ML20033F378
| ML20033F378 | |
| Person / Time | |
|---|---|
| Issue date: | 06/17/1988 |
| From: | King T NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Baer B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20033D944 | List: |
| References | |
| FOIA-89-482 NUDOCS 9003200218 | |
| Download: ML20033F378 (3) | |
Text
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JUN 171988 NEMORANDUM FOR: Bob Baer, Chief, Engineering issues Branch, Division of Engineering, RES FROM:
Thomas L King, Chief, Advanced Reactors & Generic Issues Branch, Division of Regulatory Applications, RES
SUBJECT:
REVIEW 0F EPRI REPORT NP 5652 DATED MARCH 1988 Your memo of April 14, 1988 to multiple addressees, including 0. P. Gormley of RES/DRA, solicited review and comments on the subject document.
In summary, we have some concerns over the impact which NRC's endorsement of the approach suggested in the document may have on the quality of safety related components.
These concerns fall into six categories, and we have discussed each of them briefly in subsequent paragraphs. They were discussed between 0. P. Gormley and R. Kirkwood of your staff on May 19, 1988.
We are aware that commercial grade items are presently being used in safety related systems and components, and that guidance such as that in the subject document may result in an improvement in quality of those items over that currently being realized. We are also aware that both military and commercial QA programs can achieve the same quality as 10 CFR 50 Appendix B programs. We believe that methods 1 and 3, if properly implemented, could result in acceptable quality and acceptable assurance of quality for certain specific types of commercial grade items. However, the document goes too far in suggesting the types of items they can be applied to. Utilities have frequently failed to satisfactorily monitor the quality of items from vendors with Appendix B programs. Perhaps direct involvement of the utility in establishing whether satisfactory quality was achieved will result in a net improvement in quality; particularly, in tho3e instances where the utility had failed to discover that vendor's Appendix B program was poorly implemented.
l Nevertheless, we have both philosophical and specific technical concerns over l
the impact of what the document is attempting to do and any role that NRC would have in endorsing it.
First, we are concerned that any NRC endorsement would be interpreted as a relaxation of.our commitment to quality.- Papers and other coments presented at the May EPRI/NCIG briefing and the March 1988 ASQC Eastern Energy Division Conference seem to indicate that the utilities have developed the impression that at least the requirements have been relaxed. As a result, they are rushing to replace Appendix B program items with commercial grade items
.wherever possible within the criteria.
Second, we are concerned over the impact that the rush to conunercial grade items may have on suppliers of similar nuclear grade items. The fact that an item can be found in a catalog to have the same Form, Fit and Function as a nuclear grade item does not mean that commercial grade failure rates or i
consequences are acceptable.
As a minimum, documentation of quality may be 900320'0218 900315 PDR FDIA l
WILLI AM89-48t' PDR
f Bob Baer 2
DUN 1 7 1988 required only_ for the assurance needed by NRC. One of the arguments used to support the use of ccmmercial grade items is that suppliers of nuclear grade items are dropping their nuclear lines. We believe that this document will accelerate that process. The most severely impacted will be those who close down and purge their manufacturing lines and then make special nuclear runs with special controls. Others impacted will be firms which provide special I
witnessing during manufacture of a special lot and then provide additional tests, identification, certifications and storage of items which have been upgraded by special treatment to provide the additional assurance needed by NRC.
No where in the document does it say that if nuclear grade is available, it should be used.
In fact, we are already seeing examples where commercial grade components, materials and services were used in preference to nuclear grade in order to save time and money. This is not the same es using them to avoid being forced to abandon the plant because nuclear grade ones are not available.
l Third, we find it difficult to believe that the program will be satisfactorily implemented, particularly with respect to vendor related activities. Utilities have traditionally done a poor job of monitoring their vendors. A limited number of nuclear vendors and a large number of utilities has helped compensate for that i.e. several utilities auditing the same vendor increases the chances that deficiencies will be identified. Moreover, there is evidence that industry views the commercial grade approach as a relaxation of requirements, including the requirement for audits. Presentations on what this document means have stressed the need to retrain auditors on how to do commercial grade surveys. Presenters have cautioned that "... this is not an Appendix B audit."
fourth, Part 21 is no longer applied at the basic supplier level, and he is no longer obligated to inform customers of defects. Worse, NRC inspectors lose their basis for access to the vendor's facilities to perform independent assessments of quality, and to evaluate the licensees' control of vendor programs, adequacy of their audits (or "surv'eys") etc.
I Fifth, the document may mislead users by suggesting that super.ficial examinations can take the place of an embedded QA program. With a few exceptions, utilities have not exhibited the commitment to quality necessary to make this system work. Rather, they have concentrated on taking auditable actions designed to show compliance-with NRC Regulations. This is different from having a commitment to success in achiev.ing. quality. This document outlines plans for taking actions which seem destined to be ineffective in l
actually achieving quality. As an illustration, Method 2 assumes that " practices" l
are as well defined and as carefully adhered to as " procedures." Also, while l-Method 1 may be entirely satisfactory for bulk material where all the relevant characteristics can be sampled for and measured, the document goes too far in suggesting applications.
It is difficult for example, to get a good sample from the coil installation of a solenoid valve, or its resilient components without damaging them. One might say that one, or a number of valves could be L
tested to destruction, and perhaps rebuilt. However, in the absence of the controls typical of a QA program, you know nothing about the valve sitting next
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Bob Baer 3
JUN 1119BB to it in the suppliers warehouse.
It may have been built by a licensee in a different country. The cliche that quality must be built-in vs inspected-in applies here. Many features cannot be effectively inspected.
Sixth, activities which require the efforts of a skilled craf tsman usually cannot be evaluated by receiving inspection or by survey.
In the absence of an i
effectively implemented vendor QA program, even witnessing the specific activity on the specific item still leaves the qualifications of the workers unevaluated.
Valve discs and pump impellers are often given as examples of components which i
can be accepted on the basis of receiving inspection and post-installation testing. Materials can be confirmed, and fit, balance and head-flow relationships determined by testing.
However, these components are usually cast. What about the skill of the foundryman and the NDE persons? Will flaws affect the ability of the components to withstand transients occurring as part of emergency operations.
In conclusion, we feel that these comments merely touch on complex underlying problems with the approaches to quality outlined in the document. Therefore, we believe that before any NRC action is taken to endorse it, the document should be subjected to close technical and public scrutiny. One way this could be achieved is through the industry consensus standard / regulatory guide process. We would suggest that some contractor support will be required to more fully define the limits for the methods outlined in the document, what minimum QA program the vendor must have in place and how NRC can independently verify the utilities' performance in monitoring their vendors.
Finally, two relevant documents have recently appeared, and we have enclosed them because they illustrate several of our concerns. The first is an article from the EPRI Journal which discusses commercial grade surveys and describes the incentives for abandoning nuclear suppliers. The second is IE Bulletin 88-35 which describes just a few cases where NRC inssectors have found vendor QA program implementation f ailures which utilities sivuld have found but did not.
Interestingly, the Agastat 7000 Series relays appear in both documents; on the cover of the EPRI document advocating commercial grade procurement, and in the NRC document describing quality program failures.
We are pleased to have had the opportunity to provide you these comments, if you would like to discuss them further, please feel free to call upon me or 0.P. Gormley. Mr. Gormley can be reached on Ext. 23743.
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Thomas L. King, Chief Advanced Reactors & Generic Issues Branch Division of Regulatory Applications, RES
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