ML20155E406

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Notice of Violation from Insp on 880801-05.Violations Noted: Vendor Did Not Impose 10CFR21 on Listed Purchase Orders & Notice of Regulations Not Posted
ML20155E406
Person / Time
Issue date: 10/07/1988
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20155E361 List:
References
REF-QA-99901108 99901108-88-01, 99901108-88-1, NUDOCS 8810120276
Download: ML20155E406 (1)


Text

APPENDIX A B&G Manufacturing Company Docket No. 99901108/88-01 NOTICE OF VIOLATION As a result of the inspection conducted on August 1 through 5, 1988, and in accordance with Section 206 of the Energy Reorganization Act of 1974 and its implementing reguletion 10 CFR Part 21, the following' violations were identified and categorized in accordance with NRC Enforcement Policy (10 CFR Part 2 Appendix C), 49 FR 8583 (March 8, 1984):

1. Section 21.31 of 10 CFR Part 21 dated October 31, 1986, states, in part, "Each... corporation... subject to the regulations in this part shall assure that each procurement document for a... basic component... specifies, when applicable, that the provisions of 10 CFR Part 21 apply."

Contrary to the above, a review of purchase orders (P0) to vendors revealed that while 10 CFR Part 21 was imposed upon B&G Manufacturing (BGM), BGM did not impose 10 CFR Part 21 requirements on P0s 50858 (March 13, 1987), 50916 (March 30, 1987), 50667 (December 17, 1986), 50742 (January 20,1987),

50695 (December 29, 1986), 50743 (January 20,1987), 52055 (February 16, 1988), 51100 (May 15, 1987), 51394 (September 10, 1987), 50728 (January 14, 1987) 50064 (May 6, 1986), 50247 (July 21, 1986), 50090 (May 12, 1986),

60042 (April 29, 1986), 50498 (October 24, 1986), 50263 (July 23, 1986),

50570 (November 14, 1986), 50220 (July 7, 1986), and 50398 (September 19, 1986) to Laboratory Testing; 50699 (December 29, 1986), 50700 (December 29, 1986), and 51370 (August 25,1987) to J. W. Rex; 50214 (July 7, 1986) to North 1988), Penn Polishing and 52270 (Marchand 28,Plating); 52147 1988 to Gage (March 3, and Laboratories; 1988), 52688 52614 (June(June 13, 13, 1986) to Professional Calibration. (88-01-01) .

This is a Severity Level IV violation (Supplement VII),

2. Section 21.6 of 10 CFR Part 21 dated October 31, 1986, states, in'part,

' "(a) Each... corporation... subject to the regulations in this part, shall post current (1) the copiesinofthis regulations thepart, following) documents (2 Section 200 of in thea Energy conspicuous position...

Reorgani-zation Act, and (3) procedures adopted pursuant to the regulations in this part. (b) If posting of the ... procedures...is not practicable, the...

firm subject to the regulations in this part may, in addition to posting Section 206, post a notice which describes the regulations / procedures...."

Contrary to the above, an inspection of four posting areas indicated that the above requirements were not satistiad and furthermore, Procedure No.

QAl-125, dated December 1, 1978, or a notice was not posted in any of the locations (88-01-02).

This is a Severity Level V violation (Supplement VII).

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