ML20077E904

Comment Supporting Proposed Rule 10CFR50 Re TS Improvements. Advises That PSA Portion of Fourth Criterion Should Be Clarified to Include Only Those Equipment Items Important to risk-significant Sequences as Defined in GL 88-20,App 2

ML20077E904
Person / Time
Site:	Callaway
Issue date:	12/02/1994
From:	Passwater A UNION ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR48180, RULE-PR-50 59FR48180-00003, 59FR48180-3, GL-88-20, ULNRC-3109, NUDOCS 9412130177
Download: ML20077E904 (3)

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December 2, 1994 Secretary U.S. Nuclear Regulatory Commission ATTN: Docketing and Service Branch Washington, D.C. 20555-0001 Gentlemen: ULNRC-3109 PROPOSED RULE ON TECIINICA L SPECIFICATION IMPROVEMENTS

References:

1) 59FR48180 dated September 20,1994

2) ULNRC-3023 dated May 20,1994

3) 58FR39132 dated July 22,1993

4) NRC letter to Westinghouse Owners Group (T. Murley to R. Newton), "NRC Staff Review of Nuclear Steam Supply System Vendor Owners Groups' Application of the Commission's Interim Policy Statement Criteria to Standard Technical Specifications,"

dated May 9,1988 Union Electric concurs with the changes to 10CFR50.36(c) as proposed in Reference 1. The following comments are in response to the '

Commission's specific request for input on the fourth criterion added to 10CFR50.36(c) as subpart (c) (2) (ii) (D) regarding those guidelines that the Commission should use in defining "significant to public health and safety."

Criterion 4 would retain in the Technical Specifications those stmetures,  ;

systems, and components (SSCs) that are safety significant based on probabilistic safety assessment (PSA) or operating experience.

Union Electric has submitted (Reference 2) a package'of Technical Specification changes based on the Final Policy Statement on i Technical Specification Improvements (Reference 3). The four criteria j g21gi77941202 50 59FR48100 PDR l MO l

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.. Secretary USNRC - 3109 Page 2 addressed in Reference 3 are the same.as those proposed for codification in Reference 1. The guidelines used to answer the PSA portion of the fourth criterion were based on the reporting criteria of Appendix 2 to Generic Letter 88-20. Technical Specifications covering equipment of prime importance in limiting the likelihood or severity of the risk-dominant sequences were retained. Risk-dominant sequences were reported in Section 3.4 of the Callaway IPE (if the sequence frequency was 2 IE-06 per reactor year for core melt or 2 lE-07 per reactor year for containment bypass). Screening forms addressing each of the four criteria (with yes/no answers and discussion) were developed for every LCO in support of Reference 2. In almost every case where an LCO was retained, the basis for retention was an affirmative uswer to one or more of the first three criteria. If an LCO screening ferm contained an affirmative answer to the fourth criterion, in most cases the form also answered one or more of the first three criteria affirmatively. The only exceptions to the above were based on NRC positions in References 3 and 4, i.e. Technical Specifications 3.3.3.5 (fourth criterion answered aflirmatively for remote shutdown instrumentation based on NRC concems with fire risk expressed in Reference 4; currently being addressed in the IPEEE), and 3.9.8.1 and 3.9.8.2 (fourth criterion answered affirmatively for RHR in Mode 6 based on References 3 and 4).

The PSA portion of the fourth criterion should be clarified to include only those equipment items important to risk-significant sequences as defined in Generic Letter 88-20 Appendix 2 and reported in licensees'IPE reports. The operating experience portion of the fourth criterion should be deleted since it is subjective and since no equipment would satisfy only that portion of the fourth criterion and none of the other criteria.

We appreciate the opportunity to provide these comments.

Should you have any questions on the above, please contact us.

Sincerely, s

A. C. Passwater Manager, Licensing & Fuels GGY/kea

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e cc: T. A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington,. D.C. 20037 M..H. Fletcher Professional Nuclear Consulting, Inc.

18225-A Flower Hill Way Gaithersburg, MD 20879-5334 L. Robert Greger Chief, Reactor Project Branch 1 U.F. Nuclear Regulatory Commission Region III 801 Warrenville Road

-Lisle, IL. 60532-4351 Bruce Bartlett Callaway Resident Office U.S. Regulatory Commission RR#1 Steedman, MO 65077 L. R. Wharton (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E21 11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102

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