ML20128B537
| ML20128B537 | |
| Person / Time | |
|---|---|
| Issue date: | 12/02/1991 |
| From: | Rossi C Office of Nuclear Reactor Regulation |
| To: | Novak T NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| Shared Package | |
| ML19341G314 | List: |
| References | |
| FRN-57FR28642, RULE-PR-50 AD03-1-006, AD3-1-6, NUDOCS 9302030090 | |
| Download: ML20128B537 (2) | |
Text
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MEMORANDUM FOR: Thomas M. Novak, D! rector Division of Safety Protra:s ppg li
.. /J/44/9T Office for Analysis and Evaluation !'
of Operational Data FROH: Charles E. Rossi Director Division of Opera,tional Events Assessment Office of Nuclear Reactor Regulation
$UBJECT: 1 PROPOSED MODIFICATION TO 10 CFR 50.72 AND 50.73 i
By memorandum dated November 22 1991 you requested that DOEA/NRR consolidated 50.73 a 21 coments on propose,d chan,ges to 10 CFR 50.72(b)(2)(ii) and provide requir(em)e(nhs(iv)byCOBonDecember2,1991. The proposed changes would delete for licensees to make certain notifications and submit certain Itcensee event reports to the staff concerning unnecessary actuations of engineered safety features and reactor protection systems at their facilities.
These changes are set forth in a draft notice for the Federal Register and in a negative consent paper for the Comission.
By note dated November 22, 1991 Raji Tripathi of your staff requested that an individual staff member in DRPE, DRPW, and 00EA Further, the note stated that the package would )e 3rovide coments directly.
sent to office directors by December 6 and that their concurrence would be requested by December 11,1991.
If we are to provide consolidated coments for NRR, additional time will- be needed to solicit comments from the divisions that your staff has not contacted, to address differont points of view, and to establish NRR's position 27, 1991.on the matter. We would expect to submit coments to you by December Notwithstanding the need for NRR's consolidated comments DOEA's initial comments on the proposed rule change are presented in the en, closure.
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If you wish to d.iscuss this matter, please call me.
C(harles E. Rossi, Directororiginal signed by C.1.l G Division of Operational Events Assessment Office of Nuclear Reactor Regulation
Enclosure:
DISTRIBUTION:
As stated WRussell RDennig CRossi RWoodruff cc: P. Baranowsky. AEOD Achaffee J. Crooks, AE00 DOEA r/f-R. Tripathi, AE00 OEAB r/f DOCUMENT NAME: M00RW.WP (ATB/WP)
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ENCL.0SURE COMMENTS ON PROPOSED HODIFICATION TO 10 CFR 50.72 AND 50.73
- 1. The proposed change to the regulations would put identical rules in 50.72(b)(2)(ii)-and 50.73(a)(21(in only because one requires a 4-hour notif tcation by t61ephone and hhe other requires a 30-day, written report.
This unnecessary duplication in two rules that are not organized in parallel is confusing and misleading. The problem would be eliminated by combining 50.72 and 50.73.
- 2. The proposed change to the regulations is convoluted. It does not i I
and integrate well Itwith organization. tie rest includes of 50.72 in a definition terms which of content, form, is unnecessary if t he proposed [
rule is clearly written. It also includes exaosition which is more h aapropriate to NUREG-1022, Rev 1 than to 10 C R 50. In lieu of the proposed P c1angeto50.72(b)(2)(ii),wesuggestthefollowing [
Cii)Anyeventorconditionthatre- '
suits in manual or automatic actuation of any- Engineered Safety Feature (E , the Reactor-Protection System (R , or both, except: .
Actuation of.an ESF or RPS that resu ts from and is part of the pre-planned sequence during testing or reactor operation,
, (B) Manual or automatic initiation l of an ESF or RPS actuation signal when l the ESF or RPS is or had been aroperly l l removed from service, or w1en the safety function of the ESF or RPS was completed prior to initiation of the actuation signal, or (C) Automatic initiation of an - ESF l or Rks actuation signal when the set-
- point for actuation is .not reached i andactuation is not needed, And the
, actuation does not affect the perfor-l - mance of a system important to safety.
Further, we suggest that 50.73(a)(2)(iv) reference 50.72(b)(2)(ii). ;
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