ML20092C055

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Comments on Draft Rev 1 to NUREG-1022, Event Reporting Sys - 10CFR50.72 & 50.73:Clarification of NRC Sys & Guidelines for Reporting
ML20092C055
Person / Time
Site: Saint Lucie  
Issue date: 01/30/1992
From: Bohlke W
FLORIDA POWER & LIGHT CO.
To: Meyer D
NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-56FR50598, RTR-NUREG-1022 56FR50598-00029, 56FR50598-29, L-92-25, NUDOCS 9202110241
Download: ML20092C055 (2)


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10 CFR S 50. 72 &h. {,[2 "j

Q yg Os David L. Meyer, Chief-FJM Regulatory Publications-Branch 5$

Division of Freedom of Information vi and-Publication Services W

q Office-of Admindstration U.

S. Nuclear RegulatoryLCommission Washington, D.

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20555 Re:

EventTReporting Systems -- 10 CFR S 50.72 and.50.73:

Clarification of NRC Systems and Guidelines for Reporting (NUREG-1022,. Rev. 1) 56 Fed. Reg. 50598 (October 7, 1991)

Recuest for Comments

Dear Mr. Meyer:

On October 7, 1991, the U.

S.

Nuclear Regulatory Commission (NRC) published for public comment a Notice of Availability (56 Fed. Reg. 50598) of draf t NUREG-1022, Revision 1,

" Event Reporting Systems --

10~ CFR S - 50.72 and 5d.73:

Clarification of NRC Systems and

. Guidelines-for Reporting."

These comments are submitted on behalf of Florida Power-and Light Company (FPL), a licensed operator of-two nuclear power plant units in Dade County, Florida and two units in-St. Lucie County, Florida.

'The Nuclear Management and Resources Council (NUMARC) is offering comment _m the subject proposed revision to NUREG-1022.

FPL endorses the'NUMARC comments and recommendations.

The Nuclear Utility.Backfitting and Reform Group (NUBARG) is iiso offering-~ comments on the-subject proposed revision to NUREG-1022.

FPL endorses the NUBARG comments and recommendations.

For the reasons discussed in both the NUMARC and NUBARG comment

letters, FPL, as well, ' urges the Commission to delete those portions of the proposed guidance which ' are contrary to the existing language of the regulations, and to perform a backfitting -

analysis of the_ portions of the guidance that are premised on new

-or'different~ Staff positions.

9202110241 920130 PDR NUREG 1022 C PDR en FPL Group company

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L-92-25 Page 2 of 2 FPL's general concern over the positions in the draf t NUREG is that they would result in a substantially increased reporting obligation with no evidence that these positions would produce any material increase-in plant safety.

FPL would prefer to cont.inue to utilize the existing guidance for reporting versus the draft revision to NUREG-1022.

FPL appreciates the opportunity to submit these comments.

Very truly yours,

/

f'k' lii

/

W.

H. Bohlke Vice President Nuclear Engineering and Licensing WHB/DMB i