ML20036C046
| ML20036C046 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/21/1993 |
| From: | CENTERIOR ENERGY |
| To: | Meyer D NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-58FR15167 2147, 58FR15167, NUDOCS 9306090060 | |
| Download: ML20036C046 (4) | |
Text
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ENERGY OFNE OF "!S TR ?. Tim Donald C. Shelton
- 93 MY 28 P1 :17 300 Madison Avenue Vice Piesident Nuclear
. Toledo, OH 43652 0001 Davis Besse.
(419)249 2300 i
Docket Number 50-346 i
License Number NPF-3
. Serial Number 2147-May 21, 1993 Mr. David L. Heyer Chief, Rules Review and Directives Branch Office of Administration United States Nuclear Regulatory Commission Vashington, D. C.
20555
Subject:
Comments on Draft NRC Inspection Procedure 38703, " Commercial Grade Procurement Inspection" Federal-Register Volume 58, Number 52 - March 19, 1993
Dear Mr. Heyer:
Toledo Edison (TE), a subsidiary of Centerior Energy, is partial. owner of and is responsible for operation of'the Davis-Besse Nuclear Power Station.
Toledo Edison has been authorized for power operation of the-Davis-Besse Nuclear Power Station since April 1977. As a 10 CFR 50 licensee, Toledo Edison has a vested interest in any policies the NRC-may adopt which can affect the management and operation of a commercial nuclear power plant.
Toledo Edison has reviewed, and endorses, the comments submitted to the NRC by the Nuclear Management and Resources Council (NUMARC) on behalf of the nuclear power industry. Attached are Toledo Edison's additional comments on the subject inspection procedure.
Should you have any questions or require additional information, please contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Ver t ul yours, i
i VW
'N
~
A A/dle attachments cc:
A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC Senior Project Manager S. Stasek, DB-1.NRC Senior Resident Inspector USNRC Document Control Desk Utility Radiological Safety Board Operating Companies:
9306090060 930521 Cleveland Doctric muminating PDR PR Toledo Edison MISC 5BFR15167 PDR;
Docket Number 50-346-License Number NPF-3 o
'a Serial Number 2147
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Page 1
= Toledo' Edison Company (TE) Comments on Draft NRC Commercial Grade. Dedication Inspection Procedure 38703 L
PART 38703B-02:
PROGRAM INSPECTION REQUIREMENTS Section 02.04 Review of Dedication' Packages - The second bullet states,
" Determine if the important design, material and performance characteristics relevant to the safety function have been identified.
Determine whether the licensee verified the characteristics necessary to provide reasonable assurance that the item vill perform its intended safety function.
If appropriate, take into account post-installation testing and periodic surveillance testing and' inspection."
TE COMMENT - The second sentence should be revised to read, " Determine whether the licensee verified enough of these characteristics to provide reasonable assurance that the item vill perform its intended safety function."
Not all safety function characteristics are expected to be verified to provide reasonable assurance that the item vill perform its intended safety function. Attachment 2 provides a logic chart which depicts the.
methodology for applying engineering judgment in the assessment of safety function characteristics in order to obtain the critical characteristics for acceptance.
It is the critical characteristics for.
acceptance which provide reasonable assurance that the item vill perform its intended safety function.
This proposed revision is consistent with the attached logic chart and with the definitions in i
EPRI NP-5652.
PART 38703B-03:
PROGRAM INSPECTION' GUIDANCE
?
Section 03.03 Review of Program Procedures - The first bullet states,
"... gain an understanding of hov processing CGI (Commercial Grade Item) procurement documents is controlled under the OA program and receive OA review and approval."
Section 03.04 Review of Dedication Packages Paragraph a. Method 1 - Special Tests and Inspections - The sixth bullet states, " Verify that CGI receiving inspection activities are adequately controlled under the OA program regardless of whether they are being done in conjunction with other plant GA receipt inspection
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activities."
TE COMMENT - Remove specific reference to OA review and approval / receipt inspection activities.
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Docket Number 50-346 License Number NPP-3
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Serial Number 2147
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Attachment l1 Page 2 These sections imply that only OA department personnel can review and' approve CGI procurement documents and perform' receipt. inspections.
At.
many plants, receipt inspection is performed by.the Materials Management organization and/or 0A is not responsible for the~ review and approval of procurement documents.
Paragraph b. Method 2 - Commercial Grade Survey TE COMMENT - NRC should provide guidance.on the control'and maintenance of commercial grade surveyed vendors.
Commercial grade vendor OA programs cover a vide range of compliance; from-full 10CFR50 Appendix B programs (while not accepting 10CFR21 reportability requirements), to a single procedure covering one critical characteristic.. Industry should be given the flexibility to control-commercial grade vendors with a graded approach ranging from the annual evaluation / triennial performance based audit to performing a commercial grade survey prior to each purchase depending on the vendor's performance and capabilities.
APPENDIX A:
DEDICATION ISSUES Section 2. Sampling TE COMMENT - NRC should endorse EPRI NP-7218, " Guideline for the Utilization of Sampling Plans for Commercial. Grade Item Acceptance (NCIG-19)",-as acceptable for providing sampling methodology. :This would promote industry use of this sample plan and'vould result in more consistency within the industry. As more'is learned about sampling, lessons learned could be incorporated into EPRI NP-7218. This vould keep industry (utilities and vendors) current with respect to evolving 1
sampling philosophy.
ADDITIONAL
GENERAL COMMENT
S
- Guidance should be provided on replacement purchase of Basic Components with IEEE 323 and 344 applied that vere originally purchased under 10CFR50 Appendix B with 10CFR21 reportability, and novfhave to be purchased commercial grade due to the supplier discontinuing;its Appendix B program, etc.
- NRC should reevaluate the Vendor Branch Staff's position regarding' failure of a Basic Component as discussed during the recent NRC Commercial Grade Dedication Vorkshop. Vendor Branch Staff -+ated that failure of a Basic Component which is determined to be the result of~ inadequate dedication activities by the supplier, would result in enforcement action against both the supplier and the licensee.
In this case, enforcement action should involve the supplier only.
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. Docket Nusber 50-346
. License Number NPF-3 Sefial Number ?A47
-yAtt'achment2 -UEDICATION OF-COMMERCIAL GRADE PARTS Characteristics related to DESIGN the design of the item from.
CHARACTERISTICS '
a utility's point of view clclclclclclclclclclc Characteristics related to APPLICATION the utility's application of CHARACTERISTICS the item Application lclclclclclclcl Characteristics related to the SAFETY FUNCTION safety function of the item CHARACTERISTICS.
8"I'*7 Function lclclclclcl Critical characteristics chosen to
. CRITICAL Engineenng-Judgment for obtain reasonable assurance that CHARACTERISTICS technical and quality FOR ACCEPTANCE
.'ssurance requirements have been met a
lclclclcl NV VERIFY ALL
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