ML20077M713

Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations.Believes That Pr Totally Unnecessary & Represents Addl Regulatory Burden Not Fully Cost Justified

ML20077M713
Person / Time
Site:	Summer
Issue date:	01/03/1995
From:	Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR52707, RULE-PR-50 59FR52707-00022, 59FR52707-22, NUDOCS 9501130142
Download: ML20077M713 (3)

Text

e South Carolina Electric & Gas Company Gory J. Taylor P.o. Box 88 Vee President  ;

Jenkinsville SC 29065 Nuclear OperatiMOc2g{} {g (803) 345-4344 C6}$C SCE&G ooCKET NUMBERne e === c- 180 POSED RULE rn Eb .6 9 ei :2B '

(SRyesanoi)

~

January 3, 1995 Refer to: RC-95-0001 0FFICE E 00CKENIL ~

J' Yf Secretary U. S. Nuclear Re ulato Commission i Washington, D 2055 0001 Attn: Docketing and Service Branch Dear Sir-l

Subject:

VIRGIL C. SUMMER NUCLEAR STATION DOCKET NO. 50/395 i OPERATING LICENSc NO. NPF-12 i COMMENTS ON PP.OPOSED AMENDMENT TO REGULATIONS CONCERNING SHUTDOWN AND LOW POWER OPERATIONS i

This letter provides South Carolina Electric & Gas'(SCE&G) comments on the Nuclear .

Regulatory Commission's proposed rulemaking on shutdown and low power operations. SCE&G fully endorses the Nuclear Energy Institute comments regarding this proposed rule. Overall, the proposed rule is totally unnecessary and represents an additional regulatory burden which has not been cost justified or demonstrated to significantly reduce the risk to the health or safety of the general public. The economic burden for SCE&G to comply with this rule is estimated at 4-7 million dollars for each refueling outage, plus approximately 0.5 million dollars in one time costs.

SCE&G appreciates the opportunity to review and provide comments on this  ;

proposed rule. ,

l Very truly yours, l

G y y1 r CAC/GJT/nkk l Attachment l c: O. W. Dixon R. R. Mahan R. J. White G. F. Wunder NSRC RTS (PR 940034)

Central File System File (811.02,50.075) 9501130142 950103 59 52707 PDR

@ NUCLEAR EXCELLENCE - A SUMMER TRAL,,TIONI M ID

'[' Attachment to Docum::nt Control Desk 1.ctttr  !

PR 940034 .

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% Page 1 of 2 i l

Specific Comments on the Contents of the Proposed Rule  !

i a) Paragraph (C)(1) states that " licensees must provide reasonable assurance that a  ;

loss of subcooled state in the reactor coolant system (RCS) will not occur."  ;

, However, the loss of subcooling is not necessarily safety significant. The loss of i decay heat removal (DHR) by forced flow with the refueling cavity water level in  ;

excess of an approved lower limit and relying on DHR by core boiling is  ;

recognized paragraph (C)(3)(E) in theii)p(roposed of the proposed rule rule, as acceptable.

this part should Therefore, be eliminated. to be consistent w b) Paragraph (C)(2) states that " licensees must assure that containment integri maintamed or can be re-established in a timely manner to prevent m releases li excess of 10CFR Part 100." The proposed rule needs to embrace the concept of  !

containment closure with non-significant pressurization, already defined in the  !

current Technical Specifications (TS). Containment integrity has the  !

requirement of proof-of-operability through Appendix J leak rate testing. i However, leak rate testing of the fuel transfer tube blind flange could not be  ;

performed in a timely manner when water is in the refueling cavity. Also, core-  ;

cooling via boiling and RCS makeu p can result in doses less than 10CFR Part 100, i even with an open containment. If containment closure is adopted, then "in a  !

timely manner needs to be tied to something more definitive, such as a Part i 100 release, assuming no significant pressurization. j c) Paragraph (C)(3)(ii) states that " licensees must establish controls for the l equipment in pwagraph (C)(3)(i) of this section such that they will perform their  ;

safety function when the plant is in a shutdown or low power condition. The  ;

controls must reflect sufficient redundancy in systems, subsystems, components, and features to ensure that, for the on-site electric power system in operation -

(assuming off-site power is not available), safety functions can be accom,plished, ,

assuming a single failure, for all conditions except refueling operations. The i requirement to assume a single failure in modes 5 and 6 (with the head  ;

detensioned) with two independent off-site vital bus power feeds unavailable is  :

overly restrictive. The assumption that off-site power is more or less restrictive l than on-site power is unrealistic regardless of operational mode or refueling  :

cavity water level. Current TS require only one off-site and one on-site power source in these modes. A more reasonable defense-in depth approach would be i to require three of four power sources be available, which is the TS + 1 concept. i This part of the rule goes far beyond this concept. For instance, the rule as I proposed would require shutdown, reactor vessel disassembly, and fill the refueling cavity to approximately 23 feet if a diesel generator fails while at power.

It will also require two DH R trains and two charging pumps to be operable in modes 5 and 6. This ignores and eliminates the option of using two steam generators in mode 5 with the RCS loops filled to take the place of one DHR train (TS 3.4.1.4.1). There is no basis for this elimination. Additionally, two charging pumps operable when the RCS is less than 300 degrees violates TS 3.1.2.3, wbich provides protection for a mass addition pressure transient.

l4 5 Attachment to Docum:nt Control Desk Lett:r PR 940034 -

C Page 2 of 2 d) Paragraph (C)(4)(i) states that " prior to (and throughout the shutdown or refuelmg outage as necessartr to accommodate unforeseen contingencies) entering cold shutdown, eva uate realistically available fire protection features and the outage plan for possible fires stemmmg from activities conducted ,

during cold shutdown or refueling operations, and determine realistically 1 whether such fires could prevent accomplishment of normal DHR capability." l What reclulatory basis does this part of the proposed rule have? The severity of  !

fires whf e shutdown are not very significant. The NRC should consider  ;

insurance requirements of fire protection. These requirements are above and .  !

beyond the current NRC requirements and are based on sound business  !

practices. Taking the severity of fires at nuclear power plants and current .

msurance requirements into consideration, this part of the proposed rule should , 1 be eliminated.  :

i e) Paragraph (D) states that "all licensees of PWRs must provide instrumentation  :

for momtoring water level in the RCS during mid- loop operation. The accuracy of the instrumentation shall not be affected by changes in pressure in the RCS or i i

connected systems." One or more additional level instruments will not eliminate level problems. Rather, these incidents are indicative of increased operator awareness while in this sensitive operational area. Therefore, this part of the proposed rule should be eliminated l t

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