ML20044D355

Comment on Draft Insp Procedure 38703, Commercial Grade Procurement Insp. Believes Appropriate Application of NRC Endorsed Stds to Critical Characteristics Remains Responsibility of Licensee Re Engineering Judgement

ML20044D355
Person / Time
Site:	San Onofre
Issue date:	05/13/1993
From:	Marsh W SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-58FR15167 58FR15167, NUDOCS 9305190041
Download: ML20044D355 (4)

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Nuclear Regulatory Commission Office of Administration, Chief, Rules Review and Directives Branch Washington, DC 20555 Gentlemen:

Subject:

Comments on the Draft NRC Inspection Procedure 38703 COMMERCIAL GRADE PROCUREMENT INSPECTION

Reference:

Federal Register Notice 58 FR 15167, " Commercial Grade Procurement and Dedication Workshop",

March 19, 1993 Attached are Southern California Edison's (SCE) comments on draft Inspection Procedure 38703 - COMMERCIAL GRADE PROCUREMENT INSPECTION - as requested by the referenced Federal Register notice.

If you have any quentions or comments, please contact me.

Sincerely, WYI Attachment cc:

J.

B.

Martin, Regional Administrator, NRC Region V S.

W.

Brown, NRC Project Manager, San Onofre Unit 1 M.

B.

Fields, NRC Project Manager, San Onofre Units 2 and 3 C.

W.

Caldwell, NRC Senior Resident Inspector, San Onofre Units 1,

2 and 3 R.

F.

Dudley, Section Chief, Non-Power, Decommissioning, and Environmental Project, Directorate of Reactor Projects - 3, 4 and 5 Nuclear Management and Resources Council gb 9305190041 930513 PDR ORG NRRD PDR

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i ATTACHMENT l

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The following are SCE's comments regarding the draft Inspection j

Procedure 38703 - COMMERCIAL GRADE PROCUREMENT INSPECTION.

Each comment has a title reflecting the specific issue; the pertinent j

text in draft Inspection Procedure is referenced; SCE comments e*

the issue are presented; and SCE recommended changes / revisions are offered.

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COMMENT 1 - REACTIVE INSPECTION REQUIREMENTS

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a REFERENCE - Section 38703A-2, page 2, paragraph 02.04 i

" Determine if the Failure was the Result of an Inadequate Dedication."

COMMENT - The inspection procedure should recognize that the 1

failure modes of commercial grade items (CGI) can include random failure.

Sampling plans will introduce a finite I

probability of a random failure of a critical characteristic l

of a CGI.

In the case where verification of a critical i

characteristic requires destructive testing, this probability i

is unavoidable.

SCE believes randomly distributed failures

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i of CGIs do not constitute a failure of the dedication process or package provided the statistical probability of a random 1

failure is enveloped within plant safety analysis f

assumptions.

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1 RECOMMENDATION - Add a new paragraph 02.04 (f) stating the i

following:

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" Characterize the CGI's failure as random or systematic, if possible, from available information.

Random failures within l

the confidence interval of the CGI dedication sample plan, i

consistent with plant safety analysis assumptions, do not l

constitute a failure of the licensee's dedication program."

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COMMENT 2 - LIKE-FOR-LIKE REPLACEMENT REFERENCE - Appendix A, page A-3; Appendix B, page A-4 1

l COMMENT - To be considered " identical", as defined in Generic Letter 91-05, items must be purchased at the same time from j

the manufacturer.

Alternatively, the licensee can verify j

that no changes in the design, materials, and manufacturing i

i process has occurred between the procurements.

Because it is f

1 very unlikely distributors and original equipment manufacturers (OEM) still have parts available that were l

manufactured when the original part was made, like-for-like j

replacement effectively does not exist.

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i RECOMMENDATION - Remove reference to like-for-like i

replacement by deleting paragraph 5 in Appendix A and the corresponding definition in Appendix B of the inspection l

procedure.

t COMMENT 3 - QA APPROVAL OF PROCUREMENT DOCUMENTS REFERENCE - 38703B, page 8, paragraph 03.03, first bullet -

"How processing of CGI procurement documents is controlled under the QA program and receive QA review and approval."

COMMENT - The above sentence implies that'all CGI procurement documents should receive QA review and approval during processing.

While it is appropriate that the commercial grade dedication program receive QA review and approval, there is no regulatory requircsent that each CGI procurement document receive QA review ara approval.

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RECOMMENDATION - Revise the sentence to read as follows:

l "How processing of CGI procurement documents is controlled under the QA program."

COMMENT 4 - USE OF INDUSTRY STANDAkD CERTIFICATIONS r

REFERENCE - Appendix A, page A-1, paragraph 1 " Basis for the

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selection and verification of critical characteristics" i

i COMMENT - Verification of certain critical characteristics should not be necessary for CGIs manufactured to an applicable, widely recognized industry or government standard (UL, MILSPEC, SAE, etc.).

It is proposed that NRC l

endorsement of specific standards or listings would allow licensees to reference them for verification of applicable critical characteristics during the CGI dedication without

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testing, survey or audit.

Appropriate application of the NRC l

endorsed standards to critical characteristics remains the l

responsibility of the licensee as prudent use of engineering

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judgement.

j RECOMMENDATION - Industry or government standards endorsed by

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the NRC could be listed under Appendix A,

" Dedication Issues" t

as a separate issue or under paragraph 1 " Basis for the selection and verification of criticel characteristics."

The NRC is requested to consider endorsing the following

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standards:

National Institute of Standards and Testing l

F Underwriter's Laboratories Listings:

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1 2

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486 A,

B, C Wire Connectors and Soldering Lugs f

198 B,

C, D,

G, H,

L Fuses and Accessories 1059 Terminal Blocks f

f COMMENT 5 - DEFINITION OF CRITICAL CHARACTERISTICS REFERENCE - Appendix A, page A-1, paragraph 1.a f

" Consideration of a Item's Safety Function"; Appendix B, page A-4, Critical Characteristics Definition i

COMMENT - The definition of critical characteristics (CC) in I

these sections of the inspection procedure is tied to the CGI's safety function and is not consistent with the EPRI

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definition of CC contained in NP-5652 (acceptance).

Because EPRI NP-5652 was conditionally endorsed in Generic Letter l

89-02, the potential for confusion on this subject still i

exists.

Notwithstanding the clarification of the NRC interpretation of " item specified" as it relates to CCs in Generic Letter 91-05, the wording of GL 89-02 causes regulatory ambiguity that sends mixed signals to the i

industry.

RECOMMENDATION - The conditional NRC endorsement of EPRI NP-i 5652 in GL 89-02 should be qualified to specifically address i

NRC expectations regarding the selection and verification of CCs.

This qualification should be promulgated to industry in j

an appropriate NRC document capable of establishing regulatory policy such as a generic letter, supplement to one i

of the applicable Generic Letters, or policy statement.

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