ML20246E171
| ML20246E171 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1989 |
| From: | Brach E Office of Nuclear Reactor Regulation |
| To: | Windt W TEXAS BOLT CO. |
| References | |
| REF-QA-99900888 NUDOCS 8907120131 | |
| Download: ML20246E171 (3) | |
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' Docket No..: 9990088u/88-01 Mr. W. E. Windt
.Vice President of Nuclear Texas Bolt Company Post Office Box 1211 Houston, Texas 77251-1211
Dear Mr. Windt:
Thank you for your letter of February 6,1989, in response to our letter, dated December 16, 1988. We have reviewed your reply and have determined that several of your responses-do not adequately address. the concerns raised in our address the Notice of Violation (88-01-01) specifically, your response did not Notice of Violation and Nonconformance. S provided in Appendix A of our report..You are required to respond to the Notice of Violation as specified in our December 16, 1988 letter.
In addition, the results of our review of your response to our Notice'of Nonconformance are as follows:
(88-01-03) - Response incomplete. TexasBolt's(TB)responsedidnot address our concerns regarding review of qualifications of subcontractor personnel.
(88-01-05)- Not responsive. Section 7.1.b of the TB Quality..
System Manual (QSM) states that TB will only purchase material from approved suppliers. Section 7.2 of the QSM-specifies how suppliers may be qualified. Although sub-item d. allows purchasing unqualified material for qualifi-cation by TB, the supplier is still required to be on the approved vendors list. Further, in order for TB to certify material made from stock produced by a manuf acturer whose Quality System Program has not been qualified under NCA-3800, TB must comply will all the requirements of NCA-3867.4(e),
including affirming through certification that all chemical analysis, test, examinations, and treatments are in comp-11ance with the material specification and Section III.
For material one inch in diameter and under, sold with a Certificate of Conformance, NCA-3867.4(e) does allow TB to upgrade material based on testing of a sample from each heat.
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-2 June 29, 1989 However, for material exceeding one inch in diameter, each piece of stock material is required to be tested.
(d) - Not responsive. The QA manager's responsibility for purchasing was not reflected in the T8 organization chart which was available at the time. Paragraph 1.2 of the QSM requires quality system personnel to be sufficiently independent. Please clarify your response with regard to the requirements of paragraph 1.2.
(88-0108) - (a) - Further clarification of your response is needed.
Paragraph 2.4 of the QSM states, "QS personnel will have sufficient and well defined responsibility, including authority and organizational freedom to:
(1) identify quality system problems; (2) initiate action which results in solutions; and (3) verify 1
implementation of solutions to these problems."
Training in visual inspection only does not comply with these goals.
l (b)-Notresponsive. Your response since it does not comply with the requirements of paragraphs 1.4, 1.6, and 2.1 of your QSM. The QSM policy statement indicates the program is applicable "...to all personnel engaged in the manufacture of these products", and is not limited to final inspections completed by' the QA department as you suggest.
(c).ResponseisacceptedregardingthePresidentandSales personnel. The response is not responsive regarding the production supervisors because of the reasons stated in 88 01-08(b) above.
We have no further questions with repect to those responses not listed above.
Please provide this additional information within 30 days of receipt of this letter.
Sincerely, l
Original signed by E. William Brach E. William Brach, Chief Vendor Inspection Branch Division of Reactor Inspection q
and Safeguards Office of Nuclear Reactor Regulation
[MR. W. E. WINDT - TEXAS BOLT] *PREVIOUSLY CONCURRED.
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DATE :05/25/89
- 06/13/89
- 06/23/89
- 06/16/89 0FFICIAL RECORD COPY l
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