ML072000467

Nfc Comments

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 TSTF-487 under the laws of the United States of America that I am authorized by TSTF-490

[LICENSEE] to make this request and that the foregoing is true and TSTF-448 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, TSTF-487 "Significant variations from the approach, or inclusion of additional TSTF-448 changes to the license, will result in NRC staff rejection of the TSTF-426 submittal. Instead, licensees desiring significant variations and/or TSTF-427 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."

1. To be consistent with 10 CFR 50.91(a), the title of Criterion 2 TSTF-490 should be revised to add the word "Accident" before "Previously TSTF-448 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." , "Revised Technical Specification Pages," should be TSTF-426 shown as optional. Many licensees do not provide retyped technical TSTF-427 specification pages in their license amendment requests. TSTF-476