ML20247B855
| ML20247B855 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/1998 |
| From: | Spessard R NRC (Affiliation Not Assigned) |
| To: | Amer A AFFILIATION NOT ASSIGNED |
| References | |
| REF-QA-99901292 NUDOCS 9805110081 | |
| Download: ML20247B855 (5) | |
Text
._
May 5, 1998 Mr. Ahmid E. Am:r, Chrirman Am r industrirl Tcchnologi;s, Inc.
1000 South Madison Street Wilmington, DE.19801 Dear Mr. Amer.
The Nuclear Regulatory Commission (NRC) staff has reviewed your letter of April 10,1998, and its attachment concerning the certification of the 35 tubes used to manufacture the heat exchangers on Amer Industrial Technologies, Inc. (AIT) Job No 442. The staff has reviewed the information you provided with respect to inspection findings that were previously issued in NRC l
Inspection Report 99901292. Based on our review of the informr. tion you have provided, we remain unable to close the Notice of Nonconformance (NON). As stateiin the inspection report and other previous correspondence, you have not been able to provide adequate documentation that all 36 tubes were tested in accordance with ASMG requirements. Information received from Marmon/ Keystone indicates that the 36 tubes providt d to AIT were all 20 foot lengths, with no l
extra material. Based upon our understanding of tho length and number of tubes needed to manufacture the heat exchangers, there would not'oe sufficient material remaining to test each tube (see Section 3.4.1.3 of Inspection Report 99901092/96-01) as required by the ASME Code.
In addition, you have not been able to reconcile the conflicting information you have provided regarding the mechanical tests, i.e., that all testr, were not performed on each tube, with the test report that shows all tests were performed on e.ach tube.
As noted in our November 7,1997, letter to you, the NRC has determined this matter to be of low safety sign?icance. Therefore, the NRC decided not to pursue the matter further with the NON remaining unresolved. Attached to this letter is a list of specific information that would be needed for the staff to satisfactorily close the issue, should you wish to pursue the matter further.
. In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice for Domestic Licensing Proceedings and issuances of Orders," a copy of this letter will be placed in the NRC Public Document Room.
If you have any questions regarding this matter, please contact Suzanne C. Black, Chief of the i
Quality Assurance, Vendor Inspection and Maintenance Branch at (301) 41S1017.
I i
Sincerely, Original signed by:
9805110001 98050,,5,,
R. Lee Spessard, Director l
PDR GA999 D'fV*
99901292 PDR Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket No. 99901292
Attachment:
As stated Distribution:
UQMB R/F Central Files Docket Files PUBLIC White Book 01 OE J. Strosnider E. Sullivan M. Modes D. Naujock DOCUMENT NAME:G:\\cwalina\\ Amer.gcc l-
- See previous concurrence AI To receive a copy of this document,indicata in the box:
"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy l
OFFICE HOMB E
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f Mr. A. E. Amer.lf you have any questions regarding this matter, please contact Suzanne C. Black, Chief of the Quality Assurance, Vendor Inspection and Maintenance Branch at (301) 415-1017.
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Sincerely
. Original signed by l
R. Lee Spessard, Director Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket No. 99901292' j
I
Attachment:
As stated
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DISTRIBUTION:
1 HQMB R/F Central Files Docket Files PUBLIC l
White Book 01 OE J. Strosnider E. Sullivan
. Modes D. Naujock DOCUMENT NAME:G:ViraftV:walina%merlett.gre i
- See previous concurrence To receive e copy of this document, Indicate in the box:
"C" = Coov without enclos es "E" = Copy with enclosures *N" = No copy OFFICE HQMB E
HQiUW E
SC:HQMB \\
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Information Needed to Resolve NRC Nonconformances 99901292/96-01-03 and 06 l
1 l
The following hformation is needed to resolve staff questions associated with NRC Nonconformances 9990192/96-06-03 and 06. This information is necessary to ascertain whether i
the heat exchanger tube material for AIT Job No. 442 met the appropriate technical requirements.
l 1.
Documentation, including supplier records, that identifies the as-supplied length of each of the 36 heat exchanger tubes (Heat 714652/AIT Job No. 442) obtained from Marmon/ Keystone.
2.
Documentation that identifies the length of tube material cut from each of the 35 tubes used to construct the heat exchanger, the number of tubes used in each heat exchanger, the total number of heat exchangers manufactured, and the number of tubes discarded or scrapped.
3.
The date(s) when the 35 tubes were actually cut for Job No. 442 and the dates when the heat exchangers were manufactured.
4.
The minimum required tube length, &nd the actuallength, of the tube sections (from each of the 35 tubes) that were sent out for chemical and physical tests.
5.
Information (including all test records, inspection records, and test instrument use logs) that substantiates that all of the tubes were subjected to a hydrostatic test prior to being cut in accordance with the requirements of the ASME Section ill Code. Conflicting information has been provided to the NRC (AIT memorandum dated February 5,1996, AIT test records, and AIT letter dated February 6,1997) regarding the point in time when the 36 tubes were subjected to a hydrostatic test.
6.
An evaluation of the chemical analysis information (from Gibson Tube and Ramball Testlab, Inc.) provided to the staff (AIT letters of February 2,1997 and April 10,1998) regarding the variances in carbon and sulfur content of the tested tube sections. Address the possibility that mixed heats of material were sent to the AIT test vendor.
7.
Reconciliation and explanation of AIT's (letter of October 11,1996) statement that "Not all tests were performed on each piece, however, because some of the available test samples were not large enough," with the provided test reports indicating that all tests had been performed on tube raaterial for Job No. 442.
i l'
i
May 5, 1998 Mr. Ahmad E. Amar, Chairman g
Amar Industrial Technologies, Inc.
1000 South Madison Street Wilmington, DE 19801
Dear Mr. Amer:
The Nuclear Regulatory Commission (NRC) staff has reviewod your letter of April 10,1998, and its attachment conceming the certification of the 35 tubes used to manufacture the heat exchangers on Amer Industrial Technologies, Inc. (AIT) Job No 442. The staff has reviewed the information you provided with respect to inspection findings that were previously issued in NRC inspection Report 99901292. Based on our review of the information you have provided, we remain unable to close the Notice of Nonconformance (NON). As stated in the inspection report and other previous correspondence, you have not been able to provide adequate documentation that all 36 tubes were tested in accordance with ASME requirements. Information received from Marmon/ Keystone indicates that the 36 tubes provided to AIT were all 20 foot lengths, with no extra material. Based upon our understanding of the length and number of tubes needed to manufacture the heat exchangers, there would not be sufficient material remaining to test each tube (see Section 3.4.1.3 of Inspection Report 99901092/96-01) as required by the ASME Code.
In addition, you have not been able to reconcile the conflicting information you have provided regarding the mechanical tests, i.e., that all tests were not performed on each tube, with the test report that shows all tests were performed on each tube.
As noted in our November 7,1997, letter to you, the NRC has determined this matter to be of low safety significance. Therefore, the NRC decided not to pursue the matter further with the NON remaining unresolved. Attached to this letter is a list of specific information that would be needed for the staff to satisfactorily close the issue, should you wish to pursue the matter further, in accordance with 10 CFR 2.790 of the NRC's
- Rules of Practice for Domestic Licensing Proceedings and Issuances of Orders," a copy of this letter will be placed in the NRC Public Document Room.
If you have any questions regarding this matter, please contact Suzanne C. Black, Chief of the Quality Assurance, Vendor Inspection and Maintenance Branch at (301) 415-1017.
Sincerely, Original signed by:
R. Lee Spessard, Director Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket No. 99901292
Attachment:
As stated Distribution:
HQMB R/F Central Files Docket Files PUBLIC White Book 01 OE J. Strosnider E. Sullivan M. Modes D. Naujock DOCUMENT NAME:G:\\cwalina\\ Amer.gcc
- See previous concurrence
,) e To receive a copy of this document, indicate in the box: "C" = Copy without enclosures "E* = Copy with enclosures "N" = No copy OFFICE HOMB E
HQMB E
SC:HOMB E
BC:HQMB lC D:DRCHe/f-tC NAME LLCampbell:cct GCwalina RAGramm SCBlack RLSpessia'rd DATE 05/01/98*
05/01/98*
05/01/98*
05/01/98*
05/f/98 OFFICIAL RECORD COPY
i a
l )
l information Needed to Resolve i
NRC Nonconformances 99901292/96-01-03 and 06 i
The following information is needed to resolve staff questions associated with NRC l
Nonconformances 9990192/96-06-03 and 06. This information is necessary to ascertain whether i
the heat exchanger tube material for AIT Job No. 442 met the appropriate technical requirements.
1.
Documentation, including supp!ier records, that identifies the as-supplied length of each of the 36 heat exchanger tubes (Heat 714652/AIT Job No. 442) obtained from Marmon/ Keystone.
2.
Docunientation that identifies the length of tube rnaterial cut from each of the 35 tubes used to construct the heat exchanger, the number of tubes used in each heat exchanger, the total number of heat exchangers manufactured, and the number of tubes discarded or scrapped.
3.
The date(s) when the 35 tubes were actually cut for Job No. 442 and the dates when the heat s xchangers were manufactured.
4.
The minimum required tube length, and the actuallength, of the tube sections (from each of the 35 tubes) that were sent out for chemical and physical tests.
5.
Information (including all test records, inspection records, and test instrument use logs) that substantiates that all of the tubes were subjected to a hydrostatic test prior to being cut in accordance with the requirements of the ASME Section !!! Code. Conflicting 4
information has been provided to the NRC (AIT memorandum dated February 5,1996, l
AIT test records, and AIT letter dated February 6,1997) regarding the point in time when
{
the 36 tubes were subjected to a hydrostatic test.
6.
An evaluation of the chemical analysis information (from Gibson Tube and Ramball Testlab, Inc.) provided to the staff (AIT letters of February 2,1997 and April 10,1998) regarding the variances in carbon and sulfur content of the tested tube sections. Address j
the possibility that mixed heats of material were sent to the AIT test vendor.
1
)
7.
Reconciliation and explanation of AIT's (letter of October 11,1996) statement that "Not all j
tests were performed on each piece, however, because some of the available test j
samples were not large enough," with the provided test reports indicating that all tests j
had been performed on tube material for Job No. 442.
1 l
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