ML20203E009

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Notice of Nonconformance from Insp on 971002-03. Nonconformance Noted:Epd Does Not Include Appropriate Quality Standards in QCP-187 Critical Characteristic Requirement Charts Re Matl Verification Category
ML20203E009
Person / Time
Issue date: 12/10/1997
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20203D954 List:
References
REF-QA-99900732 NUDOCS 9712160365
Download: ML20203E009 (2)


Text

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NOTICE OF HONCONFORMANCE Gould's Pumps, incorporated Docket No.: 99900732 240 Fall Street Seneca Falls, New York 13148 Based on the results of an inspection conducted on October 2 and October 3, 1997, it appears that certain of your activities were not conducted in accordance with NRC requirements.

Criterion Ill, " Design Control," of Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," of 10 CFR Part 50 requires in part, that measures shall be established to assure that applicable regulatory requirements and the design t, asis are correctly translated into specifications, drawings, procedures, and instructions, to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled.

Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.

Commonwealth Edison purchase order (P0) 47D744, dated June 17, 1997, requested one 7 3/8 inch pump impeller, Part Number R76793-1203, Material - American Society for Testing and Materials (ASTM) type ASTM A-296, Grade CF8M.

Purchase Order 47D744 stated that the P0 was safety-related and the requirements of 10 CFR Part 21 and 10 CFR Part 50, Appendix B were applicable.

ASTM A 296-1977, " Standard Specification for Corrosion-Resistant Iron-Chromium, Iron-Chromium-Nickel, and Nickel-Base Alloy Castings for General Application," requires that alloys conform to the chemical composition prescribed in Table 2.

Item (C), page 4 of EPD's QCP-187, states: " Critical Characteristics Chart -

All critical characteristics will be inspected after the parts are selected from stock for use on a Non Code Safety Related order... Information shown on the chart will be verified to be complete and accurate. The Inspection / Test Record will be signed and dated by the person performing the verification, when complete and acceptable.

The Inspection test record will be certified by a QA Engineer...."

Contrary to the above requirements, the inspector determined:

a)

EPD did not include appropriate quality standards in its QCP-187 critical characteristic requirement charts regarding the material verification category.

I 9712160365 971210 PDR GA999 ENVQOUP 99900732 PDR

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Gould's Pumps, Incorporated b)

Although Gould's Pun.ps, Incorporated, July 24, 1997, Certificate of Compliance to Commonwealth Edison, P0 470744, certified that the replacement part was in compliance with the original part supplied and the customer's P0 requirements, EPD did not verify all of the ASTM chemical composition elements, and did not verify ASTM heat treatment.

(Nonconformance 99900732/97-01-01)

Please provide a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, D.C. 20555, with a copy to the Chief, Special Inspection Branch, Division of Inspection and Support Programs, Office of Nuclear Reactor Regulation, within 30 days of the date of the letter transmitting this Notice of Nonconformance.

Thi; reply should be clearly marked as a " Reply to a Notice of Nonconformance" and should include for each nonconformance: (1) a description of steps that have been or will be taken to correct these items; (2) a description of steps that have been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventive measures were or will be completed.

Dated at Rockville, Maryland this day of December 1997.

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