ML20011F600
| ML20011F600 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/1990 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | Marion A NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| GL-89-02, GL-89-2, NUDOCS 9003070022 | |
| Download: ML20011F600 (3) | |
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February 27, 1990 z
u MrJ Alex Marion Manager, Technical Division Nuclear Management and Resources Council
. 1776 Eye Street N.W.
Suite 300 Washington, D.C.
20006
Dear Mr. Marion:
We have reviewed your letter to Mr. Frank Miraglia of January 30, 1990, and 1
have:a number of comments to offer on your proposed position paper on " critical characteristics." We certainly agree that the NRC and the nuclear industry need to have more dialogue to clearly communicate expectations and understandings on regulatory issues such as commercial-grade procurement and dedication programs.
We offer the following comments relative to the proposed position paper:
1.
NRC's endorsement of EPRI NP-5652 in Generic Letter 89-02 specifically stated that the " guidelines, as modified below, establish methods which satisfy existing requirements." The generic letter endorsement was not meant and should not be construed to imply any new requirements.
t 2.
The term " critical-characteristics" is not contained in Appendix B.and has no special regulatory significance beyond its use and definition in
'various-industry guides / standards or as defined in licensee programs.
3.
NRC has not taken the )osition that "all" important design requirements' i
must'be considered to >e critical characteristics as used in:EPRI NP-5652, 1
Rather, NRC has;always taken the position as stated in Appendix B, Criterion III, that licensees must assure the suitability of all parts materials, and services for their intended safety-related application.
The design documents should establish the critical design, material, and performance characteristics for each part, material, and service intended forl safety-related application. - The licensee is responsible for 1
identifying these characteristics and assuring the conformance of items to
'these characteristics. There is no minimum or maximum number of critical characteristics.
Further, the critical characteristics for an item may vary from application to application depending on the design and performance requirements unique to each application.
4 The definition of critical characteristics contained in the EPRI guideline is adequate. However, it is clearly not the intent of the EPRI guideline to permit the purchaser to order a commercial grade part by the catalogue
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-I Mr. Alex Mari,on 2-February 27, 1990 number, to verify acceptability by comparing to the catalogue description that "the item received is the item specified" and, on that basis, consider the part suitable for safety related service. There has been much apparent i
confusion in the identification and selection of critical characteristics.
I We believe that, consistent with comment 3 above, the specification for an item should include those performance characteristics that the licensee has determined essential for assuring suitability of the item for its safety function. This specification may or may not become a part of-the purchase order, but the critical characteristics identified therein need to be verified as a part of the dedication process.
5.
Licensees need to exercise care in determining when commercial. grade pro.
1 curement and dedication is appro>riate. The critical characteristics to be verified need to be identificile and measurable. Many items, for example, molded case circuit breakers, have easily identifiable charac.
teristics which may not be readily measurable or verifiable by the licensee.
In such cases, the licensee needs to consider other alter-natives such as procuring the item as a safety-related vendor product, or using commerical grade audits as a part of the dedication process.
As you suggested, I believe it would be beneficial fcr you and nty staff to meet
'l to discuss these comments and concerns on procurement and dedication programs.
I have asked Bill Brach to contact you to arrange a meeting on this topic at your convenience.
Sincerely, 3
Original signed by Brian K. Grimes i
Brian K. Grimes, Director Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION Centr,e M iles JRichardson PDR AThadani VIB Reading JRoe DRIS Readin9 ERossi FJMiraglia BKGrimes EWBrach
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IATE :02/ /90'
- 02h,7/90 OFFICIAL RECORD COPY Document Name: LTR TO ALEX MARION
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Mr. Alex Marion February 27, 1990
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number, to verify acceptability by comparing to the catalogue description that "the item received is the item specified" and, on that basis, consider the part suitable for safety-related service. There has.been much apparent confusion in the identification and selection of critical characteristics.
We believe that, consistent with comment 3, above, the specification for an item should include those performance characteristics that the licensee has determined essential for assuring suitability of the item for its-safety function. This specification may or may not become a part of the purchase order, but the critical characteristics identified therein need to be verified as a part of the dedication process.-
5 Licensees need to exercise care in determining when commercial-grade pro-curament and dedication is appro)riate. The critical characteristics to be verified need to be identifia)1e and measurable. Many items, for example, molded case circuit breakers, have easily identifiable charac-teristics which may not be readily measurable or verifiable by the licensee.
In such cases, the licensee needs to consider other alter.
natives such as procuring the item as a safety-related vendor product, or using commerical grade audits as a part of the dedication process.
As you suggested, I believe it would be beneficial for you and my staff to meet to discuss these comments and concerns on procurement and dedication programs.
I have asked Bill Brach to contact you to arrange a meeting on this topic at your convenience.
Sincerely, Original signed by Brian K. Grimes Brian K. Grimes, Director Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation DISTRIBUTION Central Files JRichardson PDR AThadani VIB Reading JRoe DRIS Reading ERossi FJMiraglia BKGrimes EWBrach-
- Previously concurred
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NAME
- EWBrach:nrp
,1-DA 1
0FFICIAL RECORD COPY Document Name: LTR TO ALEX MARION
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