LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991

Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991

ML20249A955
Person / Time
Site:	Salem, Hope Creek
Issue date:	06/12/1998
From:	Dawn Powell Public Service Enterprise Group
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR20136, RULE-PR-50 63FR20136, LR-N980284, NUDOCS 9806190186
Download: ML20249A955 (3)

Text

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) ' O PSEG DOCKETED Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 080NNb Nuclear Business Unit g

LR-N980284 'h, ~ 7 .

ADJUQ -

i'F U.S. Nuclear Regulatory Commission <

Secretary l Washington, DC 20555  !

Attn: Rulemakings and Adjudications Staff .D M gN g go

Dear Sir:

bNOI l COMMENTS ON NRC PROPOSED RULE ON lEEE STANDARD 603-1991 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272,50-311 AND 50-354 l

Enclosed are the Public Service Electric & Gas (PSE&G) comments on the proposed rule revising 10CFR50.55a(h) as published in the Federal Register on April 23,1998, 63FR20136 submitting a direct rule to amend the Commissions rules in 10 CFR Part 50.55a(h). The enclosed comments were provided to Mr. S. Aggarwal of the NRC via E-Mail on May 27,1998.

If you have any questions or require additional information, please contact Mr. Vic Fregonese at (609) 339-1607.

Sincerely, h.$,leedf l D. R. Powell l Director -

Licensing / Regulation and Fuels Attachment

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9806190186 980612 PDR PR I 50 63FR20136 PDR l

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Document Control Desk 2 LR-N980284 l

1C Mr. H. J. Miller, Administrator - Region l l l

U. S. Nuclear Regulatory Commission 475'Allendale Road '

King of Prussia, PA 19406

! L Mr. P. Milano, Licensing Project Manager - Salem ,

U. S. Nuclear Regulatory Commission 1 One White Flint North Mail Stop 14E21 11555 Rockville Pike

. Rockville, MD ' 20852 '

l Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission  ;

- One White Flint North

- Mail Stop 14E21' 11555 Rockville Pike ~

Rockville, MD 20852 '

Mr. S. Morris .(X24)

USNRC Senior Resident inspector - Salem Mr. S. Pindale ~ (X24) -

USNRC Senior Resident inspector - Hope Creek Mr. K. Tosch, Manager IV, Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625

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- LR-N980284 ATTACHMENT 1 i a

PSE&G COMMENTS ON PROPOSED RULE ON IEEE STANDARD 603-1991

1. Endorsement of other referenced IEEE standards Within the proposed rules published in the Federal Register as noted above, the NRC in its response to significant comment #1, PSE&G does not believe the NRC has fully addressed the outright endorsement of other IEEE standards. The statement that IEEE 603 - 1991 does not imply endorsement of later versions of IEEE Standards is not technically substantiated within the proposed rule by the NRC if IEEE 603 - 1991 is to be endorsed by rule and not regulatory guidance. The NRC states that it did not seek for any other standards referenced in IEEE 603 - 1991 to be approved for incorporation by reference, even going so for as to state the referenced standards in IEEE 603 - 1991 are not mandatory requirements, although IEEE 603 - 1991 invokes the referenced standards by the 3 use of "shall". PSE&G believes the NRC position has not been clarified due to "shall"in the  !

IEEE 603 -1991 standard; once IEEE 603 -1991 becomes part of 10 CFR 50.55a , then l IEEE 603 -1991 becomes part of the license commitment. I

2. Definition of System Level Replacement The term " system level" replacement is not clearly defined and likely cannot specifically be established regarding what constitutes a system-level replacement versus an upgrade or modification to components and subsystems. The proposed NRC interpretation would require compliance with IEEE-603 -1991 for system level replacement / upgrades of protection systems / subsystems that require replacement due to age or obsolescence. Currently, this can be performed under 10CFR50.59 guidance, using design criteria (IEEE standards and

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Reg Guides) that are part of the plants design and licensing basis. Imposition of IEEE-603 -

1991 in this situation appears to be a backfit. The NRC's perceived impact of incorporating IEEE-603 in this manner is understated.

3. IEEE 603 - 1991 Industry Acceptance PSE&G disagrees that IEEE-603 and RG 1.153 represent a general public concensus position. The NRC's statement that they believe the RG was appropriate due to lack of negative comment on the draft RG (proposing to endorse IEEE 603 -1991) should have considered that the majority of operating plants are not required to meet IEEE-603 -1991 or ,

RG 1.153. The lack of adverse comments (to the draft RG) should not have been construed as an endorsement of IEEE 603 -1991.

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