ML20153C779

Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments

ML20153C779
Person / Time
Site:	Seabrook
Issue date:	09/18/1998
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR39522, RULE-PR-50 63FR39522-00008, 63FR39522-8, AR#-98014243, NYN-98109, NUDOCS 9809240196
Download: ML20153C779 (2)

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g""'N 00CX TED North Atlantic Energy Service Corporation North ussc ro. u- am Seabrook, Nll 03874 3

Atlantic mo3347uai W SEP 23 P 1 :26 - The Northeast Utilities System September 18,1998 ADJi>0 "'

Docket No. 50-443 NYN-98109 DOCKET NtNBER oROPOSED RUL.E $ 50 _

AR # 98014243 (43FR39622)

United States Nuclear Regulatory Commission Rulemaking and Adjudications Staff Washington, DC 20555-0001 Seabrook Station Comments oa NRC Advanced Notice of Proposed Rulemaking (ANPR),

Reportine Reauirements for Nuclear Power Reactors This letter provides North Atlantic Energy Service Corporation's (North Atlantic) comments in response to the Advanced Notice of Proposed Rulemaking (ANPR), Report ng Requirements for Nuclear Power 4 Reactors, published in the Federal Register on July 23, 1998 (63 Federal Register 39522). North

' Atlantic appreciates the opportunity 'to provide comments. North Atlantic endorses the_ comments provided by the Nuclear Energy Institute (NEI) on behalf of the nuclear industry end endorses the efforts made by the Nf'C Staff with this proposed rulemaking in reducing the reporting burden on licensees and the NRC with regard to reports that have little or no safety significance.

North Atlantic endorses the NRC Staff's focus on the operability and functionality of equiprnent and concurs with NEl that reporting under 10CFR50.72 should be reserved for current conditions that have the potential to affect the ability of structures and systems to perform their safety function.

In addition to the reporting rules addressed by NEl, in response to the ANPR request under the heading of Other Reactor Reporting Requirements, North Atlantic believes that the annual or periodic reporting pursuant to 10CFR50.59(b)(2) should be eliminated. The creation of the periodic .50.59 reports requires the expenditure of significant licensee manpower to create a summary report that does not contribute to protecting the health and safety of the public. This report, by its specified requirements, is a summary report and to be useful requires the review of additional licensee documentation. A better utilization of licensee and NRC resources would be a review of selected 10CFR50.59 evaluations as part of the NRC inspection process, thereby ensuring a full review of the activity performed pursuant to 10CFR50.59.

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9809240196 980918 PDR PR 50 63FR39522 PDR [

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U.S. Nuclear Regulatory Commission i NYN-98109/Page 2 If you have questions regarding our comments, please contact Mr. James M. Peschel, Regulatory

,. Compliance Manager at (603) 773-7194.

Very truly yours, NORTil ATLANTIC ENERGY SERVICE CORP, b 92 f' Ted C. Feigenbau[ ~

Executive Vice President and Chief Nuclear Officer

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