ML19263A912
| ML19263A912 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1978 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Anderson K EMVGRIN |
| References | |
| TASK-OS, TASK-RS-519-1 NUDOCS 7901030201 | |
| Download: ML19263A912 (2) | |
Text
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f -8 UNITED STATES NUCLEAR REGULATORY COMMISSION y~ j WASHINGTON. D. C. 20555 ,.s e e %v f DEC 2 01978 ITT Grinnell Industrial Piping, Inc. Attention: K. B. Anderson P. O. Box 566 Kernersville, NC 27284
Dear Mr. Anderson:
Your letter dated November 8,1978 to the Secret! y of the Comission concerning 10 CFR Part 21 has been forwarded to me for reply. Your letter, among other things, includes (a) your definition of com-mercial grade items, i.e. those ordered in accordance with the require-ments of ASME Section III, (b) your belief as to when dedication should take place, i.e. "the actual fabrication cycle of the piping components," and (c) your recomendations that for those companies ordering all of their stock material to " nuclear quality" (1) the need for 10 CFR Part 21 on purchase orders be eliminated and (2) that the application of 10 CFR Part 21 be picked up at the fabricator's shop. In addition your letter states that "The amendment...does add to the cost of nuclear power piping systems." Your definition is not in accordance with 10 CFR 21,3(a-1) since ASME Section III contains unique design and/or specification requirements for the construction of nuclear power plant components. 10 CFR 21,3(a-1) excludes from the definition of a commercial grade item an item that is " subject to design or specification requirements that are unique to facilities... licensed pursuant to part.. 50..."; e.g. nuclear reactor. The point of dedication mentioned in your letter is not in accordance with 10 CFR 21.3(c-1) if the piping components are themselves items that are subject to design or specification requirements unique to a facility licensed pursuant to 10 CFR Part 50, e.g. ASME Section III Class 2. Dedication is applicable only to commercial grade items. The Supplementary Information accompanying the amendments to 10 CFR Part 21 discusses the improper interpretation that has been given to the definition " basic component" (121,3(a)) and states that when that ?S0103o2of
Mr. Anderson 2-improper definition is applied the quality of items _ has not improved, safety has not been enhanced and cost increases have resulted. The purpose of the amendment was, in part, to relieve the conditions resulting from the improper definition. The staff is not aware that the amendment will add to the cost of nuclear power piping systems. This reply is provided you at this time in the event that you may desire to propose specific amendments to 10 CFR Part 21 that reflect your concern.. Your interest in and comments on this matter are appreciated. Sincerely, f Robert B', Minogue; Director Office of Standards Development e =}}