ML072000467
| ML072000467 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 07/19/2007 |
| From: | Project Engineering Consultants, Ltd |
| To: | Office of Nuclear Reactor Regulation |
| Hamm, Matthew DIRS/ITSB 415-1472 | |
| References | |
| Download: ML072000467 (1) | |
Text
Comment CLIIPs
- 3. The Model Application states, "I declare under penalty of perjury under the laws of the United States of America that I am authorized by
[LICENSEE] to make this request and that the foregoing is true and correct." This statement is not consistent with the recommended statement given in RIS 2001-18, "Requirements for Oath or Affirmation." RIS 2001-18 recommends the statement, "I declare [or certify, verify, state] under penalty of perjury that the foregoing is true and correct." Note that RIS 2001-18 states that this statement must be used verbatim. We recommend that the Model Application be revised to be consistent with RIS 2001-18.
- 4. In the Notice under "Applicability," the last two sentences state, "Significant variations from the approach, or inclusion of additional changes to the license, will result in NRC staff rejection of the submittal. Instead, licensees desiring significant variations and/or additional changes should submit a LAR that does not claim to adopt TSTF-487." Should a licensee submit an application that requests adoption of TSTF-487 but includes significant variations or additional changes (for example, as part of a license amendment request to convert to the Standard Technical Specifications), it would facilitate the NRC's review for the licensee to acknowledge that the change is based on TSTF-487 so that the NRC may use the model Safety Evaluation to the extent possible. We recommend revising the sentence to state, "Instead, licensees desiring significant variations and/or additional changes should submit a LAR that does not request to adopt TSTF-487 under the Consolidated Line Item Improvement Process."
TSTF-487 TSTF-448 TSTF-426 TSTF-427
- 1. To be consistent with 10 CFR 50.91(a), the title of Criterion 2 should be revised to add the word "Accident" before "Previously Evaluated." Specifically, it should state, "The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated."
TSTF-490 TSTF-448, "Revised Technical Specification Pages," should be shown as optional. Many licensees do not provide retyped technical specification pages in their license amendment requests.