ML19326B822
| ML19326B822 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/27/1974 |
| From: | Pettitt A ARKANSAS POWER & LIGHT CO. |
| To: | Anthony Giambusso US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML19326B817 | List: |
| References | |
| RTR-REGGD-01.016, RTR-REGGD-1.016 12159, NUDOCS 8004180569 | |
| Download: ML19326B822 (5) | |
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AEC DISTR!CUTIO*J FOR PART 50 DOCKET f.1ATERI AL
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CONTROL NO: 12159 FILE:
FROM: Arkansas Power & Light Co, DATE OF DOC ' DATE REC'D LTR TV!X RPT OTHER Little f(ock, Ark. 72203 Arch. T_,._fettit 11-27-74 12-2-Th-X TO:
ORIG CC OTHER SENT AEC PDR YX Mr. A. Giambusso 1 signed 39 SENT LOCAL PDR XX CLASS UNCLASS PROPINFO INPUT NO CYS REC'D DOCKET NO:
40 50-313 XXX DESCRIPTION:
Ltr re our 10-15-74 ltr...
ENCLOSURES:
Specific Comments on Reg.
furnishing comments on change to Tech Specs -
Guide 1.16, Rev. 2, ' 9/74.....
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'ety gg n e t ss t N G BUILO ARKANSAS ARK ANS AS POWER & LIGHT PANY 97H G LoutSIANA STAEers. Larr AS 72203. (5013 372-4311 Novembe
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SUBJECT:
ARKANSAS POWER 6 LIGHT COMPANY I
ARKANSAS NUCLEAR ONE - UNIT 1 DOCKET NO. 50-313 93 C
LICENSE NO. DPR-51 STANDARD TECHNICAL SPECIFICATIONS
Dear Mr. Giambusso:
Mr. Dennis L. Ziemann's letter of October 15, 1974, transmitted a copy of the standard Technical Specifications, Section 6, Administrative Controls, and requested that we submit by December 1, 1974, a proposed change to our Technical Specifications to incorporate the standard.
A review of our Technical Specifications indicates that the only major difference from the standard is in the reporting requirements.
The standard Technical Specifications reference Regulatory Guide 1.16, Revision 2, " Reporting of Operating Information - Appendix A Technical Specifications" which was issued on September 30, 1974. Our review of that Regulatory Guide and discussions held on November 4,1974, in Atlanta, Georgia, with representatives of the AEC staff and other Region II utilities indicate that the guide is in need of significant revisions before it is implemented.
Pursuant to Lester Rogers' letter of transmittal of September 30, 1974, we have submitted our comments on the guide. A copy of my comments are attached.
Our meeting with the AEC indicated that there would be substantial and significant comments filed on Regulatory Guide 1.16, Revision 2, and more than likely this will lead to substantial changes in it.
When this fact is taken along with the fact that the standard Technical Specifications differ significantly only with regard to reporting from ANO-l's proposed Technical Specifications, we feel that we should be allowed to wait and amend our Technical Specifications in accordance with the final Regulatory Guide.
We will continue to follow the develop-ments of Regulatory Guide 1.16 and will submit proposed changes in the Technical Specifications as soon as possible after they are issued in final form.
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Mr. A. Giambusso November 27, 1974 1
We certainly appreciate your cooperation in this matter.
Very truly yours, Arch P. Pettit Senior Vice President APP:DR:me Attachment I
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O Regu W SPECIFIC CGt!ENTS J
REGULATORY GUIDE 1.16, REV. 2, 9/74 ll_Q7'7Y g_
L ne following specific comments are referenced to paragraphs of Regulatory Guide 1.16, Revision 2, September 1974, to fa,cilitate review:
1.
Paragraph C.I.a - Ec statement that the startup report "should address each of the tests conducted" is too broad and vague.
Tne scope of this report should be limited to those tests done to prove core performance, nuclear safety, etc., and those done tu demonstrate specific license requirements.
2.
Paragraph C.I.b Sub-paragraphs (1) and (2) are an annual duplication of the information presented in the Monthly Operating Reports and Abnormal Occurrence Reports and could be eliminated from the Annual Report.
He requirement of sub-paragraph (2) to report forced 5%
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reductions in power should be made consistent with the Monthly Operating Report requirement to report 20% reductions in power and should refer specifically to percentage of rated net electrical generation.
3.
Paragraph C.1.b(3) - Tabulation of personnel exposures according to duty function would place an excessive paperwork and badge / dosimeter processing on plant health physics personnel.
It would be more appropriate to tabulate exposures by job classification, e.g.,
operators, maintenance personnel, etc.
4.
Paragraph C.I.b(4)(d) - This section imposes an excessive new sampling requirement and should be limited to apply only to t_ hose times when a specific percent fuel failure is present (e.g., 0.1%).
5.
Paragraph C.1.b(4)(e) - Re term " failed fuel" should be changed to
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" irradiated fuel".
i 6.
Paragraph C.I.b - Haterial operating report on changes, previously required in the semi-annual
, tests, and experiments and F3AR changes l
should be included in the annual report to meet the requirements of 10CFR59 and to keep the FSAR as a living, meaningful and useful document.
7.
Paragraph C.2.a(5) - Re reporting requirements of this section should be made less restrictive to coincide more closely with present Technical Specification reports following unanticipated reactivity changes of more than 1% 4K/K.
8.
Paragraph C.2.b - R e report date for B irty Day Written Reports should I
be changed to thirty days after the event to avoid short length l
report periods for events that occur near the end of a month.
9.
Paragraph C.2.b(2) - Reporting of all conditions Itading to operation between the most conservative and least conservative aspects of a t
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~.u limiting condition for operation would require reporting maintenance on all safety related equipment as well as outages of, equipment within Technical Specification limits.
This require' ment should be changed to require reporting only forced degradation of safety systems in excess of outage times defined by Technical Specifications.
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10.
Paragraph C.2.c - This section should not be included with the Abnormal Occurrences as these events cannot be considered as affecting the, safety of the plant.
Perhaps it would be more appropriate to make a new tection for these items called " Items of Public Interest".
11.
Paragraph C;2.c(1) - Reports of property damage to the plant in excess of $10,000 with today's high prices is unrealistic.
It would be more appropriate to change this figure to $100,000.
12.
Paragraph C.2.c(4) - In most cases of transport of radioactive material to or from nuclear power plants, the nuclear pbwer plant has no responsibility since such materials are turned over to the shipper when they are offsite.
This. reporting requirement should thus rest on the shipper, not the nuclear power plant.
13.
Paragraph C.2.c(5) - Reporting' of unscheduled shutdowns in excess of one week is already covered by C.1.c, Monthly Operating Reports.
14.
Appendix D - Items 12,13, and 14 should not include time required for refueling outages in determining the hours in the reporting period.
It is general knowledge that every nuclear plant is shut down each year for refueling while fossil plants are not, thus, including refueling outages in the calculation of availability and capacity factors for nuclear power plants makes these' factors inappropriate for comparison to fossil plants.
- 15. Appendix D, Item 12 - Including only hours the reactor was critical in calculation of a reactor availability factor is inappropriate as there are many times when the reactor is available, but shut down due to balar. e of plant problems.
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