ML20077M579

Comment Supporting Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Np Reactors.Expresses Concern Over Basis for Pr Not Recognizing Improvements in Outage Planning,Flawed Regulatory Analysis & Unneeded Restrictions

ML20077M579
Person / Time
Site:	Kewaunee
Issue date:	01/03/1995
From:	Schrock C WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR52707, RULE-PR-50 59FR52707-00019, 59FR52707-19, NUDOCS 9501130113
Download: ML20077M579 (7)

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o NRC-94-131 o

WPSC (414) 433-1598 00CKF,JpLINK 62891993 TELECDPIER [414) 433-5544 I ig [tyt ,

wasCOwsIN PU5l.lC SERVICE CORPORATION 600 North Adams e P.O. Box 19002 e Green Bay, WI 54307-9002 g JAN -6 p 3 $7 0FF: li '

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DOCKET NUMBER PROPOSED RULE 50 _

(.59Fe-5WTo'D January 3,1995 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Docketing and Service Branch Ladies / Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Comments on Prooosed Rule. " Shutdown and Low Power Operations for Nuclear Power Reactors" Wisconsin Public Service Corporation OVPSC) is submitting the following comments in response to the Nuclear Regulatory Commission's proposed rule, " Shutdown and Low Power Operation for Nuclear Reactors" published in the Federal Register on October 19,1994 (59 FR 52707).

WPSC endorses the comments provided to the NRC by the Nuclear Energy Institute (NEI) and Westinghouse Owners' Group OVOG) and urges the staff to consider these in preparation of rule. The purpose of WPSC's comments is to reiterate the key points presented by NEI and WOG and provide plant specific information on outage impact.

There are three main areas of the proposed rulemaking package that concern us. These are:

-The basis for the proposed rule does not recognize improvements in outage planning and controls that have been made by the industry.

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-The regulatory analysis for the proposed rule is flawed and does not fully assess the economic impact of the proposed requirements.  ;

-The proposed rule contains restrictions that are not warranted and may hinder our ability ,

to effectively manage plant shutdown conditions and outages.

Specific comments on the proposed rule are provided in the attachment to this letter. If you have any questions or comments please contact me or a member of my staff. .

l' Sincerely, 00 C.A. Schrock [

Manager - Nuclear Engineering  !

SLB/ san j i

Attach.

cc - US NRC Region III  !

US NRC Senior Resident Inspector i

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ATTACHMENT 1 letter from C.A. Schrock (WPSC)

To Secretary (NRC)

Dated January 3,1995 3:\wpGes\liciarc\74.wp 1

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WPSC's concerns on the rulemaking package concentrate on the following three areas. <

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-The basis for the proposed rule does not recognize improvements in the outage planning l and controls that have been made by the industry. j

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-The regulatory analysis for the proposed rule is flawed and does not fully assess the economic impact of the proposed requirements.

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-The proposed rule contains restrictions that are not warranted and may hinder our ability. $

to effectively manage plant shutdown conditions and outages.

Each of these areas is discussed in greater detail below. I Rncit for the Rule i

WPSC believes that there is no need for regulatory action in the form of rulemaking to regulate k low-power, shutdown and refueling operations of nuclear power reactors. The basis for the  ;

proposed rule does not take into consideration significant improvements that have been made by the industry, specifically the development and implementation of NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Mananement. Implementation of this industry initiative  !

has resulted in a reduction of frequency and safety significance of shutdown events over the past j three years. q J

r The basis for the proposed rule was developed by the NRC staffin NUREG-1449. This data l is several years old and was obtained prior to the implementation of NUMARC 91-06. We j believe that the staff should reevaluate the need for a rule based on current industry data. ,

a-Inndannate Renulatory Analysis l WPSC believes that the regulatory analysis contained in SECY-94-176 is flawed and does not -

fully assess the economic impact of the proposed requirements. The cost estimates associated {

with implementation of the proposed rule do not agree with those estimates developed by utilities ,

and vendors. In particular, the regulatory analysis is based on the assumption that there is no  :

increase in outage duration following implementation of the proposed rule requirements. The ,

reason for this assumption is that the staff believes improvements made in outage planning and .i control should help offset any outage delays. While there may be cases in the industry where .

improvements in outage planning and control can be made to reduce outage lengths, this is not l universally the case. Plants with well managed outages will be impacted by the proposed rule and an increase in outage duration will occur.

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Document Control Desk y January 3,' 1995  ;

Attachment 1, Page 2  ;

l WPSC performs well managed outages and estimates that the proposed rule will extend a typical j i

refueling outage by approximately 10 days. l This is due to the proposed requirement that would require redundant onsite power sources when the refueling cavity is not flooded and the proposed ; ,

requirement to impose containment integrity conditions verses containment closure. Estimating . j refueling outage costs at $200,000 per day, the proposed rule will result in an average increased .:

' cost of $2 million per refueling outage. Provided below is a tabulation of the expected costs that i would be required to implement the proposed rule at the Kewaunee Nuclear Power Plant l l

. (KNPP)..

Rule Requirement Outage Impact Total' Cost to Implement-Paragraph (c)(3)(ii) of the Given that a number of $1.6 million per refueling -

proposed rule requires plants do not perform outage.

sufficient redundancy to emergency diesel generator j perform safety functions maintenance on-line, this  ;

assuming offsite power is will limit the time frame for .

not available except for . maintenance to a narrow ,

refueling conditions when outage window. Typically the refueling cavity is KNPP is in a flooded j flooded. condition for 7 days. This  ;

requirement will require the plant to remain in a flooded condition for a minimum of 15 days. l Paragraph (c)(2) of the Containment integrity versus $400,000 per refueling  :

proposed rule requires the containment closure outage for increased outage - l assurance that conta' at will require a modification duration.  !

integrity be maintai ;r to the containment $60,000 one. time cost to  !

can be reestablished m a penetration used for steam modify the containment  :

timely manner. generator inspection work - penetration for steam j and will impact the outage - generator inspection and j schedule to comply with repair work.

Appendix J testing requirements. The impact l

on outage duration is E estimated to be 2 days.

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' Rule Requinsnent Outage Impact Total Cost to Implement i Paragraph (d) of the 'Ihe required equipment is $350,000 one time cost to i proposed rule requires estimated to cost $350,000 install ultrasonic level diverse RCS level .

to install and require an instrumentation.

instrumentation not affected additional 1 man rem per  ;

by changes in pressure or outage to maintain.

interconnected systems. ]

Paragraph (c)(4) of the An estimated cost of the $10,000 per refueling proposed rule requires manpower for the additional outage.  !

additional fire hazard paperwork is $10,000 per analysis and fire watches refueling cycle.

during shutdown operations  ;

It is our feeling that these additional costs were not adequately addressed in the regulatory i analysis provided in SECY 94-176. This is not in compliance with the Backfit Rule.  !

Specifically,10 CFR 50.109(a)(3) requires that "...all direct and indirect cost ofimplementation for that facility are justified...". We feel that the NRC staff needs to revisit the regulatory ,

analysis addressing the economic information provided by ourselves and other licensees.

Unwarranted Restrictions Imoosed by the Proposed Rule The proposed rule and supporting Regulatory Guide contain restrictions that would inhibit our [

ability to effectively manage the outage with no commensurate increase in public health and safety. These are outlined below:

-Requirement for containment integrity versus containment closure. Generic letter 88-17 provided a definition for containment closure that has been implemented by licensees.

Use of the word integrity implies the capability to withstand peak containment pressure j conditions and demonstrated abilities in accordance with 10 CFR 50 Appendix J leakage testing requirements. Having the ability to reestablish containment integrity in a

' reasonable time' frame is an unrealistic expectation and restricts flexibility during )

outages. This requirement will result in lengthening the outage. Furthermore, the '

background information for the proposed rule does not provide an adequate justification for this requirement.

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Document Control Desk l January 3,1995 t Attachment 1, Page 4 l

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-De proposed equipment operability requirements are overly restrictive. De wording i of the proposed rule would require a significant amount of maintenance work te l performed during a single outage window, namely when the cavity is flanded. This will . l result in outage delays with no increase in public health and safety. Additionally, the l'

rule implies that only safety-related equipment can be used and passive means of decay.

heat removal can not be credited. We believe that 'with proper alaaaiar and  !

administrative controls these options should be allowed. This increases flexibility m l outage management while ensuring safety is being maintained.

-The proposed rule requires RCS level instrumentation not affected by pressum or interconnected systems. Licensees have implemented additional RCS monitoring instrumentation and controls in accordance with GL 88-17. If the staff has concerns with i RCS monitoring instrumentation it should be handled on a plant specific basis. Requiring a all PWRs to install ultrasonic level instrumentation is not necessary and unjustified from a cost benefit perspective. l l -The proposed rule requires additional fire protection requirements during shutdown conditions. This requirement is vague and it is not nee-ary. Fire hazard analysis and i fire watches are already performed during shutdown conditions to comply with personnel '

safety and insurance considerations. Regulating this area will result in an additional paperwork burden that is not justified. ]

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-De supporting draft Regulatory Guide is overly prescriptive in its discussion on outage I planning and control guidance. The detail provided is beyond public health and safety  :

concerns and suggests management practices. This is clearly not appropriate for a l regulatory guidance document. Additionally, the Regulatory Guide introduces two new I terms, " capable" and "connectable". There is already an industry consensus formed j

i using the terms available and functional. Introduction of new terms will only confuse the issue.

Summary WPSC remains committed to operating KNPP in a safe, efficient and economical manner. We feel that implementation of the proposed shutdown and low power operation rule will not be -

consistent with these objectives. It will impose undue costs with negligible impact on plant safety. The regulatory analysis is flawed and does not take into consideration improvements made by the industry or accurately account for all of the cost that will be required to implement the rule. Additionally the rule will restrict flexibility in outage planning and management. We believe that the need for the rule and the regulatory bases need to be carefully reexamined, g:\wpGes\t.c\nrc\74.wp l

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