ML20080G847

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Comment on Proposed Rule 10CFR21 Re Procurement of Commercial Grade Items by NPP Licensees.Recommends That New Definitions Be Applicable & Consistent to Licensees Who Hold Other Licenses as Well as Part 50 License
ML20080G847
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 02/01/1995
From: Dennis Morey
SOUTHERN NUCLEAR OPERATING CO.
To: Hoyle J
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR53372, FRN-60FR48369, RULE-PR-21 59FR53372-00017, 59FR53372-17, AF01-2-018, AF1-2-18, NUDOCS 9502090164
Download: ML20080G847 (2)


Text

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Southem Nuclear Oper: ting Campany a

Post Office Sox 1295

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DOCKET NUMBER DOCKEiED PROPOSED RULE M

-USWC (5RFR.583@ hem #uaip@pating Com a Sout o..e u. rey Vee President Farley Project thesouthem.

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% FEB -7 P4 :14 John C. Hoyle, Ac' s.: Secretary l

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Q U. S. Nuclev Regulatory Commission Washington, D.C. 20555-0001 y@

Comments on Procurement of Commercial Grade Items by Nuclear Power Plant Licensees i

(59 Federal Renister 53372 of October 24.1994)

Dear Sir:

Southem Nuclear Operating Company has reviewed the proposed rule, " Procurement of Commercial Grade Items by Nuclear Power Plant Licensees," published in the Federal l

Register on October 24,1994. In accordance with the request for comments, Southern i

Nuclear is in total agreement with the NEI comments that are to be provided to the NRC.

Additionally, Southern Nuclear would like to offer the following comment: The NRC indicates that the new definitions of Basic Component, Commercial Grade Item, Critical I

Characteristic, Dedication and Dedicating Entity would apply only to Part 50 licensees while the current definitions of the Basic Component, Commercial Grade Item and i

Dedication would continue to be applicable to Part 30,40,60,61,71 and 72 licensees Furthermore, the definitions of Critical Characteristics and Dedicating Entity would not be applicable to licensees except those under Part 50. It will be confusing and costly for nuclear plant operators to procure and dedicate equipment under different regulatory requirements due to the fact that many Part 50 licensees have additional licenses The current wording of the regulations indicate that a Part 50 licensee that holds additional licenses would be working under differing definitions. The evaluation and reporting of potential defects would also be more difficult. It is recommended that the new definitions be applicable and consistent to licensees who hold other licenses as well as a Part 50 heense Should you have any questions, please advise.

I Respectfully submitt j

(, b k W h D. N. Mor >

DNM/JMG j

9502090164 950201 PDR PR 21 59FR53372 PDR 90

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U.S. Nuclear Regulatory Commission Page 2 I

cc: Southarn Ntelaar Operatino Company Mr. R. D. Hill, Plant Manager U. S. Nimlaar Ramilatory Comminaion. Washinoton. DC Mr. B. L. Siegel, Licensing Project Manager U. S. Niel=r Remilmtary Camminaion. Region II Mr. S. D. Ebneter, Regional r#strator Mr. T. M. Ross, Senior Resident Inspector i

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