ML20062M414

From kanterella
Jump to navigation Jump to search
Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items
ML20062M414
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 12/27/1993
From: James M. Levine
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR53159, FRN-59FR53372, RULE-PRM-21-2 102-02766-JML-R, 102-2766-JML-R, 58FR53159-00021, 58FR53159-21, AF01-1-027, AF1-1-27, NUDOCS 9401070066
Download: ML20062M414 (2)


Text

'

' W 2-(5tF8 53157)

c. 2.I Arizona Public Service Company PALO VEnDE NUCLEAR GENERATING STATIOPg- q" i _g ' ~

P O BOX 52034 PHOENIX ARIZONA B5072-2034 102-02766-JML .RAB-SAB JAMES M LEVINE December 27,J1993

~uc 210ZEL~

Secretary of the Commission U. S. Nuclear Regulatory Commission ATTN: Docketing and Service Branch Washington, DC 20555

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Comments on Petition for Rulemaking File: 93-001-503 On October 14,1993, the Nuclear Regulatory Commission (NRC) published in the Feder,a!

Reaister a notice of receipt of a petition for rulemaking regarding procurement of commercial grade items. Arizona Public Service Company (APS) has reviewed this petition and fully supports it because,6s the petitioner states, we have found that the current procurement environment has changed significantly from what it was just a few years ago and the regulation no longer fits the current situation.

Over time, the number of suppliers with programs qualifvJ to the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, has diminished making it increasingly more difficult to obtain pre-qualified replacement parts. More and more, APS has had to revert to purchasing items commercial grade and dedicuting the parts for use in the plant. As this trend continues, the current definition of commercial grade presents a more significant obstacle, to obtaining the appropriate parts. In v2w of this trend, a change to the existing regulations is .varranted.

The net effect of the proposed rule change is to shift more responsibility for ensuring the quality of parts on the licensee and less on the supplier. As long as reasonable assuranue is provided that the commercial grade item will perform its intendthi function, whether that be done by the supplier or the licensee, there will be no adverse impact on plant safety. As such, APS fully endorses the petition for rulemaking.

9401070066 931227 PDR PRM g 21-2 evR p A

i e

L Secretary of the Commission '  !

U. S. Nuciear Regulatory Commission ATTN: Docketing and Service Branch ,

Comments on Petition for Rulemaking Page 2 ,

Should you have any questions, please contact Richard A. Bernier, Nuclear' Regulatory R

Affairs Supervisor at (602) 393-5882..

r Sincerely, wp y

?

JMURAB/SAB/rv

/

cc: . W. F. Conway  :

B. E. Holian .

R. W. Bishop d (NUMARC) i 1

a

?

l e