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| | number = ML20202C141 | | | number = ML20202C141 |
| | issue date = 01/29/1998 | | | issue date = 01/29/1998 |
| | title = Comment on Draft Rg DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants | | | title = Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants |
| | author name = Boyer G | | | author name = Boyer G |
| | author affiliation = WOLF CREEK NUCLEAR OPERATING CORP. | | | author affiliation = WOLF CREEK NUCLEAR OPERATING CORP. |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196K7991999-07-0606 July 1999 Comments of Nuclear Energy Institute,Inc on Treatment of Existing Antitrust Conditions in License Transfer Cases.* Recommends Establishing Basic Guidelines for Evaluating Disposition of Antitrust Conditions.With Certificate of Svc ML20196H1511999-06-30030 June 1999 Response of Wml Associates to Commission Memorandum & Order CLI-99-19.* Strongly Urge Commission to Reconsider Decision in CLI-99-19 & Seek Congressional Input,Per Commission Review Responsibilities.With Certificate of Svc ML20195J4341999-06-18018 June 1999 Memorandum & Order.* Concludes That AEA Does Not Require Antitrust Reviews of post-operating License Transfer Applications & Dismisses Kepco Petition to Intervene on Antitrust Grounds.With Certificate of Svc.Served on 990618 ML20206H3351999-04-30030 April 1999 Exemption from Certain Requirements of 10CFR50.60, Acceptance Criteria for Fracture Prevention Measures for Lightwater Nuclear Power Reactors for Normal Operation. Exemption Related to Application ML20205K9381999-04-0505 April 1999 Amicus Curiae Brief Wml Associates.* Commission Should Not Eliminate Antitrust Review of License Transfers,For Listed Reasons.With Certificate of Svc ML20205C7681999-03-31031 March 1999 Amicus Filing National Association of State Utility Consumer Advocates.* Brief Submitted in Accordance with Memo & Order of 990302 & in Support of Argument 1 in Initial & Reply Briefs of Kepco & Nreca.With Certificate of Svc ML20205G0511999-03-31031 March 1999 Amicus Brief of Nuclear Energy Institute on Issue of Antitrust Reviews in License Transfer Cases.* Industry Supports Agency Actions & Urges Commission to Implement Recommended Changes.With Certificate of Svc ML20205C8701999-03-31031 March 1999 Motion to Submit Comments & Comments of Amici Curiae of American Antitrust Institute.* for Listed Reasons, Interpreting Act as If No Transfer Took Place Would Turn Statutory Purpose on Its Head.With Certificate of Svc ML20205C8081999-03-31031 March 1999 Affidavit of D Penn.* Affidavit of D Penn in Support of NRC Antitrust License Conditions & Significant Impacts Conditions Have in Shaping Competitive Electric Markets ML20205C7791999-03-31031 March 1999 Joint Brief of American Public Power Association & Florida Municipal Power Agency.* Brief Addresses Question on Whether Commission May & Should Eliminate All Antitrust Reviews in Connection with License Transfers.With Certificate of Svc ML20204H5211999-03-23023 March 1999 Reply to Brief of Applicants in Response to Joint Brief of Kansas Electric Power Cooperative & National Rural Electric Cooperative Association.* Petition Should Be Dismissed.With Certificate of Svc ML20205A8561999-03-23023 March 1999 Reply Brief of Kansas Electric Power Cooperative Inc.* Facts of Case Warrant Changes Occurred.Commission Should Perform Changes Review in Case & Based on Results Should Perform Antitrust Review on Competition.With Certificate of Svc ML20207M8241999-03-16016 March 1999 Joint Brief of Kansas Electric Power Cooperative,Inc & Amicus Curiae Natl Rural Electric Cooperative Assoc.* Commission Should Perform Significant Changes Review Mandated by Statute & Regulations.With Certificate of Svc ML20204E5131999-03-16016 March 1999 Initial Brief of Applicants in Response to NRC Memorandum & Order Re Antitrust Review of License Transfers.* Commission Should Deny Licensee Petition,For Listed Reasons.With Certificate of Svc ML20207G3041999-03-0303 March 1999 Computer Access & Operating Agreement Between NRC & WCNOC, for Purpose of Providing NRC with Access to Certain WCNOC Computer Data Bases ML20154K2231998-10-0707 October 1998 Comment Opposing Integrated Review of Assessment Process for Commercial Nuclear Power Plants.Wolf Creek Endorses Comments Submitted by NEI in from Re Beedle to Dl Meyer ML20217F5411998-03-26026 March 1998 Comment Re Draft RG DG-5008, Reporting of Safeguards Events ML20202C1411998-01-29029 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants ML20141D5191997-06-24024 June 1997 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements, for Plant,Granted ML20148N0641997-06-19019 June 1997 Comment on Proposed Suppl to NRC Bulletin 96-001, Control Rod Insertion Problems ML20136H6441997-03-14014 March 1997 Comment Opposing Proposed NRC GL 97-XX Loss of Reactor Coolant Inventory & Associated Potential for Loss of Emergency Mitigation Functions While in Shutdown Condition ML20086M8151995-07-13013 July 1995 Comment Supporting Proposed Generic Ltr Re Process for Changes to Security Plans W/O Prior NRC Approval ML20077E8671994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re Regulations Governing NPP License Renewal Process ML20077E1861994-12-0202 December 1994 Comment Supporting Proposed GL on Reconsideration of NPP Security Requirements for Internal Threat.Endorses Comments Submitted to NRC by NUMARC on 941202 ML20076L1471994-10-24024 October 1994 Comments on Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Endorses Response Submitted by Nuclear Energy Institute ML20045D7351993-06-0303 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule ML20094L4441992-03-20020 March 1992 Application Under Exigent Circumstances to Extend Effective Period of NRC Approval of Transfer & Amend to OL NPF-42 in Connection W/Merger of Ksge W/Kansas Power & Light Co ML20091A2281992-03-18018 March 1992 Comment Endorsing Comments Provided by NUMARC Re Proposed Rule 10CFR51 Re Requirements for Environ Review of Applications to Renew OLs for Nuclear Power Plants ML20095B7741992-03-17017 March 1992 Application Under Exigent Circumstances to Extend Effective Period of NRC Approval of Transfer of & Amend to License NPF-42 in Connection W/Merger of Ksge W/Kansas Power & Light Co ML20073P7301991-05-16016 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery ML20073F9331991-04-25025 April 1991 Testimony Re Application of Kansas Power & Light Co & Kca Corp for Approval of Acquisition of All Classes of Capital Stock of Kansas Gas & Electric Co,To Merge W/Kansas Gas & Electric Co,To Issue Stock & Incur Debt Obligations ML20029A7471991-02-0606 February 1991 Testimony of Kpl Gas Svc & Ks G&E Re Co Merger ML20245J8761989-06-26026 June 1989 Director'S Decision 89-04,denying Sierra Club of Kansas 2.206 Petition to Revoke Ol,Based on Safety Concerns W/Qa Program & Mgt Failure to Safeguard Integrity of QA Program ML20116M7641989-01-30030 January 1989 Petition for Immediate Action to Protect Public Health & Safety from Undue Risks Posed by Lack of Quality Assurance Compliance at Wolf Creek Generating Station,Burlington,Ks ML20155G0961988-09-30030 September 1988 Exemption from Schedular Requirements of Property Insurance Rule 10CFR50.54(w)(5)(i),effective 881004 ML20151K0201988-07-28028 July 1988 Order Imposing Civil Monetary Penalty in Amount of $100,000 Re Mgt Oversight of safety-related Activities to Preclude Procedural Control Weaknesses ML20236Q2501987-11-12012 November 1987 Petition Per 10CFR2.206 Requesting Investigation of Plant Security Problems Resulting from Easy Access to Cooling Lake Which May Be Exploited by Terrorists.Supporting Info & Certificate of Mailing Encl ML20150C2791987-06-0303 June 1987 Sanitized Version of Investigative Interview of Rl Scott Conducted by Hb Griffin on 870603 Re Util Investigation ML20150C3011987-05-13013 May 1987 Sanitized Version of Investigative Interview of GL Koester on 870513 Re Investigation of Util ML20150C2931987-05-12012 May 1987 Sanitized Version of Interview of C Snyder by Hb Griffin on 870512 in Burlington,Ks Re Investigation of Util ML20150C2401986-08-21021 August 1986 Sanitized Version of 860821 Testimony of OL Thero in Lebo,Ks Re Investigation of Util ML20150C2581986-06-27027 June 1986 Sanitized Version of Investigative Interview of C Hill Taken by DD Driskill on 860627 Re Plant Quality First Program ML20125E0641985-06-0404 June 1985 Unexecuted Amend 3 to Indemnity Agreement B-99,changing Item3 Re License Number ML20138B6151985-06-0303 June 1985 Transcript of Closed Commission 850603 Meeting in Washington,Dc Re Pending Investigations.Pp 1-38.Portions Deleted ML20138P8761985-06-0303 June 1985 Transcript of Closed Commission 850603 Meeting in Washington,Dc for Discussion of Pending Investigations. Pp 1-48.Portions Deleted ML20126E3881985-06-0303 June 1985 Transcript of Commission 850603 Meeting in Washington,Dc Re Discussion/Possible Vote on Full Power OL for Facility. Pp 1-46 ML20128P3111985-05-28028 May 1985 Affidavit of CA Snyder Re Development,Staffing,Mgt, Implementation & NRC Review of Quality First Program. Supporting Documentation Encl ML20128P2971985-05-28028 May 1985 Affidavit of Kr Brown Re Gap 850515 Petition Filed Per 10CFR2.206 Concerning Util Quality First Program.Program Provides Mechanism for Personnel to Confidentially Rept on Concerns Re Quality at Facility ML20090F5211984-07-17017 July 1984 Motion for Clarification of ASLB 840702 Initial Decision Re Offsite Emergency Planning,Including Info on Two Conditions, Evacuation of Hosp & Nursing Home Patients & Redmond Reservoir Notification.Certificate of Svc Encl ML20092J7771984-06-25025 June 1984 Proposed Corrections to Transcript of Evidentiary Hearings 1999-07-06
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20154K2231998-10-0707 October 1998 Comment Opposing Integrated Review of Assessment Process for Commercial Nuclear Power Plants.Wolf Creek Endorses Comments Submitted by NEI in from Re Beedle to Dl Meyer ML20217F5411998-03-26026 March 1998 Comment Re Draft RG DG-5008, Reporting of Safeguards Events ML20202C1411998-01-29029 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants ML20148N0641997-06-19019 June 1997 Comment on Proposed Suppl to NRC Bulletin 96-001, Control Rod Insertion Problems ML20136H6441997-03-14014 March 1997 Comment Opposing Proposed NRC GL 97-XX Loss of Reactor Coolant Inventory & Associated Potential for Loss of Emergency Mitigation Functions While in Shutdown Condition ML20086M8151995-07-13013 July 1995 Comment Supporting Proposed Generic Ltr Re Process for Changes to Security Plans W/O Prior NRC Approval ML20077E8671994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re Regulations Governing NPP License Renewal Process ML20077E1861994-12-0202 December 1994 Comment Supporting Proposed GL on Reconsideration of NPP Security Requirements for Internal Threat.Endorses Comments Submitted to NRC by NUMARC on 941202 ML20076L1471994-10-24024 October 1994 Comments on Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Endorses Response Submitted by Nuclear Energy Institute ML20045D7351993-06-0303 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule ML20091A2281992-03-18018 March 1992 Comment Endorsing Comments Provided by NUMARC Re Proposed Rule 10CFR51 Re Requirements for Environ Review of Applications to Renew OLs for Nuclear Power Plants ML20073P7301991-05-16016 May 1991 Comment Opposing Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery 1998-03-26
[Table view] |
Text
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W$LF CREEK NUCLEAR OPERATING CORPORATION
/f Gary D. Doyer Chief Adminstrative Offecer g g CO 98-0006 7 5 ta U. S. Nuclear Regulatory Commission
- Rulea and Directives Branch qC* Cu
? M b h Office of Administration I ?g 2
washington, DC 20555 d'*d<
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Subject:
Docket No.50-4821 Wolf Creek Nuclear Operating CorporatJon ar Comrnents on Draf t Regulatory Guide DG-1070 W gfy i N
Gentlemen:
Wolf Creek Nuclear Operating Corporation (WCNOC) has reviewed Draft Regulatory
, Guide, DG-1070, " Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants", dated September 1997, and the
" Indust ry Comment s on DG-1070", dated November 23, 1997, provided by Nuclear Electric Institute (NEI). Based on the review of these documents, WCNOC provides the following comments.
WCNOC endorses the NEI t;sition concerning the Draft Regulatory Guide DG-1070 in regards to Industry Background, Performance History of Dedicated Commercial Grade Items, and the Regulatory Basis for Sampling During the Dedication Process. In addition, WCNOC strongly agrees with the position NEI has identified concerning the Cost of the Regulatory Guide Implementation.
The cost to implement the guidance provided on the Dn; ilegulatory Guide
! would be significant to WCNOC and the industry. The drut guide requires a tighter sampling size than most utilities and suppliers use on larger lots, and it specifies verification of overly conservative critical characteristics and acceptance criteria for simple inetallic items. If implemented, increased costs would be created by the following:
The man-hours required to complete additional testing will require adding personnel to staff.
- The procurement of additional test equipment to accommodate increased testing.
- Increased population of stock numbers and total stock to accommodate different levels of safety significance.
- The cost to reviso current procurement engineering and dedication g; procedures to address revised sampling practices. l~
- The cost to revise all current dedication plans.
- The increased cost of items that were dedicated by approved 10 CFR 50, Appendix B suppliers who significantly increase sampling because they must assume items are intended for safety-significant applications.
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- Increased engineering resources to evaluate homogeneity of lot. There will also be increased costs to obtain the level of lot homogeneity the Draft Regalatory Guide requires for sampling.
- Many of the tests the NRC considers nondestructive, would actually be destructive f or cruall simple rnetallic items. Therefore, a significant nurnber of additional products would need to be procured.
Increased off-site testing because many utilities and suppliers do not currently have all of the test equipment required to cort.plete testing specified in the Draft Regulatory Guide.
The time to ecmplete dedication will be increased which may have an A rnpact on parts availability to support plant operation or potentially becomo critical path during refueling outages.
The cost of obtaining additional paperwork from suppliers (such as, certified Material Test Reports, certificates of Conformance, etc.).
Huelear utilities have self-initiated actions on two fronts to improve sampling in the dedication process. These initiatives are as follows:
l Nuclear Procurement Issues Committee (NUPIC) -
Action to enhance the NUPIC checklist to provide additional guidance on ensuring that ;
! rnanufacturers have a technically justifiable sampling plan.
L I Electric Power Research Institute (EPRI) -
Action to develop a revision to EPRI document NP-7218 " Utilization of Sampling Plans for CGI Acceptance" to address the sampling sizes for destructive testing, consideration of safety function and safety significance when selecting a sample size and lot homogeneity considerations.
In conclusion, WCNOC believes that based on excellent performance history of dedicated commercial grade items, the current sampling programs utilized by utilities and 10 CFR 50, Appendix B manuf acturers/ suppliers are adequate to ensure safe operation of nuclear power plants. WCNOC believes that the sampling plans utilized are in accordance with current regulatory requiremants and industry standards and that no additional guidance from the NRC is required. In addition, WCNOC believes that implementation of the recommendations orovided in the Draft Regulatory Guide would significantly increase the cost of procurement witnout improving the quality of installed items.
If you have any questions concerning this matter please contact me at (316) 364-8831, extension 4450, or Mr. Michael J. Angus at extension 4077 Ver truly yours, G
Gary D. Boyer GDB/jad cet W. D. Johnson (NRC)
E. W. Merschoff (NRC)
J. F. Ringwald (NRC)
K. M. Thomas (NRC)
NRC Document Control Desk
,