B17889, Comment on Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Util Supports NEI Comments on Subj Rules

Comment on Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Util Supports NEI Comments on Subj Rules

ML20212F709
Person / Time
Site:	Millstone
Issue date:	09/23/1999
From:	Necci R NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR36291, RULE-PR-50, RULE-PR-72 64FR36291-00020, B17889, NUDOCS 9909280332
Download: ML20212F709 (2)

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Nordicast h Fem M @ouw %, %W, mm Nuclear Energy ' - niii.ione Nocicar ro e, statiou Northeast Nuclear Energy Compan3 P.O. Box 128 Waterferd, CT 06385-0128 (800) 447-1791

• 00 T 2d C[ ]3 Fax (860) 444-4277 The Northeast Utditica System

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SEP 2 31999

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817889 D X C NuMBEH Re: 10CFR50.72 F?OPOSED RULE O 60/7A 10CFR50.73 hfNBb$91)

Secretary, U.S. Nuclear Regulatory Commission Attention: Rulemaking and Adjudications Staff Washington, DC 20555-0001 Millstone Nuclear Power Station 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 prcposed rulemaking on Reporting Requirements for Nuclear Power Reactors (64 Federal Register 36291 of July 6,1999). Northeast Nuclear Energy Company (NNECO) endorses the comments provided by the Nuclear Energy Institute (NEI) on behalf of the nuclear industry. NNECO 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.

NNECO wants to emphasize the concern raised by NEl regarding the last minute addition of the requirement to report significantly degraded components in Section 50.73(a)(2)(ii)(C). This reporting criterion does not meet the stated objectives of tne rule change and should be deleted. The lack of specificity in the reporting threshold associated with this aspect of the rule change renders this criterion ambiguous 'd thus, subject to widely varying interpretations. As a result, the reporting burden o i-safety-significant events or conditions will very likely increase. Further, based on ie discussions surrounding this criterion at the workshop of August 3,1999, it is NNECO's opinion that the information sought by the staff can be obtained through other reporting criteria and may be available currently through other measures such as the Equipment Performance information Exchange or the NRC Inspection Program.

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.. i U.S. Nucirr R:gulatory Commission l B17889\Pcg3 2 1 NNECO is also commenting on the change from the current requirement to report a plant being in an "unanalyzed condition that significantly compromises plant safety" to the proposed wording in Section 50.72(b)(2)(ii)(B) to report being in an "unanalyzed  !

condition that significantly affects plant safety" If implemented this change could  !

broaden the scope of scenarios subject to reporting. Although this change is being j characterized as editorial, the wording of the proposed revision invites a broader I application of what could be considered reportable, and thus, has the potential of not l meeting the stated objectives.

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NNECO agrees with extending the non-emergency prompt notifications to eight hours l and the LER reporting to 60 days. This will help to eliminate unnecessary reports and  !

retractions as well as unnecessary LER supplements. NNECO also agrees with l eliminating the "outside design basis" reports. This will result in a significant burden j reduction to both the NRC and Licensees.

l' If you have any questions regarding these comments, please contact Ms. Mari Jaworsky at (860) 447-1791, extension 5379. ,

I Very truly yours, j

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NORTHEAST NUCLEAR ENERGY COMPANY l Cth R. P. Necci Vice President - Nuclear Oversight and ,

Regulatory Affairs  !

cc: H. J. Miller, Region i Administrator L. L. Wheeler, NRC Project Manager, Millstone Unit No.1 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 R. B. Eaton, NRC Senior Project Manager, Millstone Unit No. 2 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3 J. A. Nakoski, NRC Project Manager, Millstone Unit No. 3 j P. C. Cataldo, NRC Resident inspector  !

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