ML14198A269
| ML14198A269 | |
| Person / Time | |
|---|---|
| Issue date: | 07/15/2014 |
| From: | Mann B Technical Specifications Task Force |
| To: | Division of Administrative Services |
| References | |
| 79FR32580 00001, NRC-2014-0131 | |
| Download: ML14198A269 (1) | |
Text
Page 1 of 1 PUBLIC SUBMISSION Docket: NRC-2014-0131 Open Phase Conditions in Electric Power System 7014~ J'JL 16A I 58 As of: July 16, 2014 Received: July 15, 2014 Status: PendingPost Tracking No. ljy-8d8j-ynet Comments Due: July 21, 2014 Submission Type: Web Comment On: NRC-2014-0131-0001 Open Phase Conditions in Electric Power System; Electric Power - Introduction 4
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Document: NRC-2014-013 1-DRAFT-0003 Comment on FR Doc # 2014-13061 Submitter Information Name: Brian Mann Submitter's Representative: Brian D. Mann Organization: Technical Specifications Task Force General Comment Section VI, "Surveillances and Limiting Conditions for Operation," states, "The technical specifications should include requirements in accordance with 10 CFR 50.36(c)(2) and (c)(3) for limiting conditions for operations, surveillance requirements, trip setpoints, alarm set points, and maximum and minimum allowable values for the open phase conditions relays and associated time delay devices." This section is overly specific and is not the preferred method by which the NRC identifies Technical Specifications requirements.
The section is overly specific in many ways. It has not been established whether addressing the Open Phase issue will fall under 10 CFR 50.36(c)(2) or (c)(3), or whether paragraph (c)(4) may be applicable. 10 CFR 50.36(c) does not describe Surveillances. It's not been established whether new limiting conditions for operation are needed. Further, alarm setpoints are not typically included in Technical Specifications. The current Standard Technical Specifications (NUREGs 1430-1434) typically include either setpoints or allowable values, but not both.
Technical Specifications requirements are not typically established in Branch Technical Positions. Since 1993, the industry Technical Specifications Task Force (TSTF) and the NRC have cooperated in developing generic Technical Specifications to address a wide range of regulatory requirements. The TSTF will work with the NRC to develop a Technical Specifications Traveler applicable to all operating plant types to incorporate any new or revised requirements needed to satisfy the requirements of 10 CFR 50.36, "Technical Specifications." This Traveler will be incorporated into the Standard Technical Specifications, and its availability will be noticed in the Federal Register for use by licensees. We recommend that issues related to Technical Specifications needed to address the Open Phase Condition be addressed in that well-proven process.
To resolve these problems, we recon-rnend that Section VI of the document be revised to state, "The technical specifications should include necessary requirements to meet 10 CFR 50.36 in a manner consistent with the Standard Technical Specifications (NUREG-1430 through NUREG-1434)."
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07/16/2014