ML20077L871
| ML20077L871 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/22/1994 |
| From: | John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-59FR54843, FRN-60FR13615, RULE-PR-50, RULE-PR-55, RULE-PR-73 59FR54843-00005, 59FR54843-5, AF18-2, AF18-2-009, AF18-2-9, TXX-94338, NUDOCS 9501120040 | |
| Download: ML20077L871 (2) | |
Text
DOCKET NUMBER PROPOSED RULE N M U N3 (59F85%G)j DOCKETED 5
Log # TXX-943380SNP.C File # 883
=
=
74 DEC 27 P4 :40 illELECTRIC 0FFiCf Gf SE N MH-DecemberIMCH1'940G & (*'O c, % ya,,,
ERAEts c,,,,,, m m U. S. Nuclear Regulatory Commission Washington. DC 20555 Attn: Docketing and Service Branch
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS 50-445 AND 50-446 COMMENTS ON REDUCTION OF REPORTING REQUIREMENTS IMPOSED ON NRC LICENSEES Gentlemen:
TU Electric welcomes the opportunity to provide coments to the proposed " REDUCTION OF REPORTING REQUIREMENTS IMPOSED ON NRC LICENSEES" published in 59 FR 54843.
TV Electric firmly agrees with the efforts of the Nuclear Regulatory Comission in reducing the duplicate reporting requirements of Appendix J and SS 50.72 50.73 of 10CFR50 concerning containment leakage the duplicate requirements of 10CFR55.25 and 10CFR50.74(c) concerning licensed operator incapacity, and the duplicate requirements of 10CFR73.71(c)(2) and Appendix G to part 73 concerning quarterly submittal of safeguards events logs. The NRC efforts to reduce the regulatory burden by reducing redundant reporting requirements conserve both NRC and Licensee resources and TV Electric encourages NRC to continue in its efforts.
Notwithstanding. TU Electric's endorsement of the NRC efforts in reducing duplicate reporting requirements, the discussion in the federal register mentions the existing 10 CFR 50.72(b)(1)(ii) and 50.73(a)(2)(ii) requirements to report events which are unanalyzed or outside the plant's design basis. A reasonable interpretation of the SS 50.72(b)(1)(11) and 50.73(a)(2)(11) reporting threshold, based on "the unanalyzed and outside of design basis", would be a leakage rate in excess of La. The threshold for preparation, but not submittal, of a sumary report. as required by S V.B. of Appendix J. is the failure to meet the acceptance criteria of Appendix J III. A.S.(b) which is a leakage rate in excess of.75La.
These differing values could be a source of confusion in interpreting the "in excess of authorized limits as listed in the plant Technical Specificaticos" prerequisites for reporting. TV Electric recommends clarification in a subsequent revision to either Appendix J or NUREG 1022.
9501120040 941222 i
l PDR PR 50 59FR54843 PDR 400 N. Olive LB. 81 Dallas. Texas 75201 3 610
e i
TXX-94338 Page 2 of 2 If you have any questions please contact Mr. Jos6 D. Rodriguez at (214) 812-8674.
Sincerely.
C. L.
By.
- 3. S. Marshall Generic Licensing Manager i
i