ML20148H994
| ML20148H994 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1988 |
| From: | Stone J Office of Nuclear Reactor Regulation |
| To: | Francois E VELAN VALVE CO. |
| References | |
| REF-PT21-88, REF-QA-99900346 NUDOCS 8803300137 | |
| Download: ML20148H994 (4) | |
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March 23, 1988 Docket No. 99900346 Ewart Francois Velan Valve Corporation Avenue C Griswald IndJstrial Park Williston, Vermont 05495
Dear Mr. Francois:
This letter is in response to the questions you asked and the request you made during a telephone conversation on March 1,1988 with Mr. Baker of my staff regarding 10 CFR Part 21.
In response to your question concerning Part 21 being self imposing; Section 21.2 states that the regulations in this part apply to each individual, corpora-tion or other entity doing business within the United States, and each director and responsible officer of such organizations, that constructs or supplies a basic component for a facility licensed by the NRC.
In other words, if you are supplying a basic component you must comply with Part 21, regardless of whether your customer contractually imposed Part 21.
With regard to your questions concerning reportability; paragraph 21.21(b)(1) requires a director or responsible officer subject to the regulations of this part or a designated person to notify the NRC when he obtains information reasonably indicating a dcfect affecting a basic component that is within his organization's responsibility and has been supplied to a facility licensed by the NRC. That is, if a responsible officer becomes aware of a defect, he must report it to the NRC. This logic also applies to paragraph 21.21(a)(1) except customers must be informed of deviations when Velan can not evaluate the affect of the deviation.
In each case, Velan would be required to report either to the NRC or the customer based on information received.
This does not mean that Velan has to take an active role in acquiring information on deficiencies and defects, but Velan must act on information received.
In performing evaluations and making reports, Velan must identify and notify all potentially affected customers. Heat number traceability would provide the best control and be the least expensive in terms of number of customers affected.
However, where heat number traceability is not available, it would be acceptable to identify a time period during which suspect parts would be used in production and notify all customers who received material manufactured during that time period.
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o Ewart Francois
-2 Concerning your question on dedication of commercial grade material and your obligation to pass down Part 21 to your subtier suppliers, if the item you are buying clearly meets all the requirements of paragraph 21.3(a)(4), you may purchase the item without imposing 10 CFR Part 21 in your contract with the subtier supplier, even though your customer imposed Part 21 on you. However, you must keep track of the items you supply for use in basic components and if you become aware of a deviation or a defect, you must comply with the evalua-tion and reporting requirements of Section 21.21.
I hope this addresses the questions you had.
If you have additional QJestions, please feel free to contact Ed Baker (301) 492-3221 or myself (301) 492-0961.
Sincerely, James C. Stone, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation
March 23, 1988 Ewart Francois Concerning your question on dedication of commercial grade material and your obligation to pass down Part 21 to your subtier suppliers, if the item you are buying clearly meets all the requirements of paragraph 21.3(a)(4), you may purchase the item without imposing 10 CFR Part 21'in your contract with the subtier supplier, even though your customer imposed Part 21 on you. However, you must keep track of the items you supply for use in basic components and if you become aware of a deviation or a defect, you must comply with the evalua-tion and reporting requirements of Section 21.21.
I hope this addresses the questions you had.
If you have additional questions, please feel free to contact Ed Baker (301) 492-3221 ormyself(301)492-0961.
Sincerely, Original signed by:
James C. Stone, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION:
RIDS Code IE:09; VIB Reading DRIS Reading JPartlow BGrimes JStone EBaker K C ir' O G C-l
- See previous page for concurrences.
ASC/VIB:DRIS OGC AC/VIB:DRIS i
EBaker:tt" k/
JStone l
03/09/88 S/ /88 $/J3/88 i
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March 23, 1988 o
Ewart Francois Concerning your question on dedication of commercial grade material and your obligation to pass down Part 21 to your subtier suppliers, if the item you are buying clearly meets all the requirements of paragraph 21.3(a)(4), you may purchase the item without imposing 10 CFR Part 21 in your contract with the subtier supplier, even though your customer imposed Part 21 on you. However, you must keep track of the items you supply for use in basic components and if you become aware of a deviation or a defect, you must comply with the evalua-tion and reporting requirements of Section 21.21.
I hope this addresses the questions you had.
If you have additional questions, please feel free to contact Ed Baker (301) 492-3221 or myself (301) 492-0961.
Sincerely, Original signed by:
Janes C. Stone, Acting Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION:
RIOS Code IE:09 VIB Reading DRIS Reading JPartlow BGrimes JStone EBaker K C1r OG '-
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1
- See previous page for concurrences.
ASC/VIB:DRIS OGC AC/VIB:DRIS EBaker:tt*
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JStone 03/09/88 3/ /88 ')/J3/88
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