ML20031C739
| ML20031C739 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1981 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Doty R GRAYBAR ELECTRIC CO, INC. |
| References | |
| NUDOCS 8110080258 | |
| Download: ML20031C739 (3) | |
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4 DISTRIBUTION: w/o attachment UCentral File SEP 0 21981 NRC PDR A.
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Hr. Robert E. Doty, Assistant Secretary WJohns ton, DE ~h "MsE^"" - ~
Graybar Electric Company, Inc.
JSpraul, QAB 420 Lexington Avenue f
New York, NY 10170 g
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Dear Mr. Doty:
In your letter dated July 31, 1981, you provided some background material concerning Graybar Electric Company and its position as a national distributor of electrical equipment and supplies to various industries including those involved in nuclear power plants. You requested infomation regarding the quality assurance that NRC would expect of a distributor such as Graybar Electric Company for " safety related" items used in nuclear power plants.
To begin with, some background relative to the infomation you seek may be useful.
l Title 10 of the Code of Federal Regulations, " Energy," contains the regulations of r
the Nuclear Regulatory Commission, including Appendix B to Part 50 of Chapter 1 of Title 10 which is entitled, " Quality Assurance Criteria for Nuclear Power Plants and i
Fuel Reprocessing ?lants." Appendix B establishes quality assurance requirements for the design, construction, and operation of safety related structures, systems, and components, i.e., those that prevent accidents or mitigate the consequences of acci-i dents that ould cause undue risk to the health and safety of the public. The regu-lations require that the pertinent requirements of Appendix B apply to all activities i
affecting the safety related functions of those structures, systems, and components including designing, purchasing, fabricating, handiing, shipping, storing, etc.
Quality assurance is defined in Appendix B as "all those planned and systematic ac-tions necessary to provide adequate confidence that a structure, system, or compo-nent will perform satisfactorily in service."
You state in your letter that you have been unable to determine precisely what the Comission or its regulations expect of distributors such as Graybar.
I appmciate your dilema since Appendix B is quite general and is directed primarily to designers, constructors, and operators of nuclear power plants; little guidance has been prc-vided by the NRC for the distribution activity in which your company is engaged.
The following should provide some assistance to you in this regard.
In its review i
of quality assurance programs for nuclear power plants, the NRC focuses its atten-tion on the applicant for a construction permit or operating license; namely, the utility - and its major contractors - the reactor vendor, the architect engineer.
l and the constructor. The NRC regulations require these organizations, in turn, to
" pass on" to their various subcontractors, vendors, and suppliers the pertinent requirements of their quality assurance programs depending upon the significance to safety associated with the specific item or service to be provided. These per-tinent mquirements should be identifled in purchase documents by your customer and,
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for Graybar's activities, may include the following typical examples, in addition to others, which were extracted from Appendix B to 10 CFR 50:
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To the extent necessary, procurement documents shall require...a quality ass urance program....
" "c'>..,... Acttv4 ties.af.fecting quali.ty..shall a prescr.ibed.... and..shall. ba.accomplishec............. ~...
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t fir. Robert E. Doty SEP 0 21981 Measures shall be established to assure that purchased material (and) equip-ment... conform to the procurement documents.... Documentary evidence that ma-terial and equipment confom to the procurement requimments shall be avcil-able....
Measures...for the identification and control of... components...shall assure that identification...is maintained....
Measures shall be established to control the handling, storage, (and) ship-ping...to prevent damage or deterioration.
Sufficient records shall be maintained to furnish evidence of activities af-fecting quality.
Your letter indicates that most of the items you sell are what we would categorize as " commercial grade items." An item characterized as a comercial grade item sat-isfies the following criteria:
a.
Ilot subject to design, specification, or supplier testing requirements unique to nuclear power plants, b.
used in applications other than nuclear power plant applications, and c.
ordered on the basis of specifications in the supplier's published pro-duct description (for example, catalog) or manufactured to national stan-dards.
For these items, the purchaser (your customer) must typically see to it that the item is inspected and tested af ter receipt to assure that:
(1) damage was not sustained during shipment, (2) the item received is the item ordered (i.e., the item is properly identified and corresponds to the identification on the purchase order and on the re-cciving documentation),
(3) documentation, as applicable to the item, was received and is acceptable, and (4) the item will perfom its intended function as determined by further accep-tance testing / inspection (i.e., special quality verification shall provide the necessary assurance of an acceptable item).
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As the distributor of these items, Graybar would normally be involved in implementing l
(2) and (3) above at shipment unless the items move directly from the manufacturer to 1
l your customer.
For the latter case, Graybar should require the manufacturer to imple-i l
ment (2) and (3) above.
For non-commercial grade items, the purchaser may specify l
additional quality assurance requirements.
The tecnnd anos of your letter asks fn7 a ruling nr guidance nn tf ran enncific aninto o-*. 3.*.?.9 f".t5 '. ".. ' P ' ' t ' d . " >. f 1. ".
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4 Mr. Robert E. Doty SEP 0 2 G81 1.
The need for a distributor to have a fomal " Quality Assurance Program."
Response: A distributor's Quality Assurance Program for items procured per 10 CFR 50 Appendix B should reflect the pertinent requirements of 10 CFR 50 Appendix B.
It should be " formalized" to the extent required to satisfy the distributor and its customers that the pertinent requirements of Appendix B are met on orders involving safety related items.
2.
Our recordkeeping responsibilities, if any.
Response: Any recordkeeping resp 3nsibilities over and above good business practice would be specified by your customer, but should satisfy the pertinent requirements of Appendix 8.
3.
The exhnt to which distributors are expected to certify product confomance or compliance wi th nuclear regulations.
(You note that Graybar has complied with customers' requests to verify material delivered as that which the cus-tomer ordered.)
Response: A distributor is expected to certify product confomance or com-pliance with NRC regulations of itenn for which he has firsit hand knowledge.
The distributor should certify not only to the accur-acy of the purchasing infomation but also to the identification of the delivered item.
For an item which moves directly from a manufacturer to a customer, the distributor would require the manu-facturer to certify product confomance.
In summary, documentation provided by the purchaser should identify the 'qua ity assurance requirements to be met by the supplier for the requested safety related items consistent with Appendix B to 10 CFR 50. These requirements should be satis-fled by a quality assurance program maintained by the supplier. / t a minimum, these requirements implemented by the r.upplier for connercial grade items should include documented evidence that the item is properly identified, that the item corresponds to the identification on the purchase order, and that the item is accompanied by the proper documentation.
For non-commercial grade items, additional quality assur-ance requirements may be necessary as specified by the purchaser.
I hope this letter provides the information you are seeking.
If further clarifica-tion or discussion is mquirod, please cal'. me or Jack Spraul of my staff on (301) 492-7741.
Sincerely,
Original signed by Walter P. Haass Walter P. llaass, Chief Quality Assurance Branch Divisina af Eagia eria;
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