ML18030A214
| ML18030A214 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/11/1981 |
| From: | Curtis N PENNSYLVANIA POWER & LIGHT CO. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| ER-100450, IEB-79-01B, IEB-79-1B, PLA-636, NUDOCS 8102230609 | |
| Download: ML18030A214 (6) | |
Text
~~e REGULATE INFORMATION DISTRIBUTION
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ACCESS IO'I NUR: 8102230609 0 JC ~ DATE: 81/02/11 NOTARIZED:
NO DOCKET FACIL;50-3~7 Susquehanna Steam Electric Stationr Unit 1r Pennsylva 05000387 50-388 Susquehanna Steam Electric Stationr Unit 2r Pennsylva AUTH'AYtE AUTHUR AFFILIATION CURTISEN ~ isr ~
Pennsylvania Power 8 Light Cod REC IP, VAMh RECIPIEN I AFFILIATION YOUIVGBLOOOEB.J.
Licensing Branch
SUBJECT:
Provides revision to rept re environ qualification of Class IE equipmentrsection 2E re procurement of spare parts to be d>scussed at vRC tr10224 meetina,Lists steps to be taken for olocurement of spar'e or replacement pal ts, 0ISTRISUTION CODE:
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PPaL TWO NORTH NINTH STREET, ALLENTOWN, PA. 18101 PHONEr {215) 770-5151 NORMAN W. CURTIS Vice President-Englneertng 8 Construction-Nuclear 770.5381 February ll, 1981 B. J. Youngblood, Chief Licensing Branch No.
1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docket Nos.
50-387 50-388 SUSQUEHANNA STEAM ELECTRIC STATION CLASS IE SPARE PARTS QUALIFICATION ER 100450 FILE 843 PLA-636
Dear Mr. Youngblood:
The following is a revision to Section 2E of Pennsylvania Power and Light Co.'s Environmental Qualification of Class 1E Equipment Report.
This revision is our position on procurement of spare parts which we will discuss with you at the February 24, 1981 meeting.
PPGL intends to comply with the provisions of the May 23, 1980 Memorandum and Order CLI-80-21, including the section that covers spare and replacement parts and states "unless there are sound reasons to the contrary, the 1974 standard in NUREG-0588 will apply".
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,/8 Following consideration of this provision we have concluded that the protection of the health and safety of the public and PP6L employees will be maximized by use of an identical replacement or spare part where ever possible.
Use of non-identical spare or replacement
- parts, whether or not they are qualified to NUREG-0588 Category I, raises serious questions concerning the compatability of the items used, and may result in added confusion and decreased human factors effectiveness due to non-standardization of equipment.
In addition the use of identical spare and replacement p'arts will insure qualification of all identical parts to at least NUREG-0588 Category II, by June 30,
- 1982, through the qualification of all Class IE equipment, as required, by the May 23, 1980 Memorandum and Order and the IE Bulletin 79-01B Supplement 2
by our ongoing qualification program.
aug~
PENNSYLVANIA POWER 8L LIGHT COMPANY 8aao cog,
Mr. B. J.
Youngblood Page 2
February ll, 1981 Therefore, a reasonable effort will be made to procure identical replacement or spare parts qualified to the 1974 standard in NUREG-0588, or to some lesser degree where a part qualified to NUREG-0588 Category I, cannot be readily obtained.
If an identical part cannot be obtained, we will procure a non-identical functionally and physically equivalent part.
This non-identical part shall be obtained qualified to NUREG-0588 Category I, where possible, or to some lesser
- standard, where an item qualified to NUREG-0588 Category I cannot be obtained.
If a non-identical part is procured, it'hall require an engineering justification and shall be traced through warehousing and installation, until questions concerning the qualification and compatability have been resolved and documented."
In accordance with this philosophy, the following steps are being taken when purchasing Class IE spare or replacement parts.
These steps constitute our present perception of a reasonable effort.
1)
Ask the supplier or suppliers (if this is the normal procedure in a given case) to supply an identical item that is qualified to NUREG 0588 Category I.
- 2) If the supplier in step 1 is not the original manufacturer or supplier under the original Bechtel Purchase
- Order, and he cannot supply an identical part qualified to NUREG-0588 Category I, a parallel effort shall be made to obtain an identical part qualified to NUREG-0588 Category I, from the original manufacturer or supplier.
This effort shall be documented and may take the form of a telephone conversation, letter, meeting minutes, etc., at the option of the purchasing organization.
Note:
Zf a qualified item cannot be obtained through step 1, then step 2 must be undertaken only if it has not been accomplished for the specific item in question for a period of 1 year prior to the date of the request for quotation or the date of the purchase order (whichever occurs first).
- 3) If an identical part qualified to NUREG-0588 Category I cannot be
- obtained, an attempt will be made to buy the identical part with the best qualification the supplier or suppliers may have.
Two things should be noted:
a) it is permissable for the purchasing organization to request, as part of step 1, that a supplier or suppliers provide (or quote) an identical part with Category I qualification or whatever qualification is the best the supplier(s)
- has, provided that step 2
is undertaken upon notification that a Category I part is not being supplied (or quoted) and (b) the purchasing organization may, at its option, extend this step to suppliers not included in steps 1 and 2.
Mr. B. J. Youngblood Page 3
February ll, 1981 4)
Tf an identical part cannot be obtained using steps 1,
2 and 3, then the supplier(s) shall be requested to provide a non-identical functionally and physically equivalent part qualified to NUREG-0588 Category T,
or to the highest standard the supplier has available.
Any parts obtained using this step (i.e.
any non-identical parts) require engineering justification and shall be tracked through warehousing and installation until questions concerning qualification and compatability are resolved and documented, or the item is replaced by a part identical to that originally used.
Very truly yours, 4145 N. H. Curtis Vice President-Engineering and Construction-Nuclear CTC/mks cc:
R. M. Stark NRC
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