United States Nuclear Regulatory Commission - Protecting People and the Environment


ACCESSION #: 9602270413



AMER

INDUSTRIAL

TECHNOLOGIES INC.



February 21, 1996



U.  S.  Nuclear Regulatory Commission

Document Control Desk

Washington, D.C.  20555



Subject:       10CFR Part 21 - Notification re: Bechtel Job 21464

               Calvert Cliffs Nuclear Power Plant

               Diesel Generator Project

               Bechtel P. O. CCDG 0065 and CCDG0767

               Safety Related Fuel Oil Filters

               Bechtel File No. DG80382 - CCDU-96/008



Reference:     Letter - A.E.Amer (A.I.T.) to R.F. Yamrus (Bechtel) dated

               2/5/96

               Letter - R.F. Yamrus (Bechtel) to A.E.Amer (A.I.T.) dated

               2/6/96



Sirs:



     Based upon the above referenced letters and our review of the A.I.T.

procurement documents associated with the oil filter cartridge used in

the Fuel Oil Filters, we have concluded that the cartridge element and

associated O-Rings may not have been properly qualified by commercial

grade dedication activities as per Bechtel's latest requirement.



     We are corresponding with Bechtel and B. G. & E. to determine the

best methods to accomplish a proper commercial grade dedication.



     A. I. T. is also to notifying Baltimore Gas & Electric and Bechtel

Power Corporation via letter or fax of this condition.



     Point of contact for this action item is A.  E.  Amer at (302) 652-

3900.  Should you have any further comments or questions, please refer

them to myself



                         Sincerely,



                         A.E.  Amer

                         President



AEA:rsc



cc:  N392 File

     Part 21 File

     QA Chron



1000 S. MADISON ST., WILMINGTON, DELAWARE 19801 TEL(302)652-3900

FAX(302)652-6400



AMER

INDUSTRIAL

TECHNOLOGIES INC.

February 5, 1996



Bechtel Power Corporation

Calvert Cliffs Diesel Generator Project

Job No.  21464

9801 Washingtonian Blvd.

Gaithersburg, Maryland 20878-5356



Attention: Mr.  Ram Yelamanchi



Reference:     Fuel Oil Transfer Filters

               Specification No.  SP-760 Revision 1

               Procurement Specification DG-80382

               Purchase Order No. CCDG0767

               A. I. T. Project 523



Dear Mr.  Yelamanchi:



     Per the requirements of the above referenced procurement

specification DG-80382, A.I.T.  would like to identify the safety-related

non-Code part of this contract as the filter cartridges.  In accordance

with the specifications A.I.T.  will identify all steps taken to control

the step by step processing of the cartridges



     A.I.T. issued Purchase Order No.  20808 (copy attached for your

review and information) to our vendor requiring strict compliance to the

Bechtel Power Corporations procurement specifications, including but not

limited to Certificate of Conformation, shelf life of the filter

cartridge, engineering information (flow vs DP), storage requirements

i.e.  temperature, ultraviolet light, etc.  Also, A.I.T.  will issue

their Certificate of Compliance to certify that we furnished these items

in accordance with our Q. A.  Program, your purchase order requirements

and ASME B & PV Code Section III, Division 1, Class 3, 1986 Edition, no

addenda, 10CFR21 applied.



     Please advise A.I.T.  of Bechtel's acceptance of this process.

Should you have any further questions or comments, please contact me.



                         Sincerely,



                         AMER INDUSTRIAL TECHNOLOGIES, INC.



                         A.  E.  Amer

                         President



AEA:rsc



1000 S.  MADISON ST..  WILMINGTON.  DELAWARE 19801 TEL (302) 652-3900 FAX

(302) 652-6400



Bechtel

9801 Washingtonian Boulevard

Gaithersburg, Maryland 20878-5356

(301) 417-3000



February 13, 1996



Mr.  A.  E.  Amer

Amer Industrial Technologies

1000 S.  Madison Street

Wilmington, Delaware 19801



Dear Mr.  Amer:



Subject:  Bechtel Job 21464

          Calvert Cliffs Nuclear Power Plant

          Diesel Generator Project

          Bechtel P. O.  # CCDG 0065 & CCDG 0767

          Safety Related Fuel Oil Filters

          Bechtel File Nos.: DG80382

          CCDV-96/010



Our review of your letter dated February 5, 1996, and the information

furnished with the letter, identified the following inconsistencies:



The Amer Industrial Technologies Inc.  (AIT) Purchase Order No.  20808

furnished with the above letter does not appear to invoke safety related

quality program requirements.  Item 3 of Attachment B to the purchase

order states that material shall be in compliance with ASME III, Class 3,

1986 Edition.  However, the filter cartridges are exempt from the

requirements of ASME III, since the filter cartridges are not associated

with the pressure retaining function.  Item 9 of Attachment B to the

purchase order states that 10 CFR 21 applies to the order.  Our review

indicates that, there is no objective evidence that the sub-supplier had

a safety related quality program, and implemented the program in the

manufacture of filter cartridges.



Based on the information furnished with your letter, we can not make a

determination, that the controls used by AIT in procurement of filter

cartridges are acceptable.  The only acceptable methods for procurement

of safety related filter cartridges are, either to purchase them as

safety related parts from an approved supplier with a ANSI N 45.2 (10 CFR

50, Appendix B) quality program, or to purchase them as commercial grade

items and dedicate them for safety related application in accordance with

EPRI NP-5652.



Further information in the following areas is necessary to determine the

acceptability:



1.   Did your sub-supplier, Norman Ultraporous Filters, have a approved

     safety related quality program?



Bechtel Power Corporation



Mr.  A.  E.  Amer

CCDV-96/010

Page 2



2.   Did Norman Ultraporous Filters acknowledge your purchase order as a

     safety related order and accept the reportability requirements under

     10 CFR 21?



3.   Did you procure the filter cartridges as commercial grade items?



4.   If the filter cartridges were procured as commercial grade items,

     was a dedication plan consisting of critical characteristics,

     acceptance criteria and verification methods developed and

     implemented in accordance with EPRI NP-5652?



5.   Was Bechtel filter data sheet included with your procurement

     documents? If it was not included, how did you provide the full

     range of design conditions including the viscosity to Norman

     Ultraporous Filters?



We request that you contact Bechtel to discuss the answers to the above

questions and take the necessary actions to document the controls used in

the procurement of filter cartridges in an expeditious manner.



Very truly yours,



R.  F.  Yamrus

Project Engineer



RY/ry



cc:  Mr.  C.  R.  Mahon

     Mr.  E.  S.  Broczkowski

     Mr.  F.  J.  Reedy



*** END OF DOCUMENT ***



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