ML20246K422

Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Industry on-going Improvement Efforts Should Be Given Opportunity to Resolve Issues

ML20246K422
Person / Time
Site:	Oyster Creek
Issue date:	07/05/1989
From:	Sullivan J GENERAL PUBLIC UTILITIES CORP.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-54FR9229, RULE-PR-50 54FR9229-00046, 54FR9229-46, GL-89-02, GL-89-2, NUDOCS 8907180169
Download: ML20246K422 (2)

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July 5, 1989 Mr. Samuel J. Chilk ~

Secretary U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch ,  ;

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Advance Notice of Proposed Rulemaking 1 Acceptance of Products Purchased for Use in Nuclear Power Plant Structures, Systems and Components 54 Fed. Reg. 9229 - March 6, 1989 Request for Comments We have reviewed the NRC's Advance Notice of Proposed Rulemaking (ANPR) entitled " Acceptance of Products Purchased for Use in Nuclear Power Plants Structures, Systems and Components (54 Fed. Reg. 9229 - March 6, 1989).

GPU Nuclear shares the NRC's concern with fraudulent, counterfeit or substandard components that have been found in commercial nuclear power plants. We believe that the potential for fraudulent or counterfeit components should be reduced by increased attention and effort by the nuclear industry.

As described in a letter transmitted by NUMARC on June 26, 1989 concerning the subject matter, the industry efforts (e.g., NUMARC Nuclear Plant i Equipment Procurement (NPEP) Working Group) are already under way to address industry and NRC concerns regarding the procurement process.

NUMARC NPEP Working Group activities encompass many areas where improved procurement practices could be expected to result in increased capability for detection of substandard, counterfeit or fraudulent materials.

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GPU Nuclear Corporation is a subsidiary of General Pubhc Utihties Corporation

Mr. Samuel J. Chilk July 5,1989 Page 2 GPU Nuclear had reviewed and concurred with the coments transmitted to you by the June 26, 1989 NUMARC letter. As indicated in that letter we believe that 10 CFR 50 Appendix B, when utilized with standards such as ANSI N45.2, N45.2.13, or ANSI /ASME NQ A1, along with their corresponding regulatory guides, already contain appropriate criteria for ensuring the acceptability of purchased items. We, therefore, do not believe that another regulation with more stringent requirements or a modification to existing regulation, would provide the best course'of action for ensuring the proper acceptability of purchased items. Rather, industry initiatives to build-up on the strengths of the current system by prosiding consistent application, implementation and interpretation of the existing standards and regulations would offer more effective means to deal with the array of procurement scenarios. ,

To this end the NUMARC NPEP Working Group has already embarked on activities to improve procurement practices as outlined in " Nuclear Procurement Issues" (Attachment I to the June 26, 1989 NUMARC letter).

NRC Generic Letter 89-02, " Actions to improve the detection of counterfeit and fraudulently marketed products," observed that some utility programs are already effective at providing an improved capability to detect fraud.

We believe the on-going industry improvement efforts should be given the opportunity to address and resolve the issues relating to the procurement. The need for a new regulation can be considered after assessing the effectiveness of the industry efforts at later time.

Very truly yours, y)Sul

. d.

n, Jr.

irector, censing & Regulatory Affairs JLS/crb i

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