ML20059C303

Comment Supporting Petition for Rulemaking PRM-21-2 Re Definition of Commercial Grade Item

ML20059C303
Person / Time
Site:	Indian Point
Issue date:	12/28/1993
From:	Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR53159, FRN-59FR53372, RULE-PRM-21-2 58FR53159-00010, 58FR53159-10, AF01-1-016, AF1-1-16, NUDOCS 9401050089
Download: ML20059C303 (3)

Text

DEC-28 '04 TUE 15:18 ID:tGDL FAX TEL to n4 757-83ts4 #307 PO4 Stephen B. Bram 1 vos renant " ' []g~

C5(r F P- 5315'1) ,. .

Consoncated Eckson Company of New York, Inc December 28, 1993 Nm indian Posnt Station Broadwav A skemev Avenue Ret Indian Point Unig No, 2 '

Guchanan. NY 10511 Docket No. SEhe'd d 2 To:ephone (914) 737 8116 Mr. Samuel J. Chilk Secretary, Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing t. Service Branch

SUBJECT:

Comments on Petition for Changes to Part 21 REFERE!3CEs Docket No. PRM-21-2

Dear Mr. Chilk:

Consolidated Edison is pleased to provide comments in responus to the notice of receipt of a petition for rulemaking, which appeared in the Federal Register on October 14, 1993 (50 FR 53159). The petitioner requested changes to 10 CFH 21 concerning the definition of " commercial grade item , the dedication process, and clarification of responsibility for natisfying reporting requirements.

Consolidated Edison agrees with the petitioner's justification for the proposed changes, and with the intent of the changes. We offer the attached coments on each proposed chango. Some of our coments suggest amended wording in order to achieve better clarification.

Should you have any questions regarding this matter, please contact Mr. Charles W. Jackson, Manager, Nuclear Safety and hiconsing.

Very truly youre.

9401050089 931228 PDR PRM 21-2 eor g5 ,

bEC-28'04TL;bi5:17iD:bst>L N d TEL N0iS14 737-8364 *3307 P03'  !

cc: Document Control Desk US Nuclear Regulatory Commission Mail Station Pl-137 Washington, DC 20555 Mr. Thomas T. Martin Regional Administrator - Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 -

Mr. Francis J. Williams, Jr., Project Manager Project Directorate I-l 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 Duchanan,2E 10511 I

l l

l I

I I

J l

1

. DEC-23 '04 TUE 15:16 1D:NS&L FAX TEL NO:914 737-8364 ~ #301 P02 -

9 DOCKET No. PRM-21-2 Consolidated Edison Comments on Petition for Changes to Part.21 PROPo m CHANCE TO 21.3 fa-1)

This proposed change is an important and appropriate change to the existing wording. It is consistent with the recognition that licensees have two possible types of sources for goods and services--the supplier who offers goods and/or services under a licensee-approved 10 CFR 50 Appendix B quality assurance program, and the supplier who does not. The distinction in practice is that goods and/or services from the latter type must undergo dedication prior to use as a basic component. The existing definition of

" commercial grade item' is flawed because it does not recognize the role of quality assurance, or the way in which goods or services become basic cornponent s . Therefore, the proposed change is a welcome clarification.

FAOPOSED CHANGE TO 21.3 fc-1)

This proposed change is also appropriate because it accurately recognizes

' dedication

• as a process. The existing definition identifies ' dedication

• as a point in time and as the act of designation *for use as a basic corrponent ,

• providing no indication of method or justification for bestowing this designation.

Iloweve r, we suggest, for the purpose of further clarification, addition of a second sentence to the new definition. 'Ihe complete paragraph would thus reads (c-1) Dedication is the evaluation process undertaken to provide reasonable assurance that a commercial grade item to be used as a basic component will perform its intended function. When dedication of a commercial grade item has been completed, that item may be used as a basic component.

The addition of this second sentence would serve to clarity that the identification, evaluation and reporting requirements apply to dedicated items, not to items undergoing the dedication process.

PROPOSED CHA90r TO 21.21 (b)

Consolidated Edison is concerned that the proposed 21.21 (b)(2) could be misconstrued. While it is true that entities performing dedications have to limit identification, evaluation and reporting responsibility for items which they have dedicated. licensees also have part 21 responsibility for items they use as basic components. We therefore suggest re-wording the new 21.21(b)(2) to say:

• The entity that performs the dedication performs activities as delineated in 21.3(a)(3), and is thus subject to the requirements for identifying, evaluating, and reporting...'

Page 1 of 2

- DEC-28 '04 TUE 15:16 ID:NS&L' FM TEL" NO:914 737-93$4 ' #307 P01 9

I l

We also ouggest that the following wording be added to the end of the proposed text:

...after it has been dedicated for uno as a basic component.* i This added wording will clarify that the identification, evaluation and reporting responsibilities apply to dedicated items, and not to commercial {

grade.itema prior to the successful completion of the dedication process.

This distinction is important because an item does not become a basic cozeponent, and thus important to safety, until after dodication. This added wording would be consistent with the petitioner's proposed change to 21.3 >

(c-1). ,

t I

f l

Page 2 of 2