ML20206M556
| ML20206M556 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/21/1988 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20206H903 | List: |
| References | |
| NUDOCS 8812010084 | |
| Download: ML20206M556 (5) | |
Text
EVALUATION OF REPLACEMENT PARTS IN THE CLINTON POWER STATION INTRODUCTION The staff has reviewed relief requests No. 5003 and 5004 from the licensee of the Clinton Power Station (Reference 1) regarding the replacement of. condensers which were produced by Carrier Corporation and installed in HVAC chillhd water and switch gear Heat Removal systems and the replacement of two ASME Ciass 1 valves which were produced by ITT Hamel DAHL/ CON 0 FLOW in the Reactor Recir-culation system for recirculating flow control of dominera11 zed water. The valve equipment numbers are B33-F060A and B33-F0608. Our review also includes additional infomation provided by the licenseit through a discussion in the subsequent confertnce call and their written responses (Reference 3) to staff questions (Reference 2).
THE ISSUE The licensee requested NRC approval to install replacement parts procured from their original vendors who no longer are able to N-stamp this equipment. However, j
the licensee indicated that the replacement parts would meet all other requirements of the original parts.
DISCUSSION l
Regarding cases where the original manufacturer or the current owner of a i
product line is unable to supply replacement in full compliance with the stamping and documentation requirements of Section III of the ASME Code, the I
following staff acceptance criteria provide a means of assuring that a replacement's level of quality is at least equivalent to that of the original Section III construction.
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1.
Replacements should be procured under the utilities Quality Assurance Program that is in conformance with 10 CFR 50, Appendix B.
Replacements procured under this Quality Assurance Program should be subjected,to inspection by the utility to verify that the replacements meet the s
procurement and design requirements. These replacements should be included in the plant operational Quality Assurance list.
2.
The procurement document issued to the mahufacturer should require that:
(a) The replacement be fabricated in accordance with Section !!!, includ-ing inspection by an Authorized Nuclear Inspector. The utility has the option of having their Authorized Inspection Agency (AIA) provide 2
the inspection service ur requiring the manufacturer to contract with j
an AIA.
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(b) The manufacturer snould provide an ASME type certification document l
certifying that all Section !!! requirements ather than stamping have been specified and complied with by the manufacturer. These replace-i 4
ments should be included in an operation Quality Assurance list.
i 3.
The utility should perform an appNpriete vendor audit to assure that i
construction of replacements will be in confonnance with Section !!! of i
the Code, except for'the Code N-symbol stamp, and that the vendor Quality Assurance Drogram meets the requirements of 10 CFR 50. Appendix B and is i
effectively implemented.
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i 4.
Activities perfonned by a utility under Section XI of the Code rnay be delegated to an agent of the utility provided that the agent's Quality Assurance Program is in confonnance with 10 CFR 50, Appendix B any subject to third party surveillance and audit / inspection by an Authorized Inspection Agency.
In order to use the guidance provided above for purchasing replacements, a licensee should first establish that a stamped replacement is not available-In addition, when replacements are required in accordance with Article IWA-7000 of ASME Code,Section XI, Cost should not be used as a justification for purchasing non-stamped parts.
Licensees who choose to use the above guidance should submit a list of replace-runt items and certify their compliance with the NRC position provided herein.
i STAFF EVALUATION As results of our evaluation, we find that this licensee has comitted to do the following:
1.
The replacement parts will be purchased frem the vendors of original parts.
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2.
The replacement parts will have the same functional characteristics as the original parts.
3.
The licensee will impose procurement controls on vendors through their Quality Assurance Program to insure the replacement parts meeting all i
requirements of the ASME Code Section XI Article IWA-7000 and the ap-plicable rules of ASME Code Section III for construction except for code certification. The :ontrols include providing services of Authorized Inspection Agency during fabrication of the replacement parts, conducting survey on vendors QA program, requiring vendors to certify their code compliance on replacement parts, and requiring doeurnentation and veri-fication on vendor's Code Data Report.
4 The licensee's 151 Program Manual will document the control for applica-.
tion of these two relief requests and their control imposed on the vendors.
5.
The licensee's QA Program will be in confonnance with 10 CFR 50, Appenoix B.
The staff believes that the licensee's comitnants as stated above are generally in compliance with our acceptance criteria.
i CONCLUSIONS a
The staff evaluation concludes that the basis provided by the licensee.for justifying their relief requests for replacemant parts is sufficient and therefore, the relief request No.'s 5003 ar.J 5044 are acceptable. However, the licensee should certify compliance with their commitments when replace-ments are complete.
I REFERENCES 1.
Letter, Clinton licensee to NRC, "Inservice Inspection Progran". U-601155, dated March 39, 1988.
2.
Note from S. Hou to J. Stevens, "RAI for Clinton Replacement Parts without ASME Certification", dated July 11, 1988.
l 3.
Letter, Clinton licensee to NRC, "Inservice Inspection". U-601238, dated August 3, 1988.
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