ML20198T467
| ML20198T467 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1997 |
| From: | Black S NRC (Affiliation Not Assigned) |
| To: | Amer A AFFILIATION NOT ASSIGNED |
| References | |
| REF-QA-99901292 99901292, NUDOCS 9711170004 | |
| Download: ML20198T467 (2) | |
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-November 7, 1997=
' Mr. A.E. Amor, Chairman Amor Industrial Technologies, Inc.
- 1000 South Madison Street Wilmington, DE 19801
DearMr. Amer:
On September 2 and October 9,1997, you sont letters to the Nuclear Regulatory Commission.
requesting an update on our review of your February 6,1997 response to our request of January 13,1997, Although your letter indicated that there had been no correspondence since your February letter, we informed you, by letter of March 26,1997, that we were reviewing your response and would advise you of the results when that review was completed.
We have completed our review of your February 6,1997 letter and we find that it is not responsive to the specific questions asked in our letter.
With respect to the hydrostatic testing of tubes (Nonconformance E), our January 13,1997, letter asked you to respond to documentation discrepancies identified in the nonconformance and, if less than 36 tubes were tested, to explain the bases for your hydrostatic test reports.
Your February 6,1997, letter states that, on February 15,1994, one tube was tested and that Amor Industrial Technologies, Inc. (AIT) performed hydrostatic testing of the 35 other tubes in August 1994, however, due to an oversight, the report of this testing was not prepared until March 13,1995.
' The discrepancies identified in Nonconformance E related to the fabrication sequence and operation sign-offs on the fabrication route sheet for the heat exchangers in which these tubes were installed. Specifically, according to the route sheet, signed by the QA manager, the tubes were receipt inspected and cut to size, per drawing requirements (four foot segments) by February 5,1994. Since the fabrication of these heat exchangers required at least 34 of the 36 tubes purchased, no more than 2 tubes would have been available for hydrostatic testing after February 5,1994. Therefore, your statement that "AIT performed hydrostatic testing of the 35 other tubes from the lot roolved from Marmon/ Keystone, now marked M-2627-1 through M 2627-35, in August,94,"is inconsistent with the information reviewed by the NRC.
With respect to Nonconformance B.2, cu January 13,1997 letter asked you to rocoi;eile your October 11,1996 response that "Not all tests were performed on each piece, however, because some of the available test samples weren't large enough," with your closure of NCR #4421 which states that mechanical tests were performed on the rest of the 35 tubes and the attached test report showing that 35 tensile tests,70 flange tests,70 flattening tests,35 reverse bend tests, and 35 hardness tests had been performed with satisfactory results. Again, you have provided apparently conflicting information concoming mechanical testing of these tubes.
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Mr. A E. Amer Because of incomplete or missing records, a number of your responses and corrective actions rely on reconstructed documentation, based on the recollections of individuals involved in specific activities. If eccuracy and credibility of information supplied to us can not be assured, additional measures m: / be appropriate to assure that the products supplied by your company are in full compliance with the applicable technical and quality requirements.
The NRC staff has evaluated the situation and decided not to initiate an investigation or to take enforcement action in this case for the following reasons: 1) the affected licensee has taken adequate measures to assure that the material supplied by Amer will perform its intended safety function,2) your letter of August 22,1996, indicates that you had no active purchase orders from NRC-licensed companies that invoke the quality assurance requirements of 10 CFR Part 50, Appendix B, and 3) this matter has been determined to be of low safety significance.
l While formal enforcement action is not being taken, AIT should be aware that submittal of incomplete or inaccurate information to the NRC is a metter of serious concern. Deliberate submission of incomplete or inaccurate information may lead to formal NRC enforcerrent action, such as the issuance of civil penalties or orders, or to criminal prosecution.
You are not required to respond to this letter. However, if you choose to provide a response, please provide your response within 30 days.
In accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room.
Sincerely, h(.<g-enb c
SuzanrWC Black, Chief Quality Assurance, Vendor Inspection and Maintenance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation l
Docket No. 99901292 i