ML20248C226

Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys

ML20248C226
Person / Time
Site:	Diablo Canyon
Issue date:	05/22/1998
From:	Womack L PACIFIC GAS & ELECTRIC CO.
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR20136, RULE-PR-50 63FR20136-00011, 63FR20136-11, NUDOCS 9806020089
Download: ML20248C226 (2)

Text

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,1  : cal Seraces O ' M' I Man Code N3B P.0 Box 77000C San Franasco CA 9W7 415'973-0600 Fax 415973-656798 MAY 29 P4 :05 1 May 22,1998 I l OF .

l PG&E Letter DCL-98-075 ho ADJ! : r Mr. John C. Hoyle Office of the Secretary {

U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTN: Rulemakings and Adjudications Staff i Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Comments on Revised Proposed Rule - Codes and Standards: IEEE National Consensus Standard (63 Federal Reaister 20136. April 23.1998)

Deer Mr. Hoyle:

On April 23,1998, the NRC reissued a proposed rule in the Federa/ Register (63 FR 20136) to give the public another opportunity to comment on an amendment to 10 CFR 50.55a(h), " Protection and Safety 5,ystems." The proposed rule would incorporate a national consensus standard, IEEE Standard (Std.) 603-1991, " Criteria for Safety Systems for Nuclear Power Generating Stations,"into NRC regulations. IEEE Std. 603-1991 establishes functional and design requirements for power, instrumentation, and control portions of safety systems in nuclear power plants.

On November 25,1997, Pacific Gas and Electric Company (PG&E) provided comments to the Commission on the proposed direct final rule that was published in the FederalRegister(62 FR 53932) on October 17,1997. (The NRC subsequently withdrew the direct final rule on December 23,1997 because I of significant adverse public comments.) Some of the comments in the PG&E November 25 letter were addressed by the clarification provided in the April 23 notice of the proposed rule; however, the primary focus of our comments remains a concern and is reemphasized below.

The revised rule specifies that system-level replacements of existing power, j j

instrumentation, and control portions of protection systems and the addition of l new safety systems in operating nuclear power plants initiated on or after , 1 January 1,1999 are required to meet the requirements of IEEE Std. 603-1991 0 i and the correction sheet dated January 30,1995.

9006020089 990522 PDR PR 50 63FR20136 PDR

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. Mr. John C. Hoyle

May 22,1998, L Page 2 l During the' operating lifetime of a nuclear generating facility, a number of plant changes l may be made due to equipment obsolescence issues. For example, when a vendor no .

4 I longer supports a particular piece of equipment, licensees often have no reasonable

. alternative other than to find a suitable replacement, which may require a system-level replacement. Under the revised rule requiring compliance with IEEE Std. 603-1991, the cost of such a system-level replacement could be significant, with no I

commensurate enhancement to safety. As a consequence, rather than replacing such

equipment or system when warranted, licensees may seek to avoid incurring these L costs by extending the life of the equipment involved. This alternative is inconsistent I

! with the NRC goal associated with endorsement of the latest version of the national consensus standard in NRC's regulations.

. Like other operating power plants of the same vintag : as Diablo Canyon Power Plant j

(DCPP), DCPP is designed and licensed to IEEE Std. 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Stations." PG&E believes that licensees should be able to retain their original design and licensing bases and maintain their .

commitments to existing standards such as IEEE Std. 279-1971. PG&E agrees that, where practical, licensees should adopt standards that are more current; however, j licensees should not be required to do so by ruitmaking. IEEE Std. 603-1991 is a well-l written, technical standard that should be applicable to new plants where its provisions ,

can be effectively incorporated into the original design.

Sincerely, I

! (

Lawrence F. Womack

, c: Steven D. Bloom l Michael. Schoppman, NEl L Ellis W. Merschoff l

Kenneth E. Perkins David L. Proulx l- Diablo Distribution dwo/220 1

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