ML030020498
| ML030020498 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/23/2002 |
| From: | Cruse C Constellation Energy Group |
| To: | Lesar M NRC/ADM/DAS/RDB |
| References | |
| 67FR70468 00010 | |
| Download: ML030020498 (2) | |
Text
Charles H. Cruse 1997 Annapolis Exchange Parkway Senior Vice President Suite 500 Technical Services Annapolis, Maryland 21401 Constellation Generation Group, LLC 410 897-5087 charles.h.cruse@hdq.cn.com 0 Constellation -"fl Energy Group December 23, 2002 )
CU "-"0 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. Michael T. Lesar, Chief, Rules and Directives Branch
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Comments on the Third Year of Implementation of the Reactor Oversight Process
REFERENCES:
(a) Solicitation of Public Comments on the Third Year of Implementation of the Reactor Oversight Process (67FR70468 - November 22, 2002)
(b) Letter from Mr. S. D. Floyd (NET), to Mr. M. T. Lesar (NRC), dated December 20, 2002, Solicitation of Public Comments on the Third Year of Implementation of the Reactor Oversight Process Constellation Energy Group welcomes the opportunity to provide comments on the Third Year of Implementation of the Reactor Oversight Process solicited by Reference (a). Constellation Energy Group has reviewed the Nuclear Energy Institute's (NEI's) industry comment which has been submitted to the Nuclear Regulatory Commission (NRC) on December 20, 2002 (Reference b). Constellation Energy Group endorses the NEI comments and wishes to add the following observations which have been addressed by comments on Questions 6, 10, and 19 in Enclosure to Reference (b).
We are concerned about the subjective nature of the Significance Determination Processes (SDPs) for cornerstones that fall outside a plant's probabilistic risk analysis. For example, a significant percentage of findings in the industry have occurred under the Emergency Preparedness Cornerstone. Many of these findings were preliminarily classified as white or yellow, and subsequently downgraded by the NRC only after significant licensee resources were expended in appealing the proposed level of severity. As stated in the NEI comment to Question 19 of Reference (a), the practice of assigning a conservative preliminary finding and subsequently changing the color provides critics with an opportunity to challenge the integrity of the process and creates doubt in the public's mind. Another example is the SDP for Public Radiation Safety, which specifies findings based on radioactive waste shipment dose rates regardless of actual risk to the public (e.g., accessibility of high dose rate area, duration of accessibility by the public, etc.).
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Mr. Michael T. Lesar December 23, 2002 Page 2 We strongly recommend that SDPs in these areas should be revised to ensure findings appropriately reflect the risk of the event as well as programmatic failures instead of single occurrences. We believe utilizing a risk-informed method will better reflect licensee performance to ensure plant safety.
Should you have questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, CHC/GT/bjd cc: Document Control Desk, NRC J. Petro, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate 1-1, NRC R. I. McLean, DNR D. M. Skay, NRC S. D. Floyd, NEI