ML20246L354
| ML20246L354 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1989 |
| From: | Brach E Office of Nuclear Reactor Regulation |
| To: | Blankenship W MQS INSPECTION, INC. (FORMERLY MAGNAFLUX CORP.) |
| References | |
| REF-PT21-89-032-000 PT21-89-032-000, PT21-89-32, NUDOCS 8903240155 | |
| Download: ML20246L354 (2) | |
Text
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NUCLEAR REGULATORY COMMISSION E.
WASHING TON, D. C. 20555
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W. G. Blankenship Director of Quality Assurance MQS Inspection, Inc.
2301 Arthur Avenue Elk Grove Village, Illinois 60007-6098
Dear Mr. Blankenship:
SUBJECT:
10 CFR 21 INQUIRY We have reviewed your. letter of January 9,1989, concerning imposing 10 CFR Part 21 on suppliers of calibration services.
In response to your specific example, 10 CFR Part 21 would not have to be passed down to the company calibrating the shunt-meter test set provided its only purpose is to verify the accuracy of the ammeter on your magnetic particle testing machine. Since the field indicator and not the ammeter is depended on to assure an adequate magnetic field exists to perform the inspection, improper calibration of the ammeter cannot create a substantial safety hazard.
However, from a general perspective, the answer to your question is not as straight forward. The general issue is addressed in 10 CFR Part 21 and other guidance issued by the NRC. Paragraph 21.31 of 10 CFR Part 21 requires that procurement documents for basic components impose the requirements of 10 CFR Part 21. Paragraph 21.3(a)(3)statesthatbasiccomponentsincludedesign, inspection, testing, or consulting services important to safety that are associated with comp (Questions and Answers Discussed) at Public Regional onent hardware.
In addition, in NUREG-0302, Revision 1,
" Remarks Presented Meetings to Discuss Regulation (10 CFR Part 21) for Reporting of Defects and Noncompliance," this issue is addressed in Question 5, under paragraph 21.3(a),
i
" Basic Component,." Question 5 asks:
"Does Part 21 also apply to suppliers of i
consumables such as welding material and services such as calibration?" The response given is:
"Yes.
Where the consumable or calibration service is related to a basic component and a deviation from specified requirements of a procurement document or failure to comply, could create a substantial safety hazard."
Paragraph 21.3(k) defines substantial safety hazard as a loss of safety Tunction to the extent that there is a major reduction in the degree of protection provided to public health and safety for any facility or activity licensed, other than for export, pursuant to Parts 30, 40, 50, 60, 61, 70, 71, or 72 of this chapter. Therefore, if a deviation in the calibration could I
create a substantial safety hazard,10 CFR Part 21 must be imposed on the company performing the calibration. As you can see, a determination whether 8903240155 890317
N W. G. Blankenship.
l 10 CFR Part 21 must be imposed requires a detailed review of the type of instrument being calibrated, its function, and the effect of an inaccurate i
calibration.
l Therefore, in response to your question if 10 CFR Part 21 applies to suppliers l
who verify the accuracy of test equipment and standards traceable to a national j
standard the answer is sometimes. Whether the answer is yes or no does not depend on how the test equipment or stanaard was purchased, i.e., commercial j
grade, but on what the equipment is used for and whether a deviation in 1
calibration could create a substantial safety hazard.
In closing, while your position that the calibration of the shunt-meter test set does not require imposition of 10 CFR Part 21 is correct, the basis used, i.e., test standards are conrnercial grade items, is not acceptable and should not be used as a basis for not imposing 10 CFR Part 21 on services for calibrating other standards.
If you have any further questions concerning this subject, please feel free to contact either Edward Baker on (301) 492-0959 or Robert Pettis on (301) 492-3214 of my staff.
Sincerely, Originalsignedby:
E. William Brach, Chief Vendor Inspection Branch Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION:
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- MOS Inspection, Inc. l Corporate Office l 230i Arthur Avenue l Elk Grove Village, IL 60007-6098 [ 312 981-8777 l i
800 638-5227 1
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.L January 9, 1989 i
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Brian Grimes Director, Division of Reactor Inspection and Safeguards l
M/S 9-E-3 l
U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
10 CFR Part 21 Requirement Inquiry l
Gentlemen:
Background:
MQS Inspection, Inc. provides services for perform-ing nondestructive examinations.
These services are provided to a wide variety of clients in all industries. All equipment, materhls, and service's purchased by MQS Inspection, Ila. are commercial grade items as defined in 10 CFR 21 paragraph
- 21. 3 (4 ) ( A-1).
The accuracy of the NDE equipment is verified by test equipment and standards trace-able to a national standard.
All equipment is calibrated in accordance with the applicable code or standard prior to use.
Question:
Does Part 21 apply to suppliers who verify the accuracy of test equipment and standards traceable to a national standard?
Examplc:
A supplier is contracted to verify the accuracy of a shunt-meter test set.
The standard used to verify the accuracy of the test set is traceable to a national standard.
The test set is used by MQS Inspection, Inc. to verify the accuracy of an ammeter on a magnetic particle machine.
The adequacy and direction of the magnetizing field produced by the machine is verified by MQS using a field indicator (a national standard).
The magnetic particle machine may bc used to inspect a basic component.
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e U.S. Nuclear Regulatory Commission Page t o January 9, 1989-J MQS Position:
Part 21 does not apply to suppliers who verify the j
accuracy of test standards to a national standard if the test standards are commercial grade items as defined in 10' CFR 21 paragraph 21.3 (4) (A-1).
Justification:
10 CFR 21 paragraph 21.7.
Very truly yours, MQS INSPECTION, I C.
si J W.
G.
Blankenship Director of Quality Assurance I
.