ML17290A390

Comments on Proposed Insp Procedure 38703, Commercial Grade Procurement Insp.

ML17290A390
Person / Time
Site:	Columbia
Issue date:	05/21/1993
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-58FR15167 58FR15167, GO2-93-117, NUDOCS 9306090002
Download: ML17290A390 (5)

Text

FORD I REGULAT INFORMATION DISTRIBUTIO STEM (RIDS)

ACCES&ION NBR:9306090002 DOC.DATE: 93/05/21 NOTARIZED: NO DOCKET SCIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRZSH,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Division of Freedom of Information S Publications Services

SUBJECT:

Comments on proposed Insp Procedure 38703, "Commercial Grade Procurement Insp." I DISTRIBUTION CODE: DS09D COPIES RECEIVED:LTR ENCL SIZE: D TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: OGC EG RES/DSIR

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1 EXTERNAL: NRC PDR 02 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM P 1-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T HEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL 7

WASHINGTON PUBLIC POWER SUPPLY ggP~M! F 4,9HIH lSTRATl0' 0goa¹ 50ecsGeosgewasblnglonway Rscbbssn< wasblnglon 995524¹ <'509)5725000 ce<~f May 21, 1993 G02-93-117 Docket No. 50-397 Chief, Rules Review and Directives Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

COMiVK<NTS ON DRAI<T COMMERCIAL GRADE PROCUREMENT INSPECTION PROCEDURE 38703 The Washington Public Power Supply System (Supply System) has reviewed proposed Inspection Procedure 38703, "Commercial Grade Procurement Inspection." Our comments are attached for your consideration.

The Supply System also endorses the NUMARC comments on the draft Inspection Procedure.

Ifyou have any questions, please contact Mr. Douglas Coleman at (509) 377-4342.

Sincerely, J.V. Parrish (Mail Drop 1023)

Assistant Managing Director, Operations cc: B. Bradley, NUMARC 9306090003 930521 V PDR'DOCK 05000397i H PDR~

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4 r t SUPPLY SYSTEM COMMENTS ON DRAFT NRC INSPECTION PROCEDURE 38703 "COMMERCIALGRADE PROCURKVJZNT INSPECTION" Specify that random failures due to normal wear, etc. should not trigger a reactive inspection.

2. Add the flow charts that were presented at the April 21-22, 1993 NRC workshop to the Inspection Procedure.

3. Revise the Dedication Examples that are presented in the Inspection Procedure to correct concerns raised by the industry at the April 21-22 workshop.

4. The terin "failure" in the Inspection Plan should be defined, paricularly in consideration of comment ¹1 above.

Put guidance in the Inspection Procedure stating that older commercial grade dedications should be evaluated against the processes in effect at the time they were prepared and not against today's standards (processes).

6. In Appendix A, Section 2.b, delete the words "and at essentially the same time" since other conditions (i.e., type, grade, class, size, etc.) are all encompassing.

7. The NRC should formally endorse EPRI N-7218, "Guideline for the Utilization of Sampling Plans for Commercial Grade Item Acceptance."

8. The NRC should revisit their definitions of critical characteristics, dedication, and reasonable assurance keeping in mind that reasonable assurance was never intended to equal absolute or total assurance.

9. Remove the "like-for-like replacement" definition from the Inspection Procedure since it is a design change consideration and is not within the commercial grade dedication scope.

10. In Appendix A, Section 3.a, clarify the term "physical possession" since, for example, it would be inappropriate to survey or audit the trucking company that delivered the item.

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