ML20006B462
| ML20006B462 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1987 |
| From: | Partlow J Office of Nuclear Reactor Regulation |
| To: | Roe J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20006B459 | List: |
| References | |
| FOIA-89-482 NUDOCS 9002020246 | |
| Download: ML20006B462 (5) | |
Text
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/'p3 ca s t.'o UNITED STATES
'l' NUCLEAR REGULATORY COMMISSION n
f WASHINGTON, D C. 20666 t.
l g
September 16, 1987
- s., e... *,a LEMORANDUM FOR:
Jack W. Roe, Director Division Licenste Performance and Quality Evaluatics Office cf Nuc1thr Reactor Regulation FROM:
Janes G. Partlow, Director Division of Reactor Inspection and Safeguarcs Offict of Nuclear Reactor Regulation
SUBJECT:
CCNMENTS ON LRAFT INSPECTION GUIDANCE ON C0FriERCIAL GRADE PROCUREMENT As requested by your August 4,19E7 tremo, we have reviewed the draft inspection guidance.
In general we believe that the guidance cculo be improved by more consistent use of terms, more accurate reflection of NRC positions concerning use of cor.rcercial grade items and more focus on an indepth review of commercial grade program implementation. Specific coninents are provided in the enclosure.
I understand that the lead on comercial grade matters is to be shifted to the Vendor Inspection Branch, DRIS, so we would like to be on concurrence for the final version of this guidance.
If you have any questicns, plerse contact either Ed Baker (492-47E3) or Ellis Merschoff (492-9664).
James
. Fa
, Director Divis on of R(actcr Inspection and Safeguards Offic'e of Nuclear Reactor Regulation i
i 9002020246 900330 N LIA g-4B2 F
SoptGmb3r-16, 1987 Jack L'.
Roe
-E-I As reo,uested by your August 4,1987 memo, we have reviewed the draft inspection guidance.
In general we believe that the guidsnce could be it..preved by tr. ore consistert use of terms, more accurate reflection of NRC positions concerning ',se of ccmercial grade iterrs and rore fccus on an indepth review of corrcercial grade prograrr implerar.tation.
Specific comer,ts are provided it. the enc 1csure.
I ur.derstand that the lead on corarrercial grace tatters is te be shiftsc to the Vendor Inspection Branch, DRIS, so we would like to be on concurrence for the fir >al version of this guidance If you have any questions, please contact either Ed Baker (49E-47E3) or Ellis Merschoff (492-9664).
ORIGINAL SIGNED BY:
JAMES G. PARTLOW James G. Partlow,_ Director Division of Reactor Inspection and Safeguards Office of Nuclear Reacter Regulation DISTRIBUTION:
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Detailed Ccncents On Draft Ir.spection Guidance On Concercial Grade Procurement 1.
Under " Background," sixth line, the TI uses the terc qualification criteria.
The use of this terminology will confuse pecple. The NRC has traditier. ally used the term qualificaticn in the content of seistic and environmental qualification. The sentence should be revised to reed, "... no censistent criteria fer determining an item's suit 6bility for its intended application has been established."
2.
Under " Background," tenth line, the TI states that current problems are a result of "... a lack of operations procurement guidance." This is not correct. The problem is a result of licer sees failing to realize that replacen.ent items have an impact on the ability cf a component or system to perform their safety function and a lack of engineering evaluation of replacement items purchased as ccmcrcial grade.
3.
Under " Background," the last sentence should be deleted. The ir.spection program cannet bc used to provide guidance to utilities as is implied by this sentence.
4 Under " Inspection Requirements," the first sentence implies that the evaluation of the procurement of comercial grade parts can be extrapolated to ccver the entire procurement program. This is oct an ap;;ropriate extrapolation.
5.
The second senunce under " Inspection Requirements' states that the inspection will cover the procurement program from initial selection to installation..
hchever, none on the fcur t,ullets which fc11cw accress reviewing insta11aticn cr post-ir.sta116tien testing.
E.
Paragraph 04.02.a states th6t the inspector shoulc perform a cursory review cf the implerenting prccedures.
In order to rencer any judgnant of the prccurement progret an indepth review must be perfcrmed.
7.
The inferr.ution ur. der paragraph 04.02.d should be deleted in its ertirety.
It provides no guidance to the inspectors as to what is an acceptable practice. The second paragraph stresses'the form of the program i.e., where in the process engineering should be done, rather than the adequacy of the engineering efforts. Additientily, it leads the inspcctors to the conclusicn that it is not acceptable to do an engineering evaluation after the item is procured. While this is not the preferred way of doing it, it is accep-table. The seven asterisked criteria under paragraph 04.02.e shculd apply to 04.02.d as well, 8.-
Paragraph 04.02.e states that the designation of a comercial grade item is a design change. This is an incorrect statement ard has no regulatory basis.
As icng as all the performance characteristics are the same, including seismic and environmental characteristics, it is not a design change. Purchasing
_ _ _ 1 ccu.ercial grade items has sir.: ply shifted thf. burcen of ccrplier.c6 from the supplicr/masufacturer to the customer. Additier. ally, this paragraph uses j
the term, "designatiorf wher, in fact it is ciscussing determinifig an itein's suitability f or. its intended fur.ction. Changing terms will only confuse the user of the TI.
Consistent use of tern.inology is' essential when providing guioance in a rew area.
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