B14483, Comment Supporting NRC Draft Insp Procedure 38703
| ML20036C041 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Millstone File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/21/1993 |
| From: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO. |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-58FR15167 58FR15167, B14483, GL-89-02, GL-89-2, NUDOCS 9306090037 | |
| Download: ML20036C041 (3) | |
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May 21, 1993.
Docket Nos. 50-213 L
50-245 50-336 50-423 B14483 Re:
10CFR50, Appendix B Chief Rules Review and Directives Branch Office of Administration l
U.S. Nuclear Regulatory Commission Washington, DC 20555 4
Gentlemen:
i Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.1, 2, and 3' Draft Inspection Procedure 38703 1
In response to Federal Register Notice 58FR15167, dated March 19, 1993, Northeast Utilities Service Company (NUSCO)', on behalf of the Connecticut Yankee Atomic Power Company for the Haddam Neck Plant and Northeast Nuclear -
Energy Company for Millstone Unit Nos.1, 2, and 3, hereby provides comments on the draft NRC Inspection Procedure 38703.
In general, the revised NRC Inspection Manual governing commercial. grade procurement inspections is acceptable.
It represents a positive development in resolving longstanding concerns regarding NRC procurement philosophy.
However, there are several areas which seem to warrant clarification.
The draft procedure uses a more performance-based approach in procurement than is reflected in the draft Regulatory Guide (RG) 1.28 (Revision 4).
Additionally, it appears to go beyond Generic Letter 89-02 requirements in that safety functions be considered for every part purchased.
As i
such, some further clarification of the NRC's guidance documents seems warranted.
The draft procedure states that licensees should ' survey any firm which l
L has " physical possession of the item.
NNECO and CYAPC0 believe L
that utilities should have the latitude to exercise engineering judgment, and under certain circumstances, grant relief to this survey-l recommendation. As an example, licensees should not perform a survey for shipping firms transporting materials.
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U.S. Nuclear Regulatory Comission B14483/Page 2 May 21, 1993 The draft Inspection Procedure contains a discussion of prescriptive deficiencies (the elbow example) which is overly restrictive.
For-example, a hardness check and an inservice erosion / corrosion monitoring program could efficiently meet requirements, but would not be considered an acceptable alternative according to the draft Inspection Procedure.
The prescriptive deficiency discussion should be sumarized to state that thi. material and dimensional verification used provides insufficient assurance of suitability for this application.
The use of new definitions (e.g., critical characteristics) should be avoided to eliminate any potential confusion.
The Staff should continue to use terms which are already defined in NRC-endorsed industry standards.
Page A-2 reflects that markings be put on every part.
This requirement should be deleted.
The NRC Staff should consider endorsing EPRI NP-7218.
It can serve as a logical standard for sample sizes under di fferent degrees of lot homogeneity.
The above comments are being forwarded for the Staff's consideration when finalizing the draft Inspection Procedure.
These coments have also been forwarded to the Nuclear Management and Resources Council for inclusio'n in the industry response to this issue.
Please contact us if you have any questions or coments.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY FOR:
J. F. Opeka Executive Vice President BY:
O. Dr Cho d t E. A. DeBarba Vice President cc:
See page 3.
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U.S. Nuclear Regulatory Commission B14483/Page 3 May 21, 1993 cc:
T. T. Martin, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. W. Andersen, NRC Project Manager, Millstone Unit No. 1 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 V. L. Rooney, NRC Project Manager, Millstone Unit No. 3 D. H. Jaffe, NRC Project Manager, Millstone Station W. J. Raymond, Senior Resident Inspector, Haddam Neck Plant P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555 i
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