NRC-95-0001, Comment Supporting Proposed Rule 10CFR21 Re Procurement of Commercial Grade Items by NPP Licensees

Comment Supporting Proposed Rule 10CFR21 Re Procurement of Commercial Grade Items by NPP Licensees

ML20077L822
Person / Time
Site:	Fermi
Issue date:	01/09/1995
From:	Goodman L DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-95-0001, CON-NRC-95-1, FRN-59FR53372, FRN-60FR48369, RULE-PR-21 59FR53372-00005, 59FR53372-5, AF01-2-006, AF1-2-6, NUDOCS 9501120021
Download: ML20077L822 (2)

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OFFIC!.u .-m,+

.-r Cr'fiARY DOCKEll% ' *i Ek u.fiCr O Secretary, U. S. Nuclear Regulatory Commission Wushington, D. C. 20555

References:

1) Fermi 2 1 i

NRC Docket No. 50-341 NRC License No. NPF-43

2) NRC Proposed Rule,10 CFR 21, Procurement of Commercial Grade Items by Nuclear Power Plant Licensees, dated October 24, 1994 (59 FH 53372)

Subject:

Detroit Edison Comments on the Proposed Rule 10 CFR 21, Procurement of Commercial Grade Items by Nuclear Power Plant Licensees The purpose of this letter is to submit Detroit Edison's comments on the proposed rule on 10 CFR 21 (Reference 2). The comments are provided in the Enclosure of this letter.

If you have any questions, please contact Mr. Girija S. Shukla at (313) 586 4270.

Sincerely.

Lynne S. Goodman .. ,

Director, Nuclear Licensing Enclosure cc: T. G. Colburn A. Marion (NCI) ,

J. B. Martin {

M. P. Phillips '

A. Vegel 9501120021 950109 '

PDR PR 21 59FR53372 PDR ym

b l JAN-09-1995 15:40 FERMI 2 DET EDISON 313 586 4208 P.02

. p Enclosure to NRC-95-0001 Page 1 l

Detroit Edison Comments on NBC P w- Rule 10 (FR 21. Procurement ,

of Commercial Grade Itama tw Muclear Pouer Plant Licenseen In general, Detroit Edison supports the NUMARC petition of October 14, '

1993 and endorses NEI's enaments on'the proposed rule. Detroit Edison's specific comments are given below* r o The proposed rule provides a definition of dedication which reads l that Dedication is an inspection and acceptance process by which a commercial grade ites is designated for use as a basic component.

This definition could cause confusion when compared with the i activities of inspections, tests, and/or analyses. We suggest 1 the definition be changed to raads that dedication is an acceptance process which includes inspections, tests, and/or analyses by which a commercial grade ites is designated for use as a basic component.

o Under Dedicating entity, the new rule implies that if the  !'

licensee is the dedicating entity, the dedicated ites is to be used only by the dedicating licensee.

We suggest the definition be changed to read that dedication may  !

be performed by either the manufacturer of the ites, a third i party dedicating entity, or a licensee. This change would permit '

one licensee to also dedicate for other licensees. ,

o Also under Dedicating entity, clarification should be added that  !

reporting requirements apply for the dedicated ites once it has been designated for use as a basic component.

This would clarify that the dedicating entity need not report i defects identified during the dedication process and prior to l designating the dedicated ites a basic component.

o New requirements are being specified for dedication, hence, a j backfit analysis should be required.

o Under Dedication, the text should be changed to read that the dedication process should provide assurance that a commercial grade iten to be used as a basic component will perform its intended safety-related function, but not that the ites is equivalent to an ites designed and manufactured under a 10 CFR 50, App. B Quality Assurance Program. Also, items currently required to be designed and manufactured as basic components, such as fuel and control rod assemblies and pressure vessels, should be allowed to be dedicated if they are built to acceptable standards. ,

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