ML20058C589
| ML20058C589 | |
| Person / Time | |
|---|---|
| Issue date: | 10/26/1993 |
| From: | Norrholm L Office of Nuclear Reactor Regulation |
| To: | Rossi C Office of Nuclear Reactor Regulation |
| References | |
| FRN-58FR15167 NUDOCS 9312020500 | |
| Download: ML20058C589 (15) | |
Text
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UNITED STATES
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I NUCLEAR REGULATORY COMM!SSION c.
E WASHINGTON. D C 20556 0001 October 26, 1993 I
MEMORANDUM FOR:
Charles E. Rossi, Director Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation FROM-Leif J. Norrholm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation i
SUBJECT:
RESOLUTION OF PUBLIC COMMENTS ON DRAFT NRC INSPECTION PROCEDURE 38703, " COMMERCIAL GRADE DEDICATION" On March 19, 1993, Federal Reaister Notice 58 FR 15167 announced that a public workshop would be held in Dallas, Texas on April 21-22, 1993 to discuss and solicit comments on key procurement and commercial grade item (CGI) dedication issues and a draft inspection procedure (IP) to be used by the NRC during inspection of licensee CGI procurement and dedication activities. This Notice gave interested persons until May 21, 1993 to submit written comments on the proposed inspection procedure and dedication issues.
j The workshop was attended by approximately 300 persons who collectively submitted 190 questions or comments (on question cards).
Twenty four 4
organizations and individuals also submitted written comments in response to the Federal Register Notice. The responders represented 17 utilities, 3 consultants, 2 major nuclear suppliers, and 1 individual. The Nuclear Management and Resources Council (NUMARC) also provided comments.
We have analyzed all of these comments and combined and paraphrased similar l
comments to avoid unnecessary duplication. As a result, 30 comments representing the issues raised during the workshop and in response to the Federal Register Notice have been compiled and are discussed in Enclosure 1.
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Charles E. Rossi October 26, 1993 Da L-Of the 30 comments, 21 have been accommodated by making appropriate changes to the IP or Appendix A to the draft IP, " Dedication issues," (Enclosure 2),
b, 2 have been partially accommodated, and 7 have not been accommodated. The rationale for these actions is summarized in the Enclosure 1.
I Leif J. Norrholm, Chief Vendor Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation i
Eralosure:
I 1.
Synom.is of Comments on Draft Inspection Procedure 38703 l
2.
A;,pendi, A to Draf t inspection Procedure 38703, " Dedication Issues."
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Charles E. Rossi Of the 30 comments, 21 have been accomodated by making appropriate changes to the IP or Appendix A to the draft IP, " Dedication Issues," (Enclosure 2),
2 have been partially accomodated, and 7 have not been accommodated. The rationale for these actions is summarized in Enclosure 1.
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Leif I. Norrholm, Chief Vendor inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation 1
Enclosures:
1.
Synopsis of Coments on Draft Inspection Procedure 38703 i
2.
Appendix A to Draft Inspection Procedure 38703, " Dedication Issues."
cc:
Alex Marion, NUMARC i
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SYNDPSIS OF COMMENTS ON DRAFT INSPECTION PROCEDURE 38703 i
1.
The NRC should issue a final Generic Letter (GL) on commercial grade item (CGI) dedication clearly stating the current NRC positions. This GL should supersede and replace all previous documents on CGI procurement and address any differences between NRC's expectations and Electric Power Research Institute (EPRI) NP-5652 with respect to selection and verification of critical characteristics.
Generic guidance on CGI dedication is contained in GLs 89-02 and 91-05 and in Appendix A to draft inspection Procedure (IP) 38703, " Commercial Grade Dedication," which was issued for public comment on March 22, i
1993, and discussed at the public workshop. Although the latest guidance in Appendix A to the draft IP (Enclosure 2) is more focused on specific issues where differing interpretations have been identified, it contains no substantive changes to the basic NRC staff positions on dedication as compared to the two GLs.
These documents are mutually consistent.
The guidance expressed in these documents should not be interpreted as representing regulatory requirements but only as a discussion of acceptable methods of achieving compliance with Appendix B to 10 CFR part 50.
Individual licensees may develop alternate methods of achieving Appendix B compliance.
Because of this and recognizing the evolutionary nature of the dedication process, another GL appears unnecessary at this time.
Public comments received in response to the Federal Reoister Notice and during the public workshop have been considered and incorporated in Appendix A to the draft IP as appropriate.
Analysis and disposition of specific comments are contained in the following paragraphs.
2.
The guidance should be clarified to clearly indicate that there is no preference for utility procurement from Appendix B to 10 CFR Part 50 sources.
Specifically, Section 1.c of Appendix A to the draft IP, which states that "the dedication process is not a substitute for Appendix B" should be rewritten as it can be misinterpreted to imply preference for Appendix B procurement.
The " Reasonable Assurance" section of Appendix A to the draft IP has been revised in part to state that "the dedication process represents an acceptable method of achieving compliance with Appendix B."
3.
Random failures, design specification deficiencies, failures unrelated to the item's safety function, and normal wear should not trigger CGI dedication inspections.
Appropriate guidance should be provided to clarify this issue.
The staf f agrees that f ailures attributed to design specification deficiencies, f ailures unrelated to the safety function, and normal wear
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should not trigger CGI dedication inspections.
Appropriate guidance has been added to Section 03.01a of the draft IP.
4.
Dedication packages selected for review should be limited to items dedicated after the implementation date of the Nuclear Management and t
Resources Council (NUMARC) initiative (similar to the pilot inspections).
The staff agrees that dedication packages selected for review under this procedure should be limited to those that were developed after the implementation of the NUMARC initiative in January 1990.
A clarifying paragraph has been added to the " General Guidance" section and to Section 03.02b of the draft IP.
However, if the inspector encounters a significant f ailure of an item dedicated before 1990, he will be expected to perform sufficient followup to assure that adequate corrective and preventative measures have been taken by the licensee including generic considerations if applicable.
5.
Since the procedure is initiated as a result of component failure, it should be consistent with other existing procedures covering similar areas (e.g., IP 92720, " Corrective Action"). The same methodology should be applied to determine the cause of failures and evaluate corrective action.
Although this procedure is initiated primarily as a result of component failure, its use does not preclude the inspector from utilizing other available inspection procedures such as IP 92720 for the review of corrective actions.
The NRC's inspector qualification program is designed to familiarize the inspectors with the scope of inspection procedures available for their use.
A note has been added to Section 03.01a of the draft IP specifically directing the inspector to use other procedures including IP 92720 when appropriate.
6.
Guidance should be provided for the use of graded quality assurance.
A new section
- Graded Quality Assurance" has been added to Appendix A to provide additional guidance on the use of graded quality assurance.
7.
The flow charts discussed at the workshop should be corrected (one has a typographical error) and made a part of the IP.
The flow charts were prepared primarily for presentation and discussion of the inspection logic during the public workshop.
The staff does not believe that adding the flow charts to the IP would improve the understanding or use of this procedure by the inspector.
E.
Engineering judgement should be defined and guidance should be provided on the extent of documentation needed to support engineering judgement.
j The definition section of the procedure has been revised to include a definition of engineering judgement.
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The guidance should indicate that the graded quality approach may be used for both the selection and verification of critical characteristics.
i The " Consideration of item's Safety Function" section of Appendix A to the draft IP has been revised to state that the graded approach can be used for both selection and verification of critical characteristics.
10.
Definitions should be standardized to the extent possible to be consistent with previously published NRC and/or industry definitions.
Differences between NRC and industry definitions should be reconciled.
Appendix B
- Definitions" to the draft IP has been revised and a new section *Use of Industry Guidance" has been added to Appendix A to i
provide a better correlation between the NRC and industry definitions.
11.
The procedure implies that failures of dedicated items are more significant than failures of items procured under Appendix B to 10 CFR Part 50, by placing primary inspection focus on dedicated item failures.
Such differentiation is not warranted.
It is not the staff's intent to assign a higher significance to failure of dedicated CGis than to failure of similar items procured from Appendix B suppliers. The primary inspection focus is on dedicated item failures because this procedure was written to specifically address only licensee dedicated items.
There are other inspection procedures such as IP 3870), " Procurement Program," and IP 38702, " Receipt, Storage, and Handling of Equipment and Materials," that are used to address the inspection of items purchased in accordance with Appendix B to 10 CFR Part 50.
12.
The requirement to provide complete lists of CGis purchased and dedicated during the last two years may be burdensome to some utilities.
The staff believes that most licensees will be able to provide lists of I
CGis dedicated during the last two years by accessing this information from electronic data bases.
However, the staff understands that the record keeping systems used by some licensees may not be able to provide this information easily.
The " General Guidance" section of the draft IP has been revised to state " Request this list only if the licensee states this type of information would be easily retrievable."
13.
The number of dedication packages for the programmatic inspection should be limited to 10, evenly divided between packages related to equipment f ailure and randomly selected packages.
l The instruction in section 03.02b of the draft IP that the inspector select approximately 20 packages for review is a recommendation.
The actual number of packages selected for review will be determined by each inspector on a case by case basis and will depend on a number of factors including the complexity of the packages and the time available.
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i However, 20 packages is believed to be a reasonable quantity based on NRC's CGl. item dedication inspection experience to enable adequate i
assessment of dedication program effectiveness. Also, Section 03.02b of l
the draft IP states that~the inspection should be performance-oriented; l
e.g., weighted toward the review of dedication packages for items that have failed.
Therefore, it is believed appropriate to retain the 75%
ratio in favor of failure related packages.
I 14.
There should be no need to survey distributors who do not open the original equipment manufacturer's (OEM) containers / packaging or otherwise manipulate the items being procured. Judgement should be a
permitted on the need to audit distributors based on the item procured, t
relationship between the distributor and the OEM, capability to detect j
tampering, etc.
The
- Traceability" section of Appendix A to the draft IP has been expanded to provide more quidance in this area. Specifically, it now i
states that a survey of the distributor may not be necessary if the distributor acts only as a broker and does not warehouse or repackage the items or in cases where traceability can be established by other means such as verification of the manufacturer's markings or shipping records.
15.
The guidance on sampling should be clarified with respect to applicability to destructive or nondestructive testing. The " heat" of l
material concept should be expanded to include certain nonmetallics such as oils and greases. Consideration should be given to combining paragraphs 2 a ud 2.b and the guidance contained in Example 6 on the i
use of product performance history should be incorporated in the draft j
IP.
Appendix A to the draf t IP on sampling guidance has been clarified.
l Specifically, the " Established Heat Traceability (Materials)" section of the draft IP now states that, for metallic materials with established l
heat traceability, single piece testing is applicable only to chemical 1
analysis and destructive testing. Also, the ' heat" of material concept
.l is extended to containers of certain nonmetallic materials such as
.j lubricants identified with trareable mix or batch number.
Paragraphs 2.a and 2.b were not combined since they represent different product classifications (homogeneous and similar). Guidance on the use of product performance history has ieen included in the " Graded Quality Assurance" and " Established Lot Batch Control (Items)* sections of i
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Appendix A to the draft IP.
i 16.
The use of certain industry standards (Underwriters Laboratories.,
l' Military Standards, etc.) should be acceptable in the dedication process provided that they are properly implemented and that they verify identified critical characteristics.
t The NRC has not reviewed or taken any positions on the acceptability of i
these standards as bases of compliance with any regulatory requirements.
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However, licensees may determine through a review of these standards and a commercial grade survey that they adequately control identified critical cha acteristics of items being purchased.
17.
NRC should endorse EPRI NP-7218 as an acceptable basis for sampling.
This item is currently under consideration.
18.
Validation of certificates of compliance (CoC) and certified material test reports (CMTR) should be required only when these documents are used as a basis for the verification of critical characteristics.
The " Acceptance of Certified Material Test Reports and Certificates of Compliance" section of Appendix A to the draft IP has been revised to reflect this comment.
19.
Heat traceability of small products should not require marking of each piece (tagging of bundles, marking containers should be acceptable)
The " Established Heat Traceability (Materials)" section of Appendix A to the draft IP has been revised to accommodate this comment by substituting " identified" for " marked".
20.
The paragraph on like-for-like replacement should be deleted from Appendix A.
This is not a dedication issue.
The paragraph on like-for-like replacement has been deleted.
21.
Guidance should be provided on the maintenance of surveyed vendor lists (survey frequencies).
A new section " Survey frequency
- has been added to Appendix A to provide guidance on commercial grade survey frequency.
22.
The procedure should include guidance on doing business with International 0 ganization for Standardization (150) ISO 9000 suppliers.
The NRC has not reviewed or taken any position on the acceptability of ISO 9000 as a basis for compliance with regulatory requirements.
Licensees, however, may determine through a review of this standard and survey or audit of the vendor that the controls in place appropriately l
address their quality assurance (QA) needs for a particular procurement.
Since Appendix A to the draft IP already contains considerable i
discussion on surveys, additional guidance does not appear to be needed.
23.
There should be no requirement for procurement documents to be reviewed and approved.by QA (Section 03.03 of the draft IP). -Only an independent review should be required, not necessarily by QA.
The draf t IP has been revised to delete this reference.
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There should be a requirement to interview the responsible engineer who 24.
developed the dedication package at some point during the inspection.
Section 03.02a of the " Specific Guidance" of the draft IP, has been modified to include interview of the responsible engineer.
It The words " audit" and " survey" appear to be used interchangeably.
25.
was suggested that audits be applied when referring to Appendix B to I
10 CFR Part 50, and surveys be applied to the evaluation process of CGI suppliers.
The draft IP has been revised as suggested.
The IP objective discusses the dedication process as
- ensuring" 26.
This should be modified to performance of intended safety functions.
note that the dedication process provides " reasonable assurance" of the performance of the safety function.
The draft IP has been revised as suggested.
When using Method 2 (comercial grade surveys), the licensee should not 27.
be required to reference the vendor's specific programatic/ procedural controls in the purchase documents. Reference to controls observed during the survey should be sufficient.
Activities affecting the critical characteristics of a CGI should be controlled by documented instructions and performed in accordance with these instructions to assure that these activities are consistently accomplished in a satisf actory manner. Recognizing that different types or levels of documented controls may exist depending on the type and corrplexity of the item or the vendor's manuf acturing process, the
" Identification of Applicable Program / Procedures" section of Appendix A to the draft IP has been revised to indicate increased flexibility in this area.
Requirement to perform a CGI survey to establish lot / batch homogeneity 28.
is burdensome and expensive.
Acceptance of as-received vendor's lot / batch control (without verification) and sampling using standard statistical methods will still provide a high level of assurance.
Most standard statistical sampling plans are based on homogeneous product lots to achieve the expected confidence level and should,The theref ore, be used only for items with established lot control.
" Material and items With No Lot / Batch Control" section of Appendix A to the draft IP recognizes situations where lot / batch control can not be established or where the necessary level of confidence can be achieved using other sampling bases.
Item specific sampling plans may be developed for these situations. _
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The basic logic behind EPR] NP-5652 is that it is reasonable to expect that the vendor will meet its contractual technical requirements and that if the selected critical characteristics are found conforming, it is reasonable to assume that the manufacturer has adequately controlled the remaining critical characteristics.
A new section, "Use of Industry Guidance," has been added to Appendix A.
This paragraph recognizes that critical characteristics can be a subset (not all) of the item's important design, material and performance characteristics. However, the staff does not agree that it is reasonable to assume that all of the identified critical characteristics can be verified based on sampling of some of the critical characteristics unless these characteristics are interrelated in such a way which makes such extrapolation reasonable or some statistical sarpling basis is applied. This new section also provides additional clarification concerning NRC's definition of critical characteristics and how it relates to definitions contained in EPRI documents.
30.
NPC should train its inspectors in the use of this procedure. Also, there should be central oversight of the inspection findings to assure consistency between the regional offices, NRC will train its inspectors and provide appropriate oversight to assure consistency in performance between the regions.
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APPENDIX A TO DRAFT INSPECTION PROCEDURE 38703
- COMMERCIAL GRADE DEDICATION" DEDICATION ISSUES BASIS FOR THE SELECTION AND VERIFICATION OF CRITICAL CHARACTERISTICS 1.
Consideration of Item's Safety Function Critical characteristics should be based on the item's safety function.
The licensee is responsible for (a) identifying the important design, material, and performance characteristics that have a direct effect on the item's ability to accomplish its intended safety function and (b) selecting from these characteristics a set of critical (or acceptance) characteristics that, once verified, will provide reasonable assurance that the item will perform its intended safety function.
Criterion II of Appendix B to 10 CFR Part 50 provides for the application of quality assurance over activities affecting the quality of structures, systems, and components to an extent consistent with their importance to safety.
This graded quality approach can be used in the selection and verification of critical characteristics for commercial grade items (CGls).
When an existing equipment specification is available that contains adequate technical requirements for the item being purchased, that specification can be used to select the critical characteristics for this item.
2.
Graded Ouality Assurance The application of graded quality assurance to the CGI dedication process should include consideration of the item's importance to safety and other factors specific to the item being procured. Certain items and services may require extensive controls throughout all stages of development while others may require only a limited quality assurance involvement in selected phases of development. The following factors should be considered in determining the extent of quality assurance to be applied: (a) The importance of malfunction or failure of the item to plant safety. (b) the complexity or uniqueness of the item, (c) the need for special controls and surveillance over process and equipment, (d) the degree to which functional compliance can be demonstrated by
-inspection and test, and (e) the quality history and degree of standardization of the item.
Additional guidance on the use of graded quality assurance can be found in the nonmandatory appendix to American National Standards Institute (ANSI) ANSI N45.2.13-1976.
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3.
Consideration of Failure Modes An evaluation of credible failure modes of an item in its operating environment and the effects of these failure modes on the item's safety function may be used in the safety classification of an item and as a basis for the selection of critical characteristics.
4.
Reasonable Assurance The dedication process represents an acceptable method of achieving compliance with Appendix B to 10 CFR Part 50 with the purchaser assuming many of the responsibilities for ensuring quality and functionality of an item that had previously been the responsibility of the vendor.
In this context, reasonable assurance consists of the purchaser controlling or verifying the activities affecting the item's quality to an extent consistent with the item's importance to safety or ensuring that these activities are adequately controlled by the supplier.
For more complex items, dialogue with the original equipment manufacturer may be necessary to identify the design and functional parameters of specific piece parts. Once the dedication process is completed, the quality assurance and/or other measures applied to those aspects of the item that directly affect its safety function should result in the same level of performance as for a like item manufactured or purchased under a quality assurance program of Appendix B to 10 CFR Part 50.
5.
Encineerina Judament Engineering judgment can be used in selecting those important design, material, and performance characteristics that are identified as the i
l 11em's critical characteristics. The bases for engineering judgment for this application should be documented.
TRACEABilllY Material / Items Purchased From Distributors Traceability can be defined as the ability to verify the history, location, or application of an item by means of recorded identification. Where the item's acceptance is based entirely or partially on a certification by the manufacturer, the traceability must extend to the manufacturer. The purchaser should ensure by survey or by other means that the manufacturer has established adequate trateability controls and that these controls are effectively irplemented.
For situations in which intermediaries (distributors) are included in the supply chain, the activities of these organizations may need to be surveyed to ensure that traceability and proper storage conditions are maintained.
A survey of the distributor may not be
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necessary if the distributor acts only as a broker and does not warehouse or repackage the items or in cases where traceability can be established by other reans such as verification of the manufacturer's markings or shipping records.
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d SAMPLING 1.
Est ablished Heat Trateabilit y (Materials)
When heat traceability of metallic material has been established and each piece of the material is identified with the material heat number, chemical analysis and destructive testing required for the acceptance
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of this material may be performed on one piece of the material. The same rationale may be used 'or the acceptance of containers of nonmetallic materials such as lubricants providing that traceability has been established and each container is identified with a unique mix or batch number.
2.
Established Lot / Batch Control fltems)
When lot / batch (defined as units of product of a single type, grade, class, size, and composition, manufactured under essentially the same conditions and at essentially the same time) control is established i
through a commercial grade survey, the party performing dedication of such items can use sampling prescribed by standard statistical methods that are based on homogeneous product lots. Such sample plans should be identified and shculd provide for the verification of the critical characteristics with confidence level consistent with the item's importance to safety. Other means of demonstrating adequate lot / batch control may include satisfactory performance history and the results of receipt inspection / testing. When such methods are used as a basis for developing product sampling strategy, they should be supported by documented objective evidence.
3.
Material and items With No Lot / Batch Control When lot / batch control cannot be established, sampling plans need to be considered on individual, item-specific basis and ensure that they are capable of providing a high level of assurance of the item's suitability for service.
There may be situations where each item needs to be tested.
COMMERCIAL GRADE SURVEYS 1.
Verification of Vendor's Control of Specific Characteristics A comrercial grade survey should be specific to the scope of the CGI(s) being purchased. The vendor's controls of specific critical charatteristics to be verified during the survey should be identified in the survey plan.
The verification should be accomplished by reviewing the vendor *s program / procedures controlling these characteristics and observing the actual implementation of these controls in the manufacture of items identical or similar to the items being purchased.
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2.
Identification of Acolicable Proaram/ procedures The vendor must have a documented program and/or procedures to control the critical characteristics of the item or items being procured that are to be verified during the survey. When many items are being purchased, a survey of a representative group of similar items may be sufficient to demonstrate that adequate controls exist.
If the vendor's controls are determined to be satisfactory, purchase orders for these items should invoke these controls as contract requirements by referencing the applicable program / procedure (s) and revision.
If multiple working level procedures are applicable to the vendor's activities, which affect the item's critical characteristics and these procedures, in turn, are controlled by a higher level document, it may be appropriate to reference that document in the purchase order.
It is important to ensure that the specific controls reviewed and accepted during the survey be applied during the manufacturing process. Upon completion of the work, the vendor should certify compliance with the purchase order requirements.
3.
Documentation of Survey Results Commercial grade survey documentation should include the identification of the item or items for which the vendor is being surveyed, identification of the critical characteristics of these items that the vendor is expected to control, identification of the controls to be applied (program / procedure and revision), and a description of the verification activities performed and results obtained. Critical characteristics that are not adequately controlled should be addressed by contractually requiring the vendor to institute additional controls or by utilizing other verification and acceptance methods.
4.
Survey Frecuency Commercial grade surveys should be conducted at sufficient frequency to ensure that the process controls applicable to the critical characteristics of the item procured continue to be effectively implemented, factors to be considered in determining the frequency of commercial grade surveys include the complexity of the item, frequency of procurement, receipt inspection, item performance history, and knowledge of changes in the vendor's controls. The survey frequency should not exceed the audit frequency established for 10 CFR Part 50, Appendix B, suppliers.
ACCEPTANCE Of CERTiflED MATERIAL TEST REPORTS (CMTRs) AND CERTiflCATES Of COMPL]ANCE (Cots)
Validitv Verified Ibrouah Vendor / Supplier Audit or Testina When the verification of critical characteristics is based on vendor CMTRs or Cots the validity of these documents should be ensured.
This can be A-4 i
accomplished through a commercial grade survey or, for simple items, periodic testing of the product on receipt. Such verifications should be conducted at intervals commensurate with the vendor's past performance.
If the item's supply chain includes a distributor, a survey of the distributor's activities may be necessary (see " Traceability").
USE Of INDUSTRY GUIDANCE The Electric Power Research Institute (EPRI) NP-5652, " Guideline fcr the Utilization of Commercial Grade Items in Nuclear Safety Related Applications (NCIG-07)," defines critical characteristics as " identifiable and measurable
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attributes /voriables of a CGI, which once selected to be verified, provide NRC's reasonable assurance that the item received is the item specified."
conditional endorsement of EPRI NP-5652 by Generic Letter 89-02 was based on interpreting that in the EPRI definition of critical characteristics the " item specified" encompassed those attributes that are essential for the performance This interpretation is consistent with the of the item's safety function.
definition of " critical characteristics for acceptance" found in EPRI NP-6406,
- Guidelines for the Technical Evaluation of Replacement Items in Nuclear Power Plants.* which notes that critical characteristics for acceptance are a subset The EPRI NP-6406 definition of of " critical characteristics for design."
- critical characteristics for design" includes those attributes that ensure the performance of the item's design function.
published NRC guidance does not differentiate between design and acceptance critical characteristics and the CGI dedication guidance provided in Generic Letters 89-02 and 9]-05 does not suggest that all design requirements of an item need to be verified during the dedication process. Rather, the licensee is expected to identify the item's design, material,_ and performance characteristics that have a direct effect on the item's ability to acccmplish its intended safety function and select from these characteristics a set of critical (or acceptance) characteristics that, once verified, will provide reasonable assurance that the item will perform that function.
Consistency in the definition of critical characteristics can be improved by equating the NRC's definition of critical characteristics to the EPRI definition of
- critical characteristics for acceptance."
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