ML18017A688

Forwards AIF Position Paper on Procurement of off-the-shelf Items.Requests NRC Concurrence Re Implementation of Project

ML18017A688
Person / Time
Site:	Harris
Issue date:	11/06/1979
From:	Mcduffie M CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 7911130332
Download: ML18017A688 (9)

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L.Oiled.O RCQVLrCr u00 L I I rC 4 I e.n4I REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIOS)

ACCESS ION NBR:7911130332 DOC 0 DATE e 79/11/06 NOTARIZEO:

NO VAGAL:50-I100 Shearon Harris Nucleai Power Planti Onit ii Carol 50 401 Shearon Harris Nuclear Power P'lanti Unit 2i Carol 50-402 Shearon Harris Nuclear Power Planti Unit 3i Carol AUTH ~ NAME AUTHOR AFFILIATION MCDUFFIEiM~ A, Cai ol ine Power 8 Light Co.

RECIP ~ NAME RECIPIENT AFFILIATION DENTONiH ~ RE Office of Nuclear Reactor Regulation ine ine ina DOCKET 05000400 05000401 05000402 9'b3

SUBJECT:

Forwards AIF position paper on procurement of "Off the-Shelf" items, Requests NRC concurrence re implementation on projects DISIRISUTION CODE:

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@ME Carolina Power & Light Company November 6, 1979 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C.

20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NOS. 1, 2, 3, AND 4 DOCKET NOS. 50-400, 50-401, 50-402, AND 50-403 PROCUREMENT OF'"OFF-THE-SHELF"-"ITEMS

'ear Mr. Denton:

Attached please find a position paper on procurement of "off-the-shelf" items recently issued by the Atomic Industrial Forum Committee on Power Plant Design, Construction, and Operation.

Carolina Power

& Light Compnay (CP&L) has reviewed the paper and finds that it is consistant with previous licensing commitments for procurement quality assurance and that it provides valuable guidance in determining what items can be purchased as "off-the-shelfne Accordingly, CP&L" desires to use this position paper for guidance in procurement of new, as well as spare and replacement parts, for the Shearon Harris Nuclear Power Plant (SHNPP).

However, in order to preclude unnecessary future compliance

problems, CP&L considers it prudent to obtain NRC concurrence with the use of this position paper prior to its implementation on the SHNPP project. It is, therefore, requested that, the NRC review the attached position paper and inform CP&L of its acceptability for use on the SHNPP project.

Since procurement for the SHNPP project is currently on-going, it is requested that this matter be handled as expeditiously as possible.

Yours very truly, M. A. McDuffie Senior Vice President Engineering

& Construction MAM/jcb Attachment cc:

Mr. V. Stello Mr. J.

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POS ITION PAPER ON P ROCUREMENT OF "OFF-THE-SHELF" ITEMS PURPOSE The purpose of this paper is to identify, genericallyi which safety related spare and replacement parts may be purchased by a utility as "off-the-shelf" items'or use in systems and components during the start-up and opera-tions phases of a nuclear power plant.

BACKGROUND Since the publication of Appendix B of 10 CFR 50, many control systems for procurement of safety related equipment have been developed.

These systems are so diverse that it is difficult to realize that they are all trying to accomplish the same thing Quality.

Nowhere is this diversity as apparent as in the area of safety related spare and replace-ment parts.

For example, a bearing for a safety related motor might be ordered as a "shelf" item from a.non-qualified vendor by one utility.

Another utility might order the identical item )with one or more of the following controls:

qualified vendor, dimensional certification, certification of compliance, receipt inspection, material identification tagging, and verification of part at point of use.

DEFINITIONS l.

Off-the-shelf items are commerical grade items which:

(a)

Do not have unique design or specification requirements wherein the item iaianufac urer must perform a separate or special operation or test to qualify-the item for use in faci-lities licensed by the NRC.

The item may be available off-the-shelf with generic test doc-umentation for equipment or seismic qualifica-tion as part of the manufacturer's published specification.

(b)

(c)

May be used in applications other than faci-lities or activities licensed by the Nuclear Regulatory Commission.

May be ordered from the manufacturer, distributor, or retailer solely on the basis of the manu-facturer's published specifications.

2.

Normal procurement controls are those inspection controls which a given utility exercises over its day-to-day non-safety related procurement activities for its nuclear facilities.

3.

Quality is "fitness for the service intended."

4.

Quality control are those quality assurance

'actions which provide a means to control and measure the charactoristics of spare and replacement parts to established requirements.

POSITION STATEMENT In order to provide a guide for consistent procurement practices, the following identifies, generically, those spare and -replacement parts that may be purchased as "off-the-shelf".items for use in safetv related systems and components of operating nuclear power plants when special nuclear design or specification requirements were not applied to the original part:

A.

Items which may be purchased "off-the-shelf" using normal procurement controls:

Individual electronic components such as resistors, capacitors, transistors, inte-grated" circuits, etc.

Use of these items in safety related modules shall. be limited to replacement of like items.

Substitutions may be made in accordance with published in-

.dustry substitution guides or standards if a postmaintenance check verifies the accept-ability of the sub'stitution'.

This may include items at the safety related "module" level such as standard printed cir-cuit boards, standard transformers or standard manufactured components or. assemblies desig-nated commercial grade in the plant specifi-cations which are manufactured to a published manufacturer's specification and can be iden-tified by a catalog or-part number which is not unique to a user's'specification.

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Generic qualification'nd seismic testing for these items is acceptable,;providing it is documented and certified by the manufacturer/

supplier and that it envelopes the qualification or seismic criteria for the particular plant where it is to be installed.'

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This does not include unique items at the safety related "module" level such as non-standard printed circuit boards, specially wound transformers or unique components and assemblies.

Zt does not in-clude items for which plant specifications require qualification or seismic testing more stringent than the manufacturer's generic published qualification or test information which is part of a manufacturer's specification.

2.

Bearings, gaskets, packing, bolting material (other than pressure retaining), 0'rings, springs, fittings (other than pressure retaining), seals, handwheels, etc. which are classified as Commercial Grade and purchased in accordance with normal procurement con-trols.

Substitution of manufacturers may be made in accordance with published industry-crossreference charts-if the replacement items meet the same cata-log specification.

3.

Replacement parts listed as catgeories 7 and 8 in ASME Boiler and Pressure Vessel Code Case N-62-2 (1621-2) and category 6-in ASME Boiler and Pressure Vessel Code Case N-119 (1739-1).

4.

Standard, catalog equipment used to conduct calibra-tions where this equipment is calibrated or calibra-tion checked prior to initial use.

5.

Individual electrical components such a's breaker

contacts, relays, springs, lamps, etc. that were originally purchased as'atalog items.

Use of these items in safety related systems is the same as

-A.l.

B.

Parts which may be= purchased "off-the-shelf" from the manufacturer, distributor or retailer of the original

'quipment provided that; (1) the supplier is qualified according to the utility's Quality Assurance program and (2) the parts can be ordered by catalog number, part

number, assembly number, or by manuf acturer '

speci-fication:

1.

Replacement parts listed as category 5, Class 2

and 3 of ASME Boiler and Pressure Vessel Code Case N-119 (1739-1).

2.

Non-Pressure Boundary parts which have been quali-fied by type for a particular safety related application and which will be tested to design conditions at receiving inspection or after in-stallation but prior to service.

-This includes

complete breaker assemblies or sub-assemblies',

and major parts for equipment such as diesel generators,

motors, and steam turbines.

3.

. Xf safety-related parts are to be purchased "off-:the-shelf" from other; than the original manufacturer, these parts would have to be verified by utility owners Engineering to perform an equivalent safety-related function.