ML20033F370
| ML20033F370 | |
| Person / Time | |
|---|---|
| Issue date: | 08/20/1987 |
| From: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Roe J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20033D944 | List: |
| References | |
| FOIA-89-482 NUDOCS 9003200202 | |
| Download: ML20033F370 (4) | |
Text
,
e August 20, 1987 MEMORANDUM FOR: Jack W. Roe, Director Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation FROM:
Albert F. Gibson, Director Division of Reactor Safety
SUBJECT:
DRAFT INSPECTION GUIDANCE ON COMMERCIAL GRADE PROCUREMENT Enclosed are our comments-on the draft temporary instruction (TI) on conenercial grade procurement.
(original signed by M. Shymlock)
Albert F. Gibson, Director Division of Reactor Safety
Enclosure:
Coninents b
h bMellen: bey ABe11sle AGibson 08/2p/87-08/ g/87 08/p/87 9003200202 900315 f0LIA89-402 PDR N//
1 Enclosure 1.02
... no consistent qualification criteria has been estabitshed."
This TI does not establish these criteria.- Prior to implementation i
of this TI the general context of the inspection criteria should be specified to ensure consistency in the T!'s implementation.
1.03 Guidelines should be given for the assessment of procurement deficiencies of safety significance.
What level of procurement should this TI address.
If a Itcensee 3.03 p(urchases a 1E component or EQ component, what nee i.e., re'listors, capacitors, nuts, bolts, screws... )? More definitive guidance needs to be' given.
4.02b.
Training of the personnel should be included. Can the personnel recognize the problems?
Recurring problems or generic deficiencies could also be identified 4.02c.
in:
10 CFR 59.59 evaluations Nonconfonnance Reports Maintenance Work Requests field Change Request Design Package Changes Additional information may be available in existing if censee trending programs.
4.02d.
(1) Class 1E is not addressed in 10 CFR 50.49.
What are the requirements for pre-procurement engineering reviews?
There should be established criteria and bases.
What are the retest requirements for consnercial grade items that 4.02e.
replace existing components, as installed by Maintenance Work Requests.
Paragraph 1 - The " Dedication" process, as another aspect of the 4.02e licensee's overall procurement program, is similarly subjected to the controls of the Operational QA program requirements.
Provision for implementing a " Dedication Verification Process,"
should be established with assigned responsibilities that ensure performance of any licensee required dedication activities, or oversee of these activities if performed by outside organizations.
4 Enclosure 2
' Dedication documents are Quality Assurance records and shall be controlled in accordance with the requirements of 10 CFR 50 Appendix 8. Criterion 17, and any other regulatory requirements as detemined by the use of the commercial grade i tem e.g.,
Storage of commercial grade equipment that has been dedicated for use in a specific application should be segregated from other items of the same type (intended for other application), and other non-dedicated commercial grade equipment.
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D8tAPP INSPECTICN GUIDAM2 5
- CDtECIAL GRADE PROCURDENT l
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M Daft: August 21, 1987 l
RE0LEST: Review Draft TI and preoare Gibson to Roe wx As on Draft Inspection i
Guidance on Ccrnercial Grade Procuranant.
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UNITED STATES NUCLEAR RECULATORY COMM18860N
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MDIORANDUM FOR:
William F. Kane, Acting Director Division of Reactor Projects. RI William V. Johnston, Acting Director 6
Division of Reactor Safety. RI p
Luis A. Reyes, Director Division of Reactor Projects, RII t F. Gibson, Director w
Division of Reactor Safety, RI!
98 Charles E. Morelius Director Division of Reactor Projects, RI!!
Hubert J. Miller Director Division of Reactor Safety. RI!!
Ramon E. Hall Acting Director Division.cf Reactor Safety-and Projects RIV Dennis F. Ktrsh, Director Division of Reactor Safety and Projects, RV James 6. Partlow Director Division of Reactor Inspection and Safeguards
.0ffice of Nuclear Reactor Regulation FROM:
Jack W. Roe, Director
' Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation-L
SUBJECT:
DRAFT INSPECTION GUIDANCE ON CO M RCIAL GRADE PROCUREMENT Enclosed for your review and comment is the draft temporary instruction (TI)
- on commercial grade procurement. The purpose of the document is to provide inspection guidance for consnercial grade procurement of spare and replacement parts..
Contact:
L. R. Wharton 492-4882 OFFidAL' COP.5
e,-
Multiple Addressees Please provide your comments by August 21. 1987.
If we have not received your response by then, we will assume you have no coments.
k k W. Roe. Director it ision of Licensee Performance ind Quality Evaluation Office of Nuclear Reactor Requistion
Enclosure:
As stated
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1 TEMPORARY INSTRUCTION 00XX/1 COMMERCIAL GRADE PROCUREMENT INSPECTION 40 l
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00XX/1-01 OBJECTIVE A/2e J
,e, j,:/ A, V /.,.c iPT,, (Op/y To provide inspection guidanhon ksksktfebd q acy of a licensee's program for the procurement of consnercial grade spare and replacement parts j'
intended for safety-related applications.
00XX/1-02 BACKGROUND l
The procurement of spare and replacement parts for operating plants in the nuclear industry has become. increasingly difficult because of the steady decline of qualified nuclear suppliers.
Further, this problem has created an increase in the use of consnercial grade items that are intended for use in safety-related applications.
While safety-related use of cosaarcial grade items has a regulatory basis no consistent qualification criteria has been established.
Current outdance primarily addrettet nrocurament with a desien and_ construction orientation. Consequently. licensee's have been tasked with g
developing a methodology for purchasing cosmercial grade spare and replacement L
parts due to a lack of operations procurement guidance.
This task has resulted in varied cosmercial grade procurement practices.
In an attempt provide some consistency in commercial grade procurement practices.- the NR has developed inspection guidance for the procurement of cosmarcial grade s
items intended for safety-related applications. ( g g j, 9 4:1 m d b w. / / de 00XX/1-03 INSPECTION P.EQUIREMENTS
-?/d.-7f m J 4e S p <.&c fn % t i k -A 4
- This inspection assesses the adequacy of a 7tcensee(s procurement program by evaluating the procurement of connercial grade spare and replacement parts..
The approach is to investigate the licensee's procurement program from initial item selection to installation and identify any deficiencies of safety significance.
03.01 Become familiar with the particular licensee's procurement system.
03.02 Identify any previous or potential problem areas.
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01.03 Review supporting documentation for selected procurement actions such as material upgrades and like for-like substitutions.
03.04 Evaluate licensee's process or mechanism for determining suitablity of application regarding commercial; grade items intended for safety-related use.
Based on the results of these activities. - the inspector should draw conclusions regarding the strengths or weaknesses of the licensee's procurement program.
00XX/1-04 INSPECTION GUIDANCE 04.01 General Performance Guidance This guidance is provided to assist the inspector in meeting the inspection requirements.
- It is not intended - to
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provide a detailed step-by-step, checklist type reference for the inspection.
Inspectors are encouraged to incorporate previous inspection experiences to enhance their efforts.
The indicators discussed below will enable the inspector to assess the effectiveness of various aspects of the licensee's procurement program.
The monitored areas should help to note developing trends or emerging problems in the overall performance of the procurement program.
04.02 Special Performance Guidance a.
Performance Inspection Requirement 03.01 The inspector should perform a cursory review of the implementing procedures to become knowledgable of the procurement system elements such as tenninology, classifications, and methodology.
b.
Performance Inspection Requirements 03.02(a)
Discussions should be held with principal procurement personnel, to inquire of any current problems.- past problems or recent changes in the system and the occurrences that brought them about. The following personnel should be interviewed:
Receipt Inspectors Procurement Clerks Prockrement Engineers
-Procurement Program Manager.
c.
Perfonnance Inspection Requirement 03.02(b)
The inspector should look Tor recurring problems or generic deficiencies by reviewing the following reports or portions of the reports which relate to procurement:
Corrective Action Reports Audit Reports NRC Inspection Reports SALP Reports INPO Reports
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(6) Licensee Event Reports (LER's) and Safety Operational Event
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Reports (50ER's).
Review the reports or portions of the reports which relate to procure--
ment or resulted from procurement problems.-
.Look for recurring-problems or generic deficiencies.
d.
Performance Inspection Reevirement 03.03 The inspector should look for information on material upgrades and like-for-like substitutions.
Request any procurement trending infonnation available~. such as the number or percentage of upgrades, or substitutions completed within a specified time period.
The average length of time for completion of these procurement actions should also be obtained.
Comphtion times that are either very long or short could indicate misuse of certain actions.
There should be distinct criteria for categorizing each type of procurement action.
The review and approval controls should be consensurate with those of the initial procurement.
To obtain a i
representative
- sample, the inspector should look at selected procurement for at least a two year period.
It is preferable to include a pre-outage period because procurement is a major activity in preparation of an outage.
The equipment considered for the sample I
should include replacements of electrical and mechanical components.
The sample should consist of upgrades, and substitutions for safety-related equipment, for the following:
Class 1E (10 CFR 50.49)
EnvironmentalQualification(R61.89)
Seismic Qualification (RG 1.100) See References.
For each type of procurement action, the su > porting document package-should be reviewed. focusing primarily on < nstalled equipment.
The major factor to be considered regarding the procurement action is the engineering interface and where in the process it is incorporated. The engineering evaluation should occur prior to procurement so that any.
appropriate technical requirements can be satisfactorily delineated.
The significant criteria when analyzing the evaluation is the technical justification that substantiates the procurement decision.
There should' be objective evidence to document the adequacy of the-('
engineering evaluation for any appropriate procurement action.
Performance Inspection Requirement 03.04 The jnspector should use e.
judgment in evaluating the licensee's process or mechanism for determining an item's suitability of application. The process should be adninistratively established so that each detemination is controlled and accomplished similiarly.
The designation of a commercia'l grade item for safety-related use is considered a design change and is subject to 10 CFR 50.59 reviews and the requirements estabiished in.
Appendix 8 Criterion III.
" Design Control."
Connercial grade equiznent or components must be designated before use to ensure the capa>ility to perfom in an intended safety-related function.
The process should include a combination of the following such that the result will attest to the item's ability to function as required:-
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o An up-front engineering determination of the item's critical attributes.(s)bility - to function in the intended safety-related
-a application and the acceptance parameters for verification of those critical attributes.
A' quality engineering evaluation to provide. adequate confidence that applicable requirements, administrative controls and appropriate responsibilities have been identified.
Qualification testing of a replacement commercial grade item where the original item is no longer available.
4 Post-installation / Pre-service testing to assure that the procured item does indeed function as intended.
- - Lab testing.
Independent verification, destructive or nondestructive testing of items for critical dimensions, material hardness and composition.. internal dimensions, surface finish, plating material, voltage or resistance ranges, to assure capabili-ty and relablity to perform under plant environmental and seismic conditions.
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Vendor evaluation and selection based on performance history or l
supplier ability to maintain production and material consistency at an acceptable standard of quality.
Receipt inspection of the item received to verify that it is indeed the item requested on the procurement document.
00XX/1-05 EXPIRATION This TI will remain in effect for twelve months after issuance.
L 00XX/1-06. NRR CONTACT
- Questions: regarding this TI should be addressed to L. Raynard Wharton on FTS 492-4882 (or 301/492-4882) or Frank Hawkins on FTS 492-4876 (or 301/492-4875).
00XX/1-07 REFERENCES 10 CFR 21. " Reporting of Defects and honcompliances" 10 CFR 50.49 " Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants" 10 CFR 50. Appendix 8. " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants
- ANSI N45.2.10.-" Quality Assurance Terms and Definitions" ANSI N45.2.13. " Quality Assurance Requirements for Control of Procurement Items and Services for Nuclear Power Plants"
-i-ANSI /ANS-3.2
" Administrative ' Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants' ANSI /ASME NQA-1, " Quality Assurance. Program Requirements for Nuclear Power Plants" IEEE Standard P934, " Requirements for Replacement Parts for Class IE Equipment in Nuclear Power Generating Stations" IEEE Standard 344, "Recomended Practices for Seismic Qualification of Class IE Equipment in Nuclear Power Generating Stations" 1EEE Standard 323 " Qualifying Class IE Equipment in Nuclear Power Generating Stations" Guide 1.89, " Environmental Qualification of Certain Electrical Regulatory!mportant to Safety for Nuclear Power Plants" Equipment.
Regulatory Guide 1.100, " Seismic Qualification" Regulatory Guide 1.123
" Quality Assurance Requirements for Control of Procurement Items and Services for Nuclear Power Plants" END 1
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