RC-95-0009, Comment Supporting Proposed Rule 10CFR21 Re inter-utility Transfer

Comment Supporting Proposed Rule 10CFR21 Re inter-utility Transfer

ML20080F133
Person / Time
Site:	Summer
Issue date:	01/09/1995
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR53372, FRN-60FR48369, RULE-PR-21 59FR53372-00009, 59FR53372-9, AF01-2-010, AF1-2-10, RC-95-0009, RC-95-9, NUDOCS 9501190095
Download: ML20080F133 (2)

Text

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l South Carolina Electric & Gas Company Gary J. Taylor PO. Box 88 Vice Pr=ident Jenkinsville. SC 29065 Nuclear Operatons (803)345MK[}[Q

'TTM DOCKETNUMBERg g SCE&G usH9c PROPOSED RULE

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'95 JM 13 P3 :25 January 9, 1995

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C3 Mr. S. J. Chilk, Secretary, U.S Nuclear RegulatoryCommission W'

7 ton, DC 20555

<on: Docketing and Service Branch

Subject:

VIRGIL C. SUMMER NUCLEAR STATION i

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 COMMENTS ON PROPOSED AMENDMENTS TO 10 CFR PART 21 1

South Carolina Electric & Gas Company (SCE&G) has reviewed the proposed amendments to 10 CFR Part 21 (59 Fed. Reg. 53372). SCE&G is in agreement with the 1

3roposed amendments; however, we believe that inter-utility transfers should also ae specifically addressed at this time by the amendment to 10 CFR Part 21, 10CFR21 does not clearly address the 10CFR21 obligations associated with a safety-related " complex" item (manufactured under an a ppendix B program) which was purchased from a qualified vendor by utility "he case where utility "A" is unwillin A", then transferred to utility "B" for use as a basic component. Problems arise in t accept 10CFR21 provisions on the transfer procurement documents, if utility "A" is unwilling to accept 10CFR21 responsibility in the transfer, the 10CFR21 amendment (section 21.31) should address that the transfer is allowed,if utility B can document their acceptance of the qualification of the vendor during the time of original manufacture and sale of the item.

We suggest the following sentence addition to 21.31: "In the case of inter-utility transfer of basic component items an exception is made to the imposition of 10CFR21 provisions on the inter-utility transfer documents,in the cases where the receiving utility can document their acceptance of the qualification of the originally supplying vendor".

9501190095 950109 PDR PR 21 59FR53372 PDR

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Mr. S. J. Chilk, Secretary Page 2 of 2 inter-utility transfers provide an opportunity to obtain qualified equipment / material when manufacturers or vendors are not able to meet immediate needs. Inter-utility transfers are not currently addressed by 10 CFR Part 21 and SCE&G believes this is an excellent opportunity to provide guidance in this area.

j SCE&G appreciates the opportunity to provide comments on this proposed rule.

Verytrul yours, GAA Gary ar /

JDH:ews c:

O. W. Dixon R. R. Mahan R. J. White G. F. Wunder NSRC CFS RTS (PR 920036)

File (811.02,21.003) l 1

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