ML19347C002
| ML19347C002 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Callaway  |
| Issue date: | 09/09/1980 |
| From: | Petrick N STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-45FR45916, RULE-PR-50 45FR45916-17, SLNRC-80-43, NUDOCS 8010160410 | |
| Download: ML19347C002 (6) | |
Text
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$ Q"yf3,'k Nicholas A. Pstrick s cha.ca.rry no.4 A
Rockvdie, Maryland 20050
//j Executive Director 001)8684010 0
s September 9, 1980 SLNRC 80-43 FILE:
0543.1 SUBJ:
Coments on Advanced Notice of Proposec Rulemaking Secretary of the Comission U. S. Nuclear Regula*ary Comission Washington, D. C. 20555 Attention:
Occketing and Service Branch Docket U s: STN 50-482, STN 50-483, STN 50-486
Dear Sir:
The Federal Register of July 8,1980 published an advanced notice of proposed changes to NRC regulations pertaining to technical specifications for nuclear power reactors.
The notice requested written coments on the changes.
The enclosure to this letter provides coments on behalf of the SNUPPS Utilities, Kansas Gas and Electric Company and Union Electric Company.
Very truly yours, CM Mt
{ icholas A. Petrick N
RLS/mtk Enclosure cc:
J. K. Bryan UE g4
,I i G. L. Koester KGE f
D. T. McPhee KCPL Y)
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8 010160 Q\\D
i Comments on Advanced Notice of procosed Rulemaking:
Technical Soecifications 1
A) 1.
Would it be appropriate to establish a fixed standard for deciding which items derived from the safety analysis report must be incor-porated into the technical specifications?
2.
If so, what should the standard be based on?
3.
Would a standard incorporating the concept of "immediate importance to safety" be appropriate?
Yes, it would be appropriate to establish a fixed standard for deciding 1
which items should be incorporated into the technical specifications.
The standard should be based on the concept of immediate imcortance to safety.
Specifically, the standard should be based on the preser-vation of the assumptions of the safety analysis portions of the safety analysis report.
The operating conditions to which technical specifica-1 tions apply should be limited to those conditions of immediate importance to safety for which equipment must be operable or for which parametric limits exist due to assumptions of the safety analysis.
In general, j
the criteria set forth in ANS 58.4, " Criteria for Technical Specifications for Nuclear power Stations", section 4.1 is acceptable with particular emphasis on subsections 7, 8 and 12.
4 B) 4.
Would it be appropriate to modify 50.36 to require technical specifi-l cations to focus more directly on reactor operation?
Yes, it would be appropriate to modify 50.36 to require technical specifi-cations to focus more directly on reactor operation.
It should be recog-nized that other portions of 10CFR50 (e.g., 50.46, Appendices G, H and J) require the inclusion of non-operational items in the technical specifica-tions and would need modification to incorporate this concept.
It is recommended that all regulatory requirements pertaining to technical speci-fication control be incorporated into one regulation.
C) 5.
Are surveillance requirements as currently defined in 50.36 apprcpriate subjects for technical specifications?
6.
Should the current scope of surveillance requirements to reduced?
7.
If so, would it be appropriate to change the scope to include only those requirements related to assuring that safety limits and limiting conditions for operation are being met and not to include other re-quirements?
l
^
1 Enclosure to SLNRC 80-43 Fage Two a
l No, the existing practice of including most applicable surveillance requirements in the technical specifications is not consistent with the concept of immediate importance to safety nor is it consistent with requiring technical specifications to focus more directly on reactor operation.
Surveillance requirements that relate directly to preservation of assumptions of the safety analysis may be appropriate for inclusion in the technical specifications providec that surveil-lance is restricted to simple checks of necessary equipment and parametric limits. Surveillance requirements which go beyond the concept of simple checks (e.g., detailed periodic pump and valve testing, flux mapping, etc.) are appropriate candidates for inclusion in a separate i
document or an overall surveillance program.
D) 8.
Would it be appropriate to define a new category of requirements separate from technical specifications that would have a different level of importance to safety?
f 9.
What types of requirements currently included in technical specifi-cations would be appropriately included in the new categcry?
- 10. Should the new category of requirements be physically attached to l
the license or included in a separate document; for example, the l
FSAR?
l Yes.
Removal of items frem the current technical specifications could be accomplished in the following manner:
a.
The Design Basis section saould be omitted since the same information is presently included in the Final Safety Analysis Report (FSAR).
b.
Administrative Controls should be included in the FSAR in j
those sections which already pertain to administration, or incorporated into administrative or quality assurance i
procedures. A possible exception would be the inclusion of minimum staffing requirements into the document described in c. below.
I c.
Items of a lesser importance to safety than as identified in A) above, which now appear in the technical specifications as
- limiting conditions for operation or surveillance requirements, should be placed in a new document that could exist as either i
a chapter in the FSAR, as a separate document for which new
]
review and change procedures would have to be developed, or as an appendix to the license but with more expedient review and i
change procedures than currently exist.
Examples of items that fall into this category are:
4 Ventilation Refueling Specifications l
Fire Protection Inservice Inspecti on and Flood Protection Testing Programs Snubbers Radioactive Waste Treat-Boration Systems ment Systems Radiological Effluent Speci-fications i
Enclosure to SLNRC 80-43 Page Three j
E) 11. How should the enforceability of the requirements that are moved into i
the new category be maintained?
Enforceability of these requirements is not deemed to be different from the enforceability of existing technical specification or FSAR requirements.
)
Because the items are of a lesser importance to safety, modification of existing reporting requirements and remedial action times are appropriate.
l 1
F) 12. Would it be appropriate to allow licensees to make certain changes to the requirements in the new category without prior NRC approval?
i 13.
If so, what conditions should be sstablished to assure that such changes would not adversely effect safety?
Yes.
It would be appropriate for licensees to make changes to this new document without prior NRC approval. A review process as set forth in 10CFR50.59 would be appropriate and would assure such changes would not adversely affect safety.
1 G) 14. What specific changes to the regulations should be included in response to the preceding questions?
l Specific changes to the regulations in response to the preceding questions are:
j a.
50.36(b): Revise this paragraph as shown below.
"Each license authorizing operation of a production or utili-1 zation facility of a type described in 50.21 or 50.22 will include technical specifications. Technical specifications t
for nuclear reactors will be those limitations and conditions imposed upon facility operation that are necessary to provide reasonable assurance that an anticipated operational occurrence will not give rise to an innediate threat to the health and safety of the public. The Technidhl 5pecificitions will be derived from the analyses and evaluation included in the safety analysis report and amendments thereto, submitted pursuant *w 50.34."
b.
50.36(c)(3), " Surveillance requirements": Revise to read as i
shown below.
" Surveillance requirements are requirements relating to periodic 4
checks and tests to assure that facility operation will be within the safety limits, and that the limiting conditions for i
operation will be met."
Delete 10CFR50.36 paragraphs (c)(4) and (5).
c.
r' 1
J 64
- 3
j I
l Enclosure to SLNRC 80-43 l
Page Four l
l l
H)
- 15. What advantages and disadvantages could be expected from the system of requirements derived from the answers to the preceding questions for:
a) License applicants?
l b)Operatinglicensees?
c) The NRC?
d) The public?
Advantaces l
a.
Technical specifications will be more relevant to actual opera-tion.
The operator will be able to place more emphasis on maintaining those parameters and equipment that are of imediate importance to safety thereby enhancing safe plant operation.
b.
Reporting requirements will be reduced.
c.
The number of change requests for technical specifications directed to the NRC will be greatly reduced thereby pennitting more effective use of staff personnel on matters of more im-portance to safety.
d.
Plant availability will be enhanced by allowing implementation of changes and by applying remedial actions which are consis-tent witn importance to safety, e.
If properly implemented, technical specification content will become more defined and less susceptible to constant change and varied interpretation.
Disadvantaces f.
Elements of the public could mistakenly perceive these pro-posed changes as a reduction of regulation of licensees with resultant decrease in emphasis on safety, i
g.
The restructuring of existing plant documents to comply with l
the new rulemaking will be costly in both time and material and would not be cost effective if the rulemaking falls short of the expressed goals, h.
A second document containing those items of less importance to safety could lead to less uniform application of enforceability to individual facilities.
We believe that implementation of the procosed changes in technical specifica-tion content and format described in response to the NRC questions, as set forth above, can best be accomplished in the near term by simoly segregating those existing technical specification items which have imediate importance to safety from those existing technical specifications items of lesser safety i
significance.
This simple split of existing technical specifications would
Enclosure to SLNRC 80-43 Page Five identify the items to be contained in the proposed technical specification format, while the remaining items would be retained in the FSAR or other appropriate documents.
This proposed method of dividing existing technical specifications will minimize the review impact on applicants, licensaes, and the NRC, and will preserve the existing safety posture of licensed facilities.
In the longer term, it is recommended that industry and the NRC cooperate in the development of criteria for technical specifications and the other documents in which specifications of a lesser importance to safety would be set forth.
1