LR-N11-0371, Comment (3) of Paul R. Duke on Behalf of PSEG Nuclear LLC on Draft NUREG-1022, Revision 3, Event Reporting Guidelines: 10 CFR 50.72 and 50.73.
| ML11347A428 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 12/12/2011 |
| From: | Duke P Public Service Enterprise Group |
| To: | Cindy Bladey Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR63565 00003, LR-N11-0371, NRC-2011-0237, NUREG-1022, Rev 3 | |
| Download: ML11347A428 (2) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 o PSEG Nuclear LLC DEC 1.2 2011 LR-N 11-0371 Ms. Cindy Bladey Chief, Rules, Announcements, and Directives Branch _ .3 Office of Administration, Mail Stop TWB-05-BOl M -I U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Salem Nuclear Generating Station, Units 1 and 2 U,
Renewed Facility Operating License Nos. DPR-70 and 75',.-
NRC Docket Nos. 50-272 and 50-311 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354
Subject:
Comments on Draft NUREG-1022, Revision 3, "Event Reporting Guidelines: 10 CFR 50.72 and 50.73." (Federal Register dated October 13, 2011, 76 FR 63565, Docket ID NRC-2011-0237).
Reference:
Letter from Chris Earls (NEI) to NRC: "NEI Comments on Draft NUREG-1022, Revision 3, "Event Reporting Guidelines: 10 CFR 50.72 and 50.73."
(Federal Register dated October 13, 2011, 76 FR 63565, Docket ID NRC-2011-0237), dated December 6, 2011.
PSEG Nuclear LLC (PSEG) appreciates the opportunity to submit comments on Draft NUREG-1022, Revision 3, "Event Reporting Guidelines: 10 CFR 50.72 and 50.73."
PSEG has reviewed and fully supports the comments made by the Nuclear Energy Institute (NEI) in the referenced letter above including all attachments.
PSEG would like to expand on NEI's comments on Section 3.2.7 of NUREG-1022.
Incorporating the term of operability when the reporting requirements of 10 CFR 50.72(b)(3)(v) and 50.73(a)(2)(v) are focused on the fulfillment of the safety function of the structures, systems or components would unnecessarily increase the event notifications and licensee event reports (LER). A component in a system may be declared inoperable due to failure to meet the surveillance requirement (SR) acceptance criteria; however, the SR acceptance criteria frequently has margin prior to
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Rulemaking and Directives Branch DEC i 2 201l LR-Nl1-0371 Page 2 the values credited in the plant's safety analysis. Ifthe component is still capable of providing the function relied upon in the plant's safety analysis, even though the component was declared inoperable for failing to meet the SR acceptance criteria, the component is still capable of fulfilling its safety function and would not be reportable under 10 CFR 50.72(b)(3)(v) and 50.73(a)(2)(v). The proposed changes in Draft NUREG-1 022 Revision 3 could result in an operator distraction for events that are not risk-significant. PSEG suggests that the NRC adopt the changes identified in of the NEI comments.
Although not specifically addressed in the NEI comment letter referenced above, the proposed changes to NUREG-1022 Section 2.8, Retraction or Cancellationof Event Reports, as described in the 'Discussion of Changes' document (Accession No. MLI1068A030) are based on the proposed changes to section 3.2.7. Any changes to section 2.8 should be consistent with this resolution of the comments to section 3.2.7.
There are no new regulatory commitments contained in this letter. Ifyou have any questions or require additional information, please contact Brian Thomas, Principal Licensing Engineer, at 856-339-2022.
Sincerely, Paul R. Duke, Jr.
Manager - Licensing C NRC Document Control Desk Corporate Commitment Tracking Coordinator