ML19309F699
| ML19309F699 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/25/1980 |
| From: | Broehl D PORTLAND GENERAL ELECTRIC CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8004300387 | |
| Download: ML19309F699 (3) | |
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80043003 E L
Pbrtland General ElectricConpay 1
Donald J. Broed Assistant Vce Prescent April 25, 1980 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. R. H. Engelken, Director U. S. Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut Creek, CA 94596
Dear Sir:
On February 27, 1980, the Nuclear Regulatory Commission (NRC) issued IE Information Notice 80-06 announcing immediately effective require-ments for reporting of significant events to the NRC in accordance with newly created 10 CFR 50.72, " Notification of Significant Events".
Although the Notice of rulemaking had been published in effective form without prior public comments, a submittal of public views and comments was suggested in IE Information Notice 80-06. We have reviewed the subject IE Notice and provide the following comments:
As a general comment to the rule, we recognize the need for the NRC to quickly collect accurate information of significant events which could cause inc.ediate threats to public health and safety so that timely decisions and appropriate public notifications can be made. However, it should be emphasized that the effective implementation of such reporting requirements can be accomplished only when the definitions of the events to be reported are unambiguously and accurately specified, and they do not contradict or duplicate any existing requirements and rules in order to avoid unnecessary confusion.
In this regard, it is our strong belief that the subject rule-making of 10 CFR 50.72 can neither be an effective vehicle for notifications nor does it improve existing reporting
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mechanisms due to ambiguities in statements. The report-l ing guidance for significant events is already defined in Regulatory Guide 1.16 and specified in Technical Specifi-g cations which have been proven to be effective mechanisms s
of notifications.
It is, therefore, strongly urged r at l
'21 S W Saimen S:reet. Po and. Ore;;cn 97204
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W Gerier-d BectricCorquuiy D. J. Broehl Mr. R. H. Engelken April 25, 1980 Page two the necessity of the subject rulemaking be reconsidered and its intent be adequately justified. Specific comments to the rule are as follows (numbers in front of the com-ments correspond to the significant events identified in 10 CFR 50.72, Section (a)]:
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i 1.
This statement is too vague and broad to be implemented. Specific reporting requirements in the case of emergency plan activation are already provided in the emergency plan which is being reviewed by the NRC for approval in the near future and should not be duplicated here.
2.
No comments.
3.
The statement of " plant not being in a con-trolled or expected condition" should be clarified to be of a practical use by deter-mination of what constitues an uncontrolled or unexpected condition.
4.
Reporting guidance for plant security con-siderations will be covered in the proposed revision to 10 CFR 73 and should not be duplicated here.
5.
The requirement for reporting the initiation of plant shutdown is already covered in detail in Technical Specifications, Section 6.9.1 9.
6.
In Item (iii), the " acceptable levels" to which the release of radioactive material is limited should be defined or, at least, refer-i enced to the existing applicable Federal Regulations.
7.
Any event resulting in actuation of Engi-neered Safety Features is impractical and should exclude insignificant causes such as
" spurious actuations".
8.
"Any accidental, unplanned or uncontrolled radioactive release" should be defined in terms of a specific quantitative limit of
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PortlanciGeneral sectricConixuly D. J. Broehl Mr. R. H. Engelken April 25, 1980 Page three releases.
10 CFR 20.403 already specifies i
the limits of personnel exposure and release j
for the immediate and 24-hr. notifications including accidental, unplanned or uncon-trolled releases. The necessity to provide separate requirements needs to be justified.
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9.
".... serious injury occurring cn the site and requiring transport to an offsite medical facility for treatment" should be specifically j
defined since most injuries, even minor ones, are usually transported to an offsite facility as a general practice.
10.
" Serious" personnel radioactive contamination needs to be defined in terms of quantitative limits. The reporting requirement for over-exposure is already covered in 10 CFR 20.403.
11.
This statement is a redundant requirement to Items 8 and 10 above and to 10 CFR 20.403 and should be deleted; it is totally unnecessary.
j Sincerely,
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DJB/10!/4jed8A22 c:
Mr. Lynn Frank State of Oregon Department of Energy Mr. A. Schwencer Operating Reactors Branch #1 Division of Operating Reactors Mr. Dudley Thompson Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission 1
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