ML20070F774

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Advises That Util Decided Not to Request Hearing on NRC Denial of 890405 & 0721 Applications for Amend to License NPF-12,changing TS 3.7.1.6 Re Feedwater Isolation Valves & TS 3.7.1.5 Re MSIVs
ML20070F774
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 03/04/1991
From: Skolds J
SOUTH CAROLINA ELECTRIC & GAS CO.
To: Murley T
Office of Nuclear Reactor Regulation
References
TAC-72893, TAC-74822, NUDOCS 9103110044
Download: ML20070F774 (2)


Text

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SCE&G MAR 0 41991 Dr. Thomas E. Murley Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

Dear Dr. Murley:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 DENIAL OF AMENDMENT REQUEST FOR FEEDWATER &

MAIN STEAM ISOLATION VALVES (TAC N0s 72893 & 74822)

In letters dated April 5, 1989, and July 21, 1989, South Carolina Electric &

Gas Company (SCE&G) requested revisions to the Action Statements for Technical Specifications (TS) Limiting Conditions for Operations (LC0) 3.7.1.6, "Feedwater Isolation Valves," and 3 ' '.5, " Main Steam Isolction Valves."

On December 26, 1990, SCE&G received a letter dated December 19, 1990, from the NRC Project Manager denying both TS revisions. In a letter to the NRC dated January 28, 1991, SCE&G requested that the NRC reconsider their denial.

C, February 19, 1991, SCE&G received a letter dated February 14, 1991, from th? NRC Associate Director for Projects Office of Nuclear Reactor Regulation denying SCE&G's request for reconsideration. In both the December 19, 1990, and the February 14, 1991, letters. the stated reasons for the denials were that both TS submittals constituted a partial implementation of the new Standardized Technical Specifications (STS), and that they were generic to Westinghouse plants from both a safety and a design standpoint and would not represent a significant improvement in safety.

SCE&G has decided not to request a hearing for these Technical Specification changes. However, several aspects of NRC's management of this process appear to be unclear or poorly implemented.

1. It took the NRC 20 months to deny a Technical Specification request.

During these 20 months, SCE&G was also asked to reformat the request and-expand the safety analysis. Neither the reformatting nor the safety analysis expansion played a part in the denial of the Technical Specification amendment request.

2. The NRC is denying the request based partially on the fact that the amendment is a partial implementation of the new STS. SCE&G reiterates its position that the NRC's referral to a draft document is not appropriate.

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Document Control Desk TSP 880020 & 890001 Page 2 of 2

3. The NRC is adopting a policy to deny TS amendment requests that have potential generic applications, in the NRC opinion, these requests should be referred to the respective ownet group for generic industry submittal to the NRC. This policy has been adopted by the NRC without defining " generic." Without some guidance, there will be no consistency in how this criterion is applied.
4. The NRC is communicat1r y its policy on TS changes through the denial of revision requests. It would seem that a policy change of this type should be communiccted tc the industry before it is implemented. The NRC has a number of effective means of communicating information to the industry, and SCE&G strongly encourages the NRC to use them.

SCE&G is interested in having TS that provide for the safe operation of the plant. Both the NRC and the industry have recognized for some time that present TS need improvement. However, current NRC policy on TS changes does nothirig to improve them; rather it presents unclear obstacles to the improvement process.

SCE&G strongly urges the NRC to provide to the industry clear guidance on TS amendments. SCE&G will pursue this issue through NUMARC.

Very truly

& d]yours, /

Job" L. Skolds WRH:JLS: led c: 0. W. Dixon Jr.

R. R. Mahan R. J. White S. D. Ebneter G. F. Wunder General Managers NRC Resident inspector J. B. Knotts Jr.

H. G. Shealy RTS (' TSP 880020 & 890001)

File (813.20)

NUCLEAR EXCELLENCE - A SUMMER TRADITION!