ML20246P606

Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Significant & Independent Industry Efforts Already Underway to Address Issue

ML20246P606
Person / Time
Site:	Indian Point
Issue date:	07/07/1989
From:	Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-54FR9229, RULE-PR-50 54FR9229-00057, 54FR9229-57, NUDOCS 8907200262
Download: ML20246P606 (2)

Text

, . _ _ _ _

, . Stephen B. Bram I DOCKETNUMBER g fg -

PROPOSED RULE -

Consohdated Edison Company of New York, Inc. [

f indsen Point Station (qQr UWC

q -[J UPF,[

Broadway & Bleakley Avenue Buchanan, NY 10511 Telephone (914) 737-8116 Julf9,JE98 7 P :28 '89 JUL M P4 j 4 C ep y Waj fe(t ett #A 9"Ndh ]

Re: Indian Point Unit No. 2 ye1 .

,~ '

DocT4tLNo. 50-247% DOCM M ' . . :. / .

3 i :. N i. '  ?.U V H Mr. Samuel J. Chilk Secretary of the Commission US Nuclear Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch

SUBJECT:

Advance Notice of Proposed Rulemaking Acceptance of Products Purchasedifor use in Nuclear Power Plant Structures, Systems and Cou'ponents 54 FR 9229 (March 6, 1989)

Request for Comments

Dear Mr. Chilk:

Consolidated Edison Company of New York, Inc. (" Con Edison"), licensee of Indian Point Unit No. 2, welcomes the opportunity to enyress its views to the Commission on the subject Advance flotice of Proposed Rulemaking (ANPR) pertaining to the acceptance of purchased components which may be installed iti the plant.

Con Edison is interested in assuring that all reasonable measures are j taken to prevent the use of fraudulent, counterfeit or substandard  ;

components at Indian Point Unit No. 2. To this end, con Edison is  !

involved in several efforts, independent of any regulatory requirements. j As a member of the Nuclear Management and Resources Council, Inc. j

("NUMARC"), we agree with the industry initiative "to review and, if j necessary, to develop or upgrade programs...that address the use of j commercial grade items in nuclear safety related applications to meet the I intent of the guidance provided in EPRI NP-5652 ' Guideline for the j Utilization of Commercial Grade Items in Nuclear Safety Related l Applications' (NCIG-07)". l 1

Also, as a member of NUMARC, Con Edison is represented on the Nuclear Plant Equipment Procurement (NPEP) Working Group which is very active in i industry efforts to address procurement issues. Con Edison has also j participated in NUMARC's efforts in commenting on this ANPR. We have reviewed and accepted the industry-wide position presented by NUMARC.

The detailed comments on the ANPR contained in the NUMARC submittal are fully endorsed by Con Edison and should be considered as an adjunct to this letter.

I 8907200262 890707 PDR PR PDR C) //h 50 54FR9229 o I

1 Con Edison is committed to the safe operation of Indian Point Unit No. 2, and, without the imposition of further requirements by the NRC will continue to participate in industry initiatives to ensure the procurement process does not adversely impact safe unit operation. We believe that the issuance of a rule or modifications to existing regulations is not necessary due to the significant and independent industry efforts already underway to address procurement issues.

Should you or your staff have.any questions regarding this matter, please contact Mr. Jude G. Del Percio, Manager, Regulatory Affairs and Safety Assessment.

Very truly yours, l-cc: Document Control Desk US Nuclear Regulatory Commission '

Mail Station PI-137 Washington, DC 20555 Mr. William Russell Regional Administrator - Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1498 Mr. Donald S. Brinkman, Project Manager Project Directorate I-1 Division of Reactor Projects I/II US Nuclear Regulatory Commission Mail Stop 14B-2 Washington, DC 20555 Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511 u_-__--________________ _ _ _ _ _ -