ML20195B718
| ML20195B718 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1986 |
| From: | Jeffrey Jacobson, Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20195B683 | List: |
| References | |
| REF-QA-99901044 99901044-86-01, 99901044-86-1, NUDOCS 8605290511 | |
| Download: ML20195B718 (4) | |
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O ORGANIZATION: STANDARD ENVIRONMENTAL PRODUCTS CHERRY HILL, NEW JERSEY INSPECTION INSPECTION REPORT DATF- 3/17 19/P6 DN 9f TF HollR9- 11 N0_- 99901044/86 01 CORRESPONDENCE ADDRESS: Standard Environmental Products ATTN: Mr. Pat Livecchi President Post Office Box 866 Cherry Hill, New Jersey 08003 ORGANIZATIONAL CONTACT: Pat Livecchi TELEPHONE NUMBER: 609-354-1600 NUCLEAR INDUSTRY ACTIVITY: Standard Environmental Products supplies flexible conduit manufactured by American Boa, Inc. of Cumming, GA to various uti.lities, architech-engineers, and subcontractors.
ASSIGNED INSPECTOR: r[f/et Date f.* Jeffrey B. Jacobyn, Reactive Inspection Section OTHER INSPECTOR (S):
/
APPROVED BY:
. Mr!rt Date Ellis W. Merschoff, C p , RIS, Vendor Program Branch INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21 and Appendix B of 10 CFR Part 50 B. SCOPE: This inspection was conducted as a result of an allegation received concerning improper certification of equipment to environmental qualification standands. This allegation was found to be unsubstantiated.
PLANT SITE APPLICABILITY: Point Beach 1 and 2 (50-266/301), Waterford 3 (50-382), Limerick 1 and 2 (50-352/353), Braidwood 1 and 2 (50-456/457),
Byron 1 and 2 (50-454/455), Vogtle 1 and 2 (50-424/425).
l 8605290511 860527 PDR GA999 EMV*****
99901044 PDR
r ORGANIZATION: STANDARD ENVIRONMENTAL PRODUCTS CHERRY HILL, NEW JERSEY REPORT INSPECTION NO.- 99901044/86-01 RESULTS: 3 AGE 2 of 4 A. Violations:
- 1. Contrary to Section 21.21 of 10 CFR Part 21, Standard Environmental Products has not adopted appropriate procedures for evaluating defects or notifying their customers of potential defects with material they have supplied under 10 CFR Part 21 requirements.
(86-01-01)
- 2. Contrary to Section 21.31 of 10 CFR Part 21, Standard Envi-ronmental Products did not specify 10 CFR Part 21 applicability on purchase orders to their subvendor American Boa Inc. for flexible metal conduit supplied to their customers under Part 21 requirements. (86-01-02)
B. Nonconformances:
- 1. Contrary to Criterion II of Appendix B to 10 CFR Part 50, Standard Environmental Products (SEP) has not established a Quality Assurance Program to meet the requirements of Appendix B to 10 CFR Part 50.
Purchase Order #B508825 from Wisconsin Electric required SEP supplied materials to be furnished in accordance with an Appendix B, Quality Assurance Program. (86-01-03)
- 2. Contrary to Criterion IV of Appendix B to 10 CFR Part 50, and the requirements of Wisconsin Electric Purchase Order B508825, SEP did not require in procurement documents to American Boa Inc. for flexible metal conduit, a quality assurance program in accordance with Appendix B to 10 CFR 50. (86-01-04)
C. Unresolved Items:
None.
D. Status of Previous Inspection Findings:
None.
E. Other Findings:
- 1. Quality Assurance Program SEP manufactures no material at their facility. All of the conduit it supplies is purchased from American Boa Inc. of Cumming, Georgia. SEP performs no in-house inspections of the conduit and most of the conduit is shipped directly from American Boa Inc. to
m ORGANIZATION: STANDARD ENVIRONMENTAL PRODUCTS CHERRY HILL, NEW JERSEY REPORT INSPECTION NO.- 99901044/86-01 RESULTS: PAGE 3 of 4 SEP's customers. SEP has no Appendix B, 10 CFR Part 50 Quality Assurance Program in place. SEP did, however produce an uncontrolled copy of an American Boa Inc. Quality Assurance Manual which appeared to address all 18 of the Appendix B criteria.
The inspector notified SEP that the previous qualification tests performed on the America Boa Inc. conduit could only be considered valid for future supplied conduit if similarity between the qualified and the newly supplied conduit could be shown. This similarity could be shown by ensuring American Boa Inc. has a valid Appendix B Quality Assurance Program in place. Regularly scheduled audits of American Boa Inc. along with reviews of controlled copies of their Quality Assurance Manual could be considered an acceptable method of ensuring compliance to Appendix B,10 CFR Part 50 criteria.
- 2. Environmental / Seismic Qualification SEP supplied a Certificate of Conformance to EBASCO under Purchase Order WP3-2523 which stated that the material provided met Louisiana Power Specification 1564.2498. This specification addressed IEEE 323-1974 environmental qualification although it did not clearly state its applicability to the SEP supplied conduit. Conduit and fittings similar to those supplied on Purchase Order WP3-2523 had been previously environmentally qualified by Isomedix, Inc. of Parsippany, New Jersey in a test done in November of 1978. In this test a conduit-connector assembly underwent thermal aging, background radiation aging, containment pressurization, vibration endurance /
seismic, accident radiation, loss of coolant simulation, and post LOCA tests. The conduit-connector assembly was then examined and was found not to have sustained any damage that would have prohibited it from performing its proper function. Similarly, SEP qualified various sizes of American Boa Inc. conduit to IEEE 344 in two tests performed by the Dayton Brown Company on July 19, 1980 and February 13, 1984. The tests qualified the conduit for use under a wide envelope of seismic disturbances.
- 3. Procurement Requirements The inspector reviewed purchase orders to SEP from various utilities, architect-engineers, and subcontractors who purchased flexible metal conduit from SEP in the seven years they have been in business. The majority of the purchase orders required nothing more than commercial grade material and a Certificate of Conformance specifying that the conduit supplied was that shown in the catalog / sales literature.
r t
t ORGANIZATION: STANDARD ENVIRONMENTAL PRODUCTS CHERRY HILL, NEW JERSEY REPORT INSPECTION NO - 99901044/86-01 RESULTS: PAGE 4 of 4 Some purchase orders however, did require Certificates of Conformance to IEEE-344 and specific utility specifications such as Louisiana Power 1564.249B and Georgia Power X3AH02. A few purchase orders such as those from L. K. Comstock specified 10 CFR Part 21 requirements.
Purchase orders from Wisconsin Electric required the material be supplied in accordance with a quality assurance program that met the requirements of Appendix B to 10 CFR Part 50.
~
No procedures for evaluating defects or for notifying the NRC of defects discovered pursuant to 10 CFR Part 21 requirements were in place at SEP. It was also revealed that SEP did not impose Part 21 requirements on their supplier American Boa Inc. even though Part 21 requirements were imposed on them by several of their customers.
SEP should understand that its responsibilities under 10 CFR Part 21 become inacted any time material ordered from them is furnished in accordance with specific nuclear related documents such as IEEE-344, IEEE-323 or Appendix B to 10 CFR Part 50.
F. Persons Contacted:
Pat Livecchi - President .
O
t Standard Environmental Products flay 27, 1986 In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, ORIG #iAL SNilitD R gAlty G. IE0tt Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement
Enclosures:
- 1. Appendix A-Notice of Violation
- 2. Appendix B-Notice of Nonconformance
- 3. Appendix C-Inspection Report 99901044/86-01
- 4. Appendix D-Inspection Data Sheets (1 page)
DISTRIBUTION:
iOft:IE:09n VPB Reading DQAVT Reading RVollmer JStone LParker EMerschoff JJacobson(2)
Dan Driskill 0/I Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
- See previous page for concurrences " '
VPB:DQAVT SC/VPB:DQAVT PB:DQAVT JJacobson:tt* EMerschoff* GGZech 04/08/86 04/25/86 5@'86 9 y
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