ML20199F296

Notice of Violation from Insp on 860505-08

ML20199F296
Person / Time
Issue date:	06/20/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20199F294	List: ML20199F288 ML20199F296 ML20199F302
References
REF-QA-99901047 99901047-86-01, 99901047-86-1, NUDOCS 8606240258
Download: ML20199F296 (2)

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APPENDIX A Nuclear Packaging Incorporated Docket No. 99901047/86-01 NOTICE OF VIOLATION the implementation of the During Nuclear Packaging an inspection conducted Incorporated (NUPAC on May)5-8,1986, Quality Assurance (QA) Program at Federal Way, Washington facility was reviewed with respect to the fabrication of transportation casks. NUPAC is a subsidiary of Pacific Nuclear Systems Incorporated (PNSI). NUPAC uses the PNSI QA Manual. This inspection also included a limited review of the quality records for the two Model 125-8 ship-ping casks to be used to transport canisters which will contain the Three Mile

' Island (TMI) Unit 2 core debris. As a result of the inspection and in accor-dance with Section 206 of the Energy Reorganization Act of 1974, 10 CFR Part 21, 4

and 10 CFR Part 71, the following violations were identified and categorized in accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C.

1.- Section 21.21 of 10 CFR Part 21 requires, in part, that each corporation adopt appropriate procedures to provide for evaluating deviations or inform-ing the licensee or purchaser of the deviation; and to assure that a director or responsible officer is informed if a basic component contains a defect and to notify th4 Commission when information is obtained which reasonably indicates a defect.

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Contrary to the above, NUPAC has not developed and implemented appropriate j procedures to provide for evaluating defects, informing the licensee or purchaser of the defect; or to assure that a director or responsible officer is informed if a basic component contains a defect, or to notify the Com-i mission when information is obtained which reasonably indicates a defect.  ;

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' This is a Severity level IV violation (Supplement VII).

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2. Section 21.31 of 10 CFR Part 21 requires, in part, that each corporation shall assure that each procurement document for a basic component issued by that corporation specifies that the provisions of 10 CFR Part 21 apply.

Contrary to the above, NUPAC issued purchase order number 3104-1B, dated i January 31, 1984, to Olympic Northwest Industries for a Type B transpor-tation cask without specifying that the provisions of 10 CFR Part 21 were 4

applicable.

This is a Severity Level IV violation (Supplement VII).

3. Paragraph 71.103 of Subpart H to 10 CFR Part 71 requires, in part, that the licensee may delegate to others such as contractors, the work of establish-ing and executing the quality assurance (QA) program, but shall retain responsibility for the program.

Contrary to the above, NUPAC, holder of Certificate of Compliance (C of C) number 9073 for the OH-142 cask, which is being retrofitted to comply 8606240258 860620

, PDR GA999 EMVNPI j 99901047 PDR

with C of C application number 9208, failed to ensure that an adequate QA program was established and executed by Ideal Machine and Manufacturing, Inc., a NUPAC subcontractor, as demonstrated by the following examples:

Section 3 of QP-4, QP-7, QP-14 of the PNSI QAM requires, in part, that orientation and training programs be developed and administered, that quality functions be performed by personnel on the Quality Personnel List, (QPL) and that quality records be maintained on PNSI form NPQ 004. How-ever, NUPAC did not maintain documentation to exhibit that training programs had been developed and administered by the NUPAC quality department to maintain quality personnel at Ideal Machine and Manufacturing, Inc. Also, NUPAC did not record the names of Ideal Machine and Manufacturing, Inc.

personnel who performed quality related activities such as initiating SDRs, issuing hold tags, and procuring safety related material, on the QPL.

This is a Severity Level IV violation (Supplement VII).