ML20033D943
| ML20033D943 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/1988 |
| From: | Weiss S Office of Nuclear Reactor Regulation |
| To: | Baer R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20033D944 | List: |
| References | |
| FOIA-89-482 NUDOCS 8805170306 | |
| Download: ML20033D943 (4) | |
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MEMORANDUM FOR:
Robert L. Baer, Chief j(j4 Engineering Issues Branch Division of Engineering Office of Nuclear Regulatory Research FROM:
Seymour H. Weiss, Chief Quality Assurance Branch Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation
SUBJECT:
REVIEW 0F EPRI REPORT HP-5652, DATED MARCH 1988 We have reviewed the subject EPRI document entitled, " Guidelines for the Utilization of Commercial Grade items in Nuclear Safety Related Applications,"
(NCIG-07, EPRI NP-5652, Final Report, March 1988).
We recommend HRC andorsement of this document with exception, since it establishes i,0 new procurement requirements. The exception is with regard to the use of method 4 Supplier / Item Performance Record, which could be misinterpreted to allow a licensee to accept an item based on a subjective performance record. The employment of this acceptance method if used alone should:
1.
set limitations on applicable items, such as those relatively simple and standard in design, manufacture, and test 2.
provide a minimum threshold of procurement period and frequency for establishing proven historical performance 3.
verify that manufacturers implement adequate measures to control design, process and material changes.
Overall, we feel that this document is an excellent step toward standardizing commercial grade procurement practices in the nuclear industry.
The QA Branch is committed to, supporting your work to. endorse the document.
If you have questions or if we can be of assistance, please contact either me (X21017) or Ray Wharton (X21019).
.et f Seymour H. Weiss, Chief Quality Assurance Brench Division of Licensee Performance I
and Quality Evaluation Office of Nuclear Reactor Regulation 1
ff6/7p4 y
1
,i Page No.
1 05/03/88 Comments on
- Guidelines for the Utilization of Commercial i
Grade items in Nuclear Safety Applications" 3/88 W. E. Campbell, Jr.
(?3806wc7336/7, cgi, com)
Cmt Page Para Coment No.
Sub.
Line para An
- indicates the comment is considered substantive.
J1 x
Glos.
The Glossary defines " safety related component" and the text uses the term "non-safety related" which is not i
defined.
For completeness recommend that term "important to safety" be included in the Glossary.
"Other suppliers have satisfactory undocumented J2 1.4 1.1.3 4
5 controls that assure a conforming product is supplied."
Such controls are not easily implemented as the production force changes with time.
Recomend that this concept not be included.
J3 2.3 2.3.2 The Glossary defines 'Ecuivalency Evaluation' on page
?
3 ix and then uses the tenn ' original item'. The text in numerous locations uses the undefined term ' parent component'.
Recomend the relationship between these terms be clarified or only one be used.
J4 2.5 Fig ?-3 It is difficult to locate any specific item in sheets 1, 2, 3.
Recommend that if there is occasion to redo this figure each sheet be put in alphabetical order.
The document addresses the subject of ' selecting the 45 2.8 2.4 appropriate acceptance method' but does not address the I
organizational entities that should be involved in this selection.
Recomend that an entity concerned.with the quality function be involved.
J 6 3.3 3.1.3 "The critical characteristics to be verified for this I
7 3
item would be material of construction...." This L
statement appears to be a closed ended statement and very narrow.
Recommend that this statement be revised to include the I
concept of "... would include but not be limited to l
material This issue occurs in a number of the section of part 3.
, 7' 374 3.1.3 Among the critical characteristics in the text is l
9 dimensions. The list includes characteristics of dimensions and configuration. They appear to be all most identical.
\\
Page No.
2 s
05/03/88 Comments on " Guidelines for the Utilization of Comercial 1
Grade items in Nuclear Safety Applications" 3/88 1
W. E. Campbell, Jr.
(23806we7336/7 egi, com)
Cmt Page Para Comment No. Sub.
Line para Recomend that the difference between the terms be clarified.
^
J 8 3.5 Fig 3 2 Figures 3 1, 2, 4 & S each contain a graphical representation of an acceptance method.
Figure 2 does not end with an ACCEPT ITEF as do the other three.
Pecomend that figure 2 be rnodified.
J9 3.16 3.4.3 The phrase " National Codes & Standards" is psed.
If 3f the usage of " national " is to mean that they were developed in the United States this usage can be accepted.
If it is to imply that the codes and standards were developed by the consensus method such is not the case since some of them that are included in Appendix E have been developed by a trade association.
Recomend that the word ' national' be deleted.
Section 4. " Specific Guideline References", contains J 10 4.1 4.0 some documents that are not the currently issued version, for example ANS 3.P.1976 is included but the 1982 version is available thru ANS.
It is noted that in some cases the I
older version that is included is the version that is referenced in the current Regulatory Guide.
Recomend that the currently issued versions be reviewed to detemine how the guidelines would need to be modified if a later version were referenced.
The phrase " passive valve" is used. The Glossary does 4 11 01 R2 not define either passive or active.
In the industry there are many usages of passive, for example, does/does not contain moving parts, self/ externally-actuated, does/does l
not perform a safety function in response to an accident.
i Recommend that the words active / passive be deleted or they be included in the Glossary.
"An approoriate means to identify the item is to a 12 D.2 02 6
reference the drawing number, including revision,...." In some organizations the technical material in a drawing may be changed but the revision number is not changed at that time. When the number of changes to a drawing is deemed sufficient then the drawing is given a new revision number.
Recomend that the supplier s drawing issuance policy be an identified item in the review of a supplier's program.
i
)
Page No.
3 05/03/88 Comments on " Guidelines for the Utilization of Commercial Grade items in Nuclear Safety Applications" 3/88 W. E. Campbell, Jr.
(23806wc7336/7,cgi,comm)
Cmt Page Para Comment No.
Sub.
Line para A ** indicates another location of a previous 13 3.8 3.2.3 9
5 consent. Here is another example of "... characteristics to be controlled...." This is on also on p 3-3.
See comment on 3.1.3.
This is another example of "...to be controlled...."
' 14 3.14 3.3.3 6
3 See comment on 3.1.3.
In appendix B there are also numerous instances of J 15 B.1 B2 the usage of " parent" component. See comment on para 2.3.2 Another location of use of " passive".
See comnient or.
4 16 P.2 B2 para B 2.
Another usage of " National". See comment on para
' 17 E.1 E 3.4.3.
il Another usage of " Parent". See comment on 2.3.2.
/ 18 F.1 F.2.2 h
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