ML20205E532
| ML20205E532 | |
| Person / Time | |
|---|---|
| Issue date: | 10/15/1985 |
| From: | Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Sugar F NUCLEAR ENERGY SERVICES (NES) MANUFACTURING |
| References | |
| REF-QA-99901018 NUDOCS 8510170321 | |
| Download: ML20205E532 (5) | |
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October 15, 1985 Docket No. 99901018/85-01 Nuclear Energy Services Manufacturing ATTN:
Mr. Frank Sugar General Manager 101' Swing Road Greensboro, North Carolina 27409 i
Gentlemen:
Thank you for your letter of August 25, 1985, in response to our letter dated July 26, 1985, which contained a Notice of Violation and a Notice of No^conformance. -The corrective action and preventive measures taken and/or planned for Nonconformance Items No. 3, 8, 9, 10, 11, 12, 13, 16, 18, 19, 20, 21, and 22 are satisfactory and additional information concerning those items is not required.
However, your response to the items identified in the Notice of Violation and to Nonconformance Items No. 1, 2, 4, 5, 6, 7, 14, 15, and 17 identified in the Notice of Nonconformance is inadequate.
Please provide additional information for these items as discussed in the enclosure within 30 days from the date of this letter.
If you would like to discuss the violation or items of nonconformance contained in our letter of July 26, 1985 or this request for additicnal information, please contact me at telephone number (301) 492-9663 so that a meeting can be scheduled in the NRC offices in Bethesda, Maryland.
I Sincerely, N.:;)Y l l (.x Gary G. Zech, Chief i
Vendor Program Branch j
Division of Quality Assurance, Vender and Technical Training Center Programs Office of Inspection and Enforcement i
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Enclosure:
Request for Additional Information cc w/ enclosure:
See next page 851017032105gd,,
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Nuclear Energy Services Manufacturing October 15, 1985 cc w/ enclosure:
Bechtel Power Corporation ATTN: Mr. T. I. Gillespie Manager, Quality Assurance Projects GPU Nuclear Corporation ATTN: Mr. F. Standerfer Vice President / Director TMI-2 Post Office Box 480 Middletown, Pennsylvania 17057 Mr. James P. Mahan N.C. Department of Labor 4 West Edenton Street Raleigh, North Carolina 27601 DISTRIBUTION:
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ENCLOSURE
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REQUEST FOR ADDITIONAL INFORMATION A.
Notice of Violation - Your August 25, 1985 response did not adequately address the Notice of Violation as stated in our July 26, 1985 letter.
Bechtel Specification 15737-2-M-101A(Q), Revision No. 1 imposed the requirements of 10 CFR Part 21 upon NES Manufacturing for items used in the fabrication of the defueling canisters for Three Mile Island, Unit 2.
The items noted on the material P0s referenced in the violation 4
were purchased by NES for specific application on the defueling canisters which Bechtel designated as "Important to Safety" for safety-related reasons. Consequently, the items are subject to requirements unique to nuclear applications.
The reasons stated in your August 25, 1985 letter for NES not imposing the requirements of 10 CFR Part 21 on certain vendors are not consistent with other NES activities in this area (i.e., the NRC inspector noted that NES imposed Part 21 requirements upon Southern Spring and Stamping for forming operations and Keystone Tubular Service (5 orders) and A. J. Metal Supply (3 orders) for ASTM material). As noted in the violation, NES did not require a certain number of vendors to furnish material and machining j
services under the requirements of 10 CFR Part 21. Based upon the requirements imposed upon NES and your failure to impose these requirements upon subtier suppliers, describe how NES can be assured that identified defects and/or noncompliances would be reported when items utilized in the defueling canisters were purchased as " general stock."
In addition, describe the proposed corrective and preventive measures, including the dates of implementation, to satisfactorily address the concerns noted in the Notice of Violation.
4 B.
Notice of Nonconformance - Your August 25, 1985 response did not adequately address certain Items of Nonconformance as stated in our July 26, 1985 letter.
Nanconformance 1 - The NES response stated that receiving inspection was performed consistently for the items furnished.
This is contrary to the NRC inspector's findings (i.e., dimensional checks to assure correct size were not performed on the neutron poison shrouds, upper closure heads, bulkheads, filter bundles, recombined catalyst and DE0X0-D catalyst). Provide copies of the documentation to verify that i
Bechtel supplied documents (e.g., data packages) were reviewed for adequacy by NES.
Nonconformance 2 - While the NES response states that the Item not honcompliance was correct the response also stated that it was NES Manufacturing's intent to provide segregation in every case.
Bechtel Technical Specification 15737-2-M-101A specifies that NES' QA Program met the applicable requirements of ANSI N45.2. Section 16 of ANSI N45.2 states that physical segregation and marking are'the preferred methods to control nonconforming items. This requirement is reflected in NES Procedure N-15.
Provide copies of the NES procedures which are used to define when physical separation will be used.
. Nonconformance!4 &'6 - In Technical Specification 15737-2-M-101(Q),Bechtel imposed upon NES the requirements of ANSI N45.2 and Appendix B to 10 CFR Part 50 for the items used in the fabrication of the defueling canisters.
Further, Section 7.0 of the specification designates the canisters as Important to Safety for nuclear safety-related reasons.
Since the items are subject to requirements unique to the nuclear applications of the furnished canisters, NES was required to qualify all suppliers.
Machinex, Inc. (machined nickel alloy bolts for the hold down fasteners in the fuel canisters); Southern Spring & Stamping (formed the clips for the "0" and "C" rings); Piedmont Hub, Charlotte Valve & Fittings, B&B Hose and Rubber, Air Products (supplied fittings); and Advanced Products (supplied seals) are not on the schedule to be post-qualified. This is clearly inconsistent with the requirement imposed upon NES. Provide information which describes the NES decision not to post-qualify these vendors.
Also during the inspection, documentation was requested but not made available to the NRC inspector to verify that NES had qualified A-Jay Metal in August 1984 as noted in your response. Provide copies of this documentation.
Nonconformance 5 - The NES response stated that the items noted were materials suitable for outdoor storage. However, this response does not consider that the materials are primarily stainless steel which is subject to stress corrosion cracking when subjected to concentrations of chemicals such as chlorides which could promote corrosion.
NES did not protect materials from corrosion, dirt, and other contamination during storage.
Provide copies of the procedures utilized to make the determination as to when and what special storage conditions may be necessary. Additionally, provide a descriptien of the specific steps which have been taken to upgrade your storage conditions to provide the material protection required by Bechtel Specification 15737-2-M-101A.
Nonconformance 7 - The NES response stated that "All of the above have an NES approved cuality program...."
Provide a copy of the documentation to verify that NES approved the quality programs for Pall Trinity and A-Jay Metal.
Additionally, NES did not approve the quality procrams of Southern Spring and Stamping, Machinex, Automotive Fasteners, Piedmont Hub, Charlotte Valve
& Fitting, B&B Hose & Rubber, Air Products and Advanced Products when these vendor supplied items or services pertain to a defueling canister (s) which is designated as "Important to Safety" for safety related reasons by the customer.
Provide copies of the procedures utilized by NES to determine which vendors should have an approved QA program and the rationale by which NES determined that the vendors listed above did not require NES approved QA programs.
i Nonconformance 14 - The NES response stated that dimensional inspection had been performed and the Supplier Quality History Logs (SQHL) located.
Provide copies of the SQHL for P0s 4356 (concrete) and 4404 (lubricant).
Your statement that receipt inspection was not performed on the initial shipment of material on P0 4467 until July 22, 1985 is not consistent with the NRC inspector's findings (i.e., two of the ten heads were in the inspection area containina green tags indicating that they had satisfactorily passedreceiptinspection).
In addition, provide a copy of the SQHL for P0 4657 which was not addressed in your response.
l Nonconformance 15 - The NES response stated that the required elements for i'
documentation of receipt inspection are present at NES. The NRC inspector noted that neither the SQHL or the' receiving inspection copy of the purchase order adequately documented the results of the inspection (i.e., recorded data). Clarify if the proposed Receiving / Inspection Report will provide for: acceptance and rejection criteria, results of the inspection, and identification of measuring equipment used.
Nonconformance B.17 - The NES response stated that this was an isolated case. Provide two copies of travelers containing approved instructions I
for identifying poison tube assemblies.
In addition, describe the proposed corrective and preventive measures, including i
the dates of implementation, to satisfactorily address the concerns noted for the above nonconformances.
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