Revision 3 when you respond to this letter.
In your response to the NON Part C (87-02-06), you state that the correct revision level for the manual section on nenconforming materials is Revision 3, not Revision 9.
It is our general practice to reference the latest revision of the QA Manual rather than the revision of the applicable section.
In order to resolve this parti:ular issue, please provide a copy of Revision 3 of Section 11 of the RE QAM so that we may assure that segregation of nonconforming items is addressed.
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Rockwell Engineering Company, Inc..,,
March 17, 1988 If you have questions concerning any of the requests for additional information, please contact Mr. Ed Baker at (301) 492-3221 or Ms. Claudia Abbate at (301)492-0981.
Sincerely.
d YJ James C. Stone, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation I
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a March 17, 1988 Rockwell Engineering Company, Inc. any of the requests for additional information, If you have questions concerninf301) 492-3221 lease contact Mr. Ed Baker at or Ms. Claudia Abbate at p(301) 492-0981.
Sincerely, James C. Stone Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION:
RIDS Code:IE:097 VIB Reading DRIS Reading JPartlow BGrimes JStone EBaker CAbbate i
M VIB:DRIS ASC/VIB:DRIS AC/VIB:DRIS CAbbate:tt EBaker JStone 3/l(;/88 J //f/88 3/g7/88
March 17, 1988 Rockwell Engineering Company, Inc.
- If you have questions concerning any of the requests for additional information, lease contact Mr. Ed Baker at (301) 492-3221 or Ms. Claudia Abbate at p(301) 492-0981.
Sincerely, James C. Stone, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION:
RIDS Code IE:09 VIB Reading DRIS Reading JPartlow BGrimes JStone EBaker CAbbate VIBp: 27B yAC/VIB:0RIS RIS ASC/VIB:DRIS CAbbate:tt EBaker JStone 3/th/88 J //f/88 3 /g7 /88 l
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