NL-03-1751, Comment (16) Submitted by Southern Nuclear Operating Co., J. B. Beasley on Proposed Rule PR-50 Re Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors

Comment (16) Submitted by Southern Nuclear Operating Co., J. B. Beasley on Proposed Rule PR-50 Re Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors

ML032450198
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	08/28/2003
From:	Beasley J Southern Nuclear Operating Co
To:	NRC/SECY/RAS
Ngbea E S
References
+adjud/ruledam200505, 68FR26511 00016, NL-03-1751, PR-50
Download: ML032450198 (2)

Text

DOCKETED USNRC J. Barnie Eeasley, Jr., P.E Southern Nuclear Vice President Operating Company. Inc. August 29, 2003 (11:18AM) 40 Inverness Center Parkway Post Office Box 1295 OFFICE OF SECRETARY Birmingham, Alabama 35201 RULEMAKINGS AND An 1Inl1('ATIIJq'STAFF Tel 205.992.7110 Fax 205.t92.0341 M SOUTHERN A COMPANY Energy to Serve Your World '

August 28, 2003 NL-03-1751 Secretary U.S. Nuclear Regulatory Comrnmission ATTN: Rulemakings and Adjudications Staff Washington, DC 20555-0001 Southern Nuclear Operating Company Comments on Notice of Proposed Rulemaking for 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors (68 Federal Register 26511 dated May 16. 2003)

Ladies and Gentlemen:

Southern Nuclear Operating Company (SNC), the licensed operator for the Joseph M. Farley Nuclear Plant, the Edwin L.Hatch Nuclear Plant and the Vogtle Electric Generating Plant, has reviewed the notice of proposed rulemaking for 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors," published in the Federal Register on May 16, 2003 (68 FR 26511). Accordingly, SNC is in total agreement with the comments provided by the Nuclear Energy Institute (NEI) regarding this proposed rulemaking.

SNC would like to emphasize that there are two major issues in the NEI comments which must be resolved for a successful final rule. The first is removal of rule language and statements of consideration language that impose prescriptive requirements and expectations for treatment of low risk significant components. The second is maintaining the current position of the proposed rule relative to PRA capability and scope to support the categorization process. The Federal Register notice for the proposed rule raises the question of whether the proposed PRA requirements should be changed to require a full scope all modes NRC reviewed PRA. Such a requirement is neither technically necessary, nor justified, and would preclude 10 CFR 50.69 as a viable option for licensees.

Sincerely, Beasley, Jr.

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U. S. Nuclear Regulatory Commission NL-03-175 1 Page 2 cc: Southern Nuclear Operating Companv Mr. J. T. Gasser, Vice President, Plant Vogtle Mr. H. L. Sumner, Jr., Vice President, Plant Hatch Document Services RTYPE: CGA02.001