0CAN059206, Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety

Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety

ML20097B844
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/28/1992
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-57FR4166, RULE-PR-CHP1 0CAN059206, 57FR4166, CAN59206, NUDOCS 9206080023
Download: ML20097B844 (3)

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U. S. Nuclear Regulatory Commission ] [

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Subject:

Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 Elimination of Requirements Marginal to Safety Comments Gentlemen:

In Federal Register Notice of Feb ruary 4, 1992, the NRC was seeking comments on-the results, conclusions, and planned actions of its prcgram to eliminate requirements marginal to safety. The following comments are being submitted on behalf of Entergy Operations at Arkansas Nuclear one (ANO).

The first two comments are to address those specific regulations discussed in the Federal Register Notice. The remainder of the comments involve concerns of a broader nature as solicited in the " Comments Requested" section of the Federal Register Notice.

1) '10CFR50 Appendix R - Since the majority of all nuclear power plants already conform to these requirements, decreasing the prescriptiveness of the regulation should prove minimal, e?:c ept for possible site modifications or new f acilities. If regulations are going to be rewritten, the revision should be in an easy to_ read format and written so as to avoid the need to issue other documents attempting to explain the intent or provide examples on the regulations. This approach is believed to be a positive step since more flexibility would be afforded the utility with respect to complying with the goals established by the NRC. It could more than likely hinder NRC inspection efforts since each utility may develop a unique method of' complying with the goals unless clear guidance is provided in inspection manuals regarding the approach.

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-U. S. NRC-May 28, 1992 i Page 2.~

- 2) 10CFR50 Appendix J - Increasing the limits in this regulation could save critical-path time during outages. The increased limits would

, not make an appreciable difference in the sa fety analyses due to the recent source term _information. Making this regulation less prescriptive would be beneficia1 by a1 lowing flexibi1ity and utilization of the latest technology. This could, however, leavn the utility open to increased interpretive arguments wi t.h the NRC unless inspection manuals are updrited to provide clear inspection i criteria.

3) 10CrR50.49 - The rule la unnecessarily prescriptive regarding the requirement for test ed components to be pre-aged. Since pre-nging methods are limited in the reasonableness of extrapolation techniques, the regulation should allow for suitable maintenance / surveillance methods to address aging. This approach was deemed acceptable by NRC in Generic Letter 82-09 and of fers a more meaningful approach in many cases to establishing suitable qualified lifetimes for equipment. The accelerated aging test creates a much more stressful testing sequence than is envisioned  ;

due to natural aging. Aging tests should be limited to be within reasonable ranges of extrapolation and should not necessarily define the maximum qualified life. Rather, they should be at most the pre-requisite for the _ maintenance / surveillance techniques which control end of lifetime for components.

4) Generic Letters 86-15 and 88 These documents require special administrative attention be directed to non-conformances/

deficiencies associated with environmental qualification (EQ) of electrical equipment. Such special requirements are unwarranted since EQ raises no intrinsic safety issues different from any other qualification issue such as seismic, flood, fire, etc. that may potentially impact operability. The plants' aon-conformance/ adverse condition ' programs and procedures are more than adequate for addressing operability and safety significance. The prescriptive

, requirement for EQ Justification of Continued Operation should not l be required and is certainly considered marginal.

5)- Reg. Guide 1. 27 - The re is one aspect to safety of this Reg. Guide

in- particular -which is considered to be marginal. This recuirement includes the need to assume- a LOCA !in one unit with shutdown of- the other, loss of primary heat sink, and wo-st case meteorological conditions, flowever , even conservative assessments of the likelihood of the simultaneous occurrence of above items indicate that the risk is- minimal (10-/ year or less). Therefore, the criteria noted should be re-assessed in light of straightforward

-risk techniques which can easily demonstrate the marginal benefit of the regulation.

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.p, S. NRC May 28, 1992 Page 3 In general, Entergy.-Operations at ANO encourages the continued NRC.

. pursuit of. performance based regulations. As noted by our comments, NRC regulations and interpretations often becomo to prescriptive where safety

- may not . bef the overriding goal. Also, . ANO concurs with the comments submitted by NUMARC and NUBARG.

Thank you for your time and consideration of our comments.- Should you have any further questions, please do not hositate to contact me or my staff. j l

Very truly yours, l

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l wl , ~f James J. .sicaro

' Director, Licensing )

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