ML20147C654
| ML20147C654 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20147C652 | List: |
| References | |
| REF-QA-99900264 NUDOCS 9702060389 | |
| Download: ML20147C654 (3) | |
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NOTICE OF NONCONFORMANCE Dragon Valves, Inc. Docket No. 99900264 Norwalk, California Based on the results of an inspection conducted on September 23 through 26, 1996, it appears that certain of your activities were not conducted in accordance with NRC requirements.
A. Criterion V, " Instructions, Procedures, and Drawings," of Appendix B to i 10 CFR Part 50 and Paragraph NCA 3853.2 of Subsection NCA of ASME Code,Section III, requires, in part, that activities affecting quality be prescribed by documented instructions or procedures and that these procedures include appropriate criteria for determining that these activities are satisfactorily accomplished.
Paragraph NCA 3853.3, " Document Control" of Subsection NCA of ASME Code,Section III, requires, in part, that instructions and procedures be controlled to assure that correct documents are being used.
Paragraph NCA 3855.5, " Utilization of Unqualified Source Material", of Subsection NCA of ASME Code,Section III states, in part, that a Material Organization (M0) may accept certification of the requirements of the material specification which must be performed during melting, heat analysis, and heat treatment from an unqualified supplier and may furnish such material, providing that the M0 performs or subcontracts a product analysis on each piece of such material and performs or subcontracts all other requirements of the material specification on each piece of the unqualified stock material, i Contrary to the above:
(1) The Unqualified Source Material Approved Vendor List, referenced in Procedure 17375, " Procedure for Procurement and Inspection of Unqualified Source Material," Rev. N/C, had not been developed and was not available for use.
(2) Procedures were not controlled, in that two procedures, 17375 and 17053, with the same title, " Procedure for Procurement and Inspection of Unqualified Source Material," but different requirements, were available for use.
(3) Procedure 17375 permitted the acceptance and furnishing of unqualified source material based on subcontracting the performance of product analysis but without performing or subcontracting all other requirements of the material specification.
(Nonconformance 99900264/96-01-01)
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l 9702060389 961029
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i B.
Criterion VII, " Control of Purchased Material, Equipment, and Services,"
of Appendix B to 10 CFR Part 50, requires, in part, that measures shall be established to assure that purchased material conforms to procurement documents, j
l Paragraph NCA 3862.2, " Quality System Program Statement," requires i
material organizations qualified by parties other than ASME to show the revision and date of the applicable written quality system program on the certified material test report or certificate of compliance.
Contrary to the above, Dragon Valves, Inc., (Dragon) accepted material
' certifications for 1 inch, type 316 stainless steel tubing from Sandvik Steel without the appropriate quality system program statement and utilized this material without upgrading.
l (Nonconformance 99900264/96-01-02)
C. Criterion VII, " Control of Purchased Materials, Equipment, and Services," of Appendix B to 10 CFR Part 50, requires, in part, that measures shall be established to assure that purchased material conforms to procurement documents.
Contrary to the above, Dragon had not established a documented basis to substantiate that the chemical sampling plan for dedicating unqualified material prescribed in Procedure 16562, " Material and Parts Handling for Customer Defined Safety Related Components and Safety Related Items,"
Rev. A, provides reasonable assurance that the dedicated material conforms to the procurement document requirements.
(Nonconformance 99900264/96-01-03)
D. Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50, requires, in part, that for significant conditions adverse to quality measures will be established to assure that the cause of the condition '
is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management.
Section 16 of the Dragon QA manual, " Corrective Action," Fifth Issue, Revision 0, dated March 6, 1996, contains requirements, for significant conditions adverse to quality, to determine the cause, take corrective action to preclude recurrence, document and report these actions to the President and Manager of the departments involved, and to take follow-up action to verify implementation of the corrective action by the QA Manager and document these actions Contrary to the above, Dragon had not documented the cause, corrective actions, reporting to management, or follow-up action to verify corrective action implementation, for a Dragon Instrument Isolation Manifold which had been shippea to Duane Arnold with the "line" and
" instrument" markings, stamped on the manifold body, reversed and where additional mismarked manifolds had been identified in the Duane Arnold and Dragon inventories.
(Nonconformance 99900264/96-01-04) 2
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. This 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 iave been or will be taken to prevent recurrence; and (3) the dates your corrective actions and preventative measures were or will be completed.
Dated at Rockville, Maryland this 29th day of October 1996 3