United States Nuclear Regulatory Commission - Protecting People and the Environment

ACCESSION #: 9506060227

Automatic Switch Co.                         Manufacturers of
                                             DEPENDABLE CONTROL 
ASCO
                                               Since 1888

FLORHAM PARK, NEW JERSEY 07932  o  N.J. (201) 966-2000 / N.Y.
(212)
344-3765 FAX-966-2628

                                             May 19, 1995

United States Nuclear Regulatory Commission
Washington, DC 20555-0001

Attention:     Robert M. Gallo
               Chief, Special Inspection Branch
               Division of Technical Support
               Office of Nuclear Reactor Regulation

Subject:       R. Gallo's letter of May 15, 1995, to Randy P.
Smith
               NRC Inspection No. 99900369/95-01 / Notice of
               Nonconformance

Dear Mr. Gallo,

Enclosed you will find Automatic Switch Company's formal reply to
the
Notice of Nonconformance forwarded to us with your letter of May
15,
1995.

Immediately following discovery of the nonconformance found
during the
NRC inspection of March 13 and 14, 1995, ASCO initiated
corrective
actions which are described in the attached response.  I believe
you will
find that these actions were appropriate, timely, and
sufficiently
thorough to fully address this nonconformance.

Automatic Switch Company has a long standing policy of full
cooperation
with the Nuclear Regulatory Commission.  We have and will
continue to do
whatever is necessary to achieve full compliance with NRC's Rules
and
Regulations and to provide the best possible products to the
nuclear
industry.

Please feel free to contact me or members of my staff as
necessary.

Sincerely,

AUTOMATIC SWITCH COMPANY

Randy P. Smith
President

/ms

Enclosure:     Appendix A - Reply to Notice of Nonconformance

                               APPENDIX A

                 REPLY TO NRC NOTICE OF NON CONFORMANCE

NRC STATED NONCONFORMANCE:

Based on the results of a U.S. NRC Regulatory Commission (NRC)
inspection
conducted at the Automatic Switch Company (ASCO) facility on
March 13 and
14, 1995, it appeared that certain of your activities were not
conducted
in accordance with NRC requirements.

     Criterion III, "Design Control," of Appendix B to 10 CFR
Part 50
     requires, in part, that measures shall be established to
assure that
     the design basis for those components to which this appendix
applies
     are correctly translated into specifications, drawings,
procedures,
     and instructions.

     Criterion V, "Instructions, Procedures, and Drawings," of
Appendix B
     to 10 CFR Part 50 requires, in part, that activities
affecting
     quality be prescribed by appropriate instructions,
procedures, or
     drawings and be accomplished according to those
instructions,
     procedures, or drawings.

     Contrary to these requirements, as of March 14, 1995, ASCO
failed to
     ensure that its September 29, 1989, engineering department
decision
     to cease using silicone-based fluids and greases in its
NP8323
     solenoid-operated valves was translated into a procedure or
     instruction for ASCO's manufacturing department personnel
     implementation.  Subsequent to that decision,
solenoid-operated
     valves supplied for nuclear use were manufactured using
silicone-
     based greases. (95-01-01)

ASCO RESPONSE:

Upon discovery of the reported nonconformance ASCO initiated a 10
CFR
Part 21 evaluation which included a discussion between John
Shank, ASCO,
and Joseph Petrosino, NRC Inspection Team leader.  On the basis
of this
evaluation and discussion, ASCO concluded with NRC concurrence,
that, the
stated nonconformance is not 10 CFR Part 21 reportable for the
following
reasons:

o    All NP 8323 valves supplied by ASCO were in full compliance
with all
     purchase order requirements supplied by ASCO's customers. 
None of
     the customer's purchase orders specified requirements
indicating the
     need to include or omit grease.

o    ASCO Valve Engineering has established the design basis
linkage for
     all NP8323 solenoid operated valves, in both of the
configurations
     supplied:

     -    The original construction with silicone greases and
oils in
          several locations within the valve.

     -    The construction that was supplied from September 1989
to the
          point of discontinuance of the NP8323 valve line where
a small
          quantity of grease was applied in one area.

                                   -2-

Therefore, all NP8323 constructions that have been supplied by
ASCO are
fully qualified to the limits specified in ASCO's qualification
reports
and are in full accordance with the qualification requirements
established by the purchase orders of ASCO's customers.

The cause of the nonconformance discovered during NRC's
inspection was an
oversight by the engineering department.  Specifically, the
engineer
performing the assigned work failed to realize that a small
portion of
Nyogel 775A grease was incorporated in the manufacture of the
disc holder
sub-assemblies part number 168410-003D & 006D.  Since this valve
line has
been discontinued, no drawing corrections were issued to address
this
error.  However, ASCO has revised Engineering Report No. 264 to
document
that the constructions shipped from September 1989 to the point
of
discontinuation of the NP8323 line are fully qualified as
constructed.

There is strong evidence that this nonconformance had no
connection to
the February 1995 MSIV problems at the LaSalle County Station. 
ASCO
worked with Commonwealth Edison to investigate this problem and
issued
ASCO Engineering Report 309 which documents the results of our

findings.
A copy of that report has already been forwarded to Joseph
Petrosino.
The following summarizes ASCO's primary findings:

o    Brown oily residues were found on the core and plugnut
contact areas
     as well as on several other internal components of the
subject
     SOV's.

o    The brown residues were mainly found on the B side
components,
     indicating possible contamination from the cylinder port
connection,
     which in this case is the Norgren Valve and associated
piping.

o    ASCO testing at high temperatures for extended periods of
time has
     never caused Nyogel 775A grease to either change color or to
change
     consistency to the point where it would cause significant
adhesion
     between two parts.  Therefore, the brown residues are not
consistent
     with Nyogel 775A.

o    Commonwealth Edison's test in which they demonstrated that
Nyogel
     775A placed on the contact areas of the core and plugnut
would cause
     these parts to adhere is not meaningful.  Since this
experiment was
     conducted external to the SOV, the weight of the parts
involved is
     only approximately 2 ounces.  When installed in this SOV,
there
     would be in excess of 3 pounds of spring force to separate
these
     components.

o    Independent analysis of the brown residues performed for
ASCO showed
     a silicone oil or silicone grease contaminated with an
ester-alcohol
     combination.

o    Since there are several differences between the Nyogel 775A
     reference spectra and the unknown residue it is questionable
whether
     the unknown residue is Nyogel 775A.

o    The IR scans of the residues from this incident are similar
to the
     IR scans from some previous ASCO investigations into
slow-shifting
     problems at other plants.  In those cases it has been
determined
     that the silicone grease or silicone oil was contaminated
with
     volatiles from uncured thread sealant or ester oils possibly
used as
     air compressor lubricant.

In summary, on the basis of the preceding facts, it is our belief
that
the probable root cause of the February 1995 incident at LaSalle
County
Station was contamination from the LaSalle air supply system or
contamination introduced during the installation of the valves at
LaSalle.

We believe the above actions fully address the nonconformance
identified
above.

                                                      
nrcinspa.doc

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