ML19347C179
| ML19347C179 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/08/1980 |
| From: | Jacobi L HOUSTON LIGHTING & POWER CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-45FR45916, RULE-PR-50 45FR45916-9, ST-HL-AE-528, NUDOCS 8010160767 | |
| Download: ML19347C179 (8) | |
Text
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The Light Company n-i.,ii umiiiim,m m n,,e nei<>>>.rma aumsmn September 8,1980 O
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ST-HL-AE-528 WAE h3."il(t/ffgVS9;g l
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'N,'N Mr. Samuel J. Chilk
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Secretary of the Commission t ,\\
Nuclear Regulatory Commission Washincton, D. C. 20555 p
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Dear Mr. Chilk:
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Docket Nos. STN 50-498, STN 50-499 Comments on Advance Notice of Proposed Rulemaking Concerning Technical Specifications As procided in the Federal Register, Vol. 45, No.132, Tuesday, July 8, l
1980, Proposed Rules, Houston Lighting & Power Company is hereby providing comments on the proposed changes to regulations,10CFR50.36 and 10CFR50.59., comprised of a comoosite of responses generated by the Mestinghouse Cwners Group and Houston Lighting & Power Company, represents the comolete responses by Houston Lighting & Power Company on the proposed rulemaking.
It is requested these comments be carefully examined and considered prior to making any changes to the subject regulations.
If there are any questions, please contact Mr. M. E. Powell at (713) 676-8592 Very truly yours,
L. R. Jacobi Supervising Engineer TAP /pib Attachment t}0 m n % c w = c... /./..t.?....C @
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3010160767
Ihst Lighting & lwer Company September 8,1980 ST-HL-AE-528 SFN: V-3000 Page 2 cc:
M. D. Schwarz (Baker & Botts)
R. Gordon Gooch (Baker & Botts)
J. R. Newman (Lowenstein, Newman, Reis, Axelrad & Toll)
D. G. Barker B. F. Duncan R. I. Moles R.
Sells (NRC)
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J ATTACHMENT 1 4
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Comments on Proposed Rulemaking on Technical Specifications i
i General Comments:
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1.
Before any changes are made to the regulations, the concept of "immediate importance to safety" must be clearly defined.
Items of a " lesser importance to safety" should not be construed to now require non-safety-related components
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be included in " Technical Specifications" type surveillance programs.
If it is i
intended items of a " lesser importance to safety" be defined as items having no j
safety significance, then they should be completely eliminated from technical specifications.
As indicated in the Federal Register, it is important to reduce the complexity of technical specifications (by focusing more directly on reactor J
operations and providing greater flexibility in processing changes) in order to
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provide additional assurance the protection of the health and safety of the public is maintained.
If changes to the regulations concerning technical specifications are made that are intended to impose additional requirements on utilities, this would be defeating the purpose of the proposed rulemaking.
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t-d Specific Comments:
A) 1.
Would it be appropriate to establish a fixed standard for deciding which items derived from the safety analysis report must be incorporated into the technical specifications?
2.
If so, what should the standard be based on?
j 3.
Would a standard incorporating the concept of "imediate importance to safety" be appropriate?
j Yes. The standard should be based on the concept of imediate importance to safety. Specifically, the standard should be based on the preservation t
of the assumptions of the safety analysis portions of the safety analysis report. The operating conditions to which technical specifications apply shall 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, 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 1
7, 8 and 12 l
1
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B) 4.
Would it be appropriate to modify 50.36 to require technical specifi-cations to focus more directly on reactor operation?
Yes, it would b'e appropriate to modify 50.36 to require technical specifi-cations to focus more directly on rentor operation.
It should be recog-nized that other portions of 10CFR30 (e.g., 50.46, Appendices G H and J) i require the inclusion of non-operational items in the technical specifica-tions and would also need modification to incorporate this concept.
It is recomended 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 appropriate subjects for technical specifications?
6.
Should the current scope of surveillance requirements be reduced?
7.
If so, would it b.e appropriate to change the scope to include only those requirements related to assuring that safety limits and limiting con-ditions for operation are being met and not t, include other requirements?
No, the existing practice of including most applicable surveil-lance requirements in the technical specifications is not consistent with the concept of imediate importance to safety nor is it consistent with -
requiring technical specifications to focus more directly on reactor opera-tion surveillance requirements that relate directly to preservation of assumptions of the safety analysis may be appropriate for inclusion in the
C)
(Continued) technical specifications provided that surveillance is restricted to simple P
Surveillance require-checks of necessary equipment and parametric ifmits.
ments which go beyond the concept of simple checks (e.g., detailed periodic
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s pump and valve testing, flux mappina, etc.) are appropriate candidates f inclusion in a separate section within technical specifications.
- 8. Would it be appropriate to define a new category of requirements separate from technical specifications that would have a different D) level of importance to safety?
- 9. What types of requirements currently included in technical specifica-tions would be appropriately included in the new category?
- 10. Should the new category of requirements be physically attached to the license or included in a separate document; for. example, the FSAR?
l Removal of items from the current technical specifications could be i
Yes.
accomolished in the following manner:
The Design Features section should be omitted since the same infonnation is presently included in the Final Safety a.
Analysis Report (FSAR).
l Administrative Controls should be included in the FSAR in those sections which already pertain to administration or b.
incorporated into administrative or quality assuranceA possi procedures.on minimum staffing requirements into the document describe in c. below, Items of a lesser importance to safety than as identified in A) above which now accear in the technical specifications as.
c.
limiting conditions for operation or survsillance requirenents should be placed in a separate section within technical specifi-l cations, but with more excedient review and change procedures l
Examples of items that fall into this than currently exist.
category are:
j Ventilation Fire Protection Flood Protection Snubbers Boration Systems Refueling Spectifications Inservice Inspection and Testing Programs Radioactive Waste Treatment Systems Radiological Effluent Specifications
l-l E) 11. How should the enforceability of the requirements that are moved into j
the new category be maintained?
Enforceability of these requirements is not deemed to be different from the j
enforceability of existing technical specification or FSAR requirements.
Because the items are of a lesser impo canc.e to safety, reporting requirements
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and requirements on remedial action cimes should be reduced.
i 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 established to assure that such changes would not adversely effect safety?
l Yes.
It would be appropriate for licensees to make changes to this.
category without prior NRC approval. A review process as set forth in 10CFR50.59 would be appropriate and would assure such changes would not i
adversely affect safety.
i G) 14. What specific changes to the regulations should be included in i
response to the preceding questions?
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Specific changes to the regulations in response to the preceding questions j
are:
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a.
50.36(b): Revise this paragraph as shown below.
"Each license authorizing operation of a production or'utili-zation facility of a type described in 50.21 or 50.22 will include technical specifications. Technkal specifications 4
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 ininediate threat to the health and safety of the public. The Technical Specifications will be derived from the analyses and evaluation included in the safety analysis report and amendments thereto, submitted pursuant to i
50.34."
b.
50.36(c)(3), " Surveillance requirements": Revise to read as shown below.
" Surveillance requirements are requirements relating to periodic checks and tests to assure that facility operation will be within the safety limits, and that the limiting conditions for operation will be met."
c.
Delete 10CFR50.36 paragraphs (c)(4) and (5).
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- 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?
b) Operating licensees?
c) The NRC7 d) The public?
Advantaces a.
Technical specifications will be more relevant to actual operation.
The operator will be able to place more emphasis on maintaining those parameters and equipment that are of immediate importance to safety thereby enhancing safe plant operation.
b.
Negotiations between the NRC and the licensee will be minimized.
c.
Reportina requirements will be reduced by focusing more attention on those items of immediate importance to safety.
d.
The number of change requests for technical specifications directed to the NRC will be greatly reduced thereby permitting more effec-tive use of staff personnel on matters of more importance to safety.
e.
Plant availability will be enhanced by allowing implementation of changes and by applying remedial actions which are consistent with the particular items important to safety.
f.
If properly implemented technical specification content will become more defined and less susceptible to constant change and varied interpretation.
g.
Licensee will have one concise document, technical specifications, containing all requirements for plant operation that are important to safety.
Disadvantages h.
Elements of the public could mistakenly perceive these proposed changes as a reduction of regulation of licensees with a subse-quent decrease in emphasis in safety.
i.
The restructuring of existing plant documents to comply with 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.
j.
A second document containing those items of less importance to safety could lead to less uniform application of enforceability to individual facilities.
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We believe that implementation of the proposed changes in technical specification content and format described in response to the NRC questions as set forth above can best be accomplished in the near term by simply segregating those existing technical specification items which have immediate importance to safety based upon SAR assumptions from those existing technical specification items of lesser safety significance.
This simple split of existing technical specifications would identify the items to be contained in the proposed technical specification format while the remaining items would be retained as a separate section within technical specifications. This proposed method of dividing existing technical specifications will minimize the review impact on applicants, licensees and the NRC and will preserve the existing safety posture of licensed facilities.
In the longer term, we recommend that industry and the NRC cooperate in the development of criteria for technical specifications and any other necessary documents in which specifications of a lesser importance to safety would be set forth.
It is recommended that the revision to 10CFR50.36 that implements this program address applicability of the regulation to CP, NT0L and operating.
plants in a fashion similar to that of the existing regulation.
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