ML20092B821

Comment Supporting Draft NUREG-1022,Rev 1, Event Reporting Sys-10CFR50.72 & 50.73;Clarification of NRC Sys & Guidelines for Reporting

ML20092B821
Person / Time
Site:	Farley
Issue date:	01/31/1992
From:	Woodard J SOUTHERN NUCLEAR OPERATING CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-56FR50598, RTR-NUREG-1022 56FR50598-00036, 56FR50598-36, NUDOCS 9202110149
Download: ML20092B821 (2)

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January 31, 1992 " "' P # "" *"""*"

Docket Nos.

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4 Comments on Draft Report, NUREG-1022, Revision 1

" Event Reportir.g Systems-10 CFR 50.72 And 50.73; Clarification of NRC Systems and Guidelines for Reporting" (5) Federal Reaister 50598 of October 7. 1991) l

Dear.Mr. Meyer:

Southern Nuclear Opersting Company has reviewed the draft report, NUREG 1022, Revision.

" Event Reporting Systems-10 CFR 50.72 And 50.73 Clarification of NRC Systems and Guidelines for Reporting," published in i

the Federal Register on October 7, 1991.

In accordance with the request for comments, Southern Nuclear Operating Company is in total agreement with the NUMARC comments which are to be provided to the NRC.

Additionally, the BWR Owners' Group is providing comments on this document which we believe to be appropriate and beneficial.

Southern Nuclear supports the efforts of the Staff to clarify existing reporting guidance. We wish to emphasize that such clarification should not result in an unwarranted expansion of reporting obligations. As reflected in the comments referenced above, the new guidance related to reporting of even',s outside the design basis of the ?lant alone will account for a significant increase in the number of _ERs. Also the i

redefinition of Engineered Safety Feature (ESF) systems for reportability purposes in the draft NUREG-1022, Revision 1, and the broadly based definition of _ESF. actuations (including ESF actuations from non ESF signals) will only result in the increased reporting of events of little or no safety significance.

Should you have any QJestiCDs, please &dvise.

Respectfully submitted, 4

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'Q.D.Woodard 9202110149 %?O131 PDR NUREO 1022 C PDR'

Mr. David L. Heyer Page 2 U.S. Nuclear Regulatory Commission

(;c Mr. S. D. Ebneter fir. S. T. Hoffman Mr. G. F. Maxwell 1

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