ML20203C046
| ML20203C046 | |
| Person / Time | |
|---|---|
| Issue date: | 02/12/1998 |
| From: | Black S NRC (Affiliation Not Assigned) |
| To: | Heid J AFFILIATION NOT ASSIGNED |
| References | |
| REF-QA-99900732 99900732-97-01, 99900732-97-1, NUDOCS 9802250045 | |
| Download: ML20203C046 (2) | |
Text
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February 12, 1998 Mr. James F. Heid, Manager Quality Systems industrial Products Group Gould's Pumps, Incorporated 240 Fall Street Seneca Falls, New York 13148
SUBJECT:
RESPONSE TO NRC INSPECTION REPORT NO. 99900732/97-01
Dear Mr. Heid:
Thank you fcc your January 8,1998, letter responding to the Notice of Nonconformance (NON) that was attached to the st.bject inspection report. We have reviSwed the Gould's Pumps, incorporated (Gould's) letter and find that your steps taken to correct the concems, steps to prevent recurrence and schedule for corrective and preventive action is responsive to the NON except for customer notification, and Gould's response and justification for the stated Nonconformance.
Since Gould's practice (a departure from the procurement document requirements) of not verifying certain chemical elements had existed for approximately 10 years, Gould's is required to inform all applicable customers where records exist to show that purchasers bought sucpect basic components even if that time period is longer than the required 10 year minimum record retention period. Section 21.21(b) of Part 21 states that if the deviation or failure to comply is discovered by a supplier of basic components, or services associated with basic components, and the supplier determines that it does not have the capability to perform the evaluation tc determine if a defect exists, then the supplier must inform the purchasers or affected licensees within five working days of this determination so that the purchasers or affected licensees may 2
evaluate the deviation or failure to comply, pu suant to Section 21.21(a).
r Conversely, each applicable customer is required by $21.21, " Notification of failure to comply or existence of a defect and its evaluation," of Part 21, to evaluate the circumstances regarding the j
identified concem for their own specific anplications.
Additionally, although we do not agree with Gould's response and justification for the NON, we believe that Gc ald's action to have a third erty entity evalua;a its dedication program is a positive step to correct the concem and to prevent recurrence. We have no further qcsstions at this time, but we do request that Gould's keep the NRC apprised of the third party evaluation n sula, and any findings or recommendations so that we may determine whether further NRC iroiWons are required to resolve this matter.
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Mr. J. F. Heid February 12, 1998 In accordance with 10 CFR 2.790 of the NRC's
- Rules of Practice," a copy of this letter wi', be placed in the NRC's Public Document Room (PDR). If you or your statt have any questions regarding this matter, we will be pleased to discuss them with you. Please contact Mr. Joseph J.
Petrosino at (301) 41o-2979, if you have any questions or need assistance regarding this matter.
Sinceiety, Orenad sened by Suzanne C thack Suzanne C. Black, Chis!
Quality Assurance, Vendor inspection and Maintenance Branch Division ol Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket 99900732/97 01 DISTRIBUTION:
HOMB R/F PUBLIC EJSult. van JDavis GDick MWebb RLaufer DSkay RPulsifer CShiraki IJLee Docket i,le 99900732 Central Files / RIDS lE:09 DOCUMENT NAME: G:\\ PETRO \\lR RES02.GP *See previous concurrence To etceive e copy of this doeurnent, Indicate in the box:
'C' = Copy w:thout encloeures *E* = Copy with enclosures *N* = No copy 8
OFFICE 'IQMB:DRCHA E DE:EMCB lE HOMB:DRrH I HQMB:DRCHl E I
NAME Petrosino M los DGNaujock RAGramm SCBlack %
IDATE 02/05/98* /JPl ~
02/ 05/98*
02/06/E8*
02/iW98
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OFFICIAL RECORD COPY l
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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20565 4001
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February 12, 1998 Mr. James F. Heid, Manager
- Quality Systems Industrial Products Group Gould's Pumps, incorporated 240 Fall Street Seneca Falls, New York 13148
SUBJECT:
RESPONSE TO NRC INSPECTION REPORT NO. 99900732/97-01
Dear Mr. Heid:
Thank you for your January 8,1998, ietter responding to the Notice of Nonconbrmance (NON) that was attached to the subject inspection report. We have reviewed the GoJd's Pumps, incorporated (Gould's) letter and find that your steps taken to correct the concems, r.eps to prevent recurrence and schedule for corrective and preventive action is responsive to the NON except for customer notification, and Gould's response and justification for the stated Nonconformance.
Since Gould's practice (a departure from the procurement document requirements) of not verifying certain chemical elements had existed for approximately 10 years, Gould's is required to inform all applicable customers where records exist to show that purchasers bought suspect basic components even if that time period is longer than the required 10 year minimum record retenticn period. Section 21.21(b) of Part 21 states that if the deviation or failure to comply is discovered by a supplier of basic components, or services associated with basic components, and the supplier determines that it does not have the capability to perform the evaluation to
.ietermine if a defect exists, then the supplier must inform the purchasers or affected licensees within five working days of this determination so that the purchasers or affected licensees may evaluate the deviation or failure to comply, pursuant to Section 21.21(a).
Conversely, each applicable customer is required by "91.21, " Notification of failure to comply or existence of a defect 9nd its evaluation," of Part 21, to evaluate the circumstances regarding the identified concem for their own specific applications.
Adodionally, although we do not agree with Gould's response and justification for the NON, we beliesa that Gould's action to have a tnird party entity evaluate its dedication program is a positive step to correct the concem and to prevent recurrence. We have no further questions at this time, but we do request that Gould's keep the NRC apprised of the third party evaluation resultr, and any findings or recommendations so that we may determine whether further NRC inspecthns are required to resolve this matter.
,a 8
1 Mr. J. F. Held February 12, 1998 in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,' a copy of this letter will be placed in the NRC's Public Document Room (PDR). If you or your ria'f have any questions regarding th'a m; iter, we will be pleased to discuss them with you. Please contact Mr. Joseph J.
Petrosino at (301) 415-2979, if you have any questions or need assisance regarding this matter.
Sincerely, orens egned t,y suenne e ax=
Suzanne C. Black, Chief Quality Assurance, Vendor Inspection and Maintenance Branch Division of Reactor Controls and Human Factorr Office of Nuclear Reactor Regulation Docket 99900732/97-01 DISTRIBUTION:
HQMB R/F PUBLIC EJSullivan JDavis GDick MWebb RLaufer DSkay RPulsifer CShiraki IJLee Docket File 99900732 Central Files / RIDS lE:09 DOCUMENT NAME: G:\\ PETRO \\lR-RES02.GP *See previous concurrence To ese:ive a copy of this document, indicate in the box: *C" = Copy without enclosures *E* = Copy with enclosures *N* = No cot y OFFICE HQMB:DRCHA E DE:EMCB lE HQMB:DRCH l HOMB:DRCHl - E l
NAME Petrosino td vs DGNaujock RAGramm SCBlack %
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02/ 05/98*
02/06/98*
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DATE 02/05/98*
OFFICIAL RECORD COPY s
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UNITED STATES s-j NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 2066H001
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February 12, 1998
- Mr. James F. Held, Manager Quality Systems Industrial Products Group
- Gould's Pumps, incorporated 240 Fall Street
' Seneca Falls, New York 13148
SUBJECT:
RESPONSE TO NRC INSPECTION REPORT NO. 99900732/97 01
Dear Mr. Heid:
Thank you for your January 8,1998, letter responding to the Notice of Nonconformance (NON) that was attached to the subject inspection report. We have reviewed the Gould's Pumps, Incorporated (Gould's) letter and find that your steps taken to correct the concems, steps to prevent recurrence and schedule for corrective and preventive action is responsive to the NON except for customer notification, and Gould's response and justification for the stated Nonconformance.
Since Gould's practice (a departure from the procurement document requirements) of not verifying certain chemical elements had existed for approximately 10 years, Gould's is required to
!nform all applicable customers where records exist to show that purchasers bought suspcct basic components even if that time period is longer than the required 10 year minimum record retention period. Section 21.21(b) of Part 21 states that if the deviation or failure to comply is discovered by a supplier of basic components, or services associated with basic components, and the supplier determine 3 that it does not have the capability to perform the evaluation to determine if a defect exists, then the supplier must inform the purchasers or affected licensees within five working days of this determination so that the purchasers or affected licensees may.
evaluate the deviation or failure to comply, pursuant to Section 21.21(a).
Conversely, each applicable customer is required by $21.21, " Notification of failure to comply or existence of a defect and its evaluation," of Part 21, to evaluate the circumstances regarding the identified concem for their own specific applications.
Additionally, although we do not agree with Gould's response and justification for the NON, we believe that Gould's action to have a third party entity evaluate its dedication program is a positive step to correct the concem and to prevent recurrence We have no further questions at this time, but we do request that Gould's keep the NRC apprised of the third party evaluation results, and any findings or recommendations so that we may determine whether further NRC inspections are required to resolve this matter.
@W6 N
t Mr. J. F. Heid Febrvary 12, 1998 I
in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC's Public Document Room (PDR). If you or yo'.'r staff have any questions regarding this matter, we will be pleased to discuss them with you. Please contact Mr. Joseph J.
Petrosino at (301) 415-2979, if you have any questions or need assistance regarding this matter.
Sincerely, Ongnal sgned by Suzanne C Dack Suzanne C. Black, Chief Quality Assurance, Vendor Inspection and Main'enance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket 99900732/97-01 DISTRIBUTION:
HQMB R/F PUBLIC EJSullivan JDavis GDick MWebb RLaufer DSkay RPulsifer CShiraki IJLee Docket File 99900732 Central Files / RIDS lE:09 DOCUMENT NAME: G:\\ PETRO \\lR-RES02.GP *See previous concurrence To victive a copy of this document. Indicate in the box: "C" = Copy witt:Jt enclosures *E" = Copy with enclosures *N* = No copy
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_ OFFICE HQMB:DRCHA E DE:EMCB lE HOMB:DRCH l HOMB:DRCHl E l
l NAME Petrosino d Irn; DGNaujock RAGramni SCBlack %
DATE 02/05/98* //~
02/ 05/98*
02/06/98*
02//d498 '~
OFFICIAL RECORD COPY c
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