ELV-03708, Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us. Informs That Licensee Believes BWROG Comments to Be Appropriate & Beneficial

Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us. Informs That Licensee Believes BWROG Comments to Be Appropriate & Beneficial

ML20096A307
Person / Time
Site:	Hatch, Vogtle
Issue date:	04/30/1992
From:	Mccoy C GEORGIA POWER CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-57FR6748, RTR-NUREG-0654, RTR-NUREG-1449, RTR-NUREG-654 57FR6748, ELV-03708, ELV-3708, HL-2201, NUDOCS 9205110024
Download: ML20096A307 (3)

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April 30,1992 Dockets Nos. 50-321 50-424 11L-2201 50-366 50-425 ELV-03708 Mr. David L. Meyer Chief, Regulatory Publications Branch d> ,51j p. a U. S. Nuclear Regulatory Commission ge4[jiHP E.4S f 7, 3

Washington, DC 20555 d

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@c Comments on Draft Report, NUREG-1449 "i d.5E

" Shutdown and Low-Power Operation at 5" Commercial Nuclear Power Plants in the ' United States" E 3 (57 Federal Register 6748 of Februarv 27.1992) g 3 m 3

Dear Mr. Meyer:

Georgia Power Company has reviewed the draft report, NUREG-1449, " Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States," published in the Federal Register on February 27,1992. In accordance with the request for comments, Georgia Power Company provides the following:

Section 6.3 introduces a concern on the part of the NRC with the working hours of plant personnel during outages and implies that they expect implementation of the NUMARC

" Guidelines to Enhance Safety During Shutdown" to result in programs " reducing time that people perform higher risk activities." It is our expectation that the NUMARC guidelines will reduce the time spent performing high risk activities by rescheduling activities for times of reduced risk, not by reducing working hours. If the NRC is expecting working hours to be reduced as the result of the draft NUREG, addhional justification is needed, especially in light of the results from the interviews with plant operators conducted by the NRC documented in Section 3.2.2 of the draft.

9205110024 920400 PDR. NUREG 1449 C PDH

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Mr. David LiMeyer -

- U. S/ Nuclear Regulatory Commission Page 2 Section 6.12.2 states, "In meeting this requirement as stated in Criterion J of -

NUREG-0654, the NRC expects each licensee to evacuate nonessential personnel and to account for onsite personnel within 30 minutes of the declaration of an emergency." This statement, left ior the readers' interpretation, may not be consistent with the application of

. Criterion J of NUREG-0654 in an individual site's Emergency ' lan. In order to -

accurately reflect the requirements of Criterion J and preclude misinterpretation of the regulations, the statement should be revised to read as follows:

"In meeting this requirement as stated in Criterion J of NUREG-0654, the NRC expects each licensee to (1) evacuate onsite non essential personnel in the event of a Site or General Emergency and (2) account for all individuals onsite at the time of

the emergency in accordance with their approved Eme gency Plan,"

Section 7.2.(1) provided a list ofitems that the NRC felt necessary for achieving effective outage planning and control. Included in the list was a " controlled information system to provide critical safety parameters and equipment status on a real-time basis during the

- outage " This item is not funher defined. It is our concern that the NRC plans to require

' installation of a system similar to SPDS to provide real-time monitoring of" shutdown critical safety function status trees." The implementation of such a requirement would be costly and offer little safety advantage over current manual methods of safety review -

utilized to determine if equipment should be removed from service during an outage.

Additionally, the SWR Owners' Group (BWROG) is providing comments on this document which we believe to be appropriate and beneficial.

.Should_ you have any questions, please advise.

- Respectfully submitted, lhf C. R. McCoy -

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l Mr. David L. Meyer U. S. Nuclear Regulatory Commission Page 3 cc: Georgia Power Company Mr. J. T. Beckham, Jr., Vice President, Plant Hatch Mr. W. B. Shipman, General Manager - Plant Vogtle Mr. H. L. Sumner, Jr., General Manager - Plant Hatch NORMS-I U. S. Nuclear Regulatory Commission. Washington. DC Mr. K. N. Jabbour, Licensing Project Manager - Hatch Mr. D. S. Hood, Licensing Project Manager - Vogtle U. S. Nuclear Regulator Commission. Region 11

~ Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector _- Hatch Mr. B. R. Bonser, Senior Resident Inspector - Vogtle i.-

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