ML20245F659

Requests That to M Hoffman Re Replacement & Repair Matls for Plants Be Retracted or Corrected

ML20245F659
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/30/1989
From:	Arlotto G, Bosnak R NRC
To:	Reedy R REEDY ASSOCIATES, INC.
References
NUDOCS 8905020451
Download: ML20245F659 (5)

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i Mr. Roger F. Reedy

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Reedy Associates, Inc.

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-15951 Los Gatos Boulevard j

Suite 1 Los Gatos, CA 95032

Dear Mr. Reedy:

Your letter of February 20, 1989 to Mr. Mark Hoffman of Portland General _

Electric has come to our attention.

Our concern with your letter is that it can be read that a utility purchasing replacement and repair material for a plant built to a Code or Standard that was published prior to the publication of any quality i

assurance requirements could purchase such material today without l

applicable quality assurance requirements, and that 10CFR 50, Appendix B

.1 did not apply. The undersigned do not subscribe to this reading, deny having 1

made'any statements supporting such a position and thus should not have been i

quoted. We believe you should retract or correct your letter.

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With respect to your statement that the undersigned have encouraged utility pilot sampling testing programs, this too is not the case. We have encouraged q

Code initiatives that would help solve or aid in the solution of the fraudulent i

material problem. This too should be corrected.

Very truly yours, R

rt J Bosnak

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Gty A. Arlotto cc:

M. R. Green

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June Ling l

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ENGINEERING MANAGEMENT CONSULTANTS February 20,1989 POR 89-00P.

Mr. Mark Hoffman Portland General Electric Co.

121 SW Salmon Street l

Portland, OR 97204

Dear Mark,

This is a summary of our teuphone conversation this morning regarding my conversations with Mr. Guy Arlotto, who is Director of Division of Engineering Technology, Office of Nuclear Regulatory Research with the NRC. Mr. Arlotto is, and has been, responsible for the contents of 10CFR50. I have had a number of discussions in the past few months with Mr. Arlotto and Mr. Bosnak, who is his Assistant Director, regarding Code applications and Appendix B of 10CFR50 as they apply to both plants in operation and under construction.

l Through these activities we have had a numbpr of changes made to the Codes and some very good understandings as to the requirements of 10CFR50.

Last week I met with Mr. Arlotto at a Board on Nuclear Codes and Standards meeting

.n Phoenix.

I raised the issue of whether or not plants which had been built to B31.7 were now required to meet 10CFR50, Appendix B for replacements and repairs to those piping systems. His answer was "no".

Section XI of the Code allows the Owner to go back to the original Ccde of Construction and meet the requirements of that Code of Construction for repairs and replacements. The NRC has accepted the Section XI Code which provides that material for repairs and replacements for plants built to B31.7 may be procured without an NCA-3800 program or the use of a 10CFR50 program on the part of the supplier. Therefore there is no intent to impose a 10CFR50 program on 831.7 material.

As a further clarification, if we were to assume that 10CFR50 were an obligatory document for a utility to follow, the provisions of 10CFR50 apply to the Owner, and not to the vendors of material.

The Owner under his 10CFR50 program would be obliged to perform some type of procurement verification, which could be an on-site review of the vendor, a receipt inspection or testing of material. There is no requirement that all materials has to be tested. The Owner can use a sampling program if that fits his needs to show that the material is what is ordered. Appendix B does not even require that the Owner qualify suppliers. It allows three alternatives which are testing material, receipt inspection or qualification of suppliers. Any of those are acceptable.

We have had a number of conversations with NRC personnel and have been working witn Georgia Power recently to help resolve some similar issues. The NRC is looking for a method to overcome the fraud issue, which is why this testing of material seems to have

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February 20,1989 Page Two

' umped into the forefront in their mind at this time. However, fraud is something that was never j

considered by the NRC or the Code Committees and is a new issue. We have presented-some ideas to the NRC (Guy Arlotto and Bob Bosnak) as to how to overcome the problem, These ideas are based on sampling testing. Sampling testing is currently being reviewed by -

Code Committees and some outside PVRC groups for incorporation into the Code, but the effort will not solve.immediate problems unless a' utility.wants to implement the program themselves. Mr. Arlotto and Mr. Bost.ak have tried to encourage me to get a utility to do this as a pilot program because they think it could be very successful.

Part of our success in the activities we have been working on with regard to material supply has been that we have been able to get the right people within the NRC organization to talk to 'each other and to work out resolutions so that everyone is a winner. Through cooperation it is possible to achieve the desired results.

If you would like to discuss this further with us please let us know.

Very truly yours,

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l March 31,1989 POR-89-005 i

Mr. Mark IIoffman Portland General Electric i

121 SW Salmon i

Portland, OR 97204

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Dear Mark,

i Some questions have been raised concerning my letter to you dated February 20,1989. The problem is that my comments can be, and were, misunderstood when taken out of the context of S

our conversation that day. In order to put that letter into'the proper context, I am making the following clarifications which are consistent with our conversation of February 20th.

1) The topic of our conversation was whether or not 10CFR50, Appendix B, r_cquired an NCA-3800 type vendor qualification program to be imposed on waterial manufacturers and material suppliers for B31,7 piping systems. All my comments in our conversation and in the letter were to address that point only.

2) My mention of meeting Mr. Arlotto at an ASME Board meeting was to indicate that my discussion with him was very informal. My conversation with Mr. Arlotto was brief and outside any Board mec:ing or function. It was a discussion between two individuals, acting as individuals.

These facts were made very clear in our conversation. My purpose of mentioning names was to-be open and informative, but it is clear that it was inappropriate.

3) In the last sentence of the second paragraph I was trying to convey the thought that Appendix B does not impose an NCA-3800 type vendor qualification.nrogram on material suppliers.

Mr. Arlotto has never stated to me that a utility does not have to follow Appendix B and I have never stated that Appendix B does not apply. Appendix B applies to the utility for procurement of material, but does not require the use of the NCA-3800 vendor qualification approach.

4) In the third paragraph, I recognized the fact that there is confusion as to whether or not Appendix B applies to B31.7 Code work for repairs to existing piping systems. For this reason, the paragraph was started with an assumption of applicability.

15951 LOS GATOS BLVD., SUITE 1 LOS GATOS, CALIFORNIA 95032 + (408) 356-6300

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Mr. Mark lloffman March 31,1989 i

Page Two

5) On the second page of my letter, there is discussion of programs to address the issues raised in NRC Bulletin 88-05 and some NRC Information Notices. The paragraph addresses the problems of possibly obtaining inferior material because of fraud or incompetence. These are important to all of the nuclear industry. The use of the names of individuals was an attempt to show the scope of the issue, nothing else. Mr. Arlotto's and Mr. Bosnak's comments to me on this were only with regard to information which is public knowledge, and had nothing to do with NRC policy or internal planning. Both gentlemen have encouraged initiatives to resolve industry problems, but the pilot program approach was minc, not theirs. This also was stated in our conversation.

The last paragraph concerns successful:elutions which can be obtained by working with the NRC to resolve issues of common interest. This is demonstrated by the mutually agreeable resolutions worked out in the last few years. By working with the different NRC groups, it is possible to understand the various issues of concern and achieve a solution that satisfies the needs of the industry.

l I am sorry for any confusion the letter may have caused.

Very trulv yours,

/

Roge

. Reed' RFR\\n

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