ML20202C141

Comment on Draft Rg DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Nuclear Power Plants

ML20202C141
Person / Time
Site:	Wolf Creek
Issue date:	01/29/1998
From:	Boyer G WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-62FR52166, RTR-REGGD-XX.XXX 62FR52166-00013, 62FR52166-13, NUDOCS 9802120175
Download: ML20202C141 (2)

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

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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

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