B12469, Comments on Interim Policy Statement on Tech Spec Improvements.Util Supports Intent of Policy Statement.Urges NRC to Support short-term Tech Spec Improvements Recognized by Nuclear Industry to Be of Significant Benefit

Comments on Interim Policy Statement on Tech Spec Improvements.Util Supports Intent of Policy Statement.Urges NRC to Support short-term Tech Spec Improvements Recognized by Nuclear Industry to Be of Significant Benefit

ML20205E580
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	03/23/1987
From:	Mrockza E NORTHEAST UTILITIES, NORTHEAST UTILITIES SERVICE CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B12469, NUDOCS 8703300640
Download: ML20205E580 (5)

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(203) 665-5000 March 23,1987 Docket Nos. 50-213 50-245 50-336 50-423 B12469 Re: 10CFR50.36 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 .

Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.1,2 and 3 Comments on the Interim Policy Statement on Technical Specification improvements On February 6,1987,(I) the Commission published for comment a proposed policy statement which provides the policy of the NRC regarding the scope and purpose of Technical Specifications for nuclear power plants as required by 10CFR50.36.

Northeast Utilities Service Company (NUSCO) has reviewed the proposed policy statement and submits the following comments on behalf of The Connecticut Yankee Atomic Power Company and Northeast Nuclear Energy Company, licensees for the Haddam Neck Plant and Millstone Unit Nos. 1, 2 and 3, respectively.

As a general comment, NUSCO fully supports the intent of the policy statement and believes that it provides for significant improvements in plant safety and reliability as well as more effective utilization of utility and NRC resources. We would also like to recognize the efforte of the NRC and Atomic Industrit1 Forum (AIF) task groups that contributed to the development of this policy statement.

Our specific comments on the policy statement are as follows:

o We concur in the Commission's opinion that Technical Specifications should identify only those plant features which are of controlling significance to safety. Thus, we believe that the Commission's statement of purpose for Technical Specifications is appropriate.

(1) 52 Federal Register 3788

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' ~ ' LU.S. Nuclear Regul: tory Commission B12469/Page 2 March 23,.I987 o We'. agree that implementation of improved Technical Specifications -

should remain voluntary, noting that the NRC Technical Specification Improvement Project (TSIP) task group concluded that current Technical Specifications provide adequate protection of public health and safety.

While we agree that all licensees should be encouraged to implement improved Standard Technical Specifications (STS), we believe that it would be inappropriate to require this of all licensees.

o The Commission states that it will entertain ' requests for license amendments based on the criteria set forth in the policy statement .that evaluate all of the Limiting Conditions for Operation (LCOs) for an individual plant. The Commission also states that it does not intend that the criteria be used to relocate individual LCOs from the Technical Specifications to other documents. We believe that the policy statement should be revised to allow app!! cation of the criteria enumerated in the-policy statement to related portions of LCOs.' The criteria for screening Technical Specifications provide a means of objectively determining the appropriate content of Technical Specifications and are equally applicable to sections of Technical Specifications as well as to the entire document.- Application of the criteria to related porti_ons of Technical Specifications is one method of accomplishing improvements in the short term.

o One of the recommendations of the NRC TSIP and AIF task groups was that a' parallel program of short-term improvements in both scope and substance of existing Technical Specifications be initiated in addition to the long-term d

improvements (3velopment identified inofthe anAIPs improved STS. A number report onof short-term U were October 1,1985 Technical Specification improvements. - Unfortunately, Commission guidance regarding short-term improvements to Technical Specifications is notably absent from the proposed policy statement. Notwithstanding the absence of Commission guidance in this area, we strongly urge the NRC to support short-term Technical Specification improvements which have been recognized by the nuclear industry and the NRC Staff to be of significant benefit and relatively simple to implement.

(2) Specifically, six areas for potential short-term improvements were suggested by the AIF in their October 1,1985 report. They are:

1) Deletion of Technical Specification requirements which duplicate requirements in federal regulations.

2) Revised Definition of Operable / Operability.

3) 18 Month vs. Refueling Outage Surveillance Interval.

4) Deletion of Cycle Specific Variables from Technical Specifications.

5) Consistent Application of Specification 3.0.4.

6) Deletion of Component Lists from Technical Specifications.

' U.S Nucl:ar Rrgulatory Commission B12469/Page 3 March 23,1987 o The nuclear Industry has committed substantial resources to the development of Technical Specification improvement programs. We urge the Commission to dedicate the resources necessary to ensure that vendor owners' group and licensee submittals are reviewed in a timely (

manner, j o The Commission has determined that Probabilistic Risk Assessments (PRAs) are an appropriate tool for defining requirements that should be retained in the Technical Specifications where including such requirements is consistent with the purpose of Technical Specifications as defined in the policy statement. The Commission encourages utilization of literature on risk insights and PRAs to strengthen technical bases for requirements that remain in Technical Specifications and to verify that none of the requirements relocated to other documents contain constraints of primary importance in limiting the likelihood or severity of accident sequences that are found to be important contributors to risk. We agree with the Commission that such use of risk evaluation techniques is appropriate when sufficient and pertinent =

information is available. However, we do not believe that licensees should be required to perform a plant-specific PRA prior to implementing the policy statement. We also believe that the Commission should amend the policy statement to allow use of PRAs to relocate items from the Technical Specifications, which would otherwise be retained based on the policy statement criteria, if they have an acceptably low contribution to risk.

o We note that Radiological Environmental Technical Specifications were cited as being an example of a requirement of 10CFR50.36 which would need to be amended in order to fully implement the policy statement.

We would like to also suggest other areas of 10CFR50.36 which the Commission should consider amending. Specifically, we recommend that the Commission consider amending 10CFR50.36 to eliminate the requirements to include Design Features and Administrative Controls in Technical Specifications. The Technical Specifications in these two areas do not impose limits on plant operation necessary to obviate the possibility of an abnormal situation which could become an immediate threat to public health and safety and thus are not within the proper scope of Technical Specifications as defined in the policy statement. Furthermore, licensee commitments to plant design features and administrative controls either already are or may easily be included in the FSAR with changes controlled under the requirements of 10CFR50.59 and 50.71.

To address the points raised by Commissioner Asselstine, we offer the following comments. We agree with Commissioner Asselstine that a good maintenance program is a key element in the safe and reliable operation of a nuclear power plant. However, we disagree with the Commissioner's assertion that maintenance programs must be strengthened as a prerequisite for the Commission to fully implement this policy statement. Other, more appropriate mechanisms exist (e.g. routine inspections, SALP evaluations) which enable the NRC to ensure that licensee maintenance programs are adequate and are being implemented properly. Secondly, any changes to testing and surveillance

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U.S. Nucitar Regulatary Commission B12469/Page 4 March 23,1987

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intervals or allowed outage tim ~es must be reviewed'by.the NRC and found to not'

adversely affect public health and safety. This review will include consideration of all technical information relevant to the proposed change including, when appropriate, maintenance practices. We recommend that the Commission not

' limit the potential for technically improving Technical Specifications based on a perception that utility maintenance programs are in some way deficient.

With regard to the need to strengthen the 10CFR50.59 review process, we believe that it is appropriate for the NRC to work with the industry to' develop

-more detailed guidance for use by licensees in the conduct of 10CFR50.59 safety evaluations. However, we view this action to be part of the natural evolution of the regulatory process. It need not, in our opinion, precede implementation of this policy statement. The Commission has, via this policy statement, made clear its intention to more closely scrutinize changes -made pursuant to 10CFR50.59.

La'stly, operating requirements that are truly of controlling significance to plant safety will remain in the Technical Specifications. Violations of such requirements will continue to be subject to NRC enforcement policy delineated in 10CFR2,. Appendix C. The Commission has made clear its intention to take

" appropriate" enforcement _ action to ensure that licensees comply with FSAR commitments and 10CFR50.59. 10 CFR 2,~ Appendix C, paragraph V.E provides for appropriate enforcement of such licensee commitments.

We disagree with Commissioner Asselstine's belief that deviations .from the FSAR or other licensee controlled documents-should be treated in the same manner as failures to comply with Technical Specifications recognizing the somewhat : lesser importance of these relative to Technical Specification violations in terms of the potential to adversely impact public health and safety.

We see no justification for revising NRC Enforcement Policy as a result of this policy statement.

We appreciate the opportunity to provide our comments on this proposed policy statement and the opportunity that the Commission's interim policy statement provides for us to improve our Technical Specifications and better achieve the objectives for which they were intended. We remain available to discuss our

. views of this subject with the Staff as necessary.

Very truly yours, NORTHEAST UTILITIES SERVICE COMPANY A

E. 3.TA ckza ~ (/

Senior ice President

' * ' US. Nucl;cr Regulatory Commission B12469/Page5 March 23,1987 L cc: S. 3. Chilk, Secretary of the Commission Dr. T. E. Murley, Region I Administrator

3. 3. Shea, NRC Project Manager, Millstone Unit No. I D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 E. L. Doolittle, NRC Project Manager, Millstone Unit No. 3 F.' M. Akstulewicz, NRC Project Manager, Haddam Neck Plant T. Rebelowski, Resident Inspector, Millstone Unit Nos. I and 2

3. T. Shedlosky, Resident Inspector, Millstone Unit No. 3 P. Swetland, Resident Inspector, Haddam Neck Plant