ML19325C854
| ML19325C854 | |
| Person / Time | |
|---|---|
| Issue date: | 09/27/1989 |
| From: | Brach E Office of Nuclear Reactor Regulation |
| To: | Bopp R APV GAULIN, INC. (FORMERLY GAULIN CORP.) |
| References | |
| REF-QA-99900286 NUDOCS 8910170324 | |
| Download: ML19325C854 (1) | |
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September 27, 1989 f
Mr. Regis E. Bopp i
Quality Assurance Manager APV Gaulin, Incorpurated i
44 Garden Street
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Everett, Massachusetts 02149
Dear Mr. Bopp:
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We have reviewed your letter of March 8,1909, where you request exemption from -
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imposing 10 CFR Part 21 on vendors who supply calibration of. measuring and test equipnent.
Paragraph 21.31 of 10 CFR Part 21 requires that procurement docunents for basic I
components impose the requirements of 10 CFR Part 21.
Paragraph 21.3(a)(3)
L states that basic components include design, inspection, testing, or consulting services important to safety that are associated with component hardware.
In addition,NUREG-0302, Revision 1."Remarkspresented-(questionsandanswersdis-cussed)atpublicregionalmeetingstodiscussregulation(10CFRPart21)for reporting oi defects and noncompliance " addresses this issue in questions which ask:
"Does Part 21 also apply to suppliers of consumables such as welding material and services such as calibration?" The response given'is: "Yes, where the consumable or calibration service is related to a basic component and a deviation f rom specified requirements of a procurement document or failure to I
l comply, could create a substantial safety hazard."
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. Paragraph 21.3(k) defines substantial safety hazard as a loss of safety j
function to the extent that there is a major reduction in the degree of protection provided to public health and safety. Therefore, if APV Gaulin identified that calibration services sup)1ied to them by a vendor could deviate from technical requirements imposed on tien by APV Gaulin, and such deviation could create a substantial safety hazard in a basic component supplied by APV Gaulin, the requiren=nts of 10 CFR Part 21 must be imposed on the vendor.
Should APV Gaulin not possess information on the basic conponent necessary to adequately Ivaluate the deviation, APV Gau11n must inform their purchaser of thedeviationinaccordancewith10CFR21.21(a)(1)(ii).
As a result of the above, APV Gaulin's request for exemption is denied.
Thould you have further questions concerning)this subject, please feel fre contact Mr. Edward Baker of sqy staff on (301 492-0959.
Sincerely, f607 o
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7 E.* W'i flam Br ch, Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation
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