ML20211J668
| ML20211J668 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/1997 |
| From: | Black S NRC (Affiliation Not Assigned) |
| To: | Dailey J AFFILIATION NOT ASSIGNED |
| References | |
| REF-QA-99900861 NUDOCS 9710080233 | |
| Download: ML20211J668 (2) | |
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S UNITED STATES j
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October 1, 1997 i
Mr. James Dailey, Manager, Quality Assurance DuBose National Energy Services, Inc.
900 Industrial Drive Clinton, NC 28328
Subject:
YOUR SEPTEMBER 5,1997, RESPONSE TO NRC LETTER OF JULY 2,1997
Dear Mr. Dailey:
We have reviewed your letter of September 5,1997, in response to our letter of Julv 2,1997, and the Notice of Nonconformance that was transmitted to you as an enclosure to our letter dated April 29,1997. The results of our review are summarized in the following paragraphs.
Our letter of July 2. W97, included specific comments regarding your interpretation of the ASME Code. Those comments were not adequately addressed in your responce. Specifically, we noted that Parograph NCA 3867.4(' ) described the certification requirements for material u
manufacturers in the 1992 (and earlier) Edition of the ASME Code. These requirements were changed in the 1995 Edition and are now contained in Paragraph NCA 3862. The material supplied under the POs referenced in the nonconformance was certified under your ASME Quality Systems Certificate (OSC) and your Quality Systems Program, Revision 5, dated January 10,1990. Since your QSC and the referenced Qualit/ Systems Program are based on the requirements of the 1995 edition of the ASME Code, we expect material certified under these documents to comply with that Code edition.
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I Further, your response again refers to NCA 1140(e), as a basis for use of the material. As we l
noted its our July 2,1997, letter, the use of Paragraph NCA 1140(e) as a basis for supplying Code material relates only to the use of previously procured and certified material in the construction of items.
We have notsJ inat you havn Jent an inquiry to ASME regarding this issue. Our review of your inquity has determined that it does not addren the following issue. The material supplied by DuBose was certified as being supplied in accordance with the DuDose ASME QSC and Quality Systems ProDram. Both documents require that, for material supplied in accordance with the DuBose QSC and Quality Systems Program, the mill heat analysis be part of the documentation. The ASME issued the QSC based upon the requirements in the DuBose QSC p)(h quality assurance program description, which requires that there be documentation for the mill heat analysis. In order to certify that material complies with the DuBose QSC and Revision 5 of the DuBose Quality Systems Program, the mill heat analysis needs to be available as part of
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Mr. J. Dailey 2-You are requested to provide additional respense to Nonconformance A. Your response should address the above comments and provide a basis for resolution of the certification issue identified in the Nonconformance. - Please provide this information within 30 days from the date of this letter, in accordance with 10 CFR 2.790 of the NRC's
- Rules of Practice,' a copy of this letter will be placed in NRC's Public Document Room.
Sincerely, m.
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/jfA.' 4, Suzanne C. Black, Chief Quality Assurance, Vendor inspection and Maintenance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation Docket No.: 99900861
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