ML20046D513

Comments on Regulatory Review Group Rept to EDO Published in Fr on 930518.Agrees W/Comments Made by NUMARC

ML20046D513
Person / Time
Site:	Farley
Issue date:	07/30/1993
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 9308200321
Download: ML20046D513 (2)

Text

51L-30-1993 69:27 FRO!1 SOUTHEW.lUCLEAR.OPER.CO. TO 913015042259 P.01 s- - -,

Post Omco Box 9295

• Dernirgham. Alabama 3s201 129s Telephone 20s 868.s000 L

Southem Nudear Operating Company the Southem electrrc system July 30, 1993 Docket Nos.

50-348 50-364 i

Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission r

Washington, DC 20555 ATTENTION: Docketing and Service Branch Regulatory Review Group; Publication of Report to Executive Director (58 Federal Reaister 2901? on May 18. 19931

Dear Mr. Chilk:

Southern Nuclear Operating Company has reviewed the publicai. ion of the Regulatory Review Group's report to the Executive Director for Operations, which appeared in the Federal Register on May 18, 1993. Southern Nuclear Operating Company is in agreement with the NUMARC comments, which are to be provided to the NRC.

In reference to NUMARC's comments on Volume Four, we recognize it is not NUMARC's intent to provide detailed, critical comments on specific methodologies. However, this should not be taken to mean that the criteria is endorsed.

Southern Nuclear Operating Company feels that certain specific criteria will need to be addressed in more detail.

For example, there is a general concern over implementation of a screening value of 3E-2 for pre-initiator human events. There are an infinite number of conceivable pre-initiator human actions, and only a few are usually modeled.

Additionally, Southern Nuclear Operating Company believes that a successful conclusion of this effort is extremely important if there is to be a viable nuclear option in the coming years. Operations and Maintenance costs rose at alarming rates during the 1980s and early 1990s, primarily due to new regulations and licensee comitments. Many of these commitments resulted in significant cost increases to the nuclear industry but had little to no safety benefit. Both the NRC and the licensees must put into place a more disciplined process for evaluating the benefits of new regulations and commitments. Performance-based initiatives should be considered whenever

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JUL-30-1993 09:28 FROM SOU mEPM.NUCLU R.0FER.CO.

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possible, old regulations and commitments which have little to no overall benefit to public health and safety need to be eliminated. The Regulatory Review Group initiative provides an important framework for the initiation i

3 of such an effort.

i Should you have any questions, please advise.

i Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY WI NZyv Dave Morey i

Vice President Farley Project DNM/DSC i

cc: Southern Nucl_ ear Operatino Company R. D. Hill, Plant Manager l

U.S. Nuclear Re_qulatory Commi_ssion. Washington._DC i

t T. A. Reed, Licensing Project Manager, NRR U.S. Nuclear ReQulatory Commission. Recion__II S. D. Ebneter, Regional Administrator G. F. Maxwell, Senior Resident Inspector l

t i

d TOTAL P.02

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