LR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr

Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr

ML20198J276
Person / Time
Site:	Salem, Hope Creek
Issue date:	12/21/1998
From:	Dawn Powell Public Service Enterprise Group
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR56098, RULE-PR-50, RULE-PR-52, RULE-PR-72 63FR56098-00031, 63FR56098-31, FACA, LR-N980595, NUDOCS 9812300129
Download: ML20198J276 (2)

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(&3PN5609g) D%e* W December 21,1998 LR-N980595 96 DE^ 23 P 3 C6 Mr. John C. Hoyle . . .

Secretary U.S. Nuclear Regulatory Commission A[i Washington, D.C. 20555-0001 Attn: Rulemakings and Adjudication Staff COMMENTS ON PROPOSED RULEMAKING TG 10CFR50.59, CHANGES, TESTS, AND EXPERIMENTS,63 FED. REG. 56098 (OCTOBER 21,1998)

SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272,50-311 AND 50-354

Dear Mr. Hoyle:

On October 21,1998, the Nuclear Regulatory Commission (NRC) issued a proposed Rulemaking to 10CFR50.59, Changes, Tests, and Experiments for public comment. This letter submits PSE&G's comments regarding the proposed rulemaking. In addition to these specific comments, PSE&G supports the comments submitted by the Nuclear Energy Institute (NEI) in their letter dated December 21,1998.

PSE&G's specific comments are as follows:

The proposed rulemaking adds several definitions. The definition of " Facility" in the Notice of Public Register (NOPR) includes those systems, structures, and components that are described in the FSAR. Many plants have systems, structures, and components descnbed in the FSAR that are not related to nuclear safety. The definition in the NOPR notes that the systems, structures, and components in question are those required to be included or described in the FSAR. The use of " required to be included or described" is not sufficiently defined. PSE&G recommends the phrase " required to be included or described" be replaced with reference to the definition of Safety-Related Structures, Systems and Components contained in 10CFR 50.2.

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PSE&G concurs that the phrase " margin of safety" should be eliminated. The NEl recommendation to address design basis limits associated with the integrity of the fuel cladding, RCS pressure, or containment boundary is more appropriate. However, this change needs careful consideration to ensure proper understanding and implementation of new terminology.

The discussion in the Probability of Occurrence of an Accident contained within the NOPR provides guidance on what constitutes a small change. The NOPR states that this determination should be made at the component level or consistent with the failure modes and effects analyses, taking into account single failure assumptions, and the level of the change being made. PSE&G believes the determinations for the probability should be commensurate with the existing analyses without reference to the component level. PSE&G supports the NEl proposed description of a minimal increase in :ne Probability of Occurrence of an Accident which provides a better approach to this issue.

We appreciate the opportunity to comment on the proposed revision and request your careful consideration of the issues.

Sincerely, original signed by David R. Powell Director -

Licensing / Regulation & Fuels PSE&G P.O. Box 236 l Hancocks Bridge, NJ 08038 l

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