IR 05000298/1992201: Difference between revisions

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{{Adams
{{Adams
| number = ML20128B865
| number = ML20034F709
| issue date = 11/25/1992
| issue date = 02/26/1993
| title = Provides Followup to Telcon on 921118 Re Insp Rept 50-298/92-201 of Procurement & Commercial Grade Dedication Programs at Plant
| title = Informs of NRCs Position on Commercial Grade Dedication Issues at 930203 Meeting & Actions Taken at Plant to Address Generic Weakness & Specific Concerns Re Dedication of Commercial Items Identified in Insp Rept 50-298/92-201
| author name = Roe J
| author name = Roe J
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 9212040118
| document report number = NUDOCS 9303040173
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 5
| page count = 4
}}
}}


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FEB 2 61933
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Docket No.


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50-298 Pr. (My Nuclear Power Group Monager Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499
.
November 25, 1992 Docket No. 50-298 Mr. Guy Nuclear Power Group Manager Hebraske Fublic Power District P.O. Box 499 Columbus, Nebraska 6860c '499


==Dear Mr. Horn:==
==Dear Mr. Horn:==
SUBJECT:
SUBJECT: MEETING WITH NEBRASKA PUBLIC POWER DISTRICT (NPPD) ON COMMERCIAL GRADE DEDICATION ISSUES As you are aware, we are currently reviewing our positions on commercial grade item (CGI) dedication as a result of industry comments following our recent pilot inspections in this area. A major component of our review is meeting with several licensees to identify and gain insights into specific areas of differing interpretations of stated positions and to identify areas in which additional clarifications or relaxations of NRC positions may be appropriate.
INSPECTION 07 THE PROCUREMENT AND COMMERCIAL GRADE DEDICATION PROGRAMS AT THE COOPER NUCLEAR STATION (REPORT NO. 50-298/92-201)
This letter is a followup to the conference call on November 18, 1992, between NRC staff and Mr. C. M. Estes, Procurement Task Force Leader, and other Nebraska Public Power District (NPPD) staff members conceraing the above inspection conducted February 24 through 28, 1992, at the Cooper Nuclear Station (CNS) by the NRC's Vendor inspection Branch.


The inspection at CNS was the second of a series of five pilot inspections conducted to evaluate the implementation of licensee programs for the procurement and dedication of commercial grade items (CGis) and to finalize an inspectir proc 2 dure for future inspections of this type.
On February 3,1993, we met with Mr. Whitman and other members of NPPD's Quality and Procurement Engineering staff at NRC headquarters in Rockville, Maryland as one part of this activity.


These inspections identified nraknesses ir licensee CGI dedication programs and their im31ementation.
We believe that this meeting provided valuable information to aid in our ongoing review. We found NPPD's presentation, including the summary of your views on the NRC's CGI dedication positions, especially helpful in better understanding the user's perspective on these issues.


The first t'iree pilnt inspections classified these ceaknesses as deficiencies with the potential for subsequent enforcement actions by the appropriate NRC regional office. During this same period, the NRL also received significant feedback from several utilities and the Nuclear Mar wement and Resources Council (NUMARC) questioning the regulatory basis for the CGI dedicatien guidance contained in Generic Letter 91-05, as well as specific interpretations of that guidance-by the NRC inspection teams.
The open discussions during this meeting were productive and helped to clarify several apparent misunderstandings concerning the interpretation of our stated positions. We are evaluating your written comments on specific issues including reasonable assurance, Appendix B equivalency, and failure modes and effects analyses.


In order fc ' the NRC to properly respond to tnese concerns and to resolve major points of contention concerning the CGI dedication process, we will be holding public meetings with individual utilities-and conducting a public workshop wh'ci, will address issues concerning the existing dedication guidance and specific interpretations of that guidanca.
In the near future, we will be issuing for public comment NRC inspection guidance and holding a public workshop on CGI dedication activities. We will consider your comments in this guidance.


Prior-to the public workshop, th proposed inspection procedure for future inspections 111 be issued for pubiic comment and discussion at the workshop.
During the February 3 meeting, we also discussed actions that you have taken at Cooper Nuclear Station to address the generic weaknesses and the specific concerns related to dedication of certain CGIs, as identified in our Inspection Report No. 50-298/92-201.


In view of these pending actions, the specific observations for the last two inspections concerning the CGI dedication program and its implementation were classified as findings, not deficiencies. Because of the need for additional discussion of the appropriate guidance for dedication of CGIs, t.o enforcement action wil? be taken based on any of the five pilot inspections.
Based on the information that was presented, it appears that these issues have been satisfactorily resolved.


It should be recognizea, nowever, that some of these findings may require corrective action based on: (1) their potential impact on the performance of specific equipment, or (2) because of noncompliance with your commitments to specific industry
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If you should have any questions or additional coments concerning the above,
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please contact C. E. Rossi, Director, Division of Reactor Inspection and
,
Licensee Performance.


We expect + hat you will evaluate the inspection findings in view.of these considerations and take appropriate corrective action as necessary, At the exit meeting, NPPD committed to strengthen and improve their program in several areas. These actions, when fully implemented, will be considered a major program strength, in accordance with 10 CFR 2.790(a) of the NRC's " Rules of Practice," a copy of
'
*
this letter will be placed in the NRC's Public Document Room.


Shoulc' yot. have any questions concerning this letter, we will be pleased to discuss them with you.
Sincerely,
 
.
Thank you for your cooperation.
w.h Jack W. Roe, Director
 
Sincerely, rhQTR
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IJack W. Roe, Director Division of Reactor Projects-III/IV/V Office of Nuclear Reactor Regulation cc:
Division of Reactor Projects-III/IV/V Office of Nuclear React a-Regulation
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Mr. Guy N standards or regulatory guides endorsing such standards. We expect that you will evalote the inspection findings in view of these considerations and take appropriate corrective action as necessary.
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At the exit meeting, NPPD comitted to strengthen and improve their program in several areas and comitted to re-evaluate affected warehouse inventory.
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These actions, when fully implemented, will be considered a major program strength.
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In accordance with 10 CFR 2.790(a) of the NRC's ' Rules of Practice," a copy of this letter will be placed in the NRC's Public Document Room.
 
Should you have any questions concerning this letter, we will be pleased to discuss them with you. Thank you for your cooperation.
 
Sincerely, ORIGINAL SIGNED BY:
Jack W. Roe, Director Division of Reactor Projects-III/IV/V Office of Nuclear Reactor Regulation cc:
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Mr. G. D. Watson, General Counsei Nebraska Public Power District P. O. Box 499 r
Mr. G.D. Watson, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 Cooper Nuclear Station ATTN: Mr. John M. Meacham Division Manager of Nuclear Operations P.O. Box 98
Columbus, Nebraska 68602-0499 Cooper Nuclear Station ATTN: Mr. John M. Meacham
-
Brownville, Nebraska 68321 Randolph Wood, Director Nebraska Department of Enviornmental'
Control P.O. Box 98922 Lincoln, Nebraska 68509-8922 Mr. Larry Bohlken, Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, Nebraska 68305 Senior Resident Inspector U.S. Nuclear Regulatory Commi!sion P.O. Box 218
.
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Brownville, Nebraska 68321 Regional ~ Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011-Mr. Harola Berchert,. Director Division' of Radiological Health Nebraska Department of Health 301-Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007
*
Site Manager P. O. Box 98 Brownville, Nebraska 68321 Randolph Wood, Director Nebraska Department of Environmental Control P. O. Box 98922 Lincoln, Nebraska 68509-8922 Mr. Richard Moody, Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street
!
Auburn, Nebraska 68305 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, Nebraska 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. Harold Borchert, Director Division of Radiological Health Nebraska Department of Health 301 Centennial Mall, South P. O. Box 95007 Lincoln, Nebraska 68509-5007
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If you should have any questions or additional comments concerning the above,
,
please contact C. E. Rossi, Director, Division of Reactor Inspection and Licensee Performance.


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At the exit meeting, NPPD comitted to strengthen and improve their program in several areas and committed to re-evaluate affected warehouse inventory.
 
These actions, when fully implemented, will be considered a major program strength.
 
In accordance with 10 CFR 2.790(a) of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC'> Public Document Room.
 
;
Should you have any questions concc ning this letter, we will be pleased to discuss them with you.
 
Thank you for your cooperation.


Sincerely,
Sincerely,
'
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Jack W. Roe, Director Division of Reactor Projects-III/IV/V Office of Nuclear Reactor Regul stion cc:
i DISTRIBUTION DOCKET flLE/ CENTRAL FILES / RIDS IE:09/PDR CHehl, RI LPDR WHodges, RI VIB R/F GGrant, OEDO DRIL R/F AGibson, RII
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Revision as of 07:03, 20 December 2024

Informs of NRCs Position on Commercial Grade Dedication Issues at 930203 Meeting & Actions Taken at Plant to Address Generic Weakness & Specific Concerns Re Dedication of Commercial Items Identified in Insp Rept 50-298/92-201
ML20034F709
Person / Time
Site: Cooper Entergy icon.png
Issue date: 02/26/1993
From: Roe J
Office of Nuclear Reactor Regulation
To: Horn G
NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 9303040173
Download: ML20034F709 (4)
v • d • e


Text

.

"#

'o UNITED STATES E" s %

%

NUCLEAR REGULATORY COMMISSION

,

$

,E

wassiNoTos, o. c. 20sss s.... /

FEB 2 61933

-

Docket No.

50-298 Pr. (My Nuclear Power Group Monager Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499

Dear Mr. Horn:

SUBJECT: MEETING WITH NEBRASKA PUBLIC POWER DISTRICT (NPPD) ON COMMERCIAL GRADE DEDICATION ISSUES As you are aware, we are currently reviewing our positions on commercial grade item (CGI) dedication as a result of industry comments following our recent pilot inspections in this area. A major component of our review is meeting with several licensees to identify and gain insights into specific areas of differing interpretations of stated positions and to identify areas in which additional clarifications or relaxations of NRC positions may be appropriate.

On February 3,1993, we met with Mr. Whitman and other members of NPPD's Quality and Procurement Engineering staff at NRC headquarters in Rockville, Maryland as one part of this activity.

We believe that this meeting provided valuable information to aid in our ongoing review. We found NPPD's presentation, including the summary of your views on the NRC's CGI dedication positions, especially helpful in better understanding the user's perspective on these issues.

The open discussions during this meeting were productive and helped to clarify several apparent misunderstandings concerning the interpretation of our stated positions. We are evaluating your written comments on specific issues including reasonable assurance, Appendix B equivalency, and failure modes and effects analyses.

In the near future, we will be issuing for public comment NRC inspection guidance and holding a public workshop on CGI dedication activities. We will consider your comments in this guidance.

During the February 3 meeting, we also discussed actions that you have taken at Cooper Nuclear Station to address the generic weaknesses and the specific concerns related to dedication of certain CGIs, as identified in our Inspection Report No. 50-298/92-201.

Based on the information that was presented, it appears that these issues have been satisfactorily resolved.

.

T zgangeR3s888b f

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..

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-

..

-

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.

,

'M.. Guy R.' Horn-2-

,

If you should have any questions or additional coments concerning the above,

>

please contact C. E. Rossi, Director, Division of Reactor Inspection and

,

Licensee Performance.

'

Sincerely,

.

w.h Jack W. Roe, Director

!

Division of Reactor Projects-III/IV/V Office of Nuclear React a-Regulation

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Mr. Guy '

Nuclear Power Group Manager Cooper Nuclear Station CC*

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Mr. G. D. Watson, General Counsei Nebraska Public Power District P. O. Box 499 r

Columbus, Nebraska 68602-0499 Cooper Nuclear Station ATTN: Mr. John M. Meacham

.

Site Manager P. O. Box 98 Brownville, Nebraska 68321 Randolph Wood, Director Nebraska Department of Environmental Control P. O. Box 98922 Lincoln, Nebraska 68509-8922 Mr. Richard Moody, Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street

!

Auburn, Nebraska 68305 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, Nebraska 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. Harold Borchert, Director Division of Radiological Health Nebraska Department of Health 301 Centennial Mall, South P. O. Box 95007 Lincoln, Nebraska 68509-5007

.

._

,

.

.

.

,

,

Mr. Guy _p_

If you should have any questions or additional comments concerning the above,

,

please contact C. E. Rossi, Director, Division of Reactor Inspection and Licensee Performance.

l

Sincerely,

'

fo/

Jack W. Roe, Director Division of Reactor Projects-III/IV/V Office of Nuclear Reactor Regul stion cc:

i DISTRIBUTION DOCKET flLE/ CENTRAL FILES / RIDS IE:09/PDR CHehl, RI LPDR WHodges, RI VIB R/F GGrant, OEDO DRIL R/F AGibson, RII

,

RMcIntyre EMerschoff, RII GCwalina TMartin, RIII SCollins, RIV LCallan, RIV KPerkins, RV MVirgilio

,

JLarkins WRussell HRood JPartlow

_

SEE PREVIOUS CONCURRENCE

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NAME RPETTIS UPOTAPOVS LN0hVkfiN RZIMMERMAN Cb~

DATE 2/09/93*

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2/09/93*

2/16/93*

2//9/93

.

COPY YES XX YES XX YES XX YES XX ES NO DOC x

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NAME JR0 DATE 2/h93

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OfflCIAL RECORD COPY Document Name: A:\\ HORN

.

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