ML20045D832

Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals.

ML20045D832
Person / Time
Site:	Comanche Peak
Issue date:	06/11/1993
From:	William Cahill, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR28523, RULE-PR-50, RULE-PR-54 58FR28523-00002, 58FR28523-2, AE63-1-004, AE63-1-4, TXX-93247, NUDOCS 9306300106
Download: ML20045D832 (2)

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== ; Log # TXX-93247 ~w.

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Ref. # 10CFR50.71(g) JUN 15 P3 :58 10CFR50.59('tT) 1UELECTRIC r . ~ 3, U.c June 11, 1993

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"I Wimam J. Cahill. Jr.

Grcup Vwe Presodent Secretary, U. S. Nuclear Regulatory Commission Attention: Docketing and Services Branch Washington, OC 20555 l

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

COMMENTS ON PROPOSED RULE CONCERNING FSAR UPDATE SUBMITTALS i

REF: Federal Register, Volume 58, No. 92, dated May 14, 1993 10CFR Parts 50 and 54, RIN 3150-AE63, "FSAR Update Submittals" i

l Gentlemen:

TU Electric supports the proposed rule ~ described in the referenced Federal Register notice, to clarify the FSAR update reporting requirement by l deleting references to annual updates in 10CFR50.54(a)(3) and 10CFR54.37(e). l In conjuction with the proposed rule TU Electric recommends that i consideration be given to extending the reporting frequency associated with '

10CFR50.59(b)(2), currently annually or sooner, to be consistent with the i FSAR update submittal. l Most 10CFR50.59 evaluations. although not all, result from changes that impact the FSAR. Thus there is a high degree of correlation between information contained in the FSAR update and the information in the 10CFR50.59 annual summaries. In general, for 50.59 evaluations affecting the FSAR, the 50.59 evaluation process is an integral part of the FSAR update process (i.e., they usually share the'same databases, are processed by the same individuals, and are on the same schedule). As a result there are significant time and resource efficiencies associated with.the submittal of the 10CFR50.59 summaries on the same frequency as the FSAR update submittal. Also, the same arguments apply for Extending the frequency of 10CFR50.59 summaries as were applied to extending the FSAR update frequency -

(e.g., the original intent for an annual submittal was to reflect changes for one cycle when the normal cycle was one year; also most plant changes, with the _ accompanying FSAR changes and 50.59 evaluations, occur during refuelingoutages).

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9306300106 930611 ' l PDR PR i 50 SOFR28523 PDR l 400 N. Olive Sweet LB. 81 Dallas, Texas 75201

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i TXX-93247 Page 2 of 2 Based on the above TU Electric recommends revising the proposed rule to -

extend the submittal frequency of 10CFR50.59 summaries to be consistent with I the frequency of FSAR update submittals, (i.e., either annually or within six months after each refueling outage).

Sincerely, w%9. CAJ>>

William J. Cahill, Jr.

i By:

R. D. Walker Manager of Regulatory Affairs BSD l

l c- Mr. J. L. Milhoan, Region IV l Resident Inspector! 'PSES (2)  ;

Mr. T. A. Bergman, j i

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