ML20210M503
| ML20210M503 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1986 |
| From: | Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Schroeppel L VALTEK, INC. |
| References | |
| IEIN-86-021, IEIN-86-21, NUDOCS 8605020300 | |
| Download: ML20210M503 (5) | |
Text
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C Leslie L. Schroeppel April 29, 1986 For your information, the ASME's Subcommittee on Inservice Inspection is also developing a Code Case on this subject which will be discussed at their next meeting' September 8-11, 1986, in Portland, Maine. A copy of the Information Notice and the draft Code Case are enclosed.
Please note that the NRC did not initiate and has not endorsed this Code Case.
I hope this information has been helpful.
If you have any additional questions, please contact Ed Baker who is on my staff (301) 492-4874.
Sincerely, g tegned W oarf ISCD G
Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement
Enclosure:
As stated i
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WASHINGTON, D. C. 20555
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April 29, 1986 Leslie L. Schrmppel Vice President - Administration 1
VALTEK Box 2200 Springville, 'Jtah 84663
Dear Mr. Schroeppel,
Thank you for your comments on this issue.
The NRC is currently developing a position paper on stamping requirements for replacement parts for ASME Code 1
components.
At the present time a large number of manufacturers that supplied ASME Code components to the nuclear industry have not renewed their Certificate of Authorization. This may place nuclear utilities in the position of not being able to purchase replacement parts which meet ASME Code requirements since component designs are usually proprietary.
As a result, utilities would be forced to operate in a degraded condition, which we cannot permit, or to shutdown. The NRC does not have the legal basis to regulate manufacturers or to order them to retain their ASME Certificate of Authorization. The NRC's current regulations require utilities to purchase replacement parts for ASME code components that fully comply with ASME code requirements.
However, we also must use good engineering judgement in allowing alternatives which permit utilities to operate their plants safely.
The NRC is considering allowing utilities to purchase replacement parts from the original manufacturer or the current manufacturer if the product line has been sold, even though the manufacturer does not have an ASME Certificate of Authorization. This alternative is predicated on the utility performing the survey that ASME normally performs and all other Code requirements being met.
If this position paper were the only action the NRC wer, undertaking with regards to the ASME accreditation program, I would tend to agree with you that the publishing of the position paper would result in more nanufacturers giving up their stamps. However, the NRC has recently publishej and distributed to all licensees and vendors an Information Notice announcing the NRC's endorsement of the ASME Accreditation Program. This will allow Silities to place holders of N, NPT, NA and NV stamps and Certificates of Authrtization on their approved bidders list without performing an audit.
This shoubt result in fewer audits of the manufacturers and should help offset the expeme of retaining the ASME Certificate of Authorization.
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Leslie L. Schroeppel April 29,1986 For your information, the ASME's Subcommittee on Inservice Inspection is also developing a Code Case en this subject which will be discussed at their next meeting, September 8-11, 1986, in Portland, Maine. A copy of the Information Notice and the draft Code Case are enclosed.
Please note that the NRC did not initiate and has not endorsed this Code Case.
I hope this information has been helpful.
If you have any additional questions, please contact Ed Baker who is on my staff (301) 492-4874.
Sincerely,
^
3 vit bv Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement
Enclosure:
As stated i
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Inquiry What alternative rules may be used in lieu of the rules contained in IWA-7200 for procuring components or parts that were required by the construction code to be stamped and that no longer can be procured as such?
4 5
D It is the opinion of the Committee that as an alternative to the rules contained in IWA-7200, the following rules may be used for the construction of components and parts that were required by the original construction code to be stamped and j
can no longer be procured as such.
These rules may only be used when the j
original supplier of the component or part no longer has a valid Certificate of Authorization and there are no other suppliers who possess a valid certificate of Authorization.
j 1000 CGO WENTS i
A.
The Owner documents the reason for the replacement in his replacement program in accordance with IWA-7130.
i B.
The services of an Authorized Inspection Agency are used during l
fabrication of 'the component. At'the Owner's discretion, this may be either the Owner or the component manufacturer's agency.
C.
The Owner qualifies the the component manufacturer in accordance with his Quality Assurance Program (e.g. audit).
In cases where the component manufacturer has no formal Quality Assurance Program, the j
Owner may qualify the component itself for use in accordance with his Quality Assurance Program (e.g. testing).
l D.
The Owner reconciles the use of the component in accordance with i
IWA-7210.C.
E.
The Owner shall perform an evaluation of the acceptability of the component in accordance with IWA-7220.
2000 PARTS i
A.
The Owner documents the reason for the replacement in his replacement I
program in accordance with IWA-7130.
8.
The services of an Authorized Inspection Agency are used during fabrication of the part.
At the Owner's descretion, this may be either 1
the Owner or the part manufacturer's agency.
I C.
The Owner qualifies the part manufacturer in accordance with his Quality i
Assurance Program (e.g.
audit).
In cases where the part manufacturer has no formal Quality Assurance Program the Owner may qualify the part l
itself (e.g, testing).
i D.
In lieu of paragraph C, the Owner may fabricate the part utilizing hisSection XI Repair Program in accordance with IWA-4120.
t E.
The Owner reconciles the use of the part in accordance with IWA-7210.C.
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F.
The Owner shall perform an evaluation of the acceptability of the part in accordance with IWA-7220.
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All replacements shall be documented on the NIS-2 Form.
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YW SSINS No.:
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IN 86-21 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 March 31, 1986 IE INFORMATION NOTICE NO. 86-21:
RECOGNITION OF AMERICAN SOCIETY OF MECHANICAL ENGINEERS ACCREDITATION PROGRAM FOR N STAMP NOLDERS Addressees:
All nuclear power facilities holding an operating license (OL) or a construction permit (CP) and all recipients of NUREG-0040 (white book).
Purpose:
This information notice is provided to licensees, construction permit holders, and vendors to inform them of the NRC's recognition of the American Society of Mechanical Engine,ers (ASME) Accreditation Program for holders of N, NPT, NA, and NV stamps and Certificates of Authorization.
It is expected that recipients will review the information for applicability to their facilities.
- However, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.
Discussion:
In March 1991, representatives of the NRC, ASME, and the National Board of Boiler and Pressure Vessel Inspectors (NB) signed an Exchange of Correspondence that outlined an agreement to work toward establishing a single set of quality requirements and recognition by the NRC of ASME's Accreditation Program for N, NA, NPT, and NV stamps and the associated Certificates of Authorization.
Quality System Certificates issued to Material Manufacturers (MM) and Material Suppliers (MS) are excluded from this recognition.
The primary reasons for developing the Exchange of Correspondence were to eliminate overlapping require-ments and to allow NRC licensees and their subcontractors to use the results of the ASME/NB nuclear accreditation and inspection system as an acceptable method for satisfying NRC requirements for evaluating the programmatic adequacy of their suppliers' documented quality assurance (QA) programs.
In a meeting on December 10, 1985, representatives of the NRC, NB, and ASME agreed that based on the requirements contained in the 1986 Edition of the ASME Boiler and Pressure Vessel Code all of the conditions established in the Exchange of Correspondence as prerequisites for NRC recognition of the Accreditation Program had been met.
On this basis, the NRC has sent letters (see attached) to the National Board and ASME recognizing the holding of an I
-1 March 31, 1986 Page 2 of 2 ASME N, NA, NPT or NV Certificate of Authorization as evidence that the holder of the Certificate of Authorization has a documented QA program that meets the requirements of Appendix 8 to 10 CFR 50.
In accordance with the Exchange of Correspondence, the NRC will make the appropriate changes to Regulatory Guides 1.28 and 1.33 in the next revision.
Licensees and their subcontractors, when assessing whether a potential supplier has an acceptable documented QA program, may rely on the fact that ASME has surveyed the supplier and issued a Certificate of Authorization of appropriate scope and for the desired location without performing any additional evaluation of the supplier's QA program.
Licensees and construction permit holders that take credit for the ASME Accreditation Program may have to revise their QA Program.
They are reminded that 10 CFR 50.54(a)(3) and 50.55(f)(3) set forth the requirements for making changes to QA programs.
It should be noted that NRC's recognition applies only to the programmatic aspects of the ASME Accreditation Program.
Licensees, construction permit holders, and their subcontractors are still responsible for ensuring that the supplier is effectively implementing the approved QA program.
No specific action or response is required by this information notice.
If you have any questions regarding this notice, please contact the Regional Administrator of the appropriate NRC regional office or the technical contact listed below.
Edward I dan, Dire,ctor Divisi of Emergency Preparedness and i
Engi ering Response Office of Inspection and Enforcement Technical Contacts:
E. T. Baker, IE 301-492-4874 G. G. Zech, IE 301-492-9663 Attachments:
1.
Letter to ASME 2.
List of Recently Issued IE Information Notices
n Attachm:nt 1
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UNITED STATES March 31,1986
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NUCLEAR REGULATORY COMMISSION n
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WASHINGTON D. C. 20555 e
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March 18, 1986 Mr. Melvin R. Green, Managing Director Codes and Standards American Society of Mechanical Engineers 345 East 47th Street New York, New York 10017
Dear Mr. Green:
SUBJECT:
NRC ENDORSEMENT OF ASME'S ACCREDITATION PROGRAM At the December 10, 1985 meeting of the NRC/ASME/NB Coordinating Committee it was agreed that all conditions established in the Exchange of Correspondence as prerequisites for NRC recognition and endorsement of the ASME Accreditation.
Program had been' met.
At that meeting it was also agreed that the NRC would publish aa information notice comunicating the NRC's recognition and endorse '
ment of the Accreditation Program.
Enclosed is a copy of the information notice which is being sent to all licensees and to other parties on the information notice distribution list.
Sincerely,
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es M. Tay r, Director ffice of I pection and Enforcement
Enclosure:
Information Notice
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IN 86-21 o,
UNITED STATES March 31, 1986 E
NUCLEAR REGULATORY COMMISSION o
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WASHINGTON. D. C. 20655 g
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March 18, 1986 Mr. Donald J. Mcdonald, Executive Director National Board of Boiler & Pressure Vessel Inspectors 1055 Crapper Avenue Columbus, Ohio 43229
Dear Mr. Mcdonald:
SUBJECT:
NRC ENDORSEMENT OF ASME';i ACCREDITATION PROGRAM At the December 10, 1985 meeting of the NRC/ASME/NS Coordinating Committee it was agreed that all cor.ditions established in the Exchange of Correspondence as prerequisites for NRC recognition and endorsement of the ASME Accreditation ;
Program had been ~ met.
At,that meeting it was also agreed that the NRC would publish an information notice communicating th~e NRC's recognition and endorse '
ment of the Accreditation Program.
Enclosed is a copy of the information notice which is being sent to all licensees and to other parties on the inforrration notice distribution list.
Sincerely, i
1
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g fo,ffice of Inspection and Enforcement es M. Tay r, Director
Enclosure:
Information Notice i
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b Attrchment 2 IN 86-21 March 31, 1986 LIST OF RECENTLY ISSUED IE INFORMATION NOTICES Information Date of Notice No.
Subject Issue Issued to 86-20 Low-Level Radioactive Waste 3/28/86 All power reactor Scaling Factors, 10 CFR facilities holding Part 61 an OL or CP 86-19 Reactor Coolant Pump Shaft 3/21/86 All power reactor Failure At Crystal River facilities holding an OL or CP 86-18 NRC On-Scene Response During 3/26/86 All power reactor A Major Emergency facilities holding an OL or CP 86-17 Update Of Failure Of Auto-3/24/86 All power reactor matic Sprinkler System Valves facilities holding To Operate an OL or CP 86-16 Failures To Identify Contain-3/11/86 All power reactor ment Leakage Due To Inadequate facilities holding Local Testing Of BWR Vacuum an OL or CP Relief System Valves 86-15 Loss Of Offsite Power Caused 3/10/86 All power reactor By Problems In Fiber Optics facilities holding Systems an OL or CP 86-14 PWR Auxiliary Feedwater Pump 3/10/86 All power reactor Turbine Control Problems facilities holding an OL or CP S6-13 Standby Liquid Control 2/21/86 All BWR facilities System Squib Valves Failure holding an OL or CP To Fire 86-12 Target Rock Two-Stage SRV 2/25/86 All power reactor Setpoint Drift facilities holding an OL or CP 86-11 Inadequate Service Water 2/25/86 All power reactor Protection Against Core Melt
' facilities holding Frequency an OL or CP OL = Operating License CP = Construction Permit
.