ML20147E346
| ML20147E346 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/1997 |
| From: | Martin T NRC (Affiliation Not Assigned) |
| To: | Sohinki S ENERGY, DEPT. OF |
| References | |
| PROJECT-697 NUDOCS 9702180328 | |
| Download: ML20147E346 (4) | |
Text
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4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION f
WASHINGTON. D.C. 20666-0001 j
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February 13, 1997 j
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i Stephen M. Sohinki, Director Office of Commercial Light Water Reactor Production Defense Programs Department of Energy Washington, DC 20585
SUBJECT:
NRC STAFF'S POSITION ON QUALITY ASSURANCE REQUIREMENTS FOR TRITIUM-PRODUCING BURNABLE ABSORBER RODS (TPBARS)
Dear Mr.-Schinki:
On January 22, 1997, the NRC held a public meeting with the Department of Energy (DOE) to discuss DOE's draft response to the staff's request for additional information on the Pacific Northwest National Laboratory (PNNL)
Report on the Evaluation of the Tritium Producing Burnable Absorber Rod Lead Test Assembly (PNNL-ll419/UC-731), dated November 1996. During this meeting, the staff and DOE were unable to resolve fundamental questions related to the safety classification for the TPBARs. Specifically, DOE and representatives from other participating organizations informed the staff that they considered the TPBARs to be non-safety related. However, they indicated that they would voluntarily apply 10 CFR Part 21 provisions and the PNNL QA program to these items. The staff disagreed and stated that they considered the TPBARs to be safety-related components.
Subsequent to this meeting the staff enduvored to clarify its position on this matter during a conference call with representatives from DOE and PNNL on January 29, 1997. During this conference call the staff emphasized that a basic component, as defined in 10 CFR Part 21, means a structure, system, or component, or part thereof [ emphasis added] that affects its safety function.
Additionally,10 CFR Part 21.3 (C)(ii) defines basic components as items designed and manufactured under a quality assurance program complying with 10 CFR Part 50, Appendix B, or commercial grade items which hwe successfully completed the dedication process.
Because the TPBARs will be installed into active fuel assemblies and will function as burnable poison absorber rods, the staff has concluded that they are part of the fuel assembly and are therefore, part of a basic component.
This position is supported by the Commission's decision presented in the statements of consideration for the final rule concerning 10 CFR Part 21 which stated, in part, that " Commercial grade items do not include items in which their design and manufacturing process require inspections and verifications 97-3/
i to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of an item cannot be verified).
Typical examples include, but are not limited to, fuel assemblies, control rod I
assemblies, and reactor coolant pressure boundary components."
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4 Mr. Sohinki February 13, 1997 i
Based on this excerpt, it is clear that the Commission considered fuel and control rod assemblies to be basic components that, by definition, are designed and manufactured under a quality assurance program complying with 10 CFR Part 50, Appendix B and that parts thereof (e.g., TPBARs) are similarly regarded because of their safety function. This is consistent with our 4
current requirements for fuel and control rod assemblies in all licensed l
reactors.
If you have any questions regarding this staff's position on quality assurance requirements for TPBARs, please contact the project manager, J. H. Wilson, at (301) 415-1108.
4 Sincerely,
{
m Thomas T. Martin, Director Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 697 j
i
Enclosures:
as stated cc:
see next page S
I
0 Project No. 697 DOE Tritium Program cc:
Max Clausen Office of Commercial Light-Water Reactor Production Tritium Project Office U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 DP-60 Records Management Office of Commercial Light-Water Reactor Production Tritium Project Office U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Jerry L. Ethridge, Sr. Program Manager Environmental Technology Division Pacific Northwest National Laboratory Battelle Blvd.
P.O. Box 999 Richland, WA 99352 i
l
l Mr. Sohinki February 13, 1997
)
Based on this excerpt. it is clear that the Commission considered fuel and control rod assemblies to be basic components that, by definition, are designed and manufactured under a quality assurance program complying with 10 CFR Part 50. Appendix B and that parts thereof (e.g.. TPBARs) are similarly regarded because of their safety function.
This is consistent with our current requirements for fuel and control rod assemblies in all licensed j
reactors.
If you have any questions regarding this staff's position on cuality assurance requirements for TPBARs. please contact the project manager, t.
H. Wilson, at (301) 415-1108.
Sincerely.
Thomas T. Martin Director Division of Reactor Program Management Office of Nuclear Reactor Regulation Project No. 697
Enclosures:
as stated DISTRIBUTION:
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