ML20216F676

Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & NUREG-1022,Rev 1

ML20216F676
Person / Time
Site:	Fort Calhoun
Issue date:	09/17/1999
From:	Gambhir S OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR36291, FRN-64FR63291, RTR-NUREG-1022, RULE-PR-50, RULE-PR-72 64FR36291-00006, NUDOCS 9909220240
Download: ML20216F676 (2)

Text

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Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTN: Rulemakings and Adjudications Staff

References:

1. Docket No. 50-285

2. Federal Register Volume 64 dated July 6,1999 (64 FR 128)

Subject:

Comments on Proposed Revision to 10CFR50.72,10CFR50.73 and NUREG 1022 Revision 1 The Omaha Public Power District (OPPD) has reviewed the Federal Register notice concerning proposed rulemaking on " Reporting Requirements for Nuclear Power Reactors"(64 Federal Register 36291 of July 6,1999).

OPPD believes that the proposed change can meet the stated objectives to align reporting with needs, reduce burden where there is no safety significance and provide clarity to reporting.

OPPD fully endorses the comments to this rule that are being sent by the Nuclear Energy Institute (NEI).

There are two areas of the proposed rule with which OPPD has signiGcant concerns.

The first concern is the requirement to report significantly degraded r.omponents, section 50.73(a)(2)(ii)(C). This section does not meet the stated objectives cf the rule change and should be deleted. The proposed requirement to report items that are not safety significant runs counter to the intent of the event reporting rule. OPPD believes that cotiecting data of components, as a part of this rule, is an unwarranted backfit. The requirement to capture items (components) which } .

are seriously degraded, but not enough -so as to render a system inoperable, is subject to widely () I varying levels ofinterpretation. Such a degree of uncertainty and lack of clarity exists in this newly proposed requirement, that the potential exists to greatly increase the number of required LERs beyond those that were submitted due to being "outside the design bases of the plant." This would lead to various thresholds of reporting being adopted by licensees and the Regions. This practice is not consistent with the proposed Risk Based Inspection Program.

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3 7i LIC-99-0081 Page 2-The second concem is that the proposed rule contains a detailed list of ESF systems for reporting. To support the time frame of this rulemaking initiative, OPPD recommends each facility define ESF systems based on their current USAR. This is option three in the rulemaking

. package. Ultimately, as part of the initiative to risk-inform 10 CFR Part 50, a plant-specific, risk-informed list should be used when criteria are fully developed. This would include only those systems that are significant to safety.

Please contact me if you have any questions.

. Sincerely,-

S. K. Gambhir ff If'YY Division Manager Engineering & Operations Support

, SKG/ epm c: E. W. Merschoff, NRC Regional Administrator, Region IV L. R. Wharton, NRC Project . Manager W. C. Walker, NRC Senior Resident inspector Document Control Desk Winston & Strawn -

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