ML20096A023
| ML20096A023 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/30/1992 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | Meyer D NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-57FR6748, RTR-NUREG-1449 57FR6748, NUDOCS 9205080026 | |
| Download: ML20096A023 (2) | |
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Southem f% clear Operating Company Post Offce Box 1295
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Bemingham. Alabama 3520t Te!ephonc 205 608 5086 QSO9 akq d.
s Southern Nudear Operating Company
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}'gej'yt t?w scuttem ewcwc rystem April 30,1992 Dockets Nos.
50-348 50-364 q
d
_4 Mr. David L Meyer 4
Chief, Regulatory Publications Branch b
rf, U. S. Nuclear Regulatory Commission 4
45 Washington, DC 20555 F
T
- o Un Comments on Draft Report, NUREG-1449 j
" Shutdown and Low-Power Operation at
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Commercial Nuclear Power Plants in the United States" (57 Federal Recister 6748 of February 27.1992)
Dear Mr. Meyer:
Southern Nuclear Operating Company has reviewed the draft report, NUREG-1449,
" Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States," published in the Federal Register on February 27,1992. In accordance with the request for comments, Southern Nuclear Operating Company provides the following:
Section 6.3 introduces a concern on the part of the NRC with the working hours of plant personnel during outages and implies that they expect implementation of the NUMARC
" Guidelines to Enhance Safety During Shutdown" to result in programs " reducing tim.
that people perform higher risk activities." It is our expecution that the NUMARC guidelines will reduce the time spent performing high risk activities by rescheduling activities for times of reduced risk, not by reducing werking hours. If the NRC is expecting working hours to be reduced as the result of the draft NUREG, additior al justification is needed, especially in light of the results from the interviews with plant operators conducted by the NRC documented in Section 3.2.2 of the draft.
92050B0026 920430 PDR NUREC 1449 C PDR
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. Mr. David L Meyer U. S. Nuclear Regulatory Commission Page 2 Section 6.12.2 states, "In meeting this requirement as stated in Criterion J of NUREG-0654, the NRC expects each licensee to evacuate nonessential personnel and to account for onsite personnel within 30 minutes of the declaration of an emergency."
This statement, left for the readcrs' interpretation, may not be consistent with the application of Criterion J of NUREG-0654 in an individual site's Emergency Plan. In order to accurately reflect the requirements of Criterion J and preclude misinterpretation of the regulations, the statement should be revised to read as follows:
"In meeting this req.lirement as stated in Criterion J of NUREG 0654, the NRC expects each licensee to (1) evacuate onsite non-essential personnel in the event of a Site or General Emergency and (2) account for all individuals onsite at the time of the emergency in accordance with their approved Emergency Plan "
Section 7.2.(1) provided a list ofitems that the NRC felt necessary for achieving effective outage planning and control. Included in the list was a " controlled information system to provide critical safety parameters and equipment status on a real-time basis during the outage." This item is not further defined. It is our concern that the NRC plans
' to require installation of a system similar to SPDS to provide real-time monitoring of
" shutdown critical safety function status trees." The implementation of such a requirement would be costly and offer little safety advantage over current manual methods of safety review utnized to determine if equipment should be removed from servic.furing an outage.
Additionally, the BWR Owners' Group (BWROG, is providing comments on this document which we believe to be approp-iate and beneficial.
Should you have any questions, please advise.
Respectfully submitted,
,YS n$s J.
. Woodard cc: Mr. S. D. Ebneter Mr. S. T. Hoffman l
Mr. G. F. ' anvell M
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.