ML20033F380
| ML20033F380 | |
| Person / Time | |
|---|---|
| Issue date: | 05/12/1988 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Baer R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20033D944 | List: |
| References | |
| FOIA-89-482 NUDOCS 9003200227 | |
| Download: ML20033F380 (1) | |
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,o WALNUT CRE EI(, CALIFORNIA MSM May 12, 1988
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MEMORANDUM FOR: Robert L. Baer, Chief Engineering issues Branch Division of Engineering Office of Nuclear Regulatory Research FROM:
Dennis F. Kirsch, Director i
Division of Reactor Safety and Projects t
SUBJECT:
COMMENTS ON EPRI NP-5652 " GUIDELINES FOR THE UTILIZATION OF COMMERCIAL GRADE ITEMS IN NUCLEAR SAFETY RELATED APPLICATIONS" In accordance with your memorandum of April 14, 1988, we have reviewed the EPRI document, NP-5652, and offer the following coments for your consideration.
It appears that this document only addresses the procurement of Comercial Grade Items specifically intended for use in safety-related applications.
Therefore, the dedication process is essentially complete, and the item is considered to be a basic component, when it has been properly received and stored in the warehouse. The EPRI document should address the need for a new dedication, including an engineering evaluation, whenever the item is utilized in an application or environment for which it was not originally intended.
This dedication process should also apply to all comercial grade items located in the warehouse, prior to their release, if for any reason the item is requested for use in a safety-related system.
In regards to Appendix A " Technical Evaluation", scenario 1 addresses like-for-like comercial grade replacement.
This scenario states that if the part number is the same it can be reasonably assured that the item has not been modified, therefore, no special engineering evaluation is required. We feel that an engineering evaluation, not an engineering approval, is a necessity whenever items are ordered by part number. The reason is that an item originally ordered in 1978 may have the same part number in 1988, but may have been modified internally or externally to a degree which may significantly affect its original properties. Additional assurance regarding modification could be provided if the Purchase. Order required the supplier to inform the purchaser if any design, processing or material changes have occurred since the' original purchase.
Should you have any questions regarding our coments, please contact W. J. Wagner at FT5 463-3731.
Dennis F. Kirsch, Director Division of Reactor Safety and Projects 9003200227 900315 PDR FOIA WILLIAM 89-482 PDR
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