ML20058L498
| ML20058L498 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 11/29/1993 |
| From: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR48004, FRN-59FR64283, RULE-PR-72 58FR48004-00005, 58FR48004-5, AE37-2-008, AE37-2-7, AE37-2-8, FYC-93-026, FYC-93-26, NUDOCS 9312170019 | |
| Download: ML20058L498 (3) | |
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YANKEE ATOMIC ELECTRIC COMPANY
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7 November 29, 1993 i
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j Mr. Samuel J. Chilk Secretary i
U.S. Nuclear Regulatory Commission Washington, DC 20555 I
Subject:
Yankee Atomic Electric Company Comments on the Proposed Rule:
" Notification of Events at Independent Spent Fuel Storage Installations and the Monitored Retrievable Storage Installation" (58FR48004)
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Dear Mr. Chilk:
Yankee Atomic Electric Company (YAEC) appreciates the opportunity to comment on the subject proposed rule. YAEC is a New England utility which owns the Yankee-plant in Rowe, Massachusetts and provides engineering and licensing services to other nuclear power plants in New England.
Yankee fully supports the comments filed by NUMARC on behalf of the industry regarding this matter.
We believe that the basic. intent of.the l
NUMARC comment is to highlight the need for consistency of reporting standards l
between Part 72 and Part 50.
Our specific comments to the subject proposed rule relate to the apparent dichotomy between the claims in the Discussion j
that the changes are based on existing requirements (e.g., 50.72(b)(1)(B)) and the proposed three conditions for reporting that do not refer to the governing Technical Specifications as a point of departure.
The proposed rule would amend NRC regulations to revise licensee reporting requirements regarding the notification of events related to radiation safety at Independent Spent Fuel Storage Installations (ISFSI's).and a Monitored Retrievable Storage Installation (MRS).
Creating one rule for l
both types of f acilities may be a fundamental flaw.
It would seem that the nature of the two facilities could be quite different. Though they both involve fuel storage. the relatively inactive ISFSI adjacent to a Part 50 facility might contrast sharply with a bustling MRS.
On the basis of that comparative perception, the reporting rules could well be different.
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Mr. Samuel J. Chilk November 29, 1993 Page 2 One proposed revision (72.75(b)(2)) requires a 24-hour report following discovery of an event in which safety equipment is disabled or fails to function as designed when:
1.
the equipment is required by regulation or licensee condition to prevent releases or exposures exceeding regulatory limits. or to mitigate the consequences of an accident.
2.
the equipment is required to be available and operable when it is disabled or fails; and 3.
no redundant equipment is available and operable to perform the required safety function when the failure occurs.
One of the examples presented to clarify implementation of this requirement highlights our point.
A 24-hour report is required upon. " Failure of monitoring equipment required by regulation or license condition to verify that safe criticality conditions exist while spent fuel bundles are being moved in a pool."
Based on the event example above. the rule appears to require a 24-hour report for a monitoring equipment failure even if the facility were operating in accordance within its Technical Specifications.
It appears as though a report would be required when Technical Specification required equipment fails, regardless of the applicability of the associated Action Statement.
This seems significantly more restrictive than reporting required by 10 CFR 50.72.
The reporting requirements in 10 CFR 50.72 do not require a report following any event or condition unless that event or condition alone would have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident (10 CFR 50.72(b)(2)(iii)(D)).
l For example, a Technical Specification Limiting Condition for Operation may require the spent fuel storage area radiation monitoring equipment to be operable when handling irradiated fuel.
If the equipment becomes inoperable.
the Technical Specification Action Statement rLquires that fuel be placed in a safe condition and fuel handling operations be.suspenced until the monitor is returned to operable status.
Adherence with the Technical Specification Action Statement would constitute compliance with the Limiting Condition for Operation.
The proposed rule appears to impose an additional 24-hour notification following this event.
It should not be necessary to report a condition requiring entry into an Action Statement to the NRC.
Use of Action Statements to meet the Limiting Condition for Operations is anticipated and has been accepted by the staff, as adequate for public protection. The j
purpose of this structure for Technical Specifications is to constrain licensee actions when the bounds of the license are approached. Additional C m 377 i
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l Mr. Samuel J. Chilk November 29, 1993 Page 3 reporting because this type of restraint has been exercised seems inconsistent with NRC reporting philosophy represented by 10CFR 50.72 and 50.73.
r The confusion created by the examples in the proposal interferes with
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making any sort of projection about the number of reports that may be filed i
yearly, as requested by the FR notice.
If the reporting standard is set entirely consistent with those of Part 50, the number for an ISFSI would likely be very low single numbers.
Yankee appreciates the opportunity to comment on the subject proposed rule and urges that it be modified to establish a reporting requirement consistent with the reporting requirements in 10 CFR 50.72.
Sincerely.
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'W D. W. Edwards i
Director. Industry Affairs DWE/dhm i
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