ML20202D230
| ML20202D230 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/24/1997 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-62FR53932, FRN-62FR53975, RULE-PR-50 62FR53932-00018, 62FR53932-18, NUDOCS 9712040198 | |
| Download: ML20202D230 (2) | |
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November 24, 1997 Om'1 m g r,R $
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'TMF Secretary U.S. Nuclear Regulatory Commission b
Attn Rulemaking and Adjudications Staff PROPOSED Ru Pl So Washington, D.C. 20555
( GD FM S21*7S
Subject:
Proposed Change to 10 CFR 50.55a(h)
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{ /8 R. E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Secretary:
This letter is in response to the proposed rule to incorporate j
the requirements of IEEE Std. 603-1991 into 10 CFR 50.55a(h),
effectivo January 1, 1998.
In the procedural background section of the Federal Register notice, it is stated th7t the NRC considers this rulemaking noncontroversial, and therefete is publishing this proposed rule as a direct final rule.
However, if the NRC receives significant adverse comments by December 1, 1997, the NRC will publish a document that withdraws the direct final ru'.e.
Our purpose is to provide such significant adverse comments, as follows:
1)
The apparent basis for judging that this rulemaking is noncontroversial is that no significant comments were received un the proposed Revision 1 to Regulatory Guide 1.153, which would endorse IEEE Std. 603-1991.
Sinco a regulatory guide is not binding, and merely suggests a method for meeting regulatory criteria, RG&E considers that issuing a final direct rule based on auch feedback is not an appropriate action.
In subparagraph (3) of this proposed rule, it is stated that changes to protection syst1ms initiated on or after January 1,
1998 must meet the requirements set forth in IEEE Std. 603-1991, e.nd the correction sheet dateo January 30, 1995.
This is considered a significant beckfit for Ginna Station, which was iss,ued a Construction Permit in 1966 and whose
/
design is generally in conformance with IEEE Std. 279-1971.
No backfit analyses was performed by the NRC for this h
proposed Rule, as required by 10 CFR 50.109.
It cannot be stated that all future changes to the Ginna Station protection systems would be voluntary, since the definition of " changes" in subparagraph (2)(ii) of the proposed rule includes modifications permitted by license amendments, 9712040198 971124 I
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. which could be imposed by the NRC.
Furthermore, changes made on account of equipment obsolescer.ca are not entirely voluntary, but would have to meet the provisions of IEEE Std. 603-1991 under this proposed rule.
We do not believe that the NRC has legitimately shown that this proposed rule is noncontroversial, and it must therefore be withdrawn, to be replaced by a rule (if any) which would have gone through the 10 CFR 50.109 process, as required by NRC regulations.
Very truly yours, f
'26*
M Robert C. Mecredy GJW\\482 xct Mr. Guy S. Vissing (Mail Stop 14B2)
Project Directorate I-1 Washington, D.C.
20555 1
U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 US NRC Ginna Senior Resident Inspector
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