ML20056G343

Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process

ML20056G343
Person / Time
Site:	Farley
Issue date:	08/27/1993
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR34726, RULE-PR-2 58FR34726-00005, 58FR34726-5, NUDOCS 9309030023
Download: ML20056G343 (2)

Text

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Docket Nos. 50-348 50-364 Mr. Samuel J. Chilk Secretary of the Cormaission U.S. Nuclear Regulatory Commission Washington, DC 20555 i

ATTENTION: Docketing and Service Branch Comments on "Section 2.206 Petitions Requesting Institution of a Proceeding to Modify, Suspend or Revoke a License, or for Such Other Action as May Be Proper" (58 Federal Reaister 34726 of June 29. 1993) l.

Dear Mr. Chilk:

I A representative of Southern Nuclear Operating Company has attended the l workshop "Section 2.206 Petitions Requesting Institution of a Proceeding To Modify, Suspend or Revoke a License, or for Such Other Action as May Be Proper," published in the Federal Register on June 29, 1993. In accordance with the request for comments, Southern Nuclear Operating Company is in total agreement with the NUMARC comments which are to be.

provided to the NRC.

In addition to the comments by NUMARC, Southern Nuclear Operating Company requests the Commission to consider the cost effectiveness of any proposed changes to the 2.206 process. Statements at the public workshop were virtually unanimous that the underlying safety issues raised by 2.206 petitions are being addressed carefully by the Staff. Even though some commentators expressed dissatisfaction that petitions were not granted as frequently as they wished, there was no suggestion that reasonable assurance of protecting public health and safety is undermined by the current 2.206 process. This means that any enhancements or refinements of the process can legitimately consider the increased regulatory burdens imposed on power reactor licensees. A balance should be struck between any proposed changes to the 2.206 process and any increase in regulatory burdens so the utili+.y customer does not unfairly bear the cost of a new 2 203 process without a concomitant enhancement of safety.

9309030023 930827 NBF 4726 PDR OS

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,L U. S. Nuclear Regulatory Commission Page Two There should be, also, a system of checks and balances that protect both the licensee and the petitioner from abuse of the 2.206 process.

Undoubtedly, there are incidences where a petitioner pursues a secondary motive besides one associated with public health and safety. Should the Staff to determine dismiss that this is the case, then the Staff should act swiftly the petition. Should a licensee somehow abuse the 2.206 process, the NRC has ample authority to take appropriate action.

Should you have any questions, please advise.

Respectfully submitted, hl } '

Dave Morey DNM/JDK cc: Southern Nuclear Otera_tinq Ccmpany -

R. D. Hill, Plant Manager

.U _S. Nuclear Regulatory Commission. Washinoton. D. C.

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

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