View source for LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft Rg Should Not Have Been Construed as Endorsement to IEEE 603-1991

{{Adams
| number = ML20249A955
| issue date = 06/12/1998
| title = Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft Rg Should Not Have Been Construed as Endorsement to IEEE 603-1991
| author name = Powell D
| author affiliation = PUBLIC SERVICE ELECTRIC &amp; GAS CO. OF NEW JERSEY
| addressee name = 
| addressee affiliation = NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000272, 05000311, 05000354
| license number = 
| contact person = 
| case reference number = FRN-63FR20136, RULE-PR-50
| document report number = 63FR20136, LR-N980284, NUDOCS 9806190186
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 3
}}

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  ) ' O PSEG                                                                                                                                    DOCKETED Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 080NNb Nuclear Business Unit g
LR-N980284                 'h, ~ 7          .
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i'F U.S. Nuclear Regulatory Commission                                                                   <
Secretary                                                                                            l Washington, DC 20555                                                                                 !
Attn: Rulemakings and Adjudications Staff                    .D M gN g                 go

==Dear Sir:==
bNOI                l COMMENTS ON NRC PROPOSED RULE ON lEEE STANDARD 603-1991 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272,50-311 AND 50-354 l
Enclosed are the Public Service Electric & Gas (PSE&G) comments on the proposed rule revising 10CFR50.55a(h) as published in the Federal Register on April 23,1998, 63FR20136 submitting a direct rule to amend the Commissions rules in 10 CFR Part 50.55a(h). The enclosed comments were provided to Mr. S. Aggarwal of the NRC via E-Mail on May 27,1998.
If you have any questions or require additional information, please contact Mr. Vic Fregonese at (609) 339-1607.
Sincerely, h.$,leedf                                          l D. R. Powell                                        l Director -
Licensing / Regulation and Fuels Attachment
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9806190186 980612 PDR    PR I                                                                   50 63FR20136            PDR l
l hpmerisinprhaak                                                                               %
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Document Control Desk                     2 LR-N980284 l
1C     Mr. H. J. Miller, Administrator - Region l             l l
U. S. Nuclear Regulatory Commission 475'Allendale Road '
King of Prussia, PA 19406
!                                                                       L Mr. P. Milano, Licensing Project Manager - Salem       ,
U. S. Nuclear Regulatory Commission                   1 One White Flint North Mail Stop 14E21 11555 Rockville Pike
                     . Rockville, MD ' 20852                               '
l                     Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission                    ;
                     - One White Flint North
                     - Mail Stop 14E21' 11555 Rockville Pike ~
Rockville, MD 20852 '
Mr. S. Morris        .(X24)
USNRC Senior Resident inspector - Salem Mr. S. Pindale       ~ (X24) -
USNRC Senior Resident inspector - Hope Creek Mr. K. Tosch, Manager IV, Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625
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      - LR-N980284 ATTACHMENT 1                                           i a
PSE&G COMMENTS ON PROPOSED RULE ON IEEE STANDARD 603-1991
: 1. Endorsement of other referenced IEEE standards Within the proposed rules published in the Federal Register as noted above, the NRC in its response to significant comment #1, PSE&G does not believe the NRC has fully addressed the outright endorsement of other IEEE standards. The statement that IEEE 603 - 1991 does not imply endorsement of later versions of IEEE Standards is not technically substantiated within the proposed rule by the NRC if IEEE 603 - 1991 is to be endorsed by rule and not regulatory guidance. The NRC states that it did not seek for any other standards referenced in IEEE 603 - 1991 to be approved for incorporation by reference, even going so for as to state the referenced standards in IEEE 603 - 1991 are not mandatory requirements, although IEEE 603 - 1991 invokes the referenced standards by the     3 use of "shall". PSE&G believes the NRC position has not been clarified due to "shall"in the  !
IEEE 603 -1991 standard; once IEEE 603 -1991 becomes part of 10 CFR 50.55a , then            l IEEE 603 -1991 becomes part of the license commitment.                                        I
: 2. Definition of System Level Replacement The term " system level" replacement is not clearly defined and likely cannot specifically be established regarding what constitutes a system-level replacement versus an upgrade or modification to components and subsystems. The proposed NRC interpretation would require compliance with IEEE-603 -1991 for system level replacement / upgrades of protection systems / subsystems that require replacement due to age or obsolescence. Currently, this can be performed under 10CFR50.59 guidance, using design criteria (IEEE standards and
{
Reg Guides) that are part of the plants design and licensing basis. Imposition of IEEE-603 -
1991 in this situation appears to be a backfit. The NRC's perceived impact of incorporating IEEE-603 in this manner is understated.
: 3. IEEE 603 - 1991 Industry Acceptance PSE&G disagrees that IEEE-603 and RG 1.153 represent a general public concensus position. The NRC's statement that they believe the RG was appropriate due to lack of negative comment on the draft RG (proposing to endorse IEEE 603 -1991) should have considered that the majority of operating plants are not required to meet IEEE-603 -1991 or  ,
RG 1.153. The lack of adverse comments (to the draft RG) should not have been construed as an endorsement of IEEE 603 -1991.
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