ML032470847
| ML032470847 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 08/29/2003 |
| From: | Burzynski M Tennessee Valley Authority |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| +adjud/ruledam200505, 68FR26511 00021, PR-50 | |
| Download: ML032470847 (2) | |
Text
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{68ER as 11)USNRC L-ta.I September 3,2003 (11:12AM)
Tennessee Valley Autht. 1101 Market Street. Chattanoa. Teressee 37402-2801 OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF August 29, 2003 Secretary U.S. Nuclear Regulatory Commission ATTN:
Rulemakings and Adjudications Staff Washington, D.C. 20555-0001 Gentlemen:
NUCLEAR REGULATORY COMMISSION (NRC)
COMMENTS ON PROPOSED RULEMAKING FOR 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER
- REACTORS, RIN 3150 -
AG42 (VOL. 68 FEDERAL REGISTER 26511, DATED MAY 16, 2003)
TVA appreciates the opportunity to comment on the subject proposed rule.
Implementation of rulemaking to properly categorize and treat structures, systems, and components (SSC) according to their contribution to risk has the potential for substantially enhancing the safety focus, coherence, and efficiency of current regulations governing nuclear power plant operations.
TVA wishes to recognize the NRC staff's efforts to this point in developing the proposed rule.
The currently proposed rule language is improved over earlier drafts.
TVA has reviewed the comments contained in the August 22, 2003 letter to NRC submitted by the Nuclear Energy Institute (NEI).
TVA endorses and supports NEI's comments.
Specifically, TVA agrees with NEI's conclusion that two major issues must be resolved for successful issuance of a final rule.
First, the rule language and statements of consideration (SOC) are inconsistent with regard to expectations for treatment and monitoring of plant SSCs that are safety-related and of low safety significance (RISC-3 SSCs).
In some cases, the proposed rule and SOC contain requirements and expectations that are impractical, not risk-effective, or that actually exceed current requirements for safety-related equipment.
It is the fundamental purpose of this rule to concentrate plant and regulatory resources on areas of higher safety significance. Additional requirements and expectations for RISC-3 SSCs result in disproportionate requirements on SSCs which can be shown to have minimal safety significance.
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U.S. Nuclear Regulatory Commission Page 2 August 29, 2003 Second, the issue of PRA (probabilistic risk assessment) scope and technical capability necessary for this application must be resolved. TVA believes that the requirements currently specified in the proposed rule provide a sufficient basis for categorizing SSCs.
The addition of a requirement for a level 2 internal and external initiating events, all-mode, peer-reviewed PRA that must be submitted to and approved by the NRC is unnecessary and burdensome to the point of outweighing the benefits of this rulemaking.
If you have any questions, please contact me at (423) 751-2508.
Sincerely, Mark J. Burzynski Manager Nuclear Licensing cc:
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001