ML19340C788
| ML19340C788 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/11/1980 |
| From: | Tramm T COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8012170447 | |
| Download: ML19340C788 (3) | |
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Comni:nwealth Edison one Fi t National P!aza. Chicago litenois Address Reply to: Post Oftce Box 767 Chicago. Ulinois 60690 December 11, 1980 Mr. Harold R.
Denton, Director Of fice of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Washington, DC 20555
Subject:
Zion Units 1 and 2 Category "A"
Lessons Learned Technical Specifications NRC Docket Nos. 50-295 ano 50-304 Reference (a):
July 2, 1980 letter from D.
G. Eisennut to All PWR Licensees
Dear M1. Denton:
Reference (a) requestad that Commonwealtn Edison submit proposed Technical Specificat;on changes covering ten TMI-2 Lessons Learned Category "A"
items.
That letter was delyed in the mail and was not received until the end of September.
This is to inform you of our schedule for transmitting the proposed changes.
An alternate schedule is also being proposed for your approval.
Schedule Unless the NRC approves the alternate schedule discussed below, proposed changes to the Zion Technical Specification will be submitted by February 1, 1981.
This represents an extension of approximately sixty days to the sixty day schedule originally set by the NRC.
An extension is necessary because of the depth of review i
required and the assignment of manpower to projects of higher safety I
significance.
This extension has no impact uoan reactor safety because all of the requested items are covered by or will soon be covered by plant procedures.
Aoherence to procedures is required and is enforced oy the NRC's Directorate of Inspection and Enforcement.
l Alternate Schedule l
l Recent actions taken on behalf of the Nuclear Regulatory i
Commission indicate that the requested Technical Specification Changes cover items wnich may be inappropriate for inclusion in an l
Operating License.
00/
s O
i 801217 0 W f
a Mr. Harold R. Denton, Director December 2, 1980 Page 2 The Atomic Safety and Licensing Appeal Board found recently in tne matter of Zion's Spent Fuel Storage Pool Modification (ALAB-616) that:
"What matters should and should not be made ' technical specifications' is not entirely free from dauot."
i I
Previously, the Apoea. Board ruled in the Trojan spent fuel pool l
case (ALAB-531) that:
"there is neither a statutory nor a regulatory requirement tnat every coerational detail set forth in an applicant's safety analysis remert (or equivalent) be subject to a tecnnical specification, to be incluoed in the license as a absolute conaition of operation whien is legally oinding upon the licensee unless anc until cnanged with specific Commision approval.
Rather, as best we can discern it, tne contemplation of both the Act and tne regulations is that technical specifications are to be reserved for those matters to which the imposition of rigid conditions or limitations uuon reactor operation is deemed necessary to obviate thelgossibility of an abnormal situation or event giving risr. to an immeciate tnreat to tne Duolic nealtn and safety."
(Empnasis accec; footnote omittec.)
Tne Commission itself nas recently puolisnea notice (45 FR 45916) that it is considering establishing a new standard for cetermining which safety requirements must be reflected in technical 30ecifications and whicn should oe placed in otner categories.
In its notice, the Commission expressed concern that:
"the increased volume of technical specifications may be decreasing the effectiveness of these specifications to focus the attention of licensees on matters of more immediate importance of safe operation of the facility.
While each of the rer;ultenents in today's technical specifications plays a rel3 in protecting public health and safety, some requirements have greater immediate importance than others in that they relate more directly to facility operation.
These are the requirements that pertain to items which the facility operator must be aware of and which he must control to operate the facility in a safe manner.
To a large extent, the relative importance of these requirements, as distinguished from those related to long' term effects or concerns, has oeen diminished by the increase in the total volume of technical specification requirements.
=-
i Mr. Harola R. Denton, Director Decemoer 3, 1980 Page 3 Moreover, the increased volume and detail of technical specifications ano the resultant increase in the numDer of proposed change requests that must be processed, has increased the paperwork ourden for both licensees and the NRC staff.
This is because 50.36 requires that technical s?ccifications be included in each_ operating license; and thus, any proposed change, regardless of its importance to i
safety, must be processed as a license amendment.
For changes involving matters of lesser importance to safety, tne processing of a license amenoment with the associateu
{
increased paperwork has had no significant benefit with j
regard to protecting the public health and safety."
The proposed Tecnnical Specification changes'which were requested in reference (a) are, for Zion, about a third of the total tabulated in the NRC's November, 1980, " Clarification of TMI Action I
Plan Requirements," (NUREG-0737).
Generally, these are matters not of "immediate importance to the safe operation of the f acility" and i
thcrefore should not be incorporateo into coerating licenses.
1 We propose postponing further action on TMI-related Technical Specification changes until the NRC has had time to act upon their rulemaking proposal.
We anticipate that this would be a delay of three to twelve months.
As discussed earlier, there would be no effect upon reactor safety in the interim because most of these items are or will be covered in plant procedures.
i Please indicate if you concur with this alternate approach.
We would be happy to meet with your staff to discuss the matter further.
Please aadress questions to my office.
Very truly yours, i
fAL s_
i T.
R.
Tramm Nuclear Licensing Administrator
[
Pressurized Water Reactors cc:
Zion Resident Inspector-i 8557A l
1
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