ML20199J465

Comment Opposing Draft RG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. RG Unnecessary Based on Use of EPRI Guideline & Excellent Past History of Commercial Grade Items at DBNPS

ML20199J465
Person / Time
Site:	Davis Besse
Issue date:	01/22/1998
From:	Donnellon R AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-62FR52166, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 62FR52166-00005, 62FR52166-5, NUDOCS 9802050319
Download: ML20199J465 (3)

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Subject:

Comments on Draft Regulatory Guide DG-1070," Sampling Plans Used For Dedicuing Simple Metallic Commercial Grade items For Use In Nuclear Power Plants" Ladies and Gentlemen:

The Toledo Edison Company is the operator and a licensee of the Davis-Besse Nuclear Power Station. As such, it has a vested interest in the promulgation of fornal regulatory guidance such as the subject draft Regulatory Guide. Toledo Edison (TE) has reviewed the subject draft Regulatory Guide and is providing the comments contained in the attachment to this letter.

Should you have any questions or require additional infocmation, please contact Mr. James L.

Freels, Manager - Regulatory Affairs, at (419) 321-8466.

Very truly yours, ,

Y T, n Robert E. Donnellon g Director-Engineering and Services I

Davis-Besse Nuclear Power Station i KAShaj T~ , g1 { { (8 a ,in)

Attachment r nc,dib cc: A. B. Beach, Regional Administrator, NRC Region 111 S. J. Campbell, NRC Region III, DB - 1 Senior Resident Inspector A. G. Hansen, NRC/NRR Project Manager USNRC Document Control Desk I.I H, y 111,1ll R

9802050319 900122

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Attachment Page1 e

Comments on Draft Regulatory Guide (RG) DG 1070," Sampling Plans Used For Dedicating Simple Metallic Commercial Grade items For Use in Nuclear Power Plants" Snecific.Commp_Du The draft RG, DO-1070, describes a method of sampling simple met allic commercial grade items when dedicating those items for unrestricted use as nuclear safety related items in nuclear power ,

plants. It provides specific instructions in the application of sampling plans for commercial grade dedication. This draft RG states that dedication is an acceptance process undertaken to provide " reasonable assurance" that a commercial grade item to be used as a basic component will perform its intended safety function and is deemed equivalent to an item designed and manufactured under a quality assurance program in accordance with 10 CFR 50 Appendix B.

This draft RG also states that "Licensecs" and " Suppliers" use of this guidance will result in a more uniform application of sampling, improve overall confidence in the industry's sampling process for the dedication of commercial grade items, provide additional supplier performance history to the dedicating entity, and provide "teasonable assurance" that the item will perform its intended safety function.

TE has reviewed this draft regulatory guide and determined that it is unnecessary and would result in a significant cost burde . to the procurement of commercial grade items, spare parts, and equipment necessary to ensure s ife plant operation, without any increase in quality. A similar document to the draft regulatory guide has ahead:, been developed by licensees and is presently in use at the Davis-Besse Nuclear Power Station (DBNPS). In June of 1992, the Electric Power Research Commission (EPRI), published sampling recommendations in NP-7218 " Guidelines for the Utilization of Sampling Plans for Commercial-Grade item Acceptance (nCIG-19)". This guideline was developed as a result of a task group of representatives from nuclear power plants, architect / engineers, and consultants reviewing industry practices and selecting those appropriate to commercial grade item acceptance. The use of this guideline already ensures that there is proper technicaljustification for the sampling plans selected and assists in obtaining industry consistency in sampling approaches. It already provides a sampling method which incorporates qualitative and technical considerations and sound engineering judgment to provide " reasonable assurance" that critical item characteristics meet specified requirements.

Since its publication, the EPRI guideline has been widely used throughout the nuclear industry and has been incorporated into many commercial grade dedication programs including the program established at the DBNPS. Based on the lack of any significant number of failures of commercial grade items in service in the nuclear industry, it can be concluded that the EPRI guideline meets its intended function, and provides for the "msonable assurance" that a dedicated commercial grade item will perfonn its safety function. Therefore, an additional method for sampling under another regulatory guide, such as DG-1070, is redundant and not warranted at this time.

Further enhancement to the EPRI guideline and the commercial grade dedication process have been planned. EPRI has been advised by utilities to enhance NP-7218 to strengthen sections on sample sizes for destructive testing of items and consideration to their safety function and significance. EPRI will also conduct regional training with utilities and interested vendors on

Attachment Page 2 s

sampling in the dedication process. The Nuclear Procurement Issue Committee (NUPIC) checklists will be enhanced to provide guidance on evaluating vendor sampling programs.

Conclusion TE views the implementation of NRC Regulatory Guide, DG-1070 as unnecessary based on the use of the EPRI guideline and the excellent past history of commercial grade items at DBNPS.

The present sampling plans utilized by TE are similar to the proposed regulaiory guide and any further guidance from the NRC is not warranted at this time. TE believes implementation of DG-1070 will increase significantly costs without improving the quality of items to licensees and suppliers. Publication of this RG could:

1. Either increase off-site testing costs due to the sophistication of the testing techniques required, or it will cause both the licensees and suppliers to invest more in sophisticated testing equipment.

2. Increase costs in the manpower required to do the testing and interpreting the test results.

3. Increase costs due to higher stock quantities to avoid the additional commercial grade dedication costs.

4. Since this applies to small items only, it will result in the procurement of greater quantities to meet the minimal mess for the additional required testing.

5. Contribute to the decrease of suppliers since it will increase their costs of doing business with nuclear facilities.

6. Require revisions of present programs and procedures dealings with commercial grade dedication.

7. Require the backfit of those procurement documents utilizing EPRI guideline, NP-7218.

8. Increase the cost of items from suppliers.

9. Increase the cost of the commercial grade items by requiring Certified Materiallest Reports.

10. Greatly increase the time it takes to perform the commercial grade dedication and therefore could impact the timely supply of items to the user.

! i. EPRI guideline, NP-7218 is used in the sampling of various commercial grade items.

Since the draft regulatory guide is specific only to simple metallic items,it would be necessary to maintain two sample programs in order to sample items outside the scope of the draft regulatory guide. This could cause confusion for the licensees, suppliers, and the NRC.

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