ML20059A512

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Provides Clarification of Implementation of Replacement Items Project at Plant for Previously Procured Warehouse Inventory.Util Committed to 100% Dedication of Commercial Grade,Qa,Level Ii,Previous Procurement Warehouse Spare
ML20059A512
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 08/15/1990
From: Wallace E
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9008230089
Download: ML20059A512 (3)


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e TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESsEC 374o1 5N IS7B Lookout Place AUS 151990 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington, D.C.

20555 Gentlement In the Matter of

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Docket Nos. 50-327 Tennessee Valley Authority

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50-328-SEQUOYAH NUCLEAR PLANT (SQN) - REPLACEMENT ITEMS PROJECT (RIP)

.In follow-up to.TVA's letter from M. J. Ray to NRC dated November 6, 1989, and NRC's letter from B. D. Liaw to 0. D. Kingsley. Jr., dated May 25, 1990 TVA would like to clarify current implementation of the RIP at SQN for previously procured warehouse inventory.

TVA committed t-ivo percen; dedication of comsnercial grade. Quality

-Assurance, Level II, previous procurement warehouse inventory spare and replacemen: arts with potential safety-related appilcation. This was in addition te, extensive restart evaluation effort for SQN Units 1 and'2 in 1988.

Impts.ating processes and procedures wera established and refined to achieve the desired dedication and provi6e reasonable assurance that the abject parts would perform their safety-relate.1 function (s). As described in TVA's letter dated November 1989, these processas have been ef fectively employed for a large number of warehouse items t tat provided considerable data and experience to further refine and streamline t e dedication processes. The RIP program at SQN has consistently led the industry in the evaluation of installed i,tems, warehouse inventory, and new procurements.

The generic

. dedication packages referred to in your letter of May 1990 r,'

mented TVA's initial ef fort at incorporating lessons learned f rom RIP and.- ariety of other sourcea to refine the dediention proceas in a more etfic,ent but still effective manner. NRC indicated that some of the resultant packages were considered too broad and suggested that the generic dedication process should be refined to pertain to similar items and vendors.

TVA acknowledged the staff's comments and has incorporated changes in the

. program. "t!11 ming the program success as a foundation to build more efficient methods for demonstrating acceptability of inventory without decreasing safety margin, TVA will continue to refine SQN's processes incorporating lessons learned to dedicate the subject inventory in a manner consistent with Appendix-B objectives and efficient utilization of procuremont-related resources. We recognize that multicomponent dedication packages must contain an adequate basis for ensuring that safety-related equipment and parts are capable of performing their safety-related function as required by 10 CPR 50, Appendix B.

We believe that SQN's 100 percent 9008230089 900015,

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t, 2-U.S. Nuclear Regulatory Commission AUS 15 B90 warehouse dedication efforts have demonstrated a level of assurance above and beyond industry standards and the NRC staff's expectations outlined in proposed Generic Letter 90-XX, " Licensee Co.snercial-Crade Procurement and Dedication Programs." The inventory evalration program is conservative with i

regard to the proposed NRC expectations reflected in the draf t generic

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letter. Technically supported, multicomionent dedication packages will be utilized to implement SQN's 100 percent i edication conunitment as appropriate.

Process refinements and output documentation will continue to be available for NRC review and inspection.

I TVA has been following Industry and staff procurement initiatives relative to existing warehouse inventory procured prior to January 1,1J90. We recognize that 100 percent dedication of the procurement warehouse inventory has not i

been widely employed by other utilities anc'. that, alternatively, sampling 4

methodologies are under consideration by both industry and NRC staff in development of industry guidance. We believe SQN's extensive efforts and resultant e:<perience provide considerable basis for support for such methodologies, constituting reasonable assurance of acceptabillt," of past procurement processes in satisfying 10 CFR 50, Appendix B.

TVA will continue.

to closely follow NRC and Nuclear Management and Resources Council initiatives, and will teevaluate this issue with the stati et a point when industry guidar.ce is better clarified.

In the interim, we will utilize more efficient methods ta meet the existing commitment while ensuring that reasonable assurance is provided.

If you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6651.

Very truly yours, TENNESSEE VALLEY AUTHORITY

/"E.G.Wallace, Manager Nuclear Licensing and Regulatory Affalrs cc t See page 3

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.e 0-U.S. Nuclear Regulatory Connission h61$ g q

I' cc Ms. S. C. Black, Deputy. Director l

Project Directorate 11-4 U.S.' Nuclear Regulatory Conunission One White Flint, North

'11555 Rockville Pike Rockville, Maryland 20852 i:

Mr. J. N. Donohew, Project Manager l

U.S. Nuclear Regulatory Conunis.sion One White Flint, North i

11555 Rockv111e Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant j

2600 Igou Ferry Road Soddy. Daisy, Tennessee. 37379 Mr. B. A. Wilson, Project Chief U.S. Nucicar Regulatory Connission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 l

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