DCL-90-200, Comment on Proposed Rules 10CFR20,30,40 & 70, Notifications of Incidents. Util Supports & Endorses Comments on Proposed Rulemaking Submitted to NRC on 900730 by NUMARC

Comment on Proposed Rules 10CFR20,30,40 & 70, Notifications of Incidents. Util Supports & Endorses Comments on Proposed Rulemaking Submitted to NRC on 900730 by NUMARC

ML20058P412
Person / Time
Site:	Diablo Canyon
Issue date:	07/31/1990
From:	Shiffer J PACIFIC GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-55FR19890, RULE-PR-20, RULE-PR-30, RULE-PR-40, RULE-PR-70 55FR19890-00039, 55FR19890-39, AC91-1-106, AC91-1-40, DCL-90-200, NUDOCS 9008170028
Download: ML20058P412 (2)

Text

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July 31, 1990 Y

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PGt.E Letter No. DCL-90-200 rner af :lW 3' Twtht W 6' N ]

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk. '

Washington, D.C. 20555 t Re: Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 ,

Diablo Canyon Units 1 and 2 Proposed Rule Notifications of Incidents for 10 CFR 20, 30, 40, and 70 (55 FR 1989) Requests for Comments l

Gentlemen:

In response to the U.S. Nuclear Regulatory Commission's (NRC) request for comments on the proposed rule " Notifications of Incidents" affecting 10 CFR 20, 30, 40 and 70 as published in the Federal Register on May 14,1990 (55 FR 19890), Pacific Gas and Electric Company (PG&E), submits the following comments. ,

l.- PG&E supports and endorses comir:nts on this proposed ,ruleciaking i submitted to the NRC on July 30, 1990, by the Nuclear ,.

Management and Resources Council.

l!

2. Although the proposed rule states that it does not apply to ,

activities reportable under 10 CFR 50, many commercial nuclear >

power plants, including PG&E's Diablo Canyon Power Plant, also hold licenses issued under.10 CFR 30, 40, and 70.

3. The proposed requirement in Paragraph (b)(1) specifying that 24-hour notification must be provided for any contamination i event that restricts access to the contaminated area by workers or the public for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> _is~ excessive and not. .

necessarily related to a potential hazard to the pubiic or the environment. As draf ted, without specific criteria specifying  :

levels of contamination and/or levels of exposure >to the worker l or the public, this requirement could generate numerous reports  ;

of insignificant events to the NRC. This requirement should be deleted or guidance written that-includes specific criteria for 4

contamination events requiring prompt acticn by the NRC to [

ensure adequate protection of public health and safety.

• Guidance is also necessary to ensure consistent enforcement of i this part of the regulation.

4. The proposed requirement in paragraph (b)(2) specifies a l 24-hour notification of any ever.1 in which equipment necessary to prevent uncontrolled releases of radioactive material, or to ,

prevent overexposures to radiation, or to mitigate the i consequences of an accident, is disabled or fails to function e 90081700128 900731 l N55N19890 PDR .

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3 . . : i.

Documeitt Control Desk l

- July 31, 1990 ,

PG&E Letter No. DCL-90-200 unless redundant equipment is operable and available to automatically pei orm f

the required function. In this proposed paragraph, the NRC again does not specify the nature and severity of the event. As a result, this requiremtnt could also result in numerous reports of insignificant events to the NRC.

This requirement 'should be deleted or specific criteria established for equipment failurs that would require prompt action by the NRC to ensure adequate protection of worker and public health and safety. Guidance would a;so be necessary to ensure consistent enforcement of this part of the rsgulation.  !

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely, i

).C Skh J. D. Shiffer

q cc: A. P. Hodgdon J. B. Martin P. J. Morrill P. P. Narbut '

H. Rood T. E. Tipton (NUMARC)

CPUC Diablo Distribution i 3287S/0084K/EMG/1216 Q .A