ML20205N147

Comment on Petition for Rulemaking PRM-50-50 Re Provision That Authorizes Nuclear Power Plant Operators to Deviate from Tech Specs During Emergency.Request by C Young Should Be Denied

ML20205N147
Person / Time
Site:	Catawba
Issue date:	10/20/1988
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR32624, RULE-PRM-50-50 53FR32624-00005, 53FR32624-5, NUDOCS 8811030467
Download: ML20205N147 (2)

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l Duke 1%wer Company H,t B T..e ,

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( ( ~0hl,*] IDI DUKEPOWER October 20, 1988

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'Ihe Secretary of the omission  ;

U.S. !bclou Ngulatory Ormission DOCKET ggg,g,gg W ahington, DC 20555 6p.gb NITDfrICN: Docketing and Service Branch ,qT

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Subject:

NRC tbtlee of Receipt of Petition for Bulemmaking by Charles Young Duke Power a===rits l

Dear Sir l In the Federal Pegister (53FR32624) dated August 26, 1988, the !bclear Regulatory Chmission published for carmnt a petition for rulmaking dated April 18, 1988, which was filed with the Cbmissicn by Charles Young. %e retitioner requests the Ommission to amnd its regulations to rescind the provisicn that authorizes nuclear power plant operators to deviate frm

'Ibchnical Specificaticms during an mergency. ,

Duke Power Cupany has reviewd the petition and feels that paragraths 50.54(X) and (Y) should ramin as now stated in the Cbde of Federal Regulaticms. tbt all situations related to operating a nuclear power plant can be anticipated and addressed in License Ctnditions, 'Dechnical Specifications or plant procedures. 'Ihe paragraphs are needed to allow  ;

l l powr plant operators,in an mergmcy, to take apprcpriate reasonable action I

to protect the health and safety of the public even if the actico departs frm a License Ctndition or 'Dechnical Specification.  !

Witlout the existing wording in 50.54(X) and (Y), power plant operators may be reluctant to take reasonable action in an mergency which is needed to  :

imediately protect the heal?.h ard safety of the p slic. Power plant cperators uust be giwn the authority to use their krowlecge gained frm training and experience, as apprtned by at least a Senior heactor operator, to handle situaticns sttich could arise that wtuld be outside the scope of written j rcquiruents.

• Since the accident at 'Ihree Mile Islard, Unit 2, thezu have been extcnsive upgrades in plant equit rent, systma and cierator t aining treiwcree NURD3 I u?27, Claritteatic i c# '::'I Mion Plet kquirerent'-) . 'Iheut upgrades should l

ensure anettar accident similar to 2nve Milo lund, Utdt 2. Will ret occur.

But in case there is a need to take rweensble action that departs frun the

'Ibchnical Specificaticas or a License Ctnii.t. ion, the licensee nust be granted 1 the fruccia to do so. 'Iherefore, the rcquest by Mr. Charles Young should be l denied. l l

l l 8811030467 001020 l

' PDR PRM ~

j 50-50 PDR

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. .o Docketing and Service &anch October 20, 1988 Page 2 Very truly yours, Ibl B. 'Ibcker IH/348/mf

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