ML20133L685
| ML20133L685 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 08/07/1985 |
| From: | Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Grunthaler G GUYON ALLOYS, INC. |
| References | |
| REF-PT21-85 NUDOCS 8508120697 | |
| Download: ML20133L685 (6) | |
Text
i AUG 0 71985 George H. Grunthaler Vice President, Technical Services i
Guyon Alloys, Inc.
950' South Fourth Street Harrison, New Jersey 07029
Dear Mr. Grunthaler:
i
SUBJECT:
10 CFR PART 21 APPLICABILITY TO STAINLESS-STEEL PIPE FURNISHED TO COMMONWEALTH EDIS0N C0. - BRAIDWOOD STATION Your letter to me dated February 14, 1985, requested guidance regarding required 10 CFR Part 21 notification concerning the above subject stainless-steel pipe.
Although some of the referenced pipe was procured by the Commonwealth Edison Company, prior to the effective date of 10 CFR Part 21 (June 6, 1977), the notification requirements of 10 CFR Part 21 still apply if a deviation amounting to a defect, as defined by Part 21, in any stainless-steel pipe supplied to Commonwealth Edison Company or other nuclear end-users is discovered after the effective date of 10 CFR Part 21.
If it is not possible for your organization to determine whether the deviation could create a significant safety hazard (SSH) for the installed condition of the pipe in the end-user's fac'ility then all pertinent information should be provided to the end-user for evaluation and determination of whether a reporta-ble defect exists.
In this case, unless you have reasons to believe that the particular deviation is limited to one specific heat identity, grade, size, wall thickness or other characteristic of the pipe, all purchasers of potentially affected pipe should be notified in order that they can evaluate the deviation to determine whether it is a defect which could create a substantial safety hazard.
Nothing in 10 CFR Part 21 should be deemed to preclude either an individual or a manufacturer / supplier of an item, such as the pipe involved in this situation, from reporting to the Commission a known or suspected defect.
If I can be of further help, please contact me.
Sincerely, oriWrmt signal By:
f.1. keden Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement D'
ribution:
CS GFlanik GZech EAB R/F WRJones JLieberman DEPER R/F JTaylor
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Amcx os PDR
George H. Grunthaler Vice President, Technical Services Guyon Alloys, Inc.
950 South Fourth Street Harrison, New Jersey 07029
Dear Mr. Grun'thaler:
N
SUBJECT:
10 CFR'PART 21 APPLICABILITY TO STAINLESS-STEEL PIPE FURNISHED TO COMMONWEALTH EDIS0N CO. - BRAIDWOOD STATION Your letter to me dated February 14, 1985, requested guidance regarding required 10 CFR Part 21 notification concerning the above subject stainless-steel pipe.
Based on the fact that theXreferenced pipe was procured by the Commonwealth Edison Company prior to the effective date of 10 CFR Part 21 (June 6, 1977),
notification pursuant to Part 21 is not required because the provisions of the rule do not apply prior to-its effective date.
However, any procurement activity related to stainless-steel pipe which could contain the same type of defects, whether to Commonwealth Edison Company or other nuclear end-users, that has occurred after the effective date of the Part 21 rule, would be subject to Part 21 notification requirements.
\\
If it is not possible for your organization to determine whether the deviation could create a significant safety hazard (SSH) for the installed condition of the pipe in the end-user's facility then all pertinent information should be provided to the end-user for evaluation hnd determination of whether a reporta-ble defect exists.
In this case, unless 'you have reasons to believe that the particular deviation is limited to one spe'cific heat identity, grade, size, wallthicknessorothercharacteristicoftyepipe,allpurchasersofpoten-tially affected pipe should be notified in order that they can evaluate the deviation to determine whether it is a defec which could create a substantial safety hazard.
eclude either an individual or Nothingin10CFRPart21shouldbedeemedtop(pipeinvolvedinthissituation, a manufacturer / supplier of an item, such as the from reporting to the Commission a known or susphcted defect.
If I can be of further help, please contact me.
Sincerely,
\\,
EdwardL.Jordkn, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Distribution:
DCS GFLani k EAB R/F WRJones DEPER R/F JTaylor
- SEE PREVIOUS CONCURRENCES SASchwartz RVol1mer
- IE
- ELD
- VPB: QAVT:IE CERossi PDR DGable JLieberman GZech 5/ /85 6/ /85 6/ /85
- EAB:DEPER:IE
- EAB:DEPER:IE
- EAB: DEPER: IE
- DD:DEPER:IE D:DEPER:IE WRJones:mj GFlanik CERossi SASchwartz ELJordan 4/ /85 4/ /85 4/ /85 6/ /85 6/ /84
George H. Grunthaler Vice President,s Technical Services Guyon Alloys, Inc.
950 South Fourth '5treet Harrison, New Jersey 07029
\\
Subject:
10 CFR Part 21 Applicability to Stainless-Steel Pipe Furnished to Commonwealth ~ Edison Co-Braidwood Station.
k
Dear Mr. Grunthaler:
Your letter to me dated February 14, 1985, requested guidance regarding required 10 CFR Part 21 notification concerning the above subject stainless-steel pipe.
BasedonthefactthattherefehencedpipewasprocuredbytheCommonwealth Edison Company prior to the effective date of 10 CFR Part 21 (June 6, 1977),
notification pursuant to Part 21 is not required because the provisions of the rule do not apply prior to its effective date.
However, any procurement activity rela'ted to stainless-steel pipe which could contain the same type of defects, whether to Commonwealth Edison Company or other nuclear end-users, that has occurred after the effective date of the Part 21 rule, would be subject to Part 21 ' notification requirements.
If it is not possible for your organization to determine whether the deviation could create a significant safety hazard (SSH)gfor the installed condition of the pipe in the end-user's facility then all pertinent information should be provided to the end-user for evaluation and dete'rmination of whether a reporta-ble defect exists.
In this case, unless you have\\ reasons to believe that the particular deviation is limited to one specific heat identity, grade, size, wall thickness or other characteristic of the pipe,'all purchasers of poten-tially affected pipe should be notified in order thatsthey can evaluate the deviation to determine whether it is a defect which could create a substantial safety hazard.
\\
Nothing in 10 CFR Part 21 should be deemed to preclude either an individual or a manufacturer / supplier of an item, such as the pipe involved in this situation, j
from reporting to the Commission a known or suspected defect.
l If I can be of further help, please contact me.
l l
l Edward L. Jordan, Director
[
Division of Emergency Preparedness and Engineering Response i
Office of Inspection and Enforcement Distribution:
DCS GFlanik l
EAB R/F WRJones i
DEPER R/F JTaylor
- SEE PREVIOUS CONCURRENCES SASchwartz RVollmer
- IE ELD /Ayu Vd.. VT:IE CERossi fbR DGable JLilfeTman GZech 5/ /85
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" 85 6/ /84
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George H. Grunthaler Vice President, Technical Services Guyon Alloys, Inc.
950 South Fourth Street Harrison,,New Jersey 07029
Subject:
10 CFR Part 21 Applicability to Stainless-Steel Pipe Furnished to Commonwealth Edison Co-Braidwood Station.
Dear Mr. Grun haler:
\\
Your letter to me dated February 14, 1985, requested guidance regarding required 10 CFR P rt 21 notification concerning the above subject stainless-steel pipe.
Based on the fact th t the referenced pipe was procured by the Commonwealth Edison Company prior to the eff2ctive date of 10 CFR Part 21 (June 6, 1977),
notification pursuant to Part 21 is not required because the provisions of the rule do not apply pr r to its effective date.
However, any procurement activity related to the 19 additional purchases and/
or the 70 additional shipments of pipe discussed in your letter, whether to CommonwealthEdisonCompany%rothernuclearend-users,thathasoccurredafter the effective date of the Part 21 rule, would be subject to Part 21 notification requirements.
If it is not possible for your o ganization to determine the presence of a significantsafetyhazard(SSH)fhrtheinstalledconditionofthepipeinthe end-user's facility and if your organization has provided all pertinent informa-tion to the end user, the SSH deter'ination and notification become the respon-sibility of the end user.
Furthermore, nothing in 10 CFR Part 21 hould be deemed to preclude either an individual or a manufacturer / supplier of an item, such as the pipe involved in this situation, from reporting to the Com ission a known or suspected defect.
If I can be of further help, please contact e.
Edward L.
rdan, Director Division of mergency Preparedness and Enginee ing Response Office of Insp ction and Enforcement Distribution:
DCS GFlanik EAB R/F WRJones DEPER R/F JTaylor
- SEE PREVIOUS CONCURRENCES SASchwartz RVollmer
- IE ELD VPB:QAVT:IE CERossi DGable JLieberman GZech 5/ /85 5/ /85 5/ /85
- EAB:DEPER:IE
- EAB:DEPER:IE
- EAB:DEPER:IE DD:DEPER:IE D:DEPER:IE WRJones:mj GFlanik CERossi SASchwartz ELJordan 4/ /85 4/ /85 4/ /85 5/ /85 5/ /84
o George H. Grunthaler Vice Presi ent, Technical Services l
Guyon Allo
, Inc.
950 South Fo rth Street Harrison,Ne% Jersey 07029
\\
Subject:
10 CFR Part 21 Applicability to Stainless Steel Pipe Furnished to Commonwealth Edison Co. - Braidwood Station.
\\
Dear Mr. GrunthaT r:
Your letter to me ted February 14, 1985, requested guidance regarding required 10 CFR Par 21 notification concerning the above subject stainless steel pipe.
Based on the fact that the referenced pipe was procured by the Commonwealth Edison Company prior to the effective date of 10 CFR Part 21 (June 6, 1977),
notifications pursuant t Part 21 are not required because the provisions of the rule do not apply prio to its effective date.
e However, should any procurement activity related to the 19 additional purchases and/or the 70 additional shipments of pipe discussed in your letter whether to Commonwealth Edison Company or\\other nuclear end-users have occurred after the effective date of the Part 21 ry Part 21 notification requirement,le, then these shipments would be subject to 2
Should it not be within your abili to determine the presence of a significant safety hazard (SSH) for the install condition of the pipe in the end user's facility, then upon provision by you organization of pertinent information to the end user, SSH determination and no ification become the responsibility of the end user.
Furthermore, nothing in 10 CFR Part 21 sh uld be deemed to preclude either an individual or a manufacturer / supplier of a item such as the pipe involved in this situation from reporting to the Commis ion a known or suspected defect.
I-If I can be of further help, please contact m.
4 l
1 Edward L. Jo dan Director i
Divisionofferg,encyPreparedness and Engineer ~ng Response Office of Inspe tion and Enforcement Distribution:
DCS GFlanik EAB R/F WRJones DEPER R/F JTaylor
- SEE PREVIOUS CONCURRENCES SASchwartz RVollmer IE g ELD
\\ VPB:QAVT:IE 1
CERossi DGabTe JLieberman
\\GZech 5////85 5/ /85 x5/ /85
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- EAB:DEPER:IE DD:DEPER:IE' D:DEPER:IE WRJones:mj GFlanik CERossi SASchwartz ELJordan 4/ /85 4/ /85 4/ /85 5/ /85 5/ /84
George H. Grunthaler Vice President, Technical Services Guyon Alloys, Inc.
950 South Fourth Street Harrison, Nes Jersey 07029
Subject:
10 CFR Part 21 Applicability to Stainless Steel Pipe Furnished to Commonwealth Edison Co. - Braidwood Station.
Dear Mr. Grunthaler:
\\
Your letter to me dated February 14, 1985, requested guidance regarding required 10 CFR Part\\21 notification concerning the above subject stainless steel pipe.
Based on the fact that the referenced pipe was procured by the Commonwealth Edison Company prior to'the effective date of 10 CFR Part 21 (Juno 6, 1977),
notifications pursuant to Part 21 are not required because the provisions of the rule do not apply prio( to its effective date.
However, should any procure \\ ment activity related to the 19 additional purchases and/or the 70 additional shipments of pipe discussed in your letter whether to Commonwealth Edison Company orgother nuclear end-users have occurred after the effective date of the Part 21 rule, then these shipments would be subject to Part 21 notification requirement's.
Should it not be within your abil y to determine the presence of a significant safety hazard (SSH) for the installed condition of the pipe in the end users facility, then upon provision by youh organization of pertinent information to g
the end user, SSH determination and not,ification become the responsibility of the end user.
Furthermore, nothing in 10 CFR Part 21 should be deemed to preclude either an individual or a manufacturer / supplier of ari item such as the pipe involved in g
this situation from reporting to the Commission a known or suspected defect.
IfIcanbeoffurtherhelp,pleasecontactme\\
\\
\\
\\
'N Edward L. Jorddn, Director Division of Emergency Preparedness and Engineering \\ Response Office of InspectioQ and Enforcement s
Distribution:
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EAB R/F WRJones s
DEPER R/F SASchwartz ELD VPB: QAVT:IE ' '
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