NRC Generic Letter 1991-05: Difference between revisions

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{{#Wiki_filter:'OA a t(o 0 UNITED STATES NUCLEAR REGULATORY  
{{#Wiki_filter:'OA at(o
COMMISSION
        0                           UNITED STATES
a WASHINGTON.
                          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.


D. C. 20555 April 9, 1991 TO: ALL HOLDERS OF OPERATING
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.
LICENSES AND CONSTRUCTION
PERMITS FOR NUCLEAR POWER REACTORS SUBJECT: LICENSEE COMMERCIAL-GRADE
PROCUREMENT
AND DEDICATION
PROGRAMS (GENERIC LETTER 91-05)This generic letter notifies the industry of the staff's pause in conducting certain procurement inspection and enforcement activities and identifies a number of failures in licensees'
coninercial-grade dedication programs identified during recent team inspections performed by the U.S. Nuclear Regulatory Commission (NRC). The pause, which began in March of 1990, will end in late summer of 1991. The purpose of the pause is to allow licensees sufficient time to fully understand and implement guidance developed by industry to improve procurement and commercial-grade dedication programs.This generic letter expresses staff positions regarding certain aspects of licensee commercial-grade procurement and dedication programs which would provide acceptable methods to meet regulatory requirements.


During the period from 1986 to 1989, the NRC conducted  
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.
13 team inspections of the licensees'  
procurement and coniTercial-grade dedication programs.


During these inspections, the NRC staff identified a common, programmatic deficiency in the licensees'
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
control of the procurement and dedication process of commercial-grade items for safety-related applications.
                                                                      (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.


In a number of cases, the staff found that licensees had failed to adequately maintain programs as required by 10 CFR Part 50, Appendix 8, to assure the suitability of commercially procured and dedicated equipment for its intended safety-related 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.


In addition, the staff identified equipment of indeterminate quality installed in the licensees'  
not satisfactorily performed this procurement and dedication
facilities.
  9104030126      W~&cL~c              0503                                  CI~i AOOC-K      OSOcOOCX'3.-G


Because of a decrease in the number of qualified nuclear-grade vendors, the NRC staff is aware that there has been a change in the industry's procurement practices.
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.


Ten years ago, licensees procured major assemblies from approved vendors who maintained quality assurance programs pursuant to Appendix B of Part 50 of Title 10 of the Code of Federal Regulations
expectations in the implementation of procurement and dedication industry meetings Further, the NRC staff continues to participate in numerous              been presented.
(10 CFR). Currently, due to the reduction in the number of qualified nuclear-grade vendors, licensees are increasing the numbers of commercial-grade replacement parts that they procure and dedicate for use in safety-related applications.


This is a substantial change from the environment in which 10 CFR Part 50, Appendix B was promulgated.
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.


This has necessitated an increased emphasis by licensees and the NRC staff to maintain procurement and dedication programs that adhere to the requirements of 10 CFR Part 50, Appendix B. and thus-assure the quality of items purchased and installed in safety-related applications.
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.


Therefore, dedication processes for commercial-grade parts have increased in importance and NRC inspections have determined that a number of licensees have not satisfactorily performed this procurement and dedication process.9104030126 W~&cL~c 0503 AOOC-K OSOcOOCX'3.-G
procurement and dedication inspection activities    in the   late
CI~i GENERIC LETTER 91-05-2-The industry has been made fully aware of the NRC's concerns in this program area. In the past, escalated enforcement cases have provided notice to the affected licensees and to the industry of NRC'S findings, concerns, and expectations in the implementation of procurement and dedication programs.Further, the NRC staff continues to participate in numerous industry meetings and conferences at which the NRC's positions in this area have been presented.
                                                        10  CFR  Part    50, Appendix B
  These resumed inspections will be conducted using                  requirement.


The Nuclear Utility Management and Resources Council (NUMARC) Board of Direc-tors recently approved a comprehensive procurement initiative as described in NUMARC 90-13, "Nuclear Procurement Program Improvements," which commits licensees to assess their procurement programs and take specific action to enhance or upgrade the program if they are determined to be inadequate.
(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.


The initiative on the dedication of commercial-grade items, which is part of NIUMARC 90-13, was to be implemented by January 1, 1990. The staff is monitor-ing implementation of licensee program improvements by conducting assessments of their procurement and commercial-grade dedication programs and maintaining close interaction with the nuclear industry through participation in confer-ences, panels, and meetings.The staff will continue to perform reactive inspections relating to plant specific operational events or to defective equipment and, as required, will continue to initiate resultant enforcement actions. In addition, the staff will continue to perform inspections of vendors. The staff expects to resume procurement and dedication inspection activities in the late summer of 1991.These resumed inspections will be conducted using 10 CFR Part 50, Appendix B (not the NUMARC initiatives)
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.
as the applicable regulatory requirement.


Licensee programs must assure the suitability of commercially procured and dedicated equipment for its intended safety-related application.
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.


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


In addition, the staff does not expect licensees to review all past procurements.
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.


However, if during current procurement activities, licensees identify shortcomings in the form, fit, or function of specific vendor products, or if failure experience or current information on supplier adequacy indicates that a component may not be suitable for service, corrective actions are required for all such installed and stored items in accordance with Criterion XVI of 10 CFR Part 50, Appendix B. Also in accordance with Criterion XVI, licensees must determine programmatic causes when actual deficiencies in several products from different vendors are identified during current procurement activities and these deficiencies lead to the replacement of installed items as Part of the corrective action. In such cases, a further sampling of previously procured commercial-grade items may be warranted.
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.


In NRC Generic Letter (GL) 89-02, "Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products," the staff described its perspective on good practices in procurement and dedication and provided the NRC's conditional GENERIC LETTER 91- 05-3-endorsement of an industry standard (EPRI NP-5652) on methods of comneercia1- grade procurement and dedication.
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.
 
A number of recent inspection finid'n2s, as discussed in Enclosure
1, indicate that licensees have failed to include certain key activities, as appropriate, in the lmplenieretatioi of the dedication process. The NRC staff's positions on the successful implementation of licensces programs for contrercial-grade dedication with respect to critical characteristics and like-for-like replacements are as follows. (These are also included in Enclosure
1.)The term "critical characteristics" is not contained in Appendix B and has no special regulatory significance beyond its use and definition in various industry guides and standards.
 
The KRC first used the term critical characteristics in GL 89-02 as constituting those characteristics which need to be identified and verified during product acceptance as part of the procurement process. The 1NRC has not taken the position that all design requirements must be considered to be critical characteristics as defined and used in EPRI flP-5652.
 
Rather, as stated in Appendix 8, Criterion III, licensees must assure the suitability of all parts, materials, and services for their intended safety-related applications (i.e., there reeds to be assurance that the item will perform its intended safety functior, when required).
The licensee is 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 if it was purchased at the same time from the same vendor as the item it is replacing, or if the user can verify that there have been no changes in the design, materials, or Manufacturing process since procurement of the item being replaced.
 
If differences from the original item are identified in the replacement item, then the item is not identical, but similar to the item being repiaced, and an evaluation is necessary to determine if any changes in design, material, or the manufacturing process-could impact the functional characteristics and ultimately the ci.oniponent's ability to perform its required safety function.
 
If the licensee can demonstrate that the replacement item is identical, then the licensee need not identity the safety function or review and verify the design requirements and critical characteristics.
 
Engineering involvement is necessary il the above activities.
 
Reliance on part number verification and certification documentation is insufficient to ensure the quality of comrercially procured produLts.The other matters discussed In Enclosure I do not cnr.stitute NRC staff positions, but provide information on inspection findings .and clarify the characterization of effective procurement and dedication programs previously described in GL 89-02.


==BACKFIT DISCUSSION==
==BACKFIT DISCUSSION==
:
:
Based or. past inspection findings and the resulting enforcement actions, the 11RC staff has determined that licensee coirnercial-grade procurement and GENERIC LETTER 91-05-4-Iedication prograr's needed to be improved to comply with the existing NRC requirements as described in 10 CFR Part 50, Appendix B, Criterion III (Design Control), IV (Procurement Document Control), VII (Control of Purchased Material, Equipment and Services), and XVIIH (Audits).
                                                                              actions, the Based or. past inspection findings and the resulting enforcement procurement    and
Specifically, licensees have failed to adequately niaintain programs to assure the suitability of commiercially procured and dedicated equipment fur its intended safety-related application.
  11RC staff has determined that licensee coirnercial-grade


Since the generic letter presents staff positions regarding implementation of existing regulatory requirements, as contained in Appendix E to 10 CFR Part 50, the staff has coricluded, that this is a compliance backfit drd has prepdred the generic letter in accordance with 10 CFR 50.109 (a)(4)(i).
GENERIC LETTER 91-05                    -4- the existing NRC
In light of the inadequacies identified in the procurement and dedication programs of a large number of licensees, the issuance of this generic letter is necessary to express the staff's position on the key element that licensees must incluce as part of the dedication process, specifically that commercial- grade procurement and dedication programs mrust assure the suitability of equipment for its intended safety-related application.
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.


This generic letter is also intended to clarify the elements of effective procurement and conmmercial-grade dedication programs that were previously provided to licensees in GL 69-02. Since licensees'  
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.
procurement and dedication programs may contain programmatic deficiencies, the staff has irncluded in the generic letter the necessary licensee corrective action to address shortcomings identified in specific vendor products or components that directly lead to the component not being suitable for safety-related service.Although no response to this letter is required, if you have any questions regarding this matter, please contact the persons listed below.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 Appendix B to 10 CFR Part 50 contains the NRC's regulations for procurement quality assurance (QA) and quality control (QC) for products to be used in safety-related applications.


In addition, the NRC has provided further -guidance in Regulatory Guides 1.28, 1.33, and 1.123. These requirements and guides, if properly implemented, provide a measure of assurance for the suitability of equipment, including commercial-grade
Although no response to this letter is required, if     you have any questions listed  below.
'ims for use in safety-related systems. Criterion III of Appendix B 1 ires licensees to select and review for suitability of application materials, parts, equipment, and processes that are essential to the safety-related functions ef the structures, systems, and components.


Criterion IV requires that procurement documents specify the applicable requirements necessary to ensure functional performance.
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


Criterion VII requires licensees to assure that the following are sufficient to identify whether specification requirements for the purchased ma.terial and equipment have been met: source evaluation and selection, objective evidence of quality, inspection of the source, and examination of products upon delivery.
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.


The process used to satisfy these requirements when upgrading commercial-grade items for safety-related applications is commonly called "dedication.*
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.
The process of ensuring compliance with 10 CFR Part S0, Appendix B, must include all those activities necessary to establish and confirm the quality and suitability of commercially procured and dedicated equipment for its intended safety-related application.


Some of the dedication activities may occur early in the procurement cycle before the item is accepted from the manufacturer.
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.


Generic Letter (GLi 89-02, "Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products, discussed commercial-grade dedication in terms of engineering involvement in the procurement process, product acceptance, and the dedication process as identified in the EPRI NP-5652 guidelines.
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.


This enclosure further-discusses the characteristics of effective procurement and dedication programs previously discussed in GL 89-02 and provides examples of specific failures by licensees to effectively implement these characteristics for dedicating and ensuring the suitability of commercial-grade products for safety-related applications.
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


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


Inspection Observations and Findings From 1986 to 1989, headquarters and regional personnel conducted
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).
13 team inspections of licensees'
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.
procurement and dedication programs.


These inspec-tions have identified a common, broad programmatic deficiency in licensees'
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
control over the process of procurement afld dedication of commercial-grade  
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.
-2-items. In a number of cases, licensees have not Maintained programs to ensure the suitability of equipment for use in safety-related applications as required by 10 CFR Part 50, Appendix B, Criterion III. These 13 ir.spections resulted in findings with significant safety implications.


The staff identified eight findings that were considered to be Severity Level III violations and three findings that were Severity Level IV violations.
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.


At one plant, the staff did not assign a severity level to individual violations.
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.


Instead, the staff considered the entire group to be a Severity Level III problem and used enforce-ment discretion, as provided under the enforcement pclicy, based on the licensee's corrective actions (see 10 CFR Part 2, Appendix C, Section V.G.2).Only one of the plants that were inspected did not receive violations in this program area.In GL 89-02, the NRC has conditionally endorsed the dedication methods described in EPRI NP-5652 guidelines.
LICENSEE and PLANT                                      INSPECTION REPORT NO.


The staff believes that licensees who implement these dedication methods, in accordance with the NRC's endorsement, can establish a basis for satisfying the existing requirements of Appendix B to 10 CFR Part 50 as these requirements apply to the dedication process for commercial-grade items. An effective conmiercial-grade dedication program must include provisions to demonstrate that a dedicated item is suitable for safety-related applications.
50-327/86-61
 
  1.   Tennessee Valley Authority (Sequoyah)                      50-328/86-61
For a licensee to adequately establish suitabil-ity, certain key activities must be performed, as appropriate, as part of the dedication process. This generic letter is intended to clarify the dedication approaches described in GL 89-02.During each of the 13 inspections, the staff iderntified a couaimon element in each of the inspection findings.
                                                                    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.


This element was the failure of the licensee to assure that a commercially procured and dedicated item was suitable for the intended safety-related application.
-3- INSPECTION REPORT NO.


A dedicated commercial-grade item must be equivalent in its ability to perform its intended safety function to the same item procured under a 10 CFR Part 50, Appendix B QA program. The follow-ing is a list of the 13 licensees inspected and the inspection report numbers.A sunciary of the general inspection findings and NRC observations on these findings follows the list of licensee inspections.
LICENSEE and PLANT
                                            (Rancho Seco)            50:312/88-02
5. Sacramento Municipal Utility District


LICENSEE and PLANT INSPECTION
REPORT NO.1. Tennessee Valley Authority (Sequoyah)
50-327/86-61
50-328/86-61
2. Southern California Edison (San Onufre) 50-206/87-02
50-361/87-03
50-362/87-04
3. Alabama Power (Farley) 50-348/87-11
50-364/87-11
4. Louisiana Power and Light (Waterford)
50-382/87-19
-3-INSPECTION
REPORT NO.LICENSEE and PLANT 5. Sacramento Municipal Utility District (Rancho Seco)6. Maine Yankee Atomic Power (Maine Yankee)7. Northern States Power (Prairie Island)8. Portland General Electric (Trojan)9. Connecticut Yankee Atomic Power (Haddam Neck)'O. washington Public Power Supply System (WHP-2)II. Florida Power (Crystal River)12. Gulf States Utilities (River Bend)13. Connonwealth Edison (Zion)50:312/88-02
* 50-309/88-200
* 50-309/88-200
50-282188-201
6. Maine Yankee Atomic Power (Maine Yankee)
50-306/88-201
                                                                    50-282188-201
50-344188-39
7. Northern States Power (Prairie Island)                            50-306/88-201
50-344/88-46
                                                                    50-344188-39
50-213/89-200
8. Portland General Electric (Trojan)                                50-344/88-46 Neck)                  50-213/89-200
50-397/89-21
9. Connecticut Yankee Atomic Power (Haddam (WHP-2)                  50-397/89-21
50-397/89-28
'O. washington Public Power Supply System                            50-397/89-28
50-302/89-200
                                                                      50-302/89-200
50-458/89-200
II. Florida Power (Crystal River)
50-295/89-200
                                                                      50-458/89-200
50-304/89-200
12.  Gulf States Utilities (River Bend)
1. Inspection Findings a. Failure to identify the methods and acceptance criteria for verify-ing the critical characteristics, such as during receipt inspection, dedication process, or post-installation testing.b. Failure to establish verifiable, documented traceability of complex commercial-grade items to their original equipment manufacturers in those cases where the dedication program cannot verify the critical characteristics.
                                                                      50-295/89-200
 
13.  Connonwealth Edison (Zion)                                      50-304/89-200
c. Failure to recognize that some commercial-grade items cannot be fully dedicated once received on site. Certain items are manufac-tured using special processes, such as welding and heat treating.Dedication testing of these items as finished products would destroy them. For these items, licensees may need to conduct vendor sur-veillances or to witness certain activities during the manufacturing process.Discussion The NRC staff has met on several occasions with NUMARC and licensee representatives to discuss "critical characteristics'
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.
as used. in-the context of commercial-grade procurement and dedication.
 
The term "criti-cal characteristics" is not contained in Appendix B and has no special regulatory significance beyond its use and definition in various industry
-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.
items cannot be c.   Failure to recognize that some commercial-grade items are manufac- fully dedicated once received on site. Certain and heat treating.


Further, the critical characteristics for an item may vary from application to application depending on the design and performance requirements unique to each application.
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.


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.
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


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.
-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.


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.
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.


For complex items that would be purchased for specific plant applications it may be appropriate to address the acceptance criteria for each item individually.
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.


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.
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.
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.
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-b. Failure to evaluatc changes in the design' on&terial, or manufactur- ing process fur the effect of these chances on safety function perforLMIce (particularly under design. basis event condltions)  
-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.
of replacement items that are similar as opposed to identical to the items being replaced.c. Failure to ensure that itemrs will function under all design require-meents. On some occasions, licensees only ensured thbt the commercil-,grade item would function ui.der normal operation cor.ditions.


d. Failure to verify the validity of certificates of conformarnce received from vendors not on the licensee's list of approved vendors/suppliers.
design require- c.     Failure to ensure that itemrs will function under all      thbt the commercil- meents.  On some occasions, licensees only ensured cor.ditions.


An unverified certificate of conformance from a commercial- gradc vetdur is not sufficient.
,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 is defined as the replacement of an item with uri itein that is identical.
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.


For example, the replacement item would be identical if it was purchased at the same time from. the same vendor as the item it is replacing, or if the user can verify that there have been no changes in the design, materials, or manufacturiqg process since procurement of the item being replaced.
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.


If differences from the original ite.i iare identified in the replacement item, then the item is rot identical, but similar to the item being replaced, and evaluation is necessary to determine if any changes in design, material, or the n.anufacturing process could impact the functional characteristics and ultimately the com.ponent's ability to perform its required safety func-tion. If the licersee can demonstrate that the replacement item is identical, then the licensee need not identify the safety function or review and verify the design requirements and critical characteristics.
original design basis) are properly translated Reliance on part number verification and certification            documentation is procured      products.


Engineering involvement is necessary ill the above activities.
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.


The extent uf this Involvement.
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.


is lependent on the nature, conmplexity, and use of the items to be dedicated.
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


Participation of engineering personnel is appropriate in the procurement process, and product acceptance, to develop purchase rpecificaticns, determine specific testing requirements applicable to the products, and evaluate the test results. When engi-reering personnel specify design requirements for inclusion on the purchase documents for replacement components, they need not reconstruct and reverify design adequacy for procurement purposes, but need only ensure that the existing design requirements (which may reference the original design basis) are properly translated into the purchase order.Reliance on part number verification and certification documentation is insufficient to ensure the quality of coniercially procured products.Effective product acceptance programs have as elements, receipt and source inspection, appropriate testinS criteria, effective vendor audits Ltd surveillances (including witness/hold points as appropriate), special tests and inspections, and post-installation tests. Procedures and adequ:te qualificatio!Is and training for implementing personnel are also r.ecessory factors in successful implenmentationr.
-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'l''c vender products or components bei-c suitable fc,r .Ltety-rclated service.


Enclosure
have any  questions no resr ctise            tu this letter is required, if )uu below.
2 LIST OF RECENTLY ISSUED GENERIC LETTERS Generic Date of Letter No. Subject Issuance Issued To 91-04 CHARGES IN TECHNICAL
SPECI lCATM N SUR- ALL HOLDERS OF OL V VEILLANCE
INTERVALS
TO ACCOMMODATE
A 24- OR CONSTRUCTION
PER-I MONTH FUEL CYCLE (GENERIC LETTER 91-04) MITS FOR NUCLEAR POWER REACTORS 91-03 91-02 91-01 91-01 90-09 REPORTING
OF SAFEGUARDS
03/06/91 EVENTS REPORTING
MISHAPS INVOLVING
12/28/90 LLW FORMS PREPARED FOR DISPOSAL REMOVAL-OF
THE SCHEDULE FOR 01/04/91 THE WITHDRAWAL
OF REACTOR VESSEL MATERIAL SPECIMENS FROM TECHNICAL
SPECIFICATIONS
ALTERNATIVE
REQUIREMENTS
FOR 12/11/90 SNUBBER VISUAL INSPECTION
INTERVALS
AND CORRECTIVE
ACTIONS CONSIDERATION
OF THE RESULTS 10/25/90 OF NRC-SPONSORED
TESTS OF MOTOR-OPERATED
VALVES SIMULATION
FACILITY 08/10/90 EXEMPTIONS
OPERATOR LICENSING
NATIONAL 08/10/90 EXAMINATION
SCHEDULE AVAILABILITY
OF PROGRAM 08/03/90 DESCRIPTIONS
ALL HOLDERS OF OLs OR CPs FOR NUCLEAR POWER REACTORS AND ALL OTHER LICENSED -ACTIVITIES
INVOLVING A FORMULA QUANTITY OF SPECIAL NUCLEAR.MATERIAL (SNM)ALL OPERATORS
OF LOW-LEVEL
RADIO-ACTIVE WASTE (LLW)DISPOSAL SITES, WASTE PROCESSORS,& ALL HOLDERS OF LICENSES FOR NUCLEAR FUELS, NUCLEAR MATERIALS
& NUCLEAR POWER REACTORS ALL HOLDERS OF OLs OR CPs FOR NUCLEAR POWER PLANTS ALL LIGHT-WATER
REACTOR LICENSEES AND APPLICANTS
ALL LICENSEES
OF OPERATING
NUCLEAR POWER PLANTS AND HOLDERS OF CONSTRUC-TION PERMITS FOR NUCLEAR POWER PLANTS ALL HOLDERS OF OPERATING
LICENSES OR CONSTRUCTION
PERMITS FOR NUCLEAR POWER REACTORS ALL POWER REACTOR LICENSEES
AND APPLICANTS
FOR AN OPERATING
LICENSE ALL LICENSEES
OF OPERATING
NPPs AND HOLDERS OF CPs FOR NPIPs 89-10 SUPP. 3 90-08 90-07 89-10 SUPP. 2 GENLRIC LETTER 91- 05-4-dedication proranms needed to be improvetd to comppy with the existing DRC recuirements as described in 10 CFR Part 50, Appendix 6, Criterion I.I-(Design Control;-, IV (Procurement Docunient Control), VII (Control of Purchased Imattrii'l, Equipment anoa Services), and XVIII (Audits).
Specifically, licensees hac failed to adtquately maintain programsto assure the suitability of cornpercilily procured and dedicated equiprent for its intended safety-related
3".icatiofl.


Since the ierQeric letter presents staft positions regarding ir-tplenfleritction of existing regulaory requirements, as contained in Appexdix b to 10 CFR Pirt 5G, the '.taff has conckded, that this is a compliance backfit:.:d has prerared the gti.Lric letter in accordance with 10 CFR 50.109 (a)(4)(i).
rt,...;UCh thb    personIs  listed reourdinc this .c.;ttr, plebsE contact Sincerel),
ir. light of the inadequ'Lies identified in the procurement and dedication pruyrar.,.
                                                                                ORIGINAL SIGNED BY:
Lf a lar;e n1upter of licensees, the issuance of this generic letter is necessary Itl vxpress the staff's position on the key element that licensees ritL5 includc as part of the dedication process, specifically that cowtmercial- Srade pruLcureifent and &ctication prograns must assure the suitabilit)
                                                                          %lmes G. Partlob Associate sirector for Projects Office of Nuclear Reactor Regulatiiun F.rc                                    cf Eftfe: .tC Coribercial-Gradte                DISTRIBUTION:
of cuipelnt f 'r its interded safety-rclated application.
                    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.


This generic letter is also irt;e.LUd to clarify the elenents of effective procuremuent and corr.erciel -jrade cedic~.ition proSrams that were previcusly provided to licensees.bL 8§-02. Since licersees'
- " EL i r.LV 'I L   I# : U                                  £ditv CF   -, I Q :   '.': L.Lk'                     ?Pr~ta poy      :7
procurement and dedicatiot1 programs -ay contain prr(drarnatc deficiencies, the staff has incluaed in the gereric letter the necessary .icensee corrective action to address shortcot..ings identified in spjL'l''c vender products or components that directly lead to the component rLot bei-c suitable fc,r .Ltety-rclated service.rt,...;UCh no resr ctise tu this letter is required, if )uu have any questions reourdinc this .c.;ttr, plebsE contact thb personIs listed below.Sincerel), ORIGINAL SIGNED BY:%lmes G. Partlob Associate sirector for Projects Office of Nuclear Reactor Regulatiiun F. rc cf Eftfe: .tC Coribercial-Gradte uit;.ren~ei.t and ~Jedicatiunl Progru~s 7. List, of Fie..evty
    ?,.;y.'j:       jjc:t,yre                                              IV
:edGeneric Litttrs lectii,(Lal Ccortlact,.:
    LA' I -
Pichaire P. cIcntyre, NF~R 11cL2l 492-3215 DISTRIBUTION:
    -
enetriFr 0i es NRC PDR VIB Reading RMcIntyre-" E L i r. LV ' L L '.I I CF -, I Q : '.' : L.Lk' # : U?,. ;y.' j:  
                      2 / I 4 / ; 1*
LA' I -2 / I 4 / 1 *?Pr~ta poy :7£ditv I V-C f?a1I 001nA/UP, KU: C:Orr. :UI A C E C I i~t 7 Fk f' :1 /'7 /9-I /- IC ED E 4 (y..9104030126}}
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Latest revision as of 02:55, 24 November 2019

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  Entergy icon.png
Issue date: 04/09/1991
From: Partlow J
Office of Nuclear Reactor Regulation
To:
References
GL-91-005, NUDOCS 9104030126
Download: ML031140508 (11)
v • d • e


'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.

- " EL i r.LV 'I L I# : U £ditv CF -, I Q  : '.': L.Lk' ?Pr~ta poy :7

?,.;y.'j: jjc:t,yre IV

LA' I -

-

2 / I 4 / ; 1*

/UP,

Cf KU:C:Orr. :UIA CCE I i~t7 Fk

?a1I /9

001nA /'7 :1 f'

/- -I IC ED E

.9104030126

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