ML19318A273
| ML19318A273 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick, Robinson  |
| Issue date: | 05/23/1980 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Mcduffie M CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8006190126 | |
| Download: ML19318A273 (2) | |
Text
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UNITED STATES hj, NUCLEAR REGULATORY COMMISSION 7,.
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MAY 2 31980 Mr. M. A. McDuffie Senior Vice President Engineering & Construction Carolina Power & Light Company P.O. Box 1551 Raleigh, NC 27602
Dear Mr. McDuffie:
SUBJECT:
PROCUREMENT OF "0FF-THE-SHELF" ITEMS Your letter of March 18, 1980 (received by us on April 16, 1980) indicates that it is your understanding that NRC is in general concurrence with CP&L's approach of applying the AIF position paper for the procurement of "off-the-shelf" items.
Fur-ther, your letter indicates that " procedures would be available to implement the off-the-shelf procurement program" and that these procedures would contain specific guidance on classification of the item and the level of controls to be applied.
In our meeting with your representatives on January 18, 1980, we indicated that the AIF position paper expressed quality assurance requirements for "off-the-shelf" spare and replacement parts in far too ger.eral terms. Also, no consideration was given to grading quality assurance requirements in accordance with the importance to safety of the item.
It appeared possible to us that a safety-related item could be clas-sified as "off-the-shelf," thereby permitting the by-passing of important quality controls such as pre-award surveys, supplier audits, and receipt inspection / testing to assure conformance to requirements for safety.
For example, an actuator for a FORV would be classified as off-the-shelf and could be procured and installed without the quality controls we believe are appropriate for such an item. The AIF position paper also did not provide a clear definition of off-the-shelf items.
You indicate that procedures would be available to implement the off-the-shelf pro-curement program and that guidance would be contained within the procedures to require the procuring engineer to determine the level of quality controls to be applied to the item. Prior to our arriving at a decision regarding your request, we would need to review the procedures / guidance to be utilized for this process, or, at a minimum, the criteria you propose to adopt for development of the procedures / guidance.
In summary, we do not concur with the CP&L approach for procuring off-the-shelf spare and replacement parts based on the information provided to us to date. Our position in this reghrd continues to be:
" Procurement of spare or replacement parts for struc-tures, systems, and components important to safety is subject to present QA program controls, to codes and standards, and te technical requirements equal to or better than the original technical requirements, or as required to preclude repetition of defects." While it may not be practicable to ir.cose the necessary QA controls on the supplier cf an off-the-shelf item, we do require the procuring organization or user to establish and implement the QA controls necenary to assure the adequacy of the item in its safety-related application.
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Mr. M. A. McDuffie' MAY 2 31980 Should-you' desire, we will be pleased to discuss this further with you at your convenience.
Sincerely.
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