ML13112A799
| ML13112A799 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/2013 |
| From: | Croft W, Gustafson O, Loeffler R, Slough R Technical Specifications Task Force |
| To: | NRC/SECY |
| SECY/RAS | |
| References | |
| 78FR08050, NRC-2012-0266, PRM-72-7 | |
| Download: ML13112A799 (3) | |
Text
PRM*072*007 (78FR08050)
TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF April 19, 2013 TSTF-13-04 PROJ0753 DOCKETED USNRC Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff April 22, 2013 (9:00 a.m.)
OFFICE OF THE SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF
SUBJECT:
Technical Specifications Task Force (TSTF) Comments on February 5, 2013 Federal Register Notice Petition for Rulemaking, "Spent Fuel Cask Certificate of Compliance Format and Content" Docket ID NRC-2012-0266 The Joint Owners Group Technical Specifications Task Force (TSTF) is pleased to provide the following comments on the subject Petition for Rulemaking. The TSTF is a jointly funded activity of the Pressurized Water Reactor Owners Group (PWROG) and the Boiling Water Reactor Owners' Group (BWROG) that serves as the focal point for industry interaction with the Nuclear Regulatory Commission (NRC) on generic technical, regulatory, and compliance issues related to nuclear power plant Technical Specifications.
The TSTF agrees with and supports the proposed changes described in the Petition for Rulemaking submitted by the Nuclear Energy Institute, and in particular, the addition of specific criteria for the format and content to be included in a spent fuel storage cask Certificate of Compliance (CoC).
On July 22, 1993, the NRC published in the Federal Register their "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39 132). The Policy Statement published four criteria to be used to determine those requirements appropriate for inclusion in the Technical Specifications for operating reactors. This Policy Statement described the conditions which led to this action:
[S]ince 1969, there has been a trend towards including in Technical Specifications not only those requirements derived from the analyses and evaluation included in the safety analysis report but also essentially all other Commission requirements governing the operation of nuclear power reactors. This extensive use of Technical Specifications is due in part to a lack of well-defined criteria (in either the body ofthe rule or in some other regulatory document) for what should be included in Technical Specifications.
This has contributed to the volume of Technical Specifications and to the several-fold increase, since 1969, in the number oflicense amendment applications to effect changes
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TSTF 13-04 April 19, 2013 Page 2 to the Technical Specifications. It has diverted both staff and licensee attention from the more important requirements in these documents to the extent that it has resulted in an adverse but unquantifiableimpact on safety."
The TSTF believes that the situation described in the Policy Statement regarding plant Technical Specifications has occurred with dry cask system Technical Specifications and, as concluded in the Policy Statement, has resulted in an adverse impact on safety. The criteria proposed in the petition are consistent with the criteria published in the Policy Statement and appropriate for a dry cask system.
The TSTF strongly encourages the NRC to adopt the petition and revise the regulations in order to focus the CoC and the contained Technical Specifications on safety significant issues, thereby improving nuclear safety.
Should you have any questions, please do not hesitate to contact us.
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Robert Slough (PWROGIW)
Otto W. Gustafson (PWROG/CE)
Speiser, Herald From:
Brian Mann [brian.mann@excelservices.com]
Sent:
Sunday, April 21, 20136:10 PM To:
RulemakingComments Resource
Subject:
TSTF-13-04 Support for NEI Dry Cask Petition, Docket ID NRC-2012-0266 Attachments:
TSTF-13-04 Support for NEI Dry Cask Petition. pdf Technical Specifications Task Force (TSTF) Comments on February 5, 2013 Federal Register Notice Petition for Rulemaking, "Spent Fuel Cask Certificate ofCompliance Format and Content" Docket ID NRC-2012-0266 Brian D. Mann Vice President of Industry Programs EXCEL Services Corporation Main (301) 984-4400 Direct (240) 880-0490 Mobile (804) 339-7034 E-mail: brianm@excelservices.com www.excelservices.com www.nukapedia.com 1