ML021370104

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Comment (2) Submitted by Southern Nuclear Operating Co., D. N. Morey, on Petition for Rulemaking PRM 50-75 Regarding Amendment of the Nrc'S Emergency Core Cooling System (ECCS) Regulations to Allow the Use of Anl Alternative Maximum Pipe Br
ML021370104
Person / Time
Site: Hatch, Vogtle, Farley  Southern Nuclear icon.png
Issue date: 05/16/2002
From: Dennis Morey
Southern Nuclear Operating Co
To: Annette Vietti-Cook
NRC/SECY/RAS
Ngbea E
References
+adjud/ruledam200505, 67FR16654 00002, PRM-50-75
Download: ML021370104 (2)


Text

MAY. 16.2002 8:46RM SOUTHERN NUCLEAR (205)992 6108 NO. 691 P. 1 DOCKETED Dave Morey Southern Nuclear. USNRC Vice President Operaling Company, Inc.

Farley Project Post Office Box 1295 May 16, 2002 (1:25PM)

Birmingham, Alabama 35201 Tei 25.9825131OFFICE OF SECRETARY Tel 205.992,5131 RULEMAKINGS AND ADJUDICATIONS STAFF ST SOUTHERNA SPP 50o.75 COMPANY a 1() Energy to Serve Yovr World' Annette L. Vietti-Cook, Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Comments on NEI Petition for Large Break LOCA Redefinition Proposed Rulemaking (PRM-50-75 dated April 8, 2002)

Dear Ms. Vietti-Cook:

Southern Nuclear Operating Company (SNC), the licensed operator for the Joseph M, Farley Nuclear Plant, the Edwin I. Hatch Nuclear Plant and the Vogtle Electric Generating Plant, has reviewed the NEI Petition for Large Break LOCA Redefinition Proposed Rulemaking. SNC suppoi zs the proposal in the petition as an important element in creating a regulatory structure that reflects today's state of knowledge and operating experience.

The double-ended design basis large break required by the current regulations has far-reaching effects on plant design and operation; however, over 30 years of operating experience and improvements in engineering knowledge and methods have shown that a double-ended break of the largest reactor coolant system piping should no longer be a dominant LWR safety criterion.

Adoption by the NRC of the proposed petition would enable more regulatory and industry energy to be focused on areas that are of more benefit to the safe and reliable operation of the nation's nuclear power plants.

Also, as described in the petition, the existing regulations are inconsistent in their treatment of the dynamic effects and other design effects of a postulated design basis pipe break. Adoption of the proposed petition would allow the NRC to make the regulations more consistent, which would be expected to increase confidence in the regulatory process.

The industry and its various owners groups have collectively worked together to develop this NEI petition. This change to risk-inform Part 50 has been identified by industry as the single broadest improvement that can be made to Part 50. To date, this effort has had significant technical and financial support from the industry. However, we believe that we must achieve success with LBLOCA redefinition; otherwise, other important risk informed changes may not generate such active support or participation. The NRC's response to this petition Will provide a clear indication to industry of your interest in real risk informed changes.

"e n phor5S 0o6 SECY-062t

MAY. 16.2002 8:47AM SOUTHERN NUCLEAR (205)992 6108 NO.691 P.2 U.S. Nuclear Regulatory Commission Page 2 It is recognized that there are technical issues to be resolved related to the implementation of the revised rule. We believe that the resolution of these implementation issues should occur in parallel with rulemaking, and that rulemaking should not hinge on the prior resolution of all implementation issues.

SNC views the regulatory change proposed in the NEI petition as a cornerstone in the NRC's process to improve the regulatory structure. From the senior management level down, the industry has actively supported redefinition of the maximum break size and frequently encouraged the NRC to move forward with it as the highest priority for risk-informing the technical requirements in the regulations. In addition, SNC has provided leadership within the industry to develop program consensus for the proposed approach and associated rulemaking.

We recognize that there are challenges associated with changing a requirement that has existed for so long and which has such far-reaching effects, but it is clear the time has come. We do not want to see this opportunity for improvement pass unanswered.

We concur with recent statements of one Commissioner that "...the Large Break LOCA is obsolete now, a true anachronism in today's safety envelope. It needs to be abandoned in favor of what really affects safety and is risk significant." We believe that the NEI proposed rule will enable us to move toward this objective.

If you have any questions, please contact Lewis Ward at 205-992-7105.

Respectfully submitted,/

D. N. Morey Southern Nuclear Operating Company DNM/LAW/JMG cc: Southern Nuclear Operating Company Mr. J. B. Beasley, Vice President - Vogtle Mr, H. L. Sumner, Jr., Vice President - Hatch