ML20040D162
| ML20040D162 | |
| Person / Time | |
|---|---|
| Site: | 05000574 |
| Issue date: | 01/14/1982 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Mandara P WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| NUDOCS 8201300345 | |
| Download: ML20040D162 (2) | |
Text
clF TE M DISTRIBUTION:
' Central File NRC PDR LPDR JAN 141982 NSIC QAB Chron. File WJohnston, DE JConway,QAB bI Mr. P. R. Mandava C
M,s
-W Philippine Pmject N'h Engineering Manager f
g-Westinghouse Electric Corporation y
^
5 Parkway Center g
jpy g g Pittsburgh, PA 15220 j o-r eum g
"./ s,/AY
Dear Mr. Mandava:
(\\
7
SUBJECT:
MATERIAL TRACEABILITY
{
The Mandava/llaass letter dated October 5,1981, requested the NRC's position on the above subject.
With regard to your Position I, Criterion VIII of Appendix B to 10 CFR Part 50 states "Those measums shall assure that identification of the item is main-tained by heat number, part number, serial number, or other appropriate means, either on the item or on records traceable to the item...."
The word " trace-able" has the common dictionary. meaning; i.e., capable of being traced or tracked. The " traceable" provision was included in Criterion VIII to take account of the fact that for some items it is not possible to maintain identi-fication on the item.
Typical examples of items where identification cannot be maintained on the item are ball bearings and uranium oxide fuel pellets. For such items Criterion VIII simply requires that identification must be main-tcined on records which can be traced or tracked to the item. While there are specific provisions in other documents such as the ASME Code for requiring that identification of certain items be maintained by heat number or physical and chemical mill test mports, no such detailed requirement is included in the general quality assurance program requirements of Appendix B to Part 50.
In addition, the material traceability requirements imposed upon a particular item should be established to the extent necessary to provide assurance of acceptability at the point of material usage. Material traceability requirements should also be dependent upon the importance to safety of the item in question.
It should be the msponsibility of Engineering during the design stage to deter-mine the need for such infonnation and then specify the requirements for main-taining the identity of components beyond specific release points consistent with this determination. Material traceability of an item directly to a heat number is-one of several valid methods for demonstrating acceptability.
If the requirements (e.g., chemical and mechanical properties) contained in the procurement document have been verified at receipt inspection, the use of lot nurbers to identify and control an item through various fabrication steps to end use is adequate.
....... ~...... ~..
omcn
~~-"
~ ~ - - -
" ~ ~ " - " " " " -
" ~ ~ " " " " " -
su' -8201300345 820114 PDR ADOCK 05000574
" " ' " " " " " " ~
A PDR OFFICIAL RECORD COPY usa m m - m ees sac ronu sta po-so> nacu eno
a:
Mr. P. R. Mandava JAN 1
- 1982 l
i For your Position II, the criteria of Appendix B to 10 CFR 50 required in a QA program are dependent upon the activities that are being perfomed, e.g., a vendor's program would not have to meet Criterion III Design Control if he is not doing design work.
I apologize for the delay in our response, but your letter reached my attention only last week.
s Sincerely, Original signed by Walter P._Haang /
Walter P. Haass, Chief Quality Assurance Branch Division of Engineering i
,n'l OFFl0E
...k.........
< Ph
.....k, -
a a t..s......
n..w..a.r...:.c..a.
v SURNAME) d
. ]
..Qt.L82............U]. l.82 omy NRC FORM 318 (10-ic) NRCM ONO OFFICIAL RECORD COPY usam au-m.m 1
.,