ML20099E044
| ML20099E044 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/27/1992 |
| From: | Woodard J SOUTHERN NUCLEAR OPERATING CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-57FR28642, RULE-PR-50 57FR28642-00013, 57FR28642-13, NUDOCS 9208100001 | |
| Download: ML20099E044 (1) | |
Text
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UhNhC 92 JUL 31 P3Sgthern Nuclear Operating Company
- a. o. woodard Vice Presdent the southem elec!nc system
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50-348 Ndef 50-364 Mr. Samuel J. Chilk Secretary of the Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 ATTENTION: Docketi_np and Service BrancF Coments on Proposed Rule
" Minor Modifications to Nuclear Power Reactor Event Reporting Requiruients" (57 Federal Reaister 28642 of June 26, 1992)
Dear Mr. Chilk:
Southern Nuclear Operating Company (Southern Nuclear) has reviewed the proposed rule, 10 CFR Part 50, " Minor Modifications to Nuclear Power Reacter Event Renorting Requirements," published in the Federal Register on June 19, 1992'.
In accordance with the request for coments, Southern Nuclear is in total agreement with tht NUMARC coments which were provided to the NRC.
.In addition to the NUMARC comments, Scathern Nuclear would like to add the following coment. The scope of the Engineered Safety Features (ESF) actuations which would be exempt from reportina under the proposed rule should not be limited to those specified.
If an ESF actuation is truly invalid, it should not be reportable under 10 CFR 50.73(a)(2)(iv). No
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" event" or " condition" exists when an invalid ESF actuation occurs. This type of ESF actuation would have little or no safety significance.
Therefore, ANY invalid ESF actuation should be exempt from the reporting require n t.
Shoul. Mu have any questions, please advise.
Respectfully submitted, 9208100001 920727 b
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$R S7 28642 PDR
, Woodard
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JDW/JMG Mr. - S. T. Hof fman
$$0 cc: Mr. S. D. Ebneter Mr. G. F. Maxwell
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