ML20044F327

Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics

ML20044F327
Person / Time
Site:	Comanche Peak
Issue date:	05/21/1993
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-58FR15167 58FR15167, NUDOCS 9305280023
Download: ML20044F327 (4)

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,I,3,N,$$f,',#' May 21, 1993 Mr. David L. Meyer Chief. Rules Review and Directives Branch Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555  ;

SUBJECT:

SOLICITATION OF PUBLIC COMMENTS ON DRAFT NRC INSPECTION PROCEDURE 38703,

' COMMERCIAL GRADE PROCUREMENT INSPECTION,"

FEDERAL REGISTER VOLUME 58 NUMBER 52

Dear Mr. Meyer:

On March 19, 1993, in the Federal Register Volume 58, Number 52 the Nuclear Regulatory Commission solicited comments on the draft NRC Inspection Procedure 38703, " Commercial Grade Procurement Inspection.' This letter is submitted to provide comments (attached) on the subject procedure.

TV Electric endorses the HUMARC letter, dated May 17, 1993, which submitted general comments on the draft inspection procedure.

To provide feedback to the industry, it would be helpful if a listing of NRC Inspection Reports which utilize the Commercial Grade Procurement Inspection Procedure would be included in the quarterly reports of NUREG-0040,

• License Contractor and Vendor Inspection Status Report.*

If you have any questions, please contact Mr. Carl B. Corbin at (214) 812 8859.

Sincerely, William . Cahill, Jr.

By: .

M S. Mafshall '

Generic Licensing Manager i CBC/gjh Attachment 9305280023 930521 PDR PR MISC SBFR15167 PDR 400 N Obvc Street L.B 81 Datas Texas 75201 l

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. f Attachment to TXX-93218  :

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l COMMENTS ON DRAFT NRC INSPECTION PROCEDURE 38703 t

" COMMERCIAL GRADE PROCUREMENT INSPECTION

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1. The NRC should use the EPRI definitions for Critical Characteristics.

Critical Characteristics under the scope of this inspection procedure l should only be critical characteristics for acceptance. The definitions  !

section (Appendix B) should match EPRI guidelines. -

2. There should be aeditional guidance and clarification as to when this l procedure is applicable. Include a statement that f ailures due to l normal wear, improper maintenance, inappropriate design application, j expected end of life, etc., are excluded.

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3. The inspection procedure section 2.02 states that "If a failed item was  !

dedicated, this inspection procedure is applicable". This leaves the '

impression that there are no inspection activities associated with  !

f ailures of items procured f rom Appendix B suppliers, and that dedicated i items are held to a higher level of accountability. This section should indicate that failure of items procured from Appendix B suppliers are covered under other inspection procedures. These procedures should be l referenced. The flow chart should also reflect this situation. j

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4. The section on sampling (App. A, Section 2) needs to be rewritten to 1 inc'ude the following: l f

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A. Sections 2a and 2b need to be combined. Section 2a is written for metallic items only. This needs to be broadened to cover  ;

other types of items such as non-metallics where a reduced sample j may be appropriate. There needs to be a graded approach to the j acceptance process that allows for the use of-Engineering i judgement in sample size selection. This is particularly true of i destructive testing for small lots. Basing the sampling strictly j on statistical samples is impractical since the sample sizes are j large compared to the lot size. '

i B. Acceptable "other means* should be expanded. These 'other means* j need to include expanded sampling, visual inspection, -i identifications and markings, packaging, experience with the l vendor, appearance. The level of verification of lot homogeneity l should be commensurate with the complexity of the item. f C. The inspection guide should acknowledge that there are industry  !

standards that assure homogeneity. These include but are not i limited to 150-9000, MIL Spec / Standards, API Standards, FDA l Requirements, Aerospace Standards, etc. The use of manufacturers j that are regulated to these industrial standards should be

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acceptable for lot and batch determination without a survey. i l

1 D.

• Standard Statistical Methods" in Section B needs to be expanded j to include

• Standard or Utility Develooed Statistical Sampling j Methods *.

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Attachment t o TXX-93200 Page 2 of 3

5. The traceability section (App. A. Section 3) should provide the latitude to survey the distributor based on the complexity of the item and the susceptibility of the item to tampering, modification, or mishandling by the distributor. If unacceptable products can be detected through the normal receipt or f raudulent inspection process, there should be no requirement for surveying the distributor. The term

• Recorded Identification" needs to be changed to

• Markings and Documentation".

6. The section on like-for-like (App. A, Section 5) needs to be removed.

The term as used in the inspection procedure indicates the acceptability ,

of an item without going through the dedication process. The term is used in the industry in conjunction with the equi' 41ency evaluation process. The discussion here serves no useful pu ose in the dedication process and is confusing.

7. The guidanr? in this inspection procedure should supplant the guidance provided in Generic Letters 89-02 and 91-05. The NRC needs to f( mally publish this guidence and retract the generic letters. All references to the generic letters should be removed f rom this Inspection Procedure.

8. The inspection procedure should match the flowchart provided in the meeting. The flowchart should be included as part of the procedure. )

9. The inspection guide (App. A Section 6) indicates that CMTRs and Certificates of Compliance may be validated through receipt testing.

This should be clarified to indicate that representative testing may be >

used to establish a confidence level in the document. A correlation

). between receipt testing validation for selected attributes, and not necessarily all of the Physical / Chemical c' tributes, should establish that the document is valid.

10. The section on Engineering Judgement (App. A Section 1.0) should state the position that Critical Characteristics are identified based on the judgement of the utility and the inspector should defer to that judgement unless failures indicate otherwise. Also the section should indicate that the documentation of engineering judgement should address the rationale for the attributes that are verified and their relationship to the safety function. The documentation should not be viewed as an open ended discussion of the critical characteristics that were not identified and why.

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Attachment to TXX-93200 Page 3 of 3 r

11. There should be guidance that failures of items should be evaluated against the procedures and initiatives in effect at the time of the ,

procurement. In addition, methodologies and processes currently used

based on experience and the evolving nature of this area should not be  :

used to evaluate previous dedication activities as long a- there are  !

mechanisms to identify problems and improve the process,

12. The NRC should publish the position that items procured from Appendix B suppliers and items commercially dedicated by the utility are  ;

equivalent. It is the utilities decision as to which method to use and '

that the NRC has no preference.

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