ML20092D279

Comment Supporting & Endorsing Positions Submitted by NUMARC & BWR Owners Group Re Rev 1 to NUREG-1022, Event Reporting Sys

ML20092D279
Person / Time
Site:	Fort Calhoun
Issue date:	01/31/1992
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-56FR50598, RTR-NUREG-1022 56FR50598-00038, 56FR50598-38, LIC-92-049, LIC-92-49, NUDOCS 9202130048
Download: ML20092D279 (2)

Text

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January 31, 1992 d LIC-92-049 (h 5 M, e David L. He er Chief 4 3 Regulatory ublicationsBranch JW Division of Freedom of Information and Public Services $ JM Office of Administration g 6 r U. S. Nuclear Regulatory Commission  ? I Washington, DC 20555 t

References:

1. Docket No. 50-285

2. 56 Federal Register 50598, October 7, 1991 Gentlemen:

Subject:

Draft NUREG 1022, Revision 1 The purpose of this letter is to respond to the Nuclear Regulatory Commission (NRC)requestforcomment'.,relatedtoNUREG-1022, Revision 1(Reference 2). l l The Boiling Water Reactor. Owners' Group (BWROG) and Nuclear Management and l Resources Council (NUMARC) are submitting extensive comments on this draft NUREG. I l Omaha Public Power District (0 PPD), while not a member of the DWROG, was actively l involved with this group in the review of the subject document. Based on OPPD's l review of the draft NUREG, the comments being submitted by both the BWROG and l NUMARC, and plant specific projections for Fort Calhoun Station, OPPD fully supports and endorses the positions being submitted by these groups. , it is OPPD's position that NUREG-1022, Revision 1 represents an expansion of the i reporting requirements that are currently implemented through 10 CFR 50.72 and 10 CFR 50.73, and would result in a significant increase in the staff hours required to support these changes, without an appreciable benefit related to capturing

                " safety significant" events.

Based on these reviews and comments, OPPD recommends that the staff positions as

              ' promulgated in the draft NUREG not be implemented pending further review and revision to this document.

l l 9202130048 920131 i PDR NUREG 1022 C PDR I as-sir 4 Empwmengtg!opgrtunrty L

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0. S. Nuclear Regulatory Commission Page Two LIC-92-049 If you have any questions, please contact me.

Sincerely, A& . 2Y. ${t=., W. G. Gates Division Manager Nuclear Operations WGGilah c: LeBoeuf, Lamb, Leiby & MacRae U. S. Nuclear Regulatory Commission, Document Control Desk R. D. Martin, NRC Regional Administrator, Region IV D. L. Wigginton, NRC Senior Project Manager R. P. Mullikin, NRC Senior Resident Inspector

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