ML20207E418

Comment Supporting Recommended Improvements to Oversight Processes for Nuclear Power Reactors Noted in SECY-99-007A

ML20207E418
Person / Time
Site:	Summer
Issue date:	05/17/1999
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR19207 64FR19207-00005, 64FR19207-5, SECY-99-007A-C, SECY-99-7A-C, NUDOCS 9906070028
Download: ML20207E418 (3)

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&, 9 Chief, Rules and Directives Branch 3 Division of Administrative Services 3 Office of Administration

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3 Ger[fisk j Gentlemen:

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Subject:

VIRGIL C. SUMMER NUCLEAR STATION j DOCKET NO. 50/395

'i OPERATING LICENSE NO. NPF-12

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COMMENTS ON SECY 99-007A AND FEDERAL j REGISTER NOTICE April 19,1999 (64-19207)

O South Carolina Electric & Gas Company (SCE&G) has reviewed the Federal 4 Register Notice "Public Comment on Recommended Improvements to the soudtmotino thtrid ce Cp Oversight Processes for Nuclear Power Reactors" and the SECY 99-007A. In VSC,sumer Nudeor stafion j addition to the review of these documents, SCE&G has reviewed the NEl draft P 0ML . . . .

response and concurs with NEl. SCE&G would like to make the following knunsvine 5dn(mlinas comments:

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801345 4344 4 j initiating Events (Power Operations) 801345.5209 ! # d usiona;mn c The proposed performance indicator for transients per 7000 critical hours should be better defined or not included as an indicator. Unplanned transients m "

should be defined more clearly for unplanned maintenance activities and

- ' 4 should be excluded for power reductions caused by natural events in which m W; there is no control. This indicator is not indicative of how the station is s

j performing and rnay be contrary to conservative decision making on the 'part of y', management. 7 a

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)$ Five (5) failures is too low based on the current defiMicr of failureThe pro m  % ,

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m < :c p) NUCLEAR EXCELLENCE- A SUMMER TRADITION!

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- Chief, Rules and Direbtives Branch I

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U. S. Nuclear Regulatory Commission l

L MSP 990005 RC-99-0034 Page 2 of 3 Barriers The proposed indicator for reactor coolant system leak rate should be revised.

Licensees should be allowed to operate within the TS limits. The proposed metric would drive plants to shutdown at 0.5 gpm unidentified leakage in order to avoid moving :

to the increased regulatory response band which would then result in a transient that- '

would be counted as an unplanned transient. j Emergency Preparedness Cornerstone This indicator is not a measure of performance but simply participation. it does not judge emergency response capability or performance quality. This area should be evaluated by inspection only.

Physical Security Cornerstone All the proposed indicators seem too restrictive. They are regulating to excellence rather than regulatory requirements or risk-informed performance. This area should be evaluated by inspection only.

Inspection Areas it appears that the number of hours projected for engineering inspection mocules is

'three-fold of the current inspection hours. As a part of the pilot program, the appropriateness of the number of inspection hours in the engineering area should be assessed.

SCE&G appreciates the opportunity to review and provide comments on this draft document. Should you have any questions, please call Ms. Susan B. Reese at (803) 345-4591.

V ry truly yours, Ga i SBR /GJT/dr c: See Page 3 t

Chief, Rules and Directives Branch

• U. S. Nuclear Regulatory Commission "

MSP 990005' RC-99-0034 -

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c: J. L.- Skolds W. F. Conway R. R. Mahan-R. J. White L. M. Padovan R. E. Beedle NSRC'-

RTS . (MSP 990005)

File (815.16)

'DMS _ (RC-99-0102)

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