ML14182A285
| ML14182A285 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/16/2014 |
| From: | Marc-Anthony Murray South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-14003145, STI: 33886126 | |
| Download: ML14182A285 (3) | |
Text
Nuclear Operating Company South Texas Pro/ect Electric GeneratinS Station P. Box 289 Wadsworth. Texas 77483 v
June 16, 2014 NOC-AE-14003145 10 CFR 50 Attention: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units I and 2 Comments to the Draft NRC Regulatory Issue Summary 2014-XX "Tornado Missile Protection" (ML13094A421)
STP Nuclear Operating Company (STPNOC) is providing comments on the draft NRC Regulatory Issue Summary (RIS) 2014-XX, "Tornado Missile Protection" (ML13094A421) published in the Federal Register April 4, 2014 (79 FR 18933) and Federal Register May 8, 2014 (79 FR 26464).
- 1. STPNOC comment/recommendation:
Related to the "STAFF POSITIONS" listed on page 2 of the draft RIS which states:
"Staff reviews and inspections of tornado missile protection are based on applicable regulations and the requirements contained in the current licensing bases documents, typically the Updated Final Safety Analysis Report (UFSAR) or for a combined license referencing a standard design certification, the Final Safety Evaluation Report and referenced design control document. When evaluating for conformance with the licensing basis for tornado missile protection, in the absence of specific descriptions of protective features for tornado missile protection, including procedures and repairs, contained in the licensing basis documents, the staff relies on NRC regulations and guidance provided in regulatory guides and the standard review plans to interpret any generalities in a plant's licensing basis."
Comment/recommendation:
- The level of detail is excessive in terms of what is required to be in the plant UFSAR (i.e., specific descriptions of protective features for tornado missile protection, including procedures and repairs.).
STPNOC is in alignment with the industry comments on the STAFF POSITION listed on page 2 of the draft RIS and recommend the following proposed revision:
"Staff reviews and inspections of tornado missile protection are based on applicable regulations and the requirements contained in the current licensing bases documents, typically the Updated Final Safety Analysis Report (UFSAR) or for a combined license referencing a standard design certification, the Final Safety Evaluation Report and referenced design control document. When evaluating for conformance with the licensing basis for tornado missile protection, in the absence of speGifiG descriptions of protective features for tornado missile protection, including prcGduro,"
aRd ropairc, contained in the licensing basis documents, the staff re`ies reviews eG NRC regulations STI: 33886126Aoo)
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NOC-AE-14003145 Page 2 of 3 referenced design control document. When evaluating for conformance with the licensing basis for tornado missile protection, in the absence of speefifio descriptions of protective features for tornado missile protection, including procedures and repairs, contained in the licensing basis documents, the staff relies reviews eo NRC regulations and guidance provided in regulatory guides and the standard review plans, apDropriate to the plant's age and licensing basis, to infer the intent of i;nter*pet any generalitie. in a plant's licensing basis. "
- 2. STPNOC concurs with the industry on the following comments and recommendations:
o The draft RIS is attempting to re-open the licensing basis for pre-General Design Criteria (GDC) plants. Licensing basis descriptions for events were not as clear for pre-GDC plants. These issues were resolved in the SEP in the Systematic Evaluation Program (SEP) and Individual Plant Examination of External Events (IPEEE). Gaps were carefully reviewed and closed during the SEP/IPEEE process, instead of through specific licensing actions. The SEP and IPEEE were included in plants' licensing basis.
The draft RIS should be withdrawn or revised. As is, it constitutes a backfit, since it re-defines the licensing basis established by the SEP and IPEEE. The RIS is also not consistent with intent of cumulative impact efforts. This is a low-risk issue and will only serve to divert licensee and NRC efforts from more important matters.
Industry mentioned that the draft RIS states, if licensing basis in unclear, NRC will apply the current guidance. This is another reason that the draft RIS is potentially a backfit.
The draft RIS does not make any distinction between pre-GDC plants and post-GDC plants. This will lead to significant resources being applied to review the current design.
Industry requested that NRC consider issuing inspection guidance concurrently with the RIS in order to allow licensees to better evaluate the issues. The RIS does not provide adequate detail.
Industry asked if this initiative would be considered in light of the current industry and NRC cumulative effects initiatives to prioritize regulatory actions based on risk. Given the low risk of this issue, the priority assigned would be very low. Industry encouraged NRC to look at the bounding risk of this issue and re-consider the potential impact of actions in light of this risk.
There are no commitments in this letter.
If there are any questions regarding this response, please contact Hung C. Le at (361) 972-7932 or me at (361) 972-8164.
Michael P. Murray Manager Regulatory Affairs STI: 33886126
NOC-AE-14003145 Page 3 of 3 cc:
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Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 8 B1) 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 A. H. Gutterman, Esquire Morgan, Lewis & Bockius LLP Balwant K. Singal U. S. Nuclear Regulatory Commission John Ragan Chris O'Hara Jim von Suskil NRG South Texas LP Kevin Polio Cris Eugster L. D. Blaylock CPS Energy Peter Nemeth Crain Caton & James, P.C.
C. Mele John Wester City of Austin Richard A. Ratliff Texas Department of State Health Services Robert Free Texas Department of State Health Services Richard A. Ratliff Texas Department of State Health Services Robert Free Texas Department of State Health Services STI: 33886126