ML20036A499
| ML20036A499 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/03/1993 |
| From: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| To: | Meyer D NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-58FR17293 58FR17293, NUDOCS 9305110348 | |
| Download: ML20036A499 (2) | |
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S tFClh 93 lhJ May 3, 1993 FYC 93-011 SPS93-041 Mr. David L. Meyer Chief, Rules and Directives Review Branch U.S.
Nuclear Regulatory Commission Washington, DC 20555
Subject:
Proposed Generic Communication; Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans (58FR17293)
Dear Mr. Meyer:
Yankee Atomic Electric Company (YAEC) appreciates the opportunity to comment on the subject draft Generic Letter.
YAEC is owner of the Yankee Nuclear Power Station in
- Rowe, Massachusetts.
YAEC's Nuclear Services Division also provides engineering and licensing services to other nuclear power plants in New England.
We support the intent of the proposed Generic Letter. Removal of requirements from Tr.chnical Specifications that also reside in the regulations for emergency planning or security is a worthwhile simplifying step.
Elimination of this unnecessary duplication is similar in context to the other simplifying changes to Technical Specifications that are currently under consideration specifically:
"The Relocation of Technical Specification Tables on Instrument Responce Time Limits".(58FR18118) and "Line-Item Technical Specification Improvements to Reduce Testing During Power Operations" (58FR16881).
The disconcerting aspect of the subject proposed Generic Letter is that the entire burden to seek these changes and to support reviews remains with the licensee.
All of the proposed generic letters are flawed in this regard.
Each licensee must formally request a Technical Specification amendment to obtain these changes.
Admittedly, these changes will likely be requested in conjunction with some other, more substantive change to reduce numbers of requests.
Certainly, the cost (which our experience indicates is currently a minimum of $25,000 per amendment for an operating plant) would not seem to justify pursuit of any such amendments individually.
However, each request must be brought separately and must be reviewed and processed individually; and therein lies an opportunity for improvement of the process.
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9305110348 930503 v
Chief, Rules and Directives Review Branch May 3, 1993 Page 2 i
This intended change, and the others like it cited above, have been identified by the NRC as an administrative simplification or a standard approach that has been found acceptable.
Would it not be possible, then, to conduct a one-time generic process for all future applicants, such that the approval is "prepositioned" for use by licensees when they select the change?
We would encourage the NRC to seriously consider the development of alternatives (i.e.,
a generic Sholley review process, an administrative rulemaking, or the like) to enable handling these generic changes to Technical Specifications as a one time process to the greatest extent possible.
It appears that this method would be the most efficient for the agency and, as a result, the least costly for licensees.
Sincerely yours,
/
D.
W.
Edwards Director, Industry Affairs DWE/sf r