B17475, Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Agrees with Extending non-emergency Prompt Notifications to Eight Hours, Which Would Help to Eliminate Unnecessary Repts

Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Agrees with Extending non-emergency Prompt Notifications to Eight Hours, Which Would Help to Eliminate Unnecessary Repts

ML20154A625
Person / Time
Site:	Millstone
Issue date:	09/29/1998
From:	Bowling M NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR39522, RULE-PR-50 63FR39522-00018, 63FR39522-18, B17475, NUDOCS 9810020364
Download: ML20154A625 (2)

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' D Re: 10CFR50.72 10CFR50.73 U.S. Nuclear Regulatory Commission Attention: Rulemaking and Adjudication Staff Washington, DC 20555-0001 Millstone Nuclear Power Station 1 Comments on the Proposed Rule for Reportina Reauirements for Nuclear Power Reactors These comments are submitted on behalf of Northeast Nuclear Energy Company's Millstone' Station in response to the Federal Register notice concerning proposed rulemaking on Reporting Requirements for Nuclear Power Reactors (63 Federal

, Register 39522 of July 23,1998). Northeast Nuclear Energy Company endorses the f comments provided by the Nuclear Energy Institute (NEI) on behalf of the nuclear industry. Northeast Nuclear Energy Company also supports the efforts made by the NRC Staff with this proposed rulemaking in reducing the reporting burden on licensees ,

and the NRC with regard to reports that have little or no safety significance. ./ i a o Northeast Nuclear Energy Company is in a unique position to provide comments on the proposed rulemaking in that almost 200 Licensee Event Reports (LER's) and over 36 supplemental LER's were issued since January 1997 to date. This volume of reporting activity afforded the station many opportunities to encounter some of the challenges of reporting and LER preparation particularly with respect to those events or conditions in the area of "outside .the design basis". Many reports that had little or no safety significance were made in literal compliance with the current rule. The preparation of the non-safety significant LER's involved significant expenditure of resources both at Northeast Nuclear Energy ' Company and at the NRC. Northeast Nuclear Energy Company, therefore, heartily agrees that this and other aspects of the rule need to be changed. "

9810020364 990929 PDR PR SO 63FR39522 PDR ~

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l l 5 l . U.S. Nuclear Regulatory Commission l B17475\Page 2 l

Additionally, the 30-day reporting requirement has and does continue to place a constraint with respect to the ability to coordinate comprehensive root cause l l evaluations and the corresponding corrective actions. Developing a complete and I accurate LER is labor intensive and involves resources across several departments. l Northeast Nuclear Energy Company recommends extending the reporting time for LER's to 60 days. This would allow for a more efficient use of resources and for a more complete and accurate LER without necessitating the submittal of a supplemental LER.

Northeast Nuclear Energy Company agrees with extending the non-emergency prompt notifications to eight hours. This would help to eliminate unnecessary reports and retractions. However, it is necessary to have the individual states closely involved with l

the rule change since they may have requirements that are more restrictive or conflict with the proposed rulemaking. For example, in Connecticut all 10CFR50.72 reports require notification of the state within one hour.

Finally, Northeast Nuclear Energy Company agrees with eliminating reports of historical issues, i.e., those events or conditions which occurred in the past and have since been corrected. For example, in the past month two such issues have been discovered at Millstone for which LER's are being prepared. These issues have no current safety significance.

If you have any questions regarding these cornments, please contact Ms. Mari Jaworsky at (860) 447-1791. 9ension 5379.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Martin L. Bowling, Jr. U i Recovery Officer - Technical Services I

cc: H. J. Miller, Region i Administratcr S. Dembek, NRC Project Manager, Millstone Unit No.1 D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit No. 2 J. W. Andersen, NRC Project Manager, MilIstone Unit No. 3 W. M. Dean, Director, Millstone Project Directorate D. P. Allison, Office for Analysis and Evaluation of Operational Data