ML19347E276
| ML19347E276 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/16/1981 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8104240496 | |
| Download: ML19347E276 (2) | |
Text
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,o UNITED STATES
~g NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 CD g
9 April 16, 1981 p
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q-MEMORANDUM FOR:
Thomas E. Murley, Director V
Division of Safety Technology 4
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FROM:
Darrell G. Eisenhut, Director Division of Licensing
SUBJECT:
REVISED CONCEPT OF TECHNICAL SPECIFICATIONS We have reviewed your memorandum of March 10, 1981 on the above subject.
We agree with the concept. Technical Specifications are increasing in volume without apparent bounds. Measures must be taken to control, if not absolutely limit, their size and scope.
l This subject is, in part, an outgrowth of the Trojan spent fuel pool proceeding wherein intervenor (the State of Oregon) asked for Technical Specificaitons governing pool. water chemistry and the staff disagreed.
In the appeal it became increasingly clear, despite a lot of words to the countrary, that we had no standard or criteria governifig when Technical Specifications are necessary.
Establishing such criteria would be of significant benefit in achieving a better focus on the content of Technical Specifications.
In the following paragraphs, we offer our comments. These comments are restricted to the general concept itself, since numerous editorial changes are still being made to the proposed rule. We have also attached the comments received from various reviewers within DL for your information.
1.
More emphasis needs to be placed on.the standard or criteria for Technical Specifications. Whereas key elements of the criteria are mentioned in the explanatory enclosure (1), the rule itself should set forth the standard.
The criteria for Technical Specifications will be largely lost if contained in the Statements of Consideration.
If contained in the rule itself, every requested addition can more easily be tested against the criteria and therefore subject to better control, l
2.
More evaluation needs to be made with respect to the currently perceived benefit of,this change. There is not much flexibility in licensee's proposed rights to make changes to FCPs or FMPs. There is no flexibility at all in design provisions or administrative controls.
If this effort doesn't result in a substantial reduction in both unimportant Technical Specifications and changes to such, it is probably not worth the effort.
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6/oMW W G
Thomas E. Murley 3.
It appears that changes approved by NRC, per the criteria in 50.36(e),
would involve a license amendment. Therefore there is no saving of effort to NRC or licensees in making such changes.
4.
The criteria for allowing changes to FMPs anJ FCPs are too restrictive.
There is very little apparent flexibility to. permit licensees to make changes without approval.
Consider using 50.59 criteria (or similar) or deleting the def9.itions of " decrease in effectiveness".
5.
There doesr't appear to be any benefit in putting desig~n features or some administrative controls in the "FSAR Technical Specifications" since the licensee cannot make changes.to them without our approval'.
6.
The " specific characteristics of the facility", including " amount, kind, and source of special nuclear material required" and place of use must be contained in the Technical Specifications and be part of the license. See Sec. 182 of the Atomic Energy Act.
7.
The proposed rule appears to conflict with 50.59. Changes to 50.59 will be needed to comport with the new rule.
8.
Consider requiring changes to FMPs and FCPs made by licensees to be included in the monthly operating report. This way, resident inspectors and project managers would.be able to stay on top of the new licensee freedom and be alert for possible abuses of the new system.
In summary, we believe that the proposed rule does not, as yet, provide clear standard or criteria for Technical Specifications in a useful form; the Technical Specifications and "FSAR Technical Specifications" appear to retain everything currently required and not provide any sub-stantial benefit. The concept and intent is good, but more work needs to be done.
We would be glad to meet with you to discuss this matter.
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TT5Freli. E senhut, ulre'ctor Division of Licensing
Contact:
C. Trammell (x27070)
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