ML20216F489
| ML20216F489 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/17/1999 |
| From: | Alexander J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-64FR36291, RULE-PR-50, RULE-PR-72 64FR36291-00009, NUDOCS 9909220064 | |
| Download: ML20216F489 (3) | |
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'99 SEP 20 P3 :06 September 17,1999 Ltr. 2.99.098 O(.
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AD Secretary Docket No. 50-293 U.S. Nuclear Regulatory Commission License No. DPR-35 Washington, DC 20555
Subject:
Comments on Proposed Reportina Rule (64 FR 36293, July 6,1999)
Dear Sir:
The following Pilgrim Nuclear Power Station comments are submitted in response to Federal Register notices regarding the proposed rulemaking on certain reporting requirements for nuclear power reactors (64 FR 36293).
The proposed changes to 10 CFR Parts 50.72 and 50.73 are considered, in general, to meet the objectives to better align the reporting requirements with NRC needs, reduce the reporting burden where there is little or no safety significance, and to improve the
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clarity of the reporting requirements.
Pilgrim Station regulatory staff experienced in the reporting requirements and reporting l
participated in workshops and table top exercises held by the Nuclear Energy institute (NEI) and NRC. The NRC workshops and exercises proved to be insightful and useful
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as part of the rulemaking process and significantly improved the context of and resolution of the proposed reporting requirements.
Pilgrim Station endorses the comments submitted by NEl on behalf of the industry.
There is, however, one specific area of concern and one other comment regarding the proposed requirements for which Pilgrim Station offers the following comments.
The proposed (new) reporting requirement,10 CFR 50.73(a)(2)(ii)(C), involves a
' [J "significantly degraded" component. This proposed, new reporting requirement seems to be contrary to the objectives of the proposed rule because it imposes an unnecessary additional reporting burden. This proposed requirement appears to stem from a NRC staff perceived need for data collection. The example (s) provided in the proposed rule and discussed at the NRC workshop on August 3,1999, indicated NRC staff concerns with evaluations performed in acccrdance with Generic Letter 91-18,
" Resolution of Degraded or Nonconforming Conditions." The concern was offered by the NRC mechanical engineering section with little discussion and no specificity relative to the veracity and merit of the concerns. Presumably, and if such concerns 9909220064 990917 PDR PR 299098 50 64FR36291 PDR T)5ID
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- (U.S. Nucler Rsguktory Commission 4 :'
Ltr. 2.99.098 Page 2
. wars merited, the concern would properly be the subject of the NRC enforcement process. The perceived need for data collection should not be a reason for a new reporting requirement. The addition of the proposed (new) reporting requirement, in lieu of the enforcement process, appears to be mis-directed.
The proposed (new) reporting requirement could result in the requirement to report a problem (condition) with a component for which an evaluation concludes a component, J
although degraded, is operable (capable of providing its required function). The distinction between " degraded" and "significantly degraded" is vague and could be subject to varying interpretations. Thus, the proposed (new) reporting requirement, in
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itself, could or would likely result in reports that are not now required. One of the 5
reasons the NRC staff proposed the deletion of the requirement to report " conditions outside the design basis" was because of the confusion and controversy over the meaning of the reporting requirement. The confusion resulted in the consequent burden by licensees to report and for the NRC to review and process the reports.
Reporting is already required for problems that adversely affect the operability of one i
or.more channels or trains of a system (s). To proscribe the reporting at the component level, when reporting is already required for problems (conditions) that affect the operability of one or more channels or trains of a system (s), is considered to be an unnecessary expansion of the reporting burden, and contrary to at least one of the reasons for the proposed rule.
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Finally, the reporting of component failures is part of the existing reporting process (EPIX). No problems were identified with the EPIX reporting process.
The following comment involves the listing of engineered safety feature (ESF) systems.
Of the options contained in the proposed rule, Pilgrim Station supports Option 1
.(maintaining the existing reporting requirements) rather than Option 2 (risk-informed
- listing) or Option 3_ (pre-1998 listing) for the following reasons. The Pilgrim Updated Final Safety Analysis Report (UFSAR) contains a listing of engineered safeguards (i.e.,
ESF systems). The existing reporting requirements and applicable UFSAR systems have been incorporated into the Pilgrim Station reporting process. The previous actions taken and experience gained resulted in a significant reduction in the number of reports for an unplanned ESF actuation. Meanwhile, the NRC and industry pilot plants are currently implementing a pilot program for the new regulatory oversight process to be implemented in April 2000. The process utilizes risk-significance. The Option 2 listing would require consequent changes to the Pilgrim Station reporting process. The risk-significant listing could change in the future because of changes to regulatory requirements other than those for reporting. The Option 3 listing would require some changes to the Pilgrim Station reporting process but the benefit of the changes is considered to be minimal to that of the existing reporting process. Therefore, Option 1 is supported by Pilgrim Station.
2esoes
U.S. Nuclerr Regulatory Commission
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Ltr. 2.99.098 Page 2 Pilgrim Station considers the opportunities provided by the NRC in the workshops to have been very useful for this proposed rule-making.
er, irector ear Assessment DWE/
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