HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions

Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions

ML20141H056
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	07/07/1997
From:	Mccoy C SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-62FR24997, RTR-NUREG-1606 62FR24997-00025, 62FR24997-25, HL-5424, LCV-1065, NUDOCS 9707140434
Download: ML20141H056 (2)

Text

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C.K. McCoy Southern Nuclear I Vice President Operati;g Compa:y,Inc. i Vogtle Project 40 nyerness Center Parkway g

(([ Birmingham, Alabama 35201 g g ff Tel 205 992.7122 "

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fM$ly N7 SOUTHERNMa COMPANY Energy toServe hur World*

Docket Nos. 50-348 50-321 50-424 HL-5424 ^

50-364 50-366 50-425 LCV-1065 C $ y.)

bW c-- FG Chief, Rules and Directives Branch pi g Division of Administrative Services T* -

O OGce ofAdminisaation zh U. S. Nuclear Regulatory Commission h 2]E .

Washington, D. C. 20555-0001 g9 g a to '

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Comments on NUREG-1606 Proposed Regulatory Guidance Related to implementation of 10 CFR 50.59 (Changes, Tests or Experiments) 4 (62 Federal Register 24997 dated May 7.1997)

Dear Sir:

Southern Nuclear Operating Company (Southem Nuclear) has reviewtxt the Nuclear Regulatory Commission's (NRC's) proposed regulatory guidance related to implementation of 10 CFR 50.59 contained in NUREG-1606 which was published in the Federal Register on May 7,1997. In mordance i with request for wuuuents, Southem Nuclear endorses wnunents of the Nuclear Energy Institute (NEI).

NEl's comments accurately convey Southem Nuclear's position on the refen:nced NRC proposal Southern Nuclear would like to emphasize that the proposed guidance contained in NUREG-1606 will ' f) create a resource burden for both industry and the NRC. The proposed guidance will lower the [/  !

screening threshold and require industry to perform additional 10 CFR 50.59 safety evaluations in order to make unreviewed safety question determinations on matters ofliille or no safety significance. Also, by using the interpretations contained in the proposed guidance, a significant increase in the number of i determinations of unreviewed safety questions (and potential plant downtime) will result, which wil! j require NRC review and approval. Unfortunately, industry and NRC focus will be on operational j compliance with an increase in cost without a discernible improvement in plant safety.

The NRC has already gone on record recognizing the improvement in quality of 10 CFR 50.59 cvaluations since the adoption of NSAC-125 by the industry, and that changes of significance are highly i likely to be identified by licensees through implementation of the guidance contained in NSAC-125.

! The industry is currently in the process of updating the guidelines contained in NSAC-125 sia NEI 96-

07. With the changes that will be incorporated into NEI 96-07, Southem Nuclear believes that NRC concerns with 10 CFR 50.59 will be adequately addressed and should be given serious consideration as  ;

an alternative to NUREG-1606.

9707140434 970707 NO PDR NUREG '

1606 C PDR l l l lllfll l ll I

l I-Chief, Rules and Directives Branch Page Two Comments on NUREG-1606 In conclusion, Southern Nuclear acknowledges NRC's concerns with the implementation of 10 CFR 50.59 at selected plants. However, those concerns should not be siewed as indicative of the industry as a whole. In the past, most plants have implemented 10 CFR 50.59 in a comprehensive and

conscientious manner. Therefore, the NRC is encouraged not to abandon some thirty years of effective implementation of 10 CFR 50.59 for new positions that will contribute little if any to plant safety. l Should you have any questions, please adsise.

l. Respectfully submitted, C. K. McCoy l' CKM/FMM cc: Southem Nuclear Ooeratina Comoany ,

R. D. Hill, General Manager - Plant Farley P. H. Wells, General Manager - Plant Hatch l L B. Beasley, General Manager - Vogtle Electric Generating Plant  !

D. N. Morey, Vice President - Plant Farley l H. L. Sumner, Vice President - Plant Hatch U. S. Nuclear Renulatorv Commission. Washington. DC l

B. L. Siegel, Licensing Project Manager - Farley

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N. B. Le, Licensing Project Manager - Hatch L. L. Wheeler, Senior Project Manager - Vogtle

! U. S. Nuclear Renulatory Commission. Reaion II l- L. A. Reyes, Regional Administrator l

' T. M. Ross, Senior Resident Inspector - Farley B. L. Holbrook, Senior Resident Inspector - Hatch C. R. Ogle, Senior Resident Inspector - Vogtle i

l HL-5407 LCV-1046