NRC Generic Letter 1991-05

NRC Generic Letter 1991-005: Licensee Commercial-Grade Procurement and Dedication Programs

ML031140508
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Washington Public Power Supply System, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Clinch River
Issue date:	04/09/1991
From:	Partlow J Office of Nuclear Reactor Regulation
To:
References
GL-91-005, NUDOCS 9104030126
Download: ML031140508 (11)

'OA at(o

0 UNITED STATES

NUCLEAR REGULATORY COMMISSION

a WASHINGTON. D. C. 20555 April 9, 1991 FOR

TO: ALL HOLDERS OF OPERATING LICENSES AND CONSTRUCTION PERMITS

NUCLEAR POWER REACTORS

SUBJECT: LICENSEE COMMERCIAL-GRADE PROCUREMENT AND DEDICATION PROGRAMS

(GENERIC LETTER 91-05)

pause in conducting This generic letter notifies the industry of the staff's and identifies a certain procurement inspection and enforcement activities programs number of failures in licensees' coninercial-grade dedication the U.S. Nuclear identified during recent team inspections performed by The pause, which began in March of 1990, will Regulatory Commission (NRC). is to allow licensees end in late summer of 1991. The purpose of the pause developed by sufficient time to fully understand and implement guidance dedication programs.

industry to improve procurement and commercial-grade certain aspects of This generic letter expresses staff positions regarding which would licensee commercial-grade procurement and dedication programs provide acceptable methods to meet regulatory requirements.

13 team inspections of During the period from 1986 to 1989, the NRC conducted programs. During the licensees' procurement and coniTercial-grade dedication a common, programmatic deficiency these inspections, the NRC staff identified process of in the licensees' control of the procurement and dedication In a number of cases, commercial-grade items for safety-related applications. maintain programs as the staff found that licensees had failed to adequately suitability of required by 10 CFR Part 50, Appendix 8, to assure the for its intended safety-related commercially procured and dedicated equipment of indeterminate applications. In addition, the staff identified equipment quality installed in the licensees' facilities.

vendors, the Because of a decrease in the number of qualified nuclear-grade industry's procurement NRC staff is aware that there has been a change in the procured major assemblies from approved practices. Ten years ago, licensees to Appendix B of vendors who maintained quality assurance programs pursuant

(10 CFR). Currently, Part 50 of Title 10 of the Code of Federal Regulations vendors, due to the reduction in the number of qualified nuclear-grade numbers of commercial-grade replacement parts licensees are increasing the applications. This that they procure and dedicate for use in safety-related CFR Part 50,

is a substantial change from the environment in which 10 emphasis by Appendix B was promulgated. This has necessitated anandincreased dedication programs licensees and the NRC staff to maintain procurement B. and thus-assure that adhere to the requirements of 10 CFR Part 50, Appendix applications.

the quality of items purchased and installed in safety-related have increased in Therefore, dedication processes for commercial-grade aparts number of licensees have importance and NRC inspections have determined that process.

not satisfactorily performed this procurement and dedication

9104030126 W~&cL~c 0503 CI~i AOOC-K OSOcOOCX'3.-G

GENERIC LETTER 91-05 -2- in this program The industry has been made fully aware of the NRC's concerns notice to the area. In the past, escalated enforcement cases have provided concerns, and affected licensees and to the industry of NRC'S findings, programs.

expectations in the implementation of procurement and dedication industry meetings Further, the NRC staff continues to participate in numerous been presented.

in this area have and conferences at which the NRC's positions Board of Direc- The Nuclear Utility Management and Resources Council (NUMARC)

procurement initiative as described in tors recently approved a comprehensive which commits NUMARC 90-13, "Nuclear Procurement Program Improvements,"specific action to licensees to assess their procurement programs and take be inadequate. The enhance or upgrade the program if they are determined towhich is part of initiative on the dedication of commercial-grade items, The staff is monitor- NIUMARC 90-13, was to be implemented by January 1, 1990. conducting assessments ing implementation of licensee program improvements byprograms and maintaining of their procurement and commercial-grade dedication in confer- close interaction with the nuclear industry through participation ences, panels, and meetings.

to plant The staff will continue to perform reactive inspections relating will and, as required, specific operational events or to defective equipment the staff continue to initiate resultant enforcement actions. In addition, expects to resume will continue to perform inspections of vendors. The staff summer of 1991.

procurement and dedication inspection activities in the late

10 CFR Part 50, Appendix B

These resumed inspections will be conducted using requirement.

(not the NUMARC initiatives) as the applicable regulatory procured and Licensee programs must assure the suitability of commercially dedicated equipment for its intended safety-related application.

action in The staff position is that the staff will not initiate enforcement corrected. In cases of past programmatic violations that have been adequately to review all past procurements.

addition, the staff does not expect licensees identify However, if during current procurement activities, licensees products, or if shortcomings in the form, fit, or function of specific vendor indicates that a failure experience or current information on supplier adequacy are required for component may not be suitable for service, corrective actions XVI of 10 CFR

all such installed and stored items in accordance with Criterion licensees must Part 50, Appendix B. Also in accordance with Criterion in XVI,

several products from determine programmatic causes when actual deficiencies activities and different vendors are identified during current procurement Part of the these deficiencies lead to the replacement of installed items as procured corrective action. In such cases, a further sampling of previously commercial-grade items may be warranted.

In NRC Generic Letter (GL) 89-02, "Actions to Improve the its Detection of Counterfeit and Fraudulently Marketed Products," the staff described perspective on and provided the NRC's conditional good practices in procurement and dedication

GENERIC LETTER 91- 05 -3- endorsement of an industry standard (EPRI NP-5652) on methods of comneercia1- grade procurement and dedication. A number of recent inspection finid'n2s, as to include discussed in Enclosure 1, indicate that licensees have failed of the dedication certain key activities, as appropriate, in the lmplenieretatioi process. The NRC staff's positions on the successfulwith implementation of licensces programs for contrercial-grade dedication respect to critical replacements are as follows. (These are also characteristics and like-for-like included in Enclosure 1.)

The term "critical characteristics" is not contained in Appendix B and has no special regulatory significance beyond its use used and definition in various industry guides and standards. The KRC first the term critical as constituting those characteristics which need to characteristics in GL 89-02 part of the procurement be identified and verified during product acceptance asdesign requirements must process. The 1NRC has not taken the position that all used in be considered to be critical characteristics as defined andIII, licensees must EPRI flP-5652. Rather, as stated in Appendix 8, Criterion for their intended assure the suitability of all parts, materials, toandbe services assurance that the item safety-related applications (i.e., there reeds required). The licensee is will perform its intended safety functior, when responsible for identifying the important design, material, and performance characteristics for each part, material, and service intended for safety- rel.ted applications, establishing acceptance criteria, and providing reasonable assurance of the conformance of items to these criteria.

A likt-for-like replacemenit is defined as the replacement of an item with an item that is identical. For example, the replacement item would be identical from the same vendor as the item it is if it was purchased at the same time changes in the replacing, or if the user can verify that there have been no of the item being design, materials, or Manufacturing process since procurement in the replaced. If differences from the original item are identified replacement item, then the item is not identical, but similar to the item being any changes in design, repiaced, and an evaluation is necessary to determinetheiffunctional material, or the manufacturing process-could impact characteristics and ultimately the ci.oniponent's ability to perform its required safety function. If the licensee can demonstrate that the replacement item is or review identical, then the licensee need not identity the safety function Engineering and verify the design requirements and critical characteristics. part number involvement is necessary il the above activities. Reliance onto ensure the verification and certification documentation is insufficient quality of comrercially procured produLts.

The other matters discussed In Enclosure I do notfindingscnr.stitute NRC staff positions, but provide information on inspection .and clarify the programs previously characterization of effective procurement and dedication described in GL 89-02.

BACKFIT DISCUSSION

actions, the Based or. past inspection findings and the resulting enforcement procurement and

11RC staff has determined that licensee coirnercial-grade

GENERIC LETTER 91-05 -4- the existing NRC

Iedication prograr's needed to be improved to comply with B, Criterion III (Design requirements as described in 10 CFR Part 50, Appendix VII (Control of Purchased Control), IV (Procurement Document Control), Specifically, licensees Material, Equipment and Services), and XVIIH (Audits).

to assure the suitability of have failed to adequately niaintain programs safety-related fur its intended commiercially procured and dedicated equipment positions regarding application. Since the generic letter presents staff as contained in Appendix E

implementation of existing regulatory requirements, a compliance backfit this is to 10 CFR Part 50, the staff has coricluded, that 10 CFR 50.109 (a)(4)(i).

drd has prepdred the generic letter in accordance with procurement and dedication In light of the inadequacies identified in the of this generic letter is programs of a large number of licensees, the issuance the key element that licensees necessary to express the staff's position on that commercial- must incluce as part of the dedication process, specifically mrust assure the suitability of grade procurement and dedication programs This generic letter is equipment for its intended safety-related application.

and also intended to clarify the elements of effective procurement provided to licensees conmmercial-grade dedication programs that were previously programs may contain in GL 69-02. Since licensees' procurement and dedication generic letter the programmatic deficiencies, the staff has irncluded in the identified in necessary licensee corrective action to address shortcomings to the component not specific vendor products or components that directly lead being suitable for safety-related service.

Although no response to this letter is required, if you have any questions listed below.

regarding this matter, please contact the persons Sincerely, Jes G. Partlow A sociate Director for Projects Office of Nuclear Reactor Regulation Enclosures:

1. Characteristics of Effective Conviercial-Grade Procurement and Dedication Programs

. List of Recently Issued Generic Letters Technical Contacts: Richard P. McIntyre, NRR

(301) 492-3215 Uldis Potapovs, URR

(301) 492-0959

Enclosure 1 CHARACTERISTICS OF-EFFECTIVE COMMERCIAL-GRADE

PROCUREMENT AND DEDiCATION PROGRAMS

Background regulations for procurement Appendix B to 10 CFR Part 50 contains the NRC's for products to be used in quality assurance (QA) and quality control (QC) NRC has provided further -

safety-related applications. In addition, and the

1.28, 1.33, 1.123. These requirements and guidance in Regulatory Guides of assurance for the guides, if properly implemented, provide a measure 'ims for use in suitability of equipment, including commercial-gradeB

1 ires licensees to safety-related systems. Criterion III of Appendix materials, parts, equipment, select and review for suitability of application functions ef the and processes that are essential to the safety-related IV requires that procurement structures, systems, and components. Criterionnecessary to ensure functional documents specify the applicable requirements to assure that the following are performance. Criterion VII requires licenseesrequirements for the purchased sufficient to identify whether specification evaluation and selection, ma.terial and equipment have been met: source the source, and examination of objective evidence of quality, inspection of satisfy these requirements when products upon delivery. The process used to applications is commonly upgrading commercial-grade items for safety-related compliance with 10 CFR Part S0,

called "dedication.* The process of ensuring necessary to establish and Appendix B, must include all those activities procured and dedicated confirm the quality and suitability of commercially Some of the dedication equipment for its intended safety-related application.

cycle before the item is activities may occur early in the procurement (GLi 89-02, "Actions to Improve accepted from the manufacturer. Generic Letter Products, discussed the Detection of Counterfeit and Fraudulently Marketed involvement in the commercial-grade dedication in terms of engineering the dedication process as procurement process, product acceptance, and This enclosure further-discusses identified in the EPRI NP-5652 guidelines.

and dedication programs previously the characteristics of effective procurement of specific failures by licensees discussed in GL 89-02 and provides examples for dedicating and ensuring the to effectively implement these characteristicssafety-related applications.

suitability of commercial-grade products for would have avoided many of Appropriate implementation of these characteristics B requirements in licensee the failures to meet 10 CFR Part 50, Appendixprograms which were identified procurement and commercial-grade dedication during past NRC inspections.

Inspection Observations and Findings personnel conducted 13 team From 1986 to 1989, headquarters and regional programs. These inspec- inspections of licensees' procurement and dedicationdeficiency in licensees'

tions have identified a common, broad programmatic of commercial-grade control over the process of procurement afld dedication

-2- Maintained programs to ensure items. In a number of cases, licensees have not applications as the suitability of equipment for use in safety-related III. These 13 ir.spections required by 10 CFR Part 50, Appendix B, Criterion The staff identified resulted in findings with significant safety implications.III violations and Level eight findings that were considered to be Severity At one plant, the staff three findings that were Severity Level IV violations.

Instead, the staff did not assign a severity level to individual violations.III problem and used enforce- considered the entire group to be a Severity Level pclicy, based on the ment discretion, as provided under the enforcement Appendix C,Section V.G.2).

licensee's corrective actions (see 10 CFR Part 2, receive violations in this Only one of the plants that were inspected did not program area.

the dedication methods In GL 89-02, the NRC has conditionally endorsed believes that licensees who described in EPRI NP-5652 guidelines. The staff with the NRC's endorsement, implement these dedication methods, in accordance requirements of Appendix B

can establish a basis for satisfying the existing the dedication process for to 10 CFR Part 50 as these requirements apply to dedication program commercial-grade items. An effective conmiercial-grade item is suitable for must include provisions to demonstrate that a dedicated establish suitabil- safety-related applications. For a licensee to asadequately appropriate, as part of the ity, certain key activities must be performed, to clarify the dedication dedication process. This generic letter is intended approaches described in GL 89-02.

a couaimon element in During each of the 13 inspections, the staff iderntified was the failure of the licensee each of the inspection findings. This element item was suitable for the to assure that a commercially procured and dedicatedcommercial-grade item must intended safety-related application. A dedicated be equivalent in its ability to perform its intended safety function to the B QA program. The follow- same item procured under a 10 CFR Part 50, Appendix inspection report numbers.

ing is a list of the 13 licensees inspected and the NRC observations on these A sunciary of the general inspection findings and findings follows the list of licensee inspections.

LICENSEE and PLANT INSPECTION REPORT NO.

50-327/86-61

1. Tennessee Valley Authority (Sequoyah) 50-328/86-61

50-206/87-02

2. Southern California Edison (San Onufre) 50-361/87-03

50-362/87-04

50-348/87-11

3. Alabama Power (Farley) 50-364/87-11 Louisiana Power and Light (Waterford)

50-382/87-19

4.

-3- INSPECTION REPORT NO.

LICENSEE and PLANT

(Rancho Seco) 50:312/88-02

5. Sacramento Municipal Utility District

• 50-309/88-200

6. Maine Yankee Atomic Power (Maine Yankee)

50-282188-201

7. Northern States Power (Prairie Island) 50-306/88-201

50-344188-39

8. Portland General Electric (Trojan) 50-344/88-46 Neck) 50-213/89-200

9. Connecticut Yankee Atomic Power (Haddam (WHP-2) 50-397/89-21

'O. washington Public Power Supply System 50-397/89-28

50-302/89-200

II. Florida Power (Crystal River)

50-458/89-200

12. Gulf States Utilities (River Bend)

50-295/89-200

13. Connonwealth Edison (Zion) 50-304/89-200

1. Inspection Findings criteria for verify- a. Failure to identify the methods and acceptance inspection, ing the critical characteristics, such testing. receipt as during dedication process, or post-installation traceability of complex b. Failure to establish verifiable, documented equipment manufacturers in commercial-grade items to their original verify the critical those cases where the dedication program cannot characteristics.

items cannot be c. Failure to recognize that some commercial-grade items are manufac- fully dedicated once received on site. Certain and heat treating.

tured using special processes, such as welding products would destroy Dedication testing of these items as finished to conduct vendor sur- them. For these items, licensees may need during the manufacturing veillances or to witness certain activities process.

Discussion with NUMARC and licensee The NRC staff has met on several occasions as used. in-the representatives to discuss "critical characteristics'

and dedication. The term "criti- context of commercial-grade procurement B and has no special cal characteristics" is not contained in Appendix in various industry regulatory significance beyond its use and definition

-4- guides and standards. The NRC first used the term critical characterls- tics in GL 89-02 as constituting those characteristics which nbed to be identified and verified during product acceptance as part of the procurement process. The ARC has not taken the position that all-design requirements must be considered to be critical characteristics as defined and used in EPRI NP-5652. Rather, as stated in Appetidix S, Criterion 11!,

licensees must assure the suitability of all parts, Materials, and services for their intended safety-related applications (i.e., there needs to be assurance that the item will perform its intended safety function when required). The licensee is responsible for identifying the important design, material, and performance characteristics for each part, material, and service intended for safety-related applirations, establishing acceptance criteria, and providing reasonable assurance of the conformance of items to these criteria. There is no nilniun. or maximum number of critical characteristics that need to be verified. Further, the critical characteristics for an item may vary from application to application depending on the design and performance requirements unique to each application.

A licensee may take different approaches for the verification of the critical characteristics, depending on the complexity of the item. In nmany cases, the licensee can verify the critical characteristics of eac'h item during receipt inspection testing. However, for a complex item with internal parts which receive special processing during Manufacturing, the licensee may need to conduct a source verification of the manu- facturer during production to verify the critical characteristics identified as necessary for the item to perform its safety function. When these methuds cannot verify the critical characteristics related to special processes and tests, certification by the original equipment manufacturer nay be an acceptable alternative provided documented, verified traceability to the original equipment manufacturer has beet.

established and the purchaser has vecrified by audit or survey that the original equipment manufacturer has itaiplemented adequate quality controls for the activity being certified.

For items with critical characteristics that can be verified for the most severe or limiting plant application, the licensee might prefer to identify and verify the item's critical characteristics to qualify that item for all possible plant applications. For complex items that would be purchased for specific plant applications it may be appropriate to address the acceptance criteria for each item individually. Engineering involvement is important in either method because the technical evaluation will identify the critical characteristics, acceptance criteria, and the miethods to be used for verification.

Inspection Findings a. Failure to demonstrate that a like-fur-like replacement iteml is identical in form, fit, and function to the item it is replacing.

Part number verification is not sufficient because of the probability of undocumented changes in the design, material, or fabrication of commercial-grade items using the same part number.

-5- or manufactur- on&terial, b. Failure to evaluatc changes in the design' function ing process fur the effect of these chances on safety under design. basis event condltions) of perforLMIce (particularly are similar as opposed to identical to the replacement items that items being replaced.

design require- c. Failure to ensure that itemrs will function under all thbt the commercil- meents. On some occasions, licensees only ensured cor.ditions.

,grade item would function ui.der normal operation d. Failure to verify the validity of certificates of conformarnce received from vendors not on the licensee's list of approved vendors/

commercial- suppliers. An unverified certificate of conformance from a gradc vetdur isnot sufficient.

Discussion A like-for-like replacement isdefined as the the replacement of an item with uri itein that is identical. For example, timereplacement item would be from. the same vendor as the identical if it was purchased at the same verify that there have been no item it isreplacing, or ifthe user can process since changes inthe design, materials, or manufacturiqg If differences from the original procurement of the item being replaced. then the item is rot item, ite.i iare identified inthe replacement replaced, and evaluation is identical, but similar to the item being design, material, or the necessary to determine ifany changes in characteristics and n.anufacturing process could impact the functional its required safety func- ultimately the com.ponent's ability to perform replacement item is tion. Ifthe licersee can demonstrate that the the safety function or identical, then the licensee need not identify critical characteristics.

review and verify the design requirements and Engineering involvement isnecessary ill the above activities. The extent uf this Involvement. is lependent on the nature, conmplexity, and use of engineering personnel is the items to be dedicated. Participation of product to appropriate inthe procurement process, and specific acceptance, testing requirements develop purchase rpecificaticns, determinethe test results. When engi- applicable to the products, and evaluate reering personnel specify design requirements for inclusion on the they need not reconstruct purchase documents for replacement components,purposes, need only and reverify design adequacy for procurement (which may but reference the ensure that the existing design requirements into the purchase order.

original design basis) are properly translated Reliance on part number verification and certification documentation is procured products.

insufficient to ensure the quality of coniercially as elements, receipt and source Effective product acceptance programs have effective vendor audits Ltd inspection, appropriate testinS criteria, as appropriate), special surveillances (including witness/hold points tests. Procedures and tests and inspections, and post-installation are also adequ:te qualificatio!Is and training for implementing personnel r.ecessory factors insuccessful implenmentationr.

Enclosure 2 LIST OF RECENTLY ISSUED GENERIC LETTERS

Generic Date of Subject Issuance Issued To Letter No. N SUR- ALL HOLDERS OF OL

91-04 CHARGES IN TECHNICAL SPECI lCATM

VEILLANCE INTERVALS

V TO ACCOMMODATE A 24- OR CONSTRUCTION PER-

MONTH FUEL CYCLE (GENERIC LETTER 91-04) MITS FOR NUCLEAR

I POWER REACTORS

03/06/91 ALL HOLDERS OF OLs

91-03 REPORTING OF SAFEGUARDS OR CPs FOR NUCLEAR

EVENTS POWER REACTORS AND

ALL OTHER LICENSED -

ACTIVITIES INVOLVING

A FORMULA QUANTITY

OF SPECIAL NUCLEAR.

MATERIAL (SNM)

REPORTING MISHAPS INVOLVING 12/28/90 ALL OPERATORS OF

91-02 LOW-LEVEL RADIO-

LLW FORMS PREPARED FOR

DISPOSAL ACTIVE WASTE (LLW)

DISPOSAL SITES,

WASTE PROCESSORS,

& ALL HOLDERS OF

LICENSES FOR NUCLEAR

FUELS, NUCLEAR

MATERIALS & NUCLEAR

POWER REACTORS

REMOVAL-OF THE SCHEDULE FOR 01/04/91 ALL HOLDERS OF OLs

91-01 OR CPs FOR NUCLEAR

THE WITHDRAWAL OF REACTOR

VESSEL MATERIAL SPECIMENS POWER PLANTS

FROM TECHNICAL SPECIFICATIONS

91-01 ALTERNATIVE REQUIREMENTS FOR 12/11/90 ALL LIGHT-WATER

90-09 REACTOR LICENSEES

SNUBBER VISUAL INSPECTION

INTERVALS AND CORRECTIVE AND APPLICANTS

ACTIONS

CONSIDERATION OF THE RESULTS 10/25/90 ALL LICENSEES OF

89-10 OPERATING NUCLEAR

SUPP. 3 OF NRC-SPONSORED TESTS OF

MOTOR-OPERATED VALVES POWER PLANTS AND

HOLDERS OF CONSTRUC-

TION PERMITS FOR

NUCLEAR POWER PLANTS

SIMULATION FACILITY 08/10/90 ALL HOLDERS OF

90-08 OPERATING LICENSES

EXEMPTIONS

OR CONSTRUCTION

PERMITS FOR NUCLEAR

POWER REACTORS

OPERATOR LICENSING NATIONAL 08/10/90 ALL POWER REACTOR

90-07 LICENSEES AND

EXAMINATION SCHEDULE

APPLICANTS FOR AN

OPERATING LICENSE

AVAILABILITY OF PROGRAM 08/03/90 ALL LICENSEES OF

89-10 OPERATING NPPs AND

SUPP. 2 DESCRIPTIONS

HOLDERS OF CPs FOR

NPIPs

-4- GENLRIC LETTER 91- 05 existing DRC

dedication proranms needed in to be improvetd to comppy with the Criterion I.I-(Design

10 CFR Part 50, Appendix 6, recuirements as described Control), VII (Control of Purchased licensees Control;-, IV (Procurement Docunient and XVIII (Audits). Specifically, Imattrii'l, Equipment anoa Services), programsto assure the suitability of hac failed to adtquately maintain equiprent for its intended safety-related cornpercilily procured and dedicated positions regarding

3".icatiofl. Since the ierQeric letter presents staftas contained in Appexdix b requirements, ir-tplenfleritction of existing regulaory that this is a compliance backfit to 10 CFR Pirt 5G, the '.taff has conckded, in accordance with 10 CFR 50.109 (a)(4)(i).

.:d has prerared the gti.Lric letter in the procurement and dedication ir.light of the inadequ'Lies identified the issuance of this generic letter is pruyrar.,. Lf a lar;e n1upter of licensees, necessary Itl vxpress the staff's position on the key element that licensees part of the dedication process, specifically that cowtmercial- ritL5 includc as of must assure the suitabilit)

Srade pruLcureifent and &ctication prograns application. This generic letter is cuipelnt f 'rits interded safety-rclated of effective procuremuent and also irt;e.LUd to clarify the elenents that were previcusly provided to licensees corr.erciel -jrade cedic~.ition proSrams and dedicatiot1 programs -ay contain

. bL 8§-02. Since licersees' procurementincluaed in the gereric letter the prr(drarnatc deficiencies, the staff has

.icensee corrective action to address shortcot..ings identified in rLot necessary that directly lead to the component spjL'lc vender products or components bei-c suitable fc,r .Ltety-rclated service.

have any questions no resr ctise tu this letter is required, if )uu below.

rt,...;UCh thb personIs listed reourdinc this .c.;ttr, plebsE contact Sincerel),

ORIGINAL SIGNED BY:

%lmes G. Partlob Associate sirector for Projects Office of Nuclear Reactor Regulatiiun F.rc cf Eftfe: .tC Coribercial-Gradte DISTRIBUTION:

uit;.ren~ei.t and ~Jedicatiunl Progru~s enetriFr 0ies NRC PDR

7. List, of Fie..evty :edGeneric Litttrs VIB Reading Pichaire P. cIcntyre, NF~R RMcIntyre lectii,(Lal Ccortlact,.: 11cL2l 492-3215 L'. 4 (y.

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