ML20070B438
| ML20070B438 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 01/28/1991 |
| From: | Skolds J SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | George Wunder NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-72893, TAC-74822, NUDOCS 9101310020 | |
| Download: ML20070B438 (2) | |
Text
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y sout car una cectric a ces company ghn L. sko s
nk ns i 29005 Nuclear 0;eahons O'
SCE&G JAN 281991
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Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. George F. Wunder
Subject:
VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO -50/395 OPERATING LICENSE NO.-NPF-12
-DENIAL OF AMENDMENT REQUESTS FOR FEE 0 WATER &
MAIN STEAM ISOLATION VALVES (TAC NOS. 72893 & 74822)
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In letters dated April 5, 1989, and July 21, 1989 South Carolina Electric &
Gas Company (SCE&G) requested revisions to the Action Statements to Technical Specification (TS) 3.7.2.6, "Feedwater Isolation Valves," and 3.7.1.5, " Main Steam Isolation Valves._"' Also, at the request of the NRC Project Manager,
-.SCE&G submitted a reformated and expanded safety analysis and basis for no significant hazards consideration for both of these TS revision requests on Septembar 21, 1989..
3 On December 26,'1990, SCE&G received a letter dated December 19, 1990; denying-both TS revisions. The stated reasons for denial'were: (1) that 4
these proposed Action Statements were consistent with the Action Statements currently planned for the new Standard Technica1' Specifications (STS), and-(2) that tney were generic in naturo and should be proposed to the respective.
' owners group for generic NRC consideration.
L SCE&G requested the revision to the Feedwater Isolation. Valve TS:because of a specific commercial need for the Virgil C. Sumer Nuclear Station.. SCE&G had experienced _ problems with the Feedwater Isolation Valves'and-it was F
determined that this revision woy1d allow SCE&G to effect repairs to more than one valve in modes 2 or 3 without having to implement Section 3.0.3 of:
Lthe TS. By allowing the plant to remain in modes 2 or 3.with these valves closed during. repairs wouldLsave SCE&G considerable time and expense; SCE&G requested the revision to the Main Steam Isolation Valve TS because of-the_same benefits in the Feedwater Iso 16 tion Valve.TS.
SCE&G_ understands the NRC concern regardingtutilities partially implementing the_new STS JAt the time that-these requests _were submitted, SCE&G-was not attempting _to partially-implement the.new STS-since we were not-_ aware of the.
specific proposed LCO's._ SCE&G does not feel that utilities should be denied approval of proposed TS amendments. based soley on the f act;that the proposed amendment is part of the new'STS.
It is also important to note that the new STS.is still a draft document.
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s, Document Control Desk TSP 880020 & TSP 890001 Page 2 of 2 SCE&G is very concerned about the ramifications to the industry if the NRC were to adopt a policy that any TS revision that has a potential generic application should be referred to the respective owners group for generic industry submittal to the NRC. Technical Specification changes that could be beneficial to other plants are not necessarily generic. This type of policy would conceivably cause a considerable delay in obtaining the necessary aporovals for much needed TS revision.
It is for the above stated raasons that SCE&G respectfully requests that the NRC reconsider the denial of both of the TS amendment requests. SCE&G does request the right to appeal if the NRC choses not to reconsider the denial.
Very truly ours, 36 d, s}',
John L. Skolds WRH:JLS:wrh c:
- 0. W. Dixon Jr.
R. R. Mahan R. J. White S. D. Ebneter General Managers NRC Resident Inspector J. B. Knotts Jr.
H. G. Shealy NSRC NPCF RTS (TSP 880020 & TSP 890001)
File (813.20)
NUCLEAR EXCELLENCE - A SUMMER TRADITION!
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