ML20033D984
| ML20033D984 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1989 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | Rasin W NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| Shared Package | |
| ML20033D985 | List: |
| References | |
| FRN-58FR15167, RULE-PR-MISC NUDOCS 8904280085 | |
| Download: ML20033D984 (2) | |
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NUCLEAR REGULATORY COMMISSION
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s, AFR 2 4 939 Mr. William Pasin Nuclear Management and Resources Council 1776 Eye Street, N.W.
Suite 300 Washington, D.C.
20006-1280
Dear Mr. Rasin:
Enclosed for your information are two letters I recently received from Mr. Lawr >nce Gradin, ECOTECH, Incorporated, on the subject of commercial grade procurerr.cnts and dedication programs.
I am' forwarding these letters to you for NUMARC's use and consideration during the Working Group's deliberations on improvements to licensees' procurement and dedication pro gams.
Sincerely, s
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Brian K. Grimes, Director Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation
Enclosures:
1.
Ltc to 5. K. Grimes, NRC fm L. P. Gradin, ECOTECH, dtd April 7, 1989 2.
Ltr to B. K. Grimes, NRC fm L. P. Gradin, ECOTECH, dtd April 11, 1989 c: Mr. Lawrence P. Gradin l*
ECOTECH, Inc.
6702 Bergenline Avenue West New York, New Jersey 07093 e
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June 1989 i
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^d Grifiestion of Certain Amets of the Commerdal Grade item (CGI)
- Dedication Proc-ss" t
for *Conv-rsion* of CGrs to Basic Comrinnents j
0 ne potenti=1 for misinterpretadon of the defint*ina of
- Commercial Grade Item * (CGI) and j
- Dedintion Process' pcmes problems in that these two concepts form the foundation of an acceptable approach to convert a CGI to a basic component. In a:!ctter to the NRC,
- EcoTech, Inc. has requested Sta.ff clarificarma of the definitinns of the concepts. The current 10 CFR 21 delir' tion of a CGI is an hem that is:
i not suliect to dei-or specification requireme=ts that are unique to facilities or j
j naivities r-~.ed or regniated by NRC, r
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used in applications aber than f=ctTitles or actidtics Ecensed or regulated by the i
NRC, and l
i ordered from a =~3mrrer/ supplier on the basis of sreiGurinns set forth in the j
,*=deurer's pubikhrd product description, eg., a catalog.
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l According to EcoTech, this defiidrion leads to the =kt=fren bcEcf by some in the industry
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that the use of a CGI for virrmste service requiring environmental or sekmie gn*Tmmtinn is i
in dotation of 10 CFR 21 since these are unique snelear i@ menrt It has also been vnhi.rerpreted that critical characteristics ennnnt be defined for =eb'e=Tiy or enviremnenr2Dy qmimed applic=rinn< iir the ded:e=tian process. Raced on this bcHef, so j
are mfrng kems nons=rety-related which are known to be de< tined for basic component or'
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nnrirar safety-related service. EcoTech think that the NRC should make it clear that the l
10 CFR 21 AMt;= phrase *not subject to design or sp---Ld e requirement ( does not i
refer to the cirrmare apprestina requirements (eg, sekmie or environmment quaEfication icq-Lents) but rather to the. physical p--A ::. quality, software or other require =ents j
i:nposed on the s=ppIIer during the pradnetina process. EcoTech believes that this t
clarification wocid be er=krent with past Staff interprmtians and with podrio=s l
promulgated to the imhr.try by Staff personnel Regardmg the A-4 eina proc::ss,10 CFR l
21 spedfies that "a commercial grade item is not part of a component until after dedication,*
j but does not define the term
- Recent concerns for fraudulent, refurbished, or
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counterfeit molded case circuit breakers have led to an NRC definition of the dedication i
process la NRC Bulletin 8S-10. He defini6on provided in NRCB 88-10 is as follows:
a dedication process is the process by which commercial grade (non-Class 1E) equipment is S t.lt, /qf $ upgraded to safety-related (Class 1E) and is thereby cxmsidered qualified for use in safety.
p related applications. He dedication proces must include:
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h1 A technical evalua6on to determine-the characteristics cridcal to fulfithng the safety 3
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An acceptance process to ensure that those characteristics are met.
Because NRCB 88-10 is an *clearical" bulletin which was not distributed to all in the M
g f [~ d* ~ b Q industry, EcoTech believes that the
- defin* tina contained in it should be l
I promulgated in a more general document and should be supplemented by a complete i
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definition of the process for the conversion of a CGI to a Basic Component.
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licrch 10, 1981 l
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'l ALL LICENSEES OF OPERATING ILANTS AND APPLICANTS FOR OPERATING LICE AND HOLDERS OF CONSTRUCTION PERMITS ENVIRONMENTAL QJALIFICATION OF CLASS IE ELECTRICAL EQJIPMENT -
SUBJECT:
c1'sRIFICATION OF STAFF'S HANDLING OF PROPRIETARY INFOPJd.ATION GENERIC LETTER NO. 81-15 Reference (a) SECY-81-119 dated February 24, 1981, Subject as above This letter transmits Reference (a) which presents the NRC staff require-ments regading the nature cf the inforr.aticn necessary to establish tne It is sent to you qualification of safety related electrical equipment.
in response to concerns from certain equipment vendors, and clarifies cur position that sumary type infonmation alone is not adequate to establish qualification.
Vincerely,
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IN VarteT G li enn. Uttd tor Division o Licensing Office of Nuclear Reactor P.egulation
Enclosure:
SECY-81-119 dated February 24, 1981 cc: See next page
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POLICY ISSLTE (Information)
S ECY-81 -119
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February'2a. 1981 Fer:
The Comissioners Wi11i t.T..J.' Dircks Frem:
Executive Director for Operations
Subject:
ENVIRCNMENTAL QUALIFICATION OF CLASS IE ELECTRICAL EQU~PeiT -
CLARIFICATION OF STAFF'S HiliDLING OF PROFRIETARY INFOR$7:Cti To inform the Commission of objections raised by certain Furpose:
equipment vendors regarding the NRC's handling of informatien concerning t'.c G:.lification of Class IE electrical eg:ipment, and the staff's solution to these objections.
Discussion:
Class IE electrical equipment qualif.ication data presently is
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available ':. t..; f;m;:
(1),a sumary, substantially c:ntaining only. identifying data and test parameters; and (2) a detailed explanation.of test procedures and the results thereof.
As stated in our August 6,1980 Information Report,.SECY-EC-367, the sumary reports are not believed to contain validly proprietary information, and thus should not be withhelo frer public disclosure, while the detailed reports are believed to be proprietary, and therefore, subject to NRC protecticn.
Sumary information in and of itself.is not sufficier.t to substantiate qualification of the equipment because the licensee
=ust examine the referenced document from which the data was extracted and certify that the data.is fully applicable and valid for qualifying his specific component. This certifica-tion process involves the traceability of design, manufacturing processes, and materials of construction to the specific component. Additionally, the NRC staff audits of such qualifica-tion require the licensee to produce the complete. documentation at his own location or at the location of a NSSS vendor.
Contact:
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R. LaGrange, NRR
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E. Shomaker, ELD
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X27242
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j Certain of the equipment vend:r:. principally Vestinghour e, are i
c:ncerned that the sumary infomatien reports will be accepted i
i by the NRC as the sole cocumentation recessary fcr equip 9ent qualification, in lieu of the requirement to produce the detailed 4
l infomation, for which the vendors levy a charge to the licensees in order to recoup the vendor's testing costs.' The vendors l
believe that if the su= cry reports are released to the public, Because of this they will be unable to recoup these c:sts.
. belief. Westinghcuse is labeling as pr:prietary its licensees sm=ary information reports.
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We have discussed this situation in cetail with Westinghouse.
i They have agreed to drcp proprietary claims on sum:ary ir.fc = ati:n e
i Tf 1..e.FC~aTiiirihis~ its present position that sumary data is not l
acceptable in and of itself to qual'ify' e6fipment.
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l Accordingly, NRR is notifying all affected licensees and vendors i
of our policy with regard to sumary information in equipment a
qualification by enclosing a copy of this paper with a letter to
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4 he sent to each licensee by the Division of 1.icensing.
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i WillitYJ. Dir:ks Executive Direct:r for Operatiens l
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