ML20077M731

Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors

ML20077M731
Person / Time
Site:	Comanche Peak
Issue date:	12/30/1994
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-59FR52707, RULE-PR-50 59FR52707-00014, 59FR52707-14, NUDOCS 9501130151
Download: ML20077M731 (4)

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DOCKET NUMBERas 9 PROPOSED RULE rn s

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(gwD Log # TXX-94333 DOCKETED USNPC y7 File # 10185 Ref. # 10CFR50.67

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7t/ELECTR/C December 30, 1994 .

OFFICE OF 5ESS.* 7 9, CL DOCKEliMG /

C b T=7 on,vwrman Bit hi8 U. S. Nuclear Regulatory Commission Washington, DC 20555 0001 ATTN: Docketing and Service Branch

SUBJECT:

C0HANCHE PEAK STEAM ELECTRIC STATION (CPSES)

Comments Regarding the Proposed Rulemaking on Shutdown and Low Power Operations REF: 1) 59FR52707. Proposed Rule on Shutdown and Low-Power Operations for Nuclear Power Reactors

2) 59FR52613 Proposed Rule on Shutdown and Low Power Operations ,

for Nuclear Power Reactors: Correction

Dear Sirs:

TU Electric has monitored the progress and development of the shutdown risk .'

management issues. TV Electric strong'y feels that it is both prudent and incumbent upon licensees to safely manage outages at nuclear plants. i TU Electric currently uses the guidance provided in NUMARC 9106, " Guidelines for  ;

Industry Actions to Assess Shutdown Management" as an aid in planning and i conducting outages. Based on this guidance Comanche Peak has established a formal l shutdown risk management program. This program ensures that necessary resources and responsibilities are maintained for shutdown risk management. As a result of 4 the progress of shutdown risk management during outages at Comanche Peak, TU Electric believes that incorporation of the proposed NRC requirements associated with shutdown and low power operation for nuclear reactors in references 1) and 2) are not necessary and will not measurably reduce risk during shutdown operations.

TU Electric has reviewed the proposed shutdown rulemaking published in the Federal f Register on October 19, 1994 and has the following comments.

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TXX 94333 . I

' Page 2 of 4 General Comments: i

1. TU Electric does not believe that requiring additional Technical . i Specifications via the proposed rule is consistant with the NRC policy ,

statement published for Technical Specifications in 58FR39132. The current' direction for improving the existing Technical Specifications'at operating r plants is to relocate requirements that complement Technical Specifications ' ,

to licensee controlled programs. These programs allow the flexibility to be tailored to a specific condition of the plant (i.e. re-establish a safety  ;

train or alternative methods to provide functions) without imposing specific restrictions as would Technical Specifications. Imposing the proposed additional Technical Specifications would eliminate this flexibility without' any reasonably defined safety benefit.

2. The proposed rule. as written, will significantly impact the cost and .

I schedule of outages for CPSES Units 1 snd 2. Restrictions, such as specific '

shutdown Technical Specifications would preclude the use of temporary equipment (restrictions on AC power sources) and would result in extending .;

outage duration with marginal reduction in shutdown risk. An increase in  :

outage length along with the additional activities identified by the  !

proposed rule would translate to an increased exposure to radiation workers  ;

and an increase in the radwaste generated during the outage. The recent-outage for.CPSES Unit 2 was evaluated against the criteria specified in the proposed rule. TU Electric determined that the rule would have increased- i the 47 day outage by 9 days ($4 million in additional outage cost). Having ,

two units, this would constitute a significant increase in the cost for.

operation of Comanche Peak Units 1 and 2.

3. TU Electric believes that the rule is not needed because Comanche Pt-ak is .;

already making changes to support the NUMARC 9106 Guidelines. The proposed i rule uses a generic PRA to justify very specific actions to be applied at  :

all reactor sites. It seems to be more appropriate for utilities to perform  !

their own plant specific PRA for alternate modes to identify any actions ,

unique to their plant design and performance that could potentially enhance ,

plant safety.

Specific Comunents:

1. Requiring the additional Containment integrity until the reactor vessel head is removed and the refueling cavity filled to 23 feet water level will extend outages. This requirement will: 1) restrict working conditions  ;

because area posting cannot be performed (Containment Sump foreign material j requirements),~ resulting in the requirement to r#n in full Protective l Equipment:

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TXX 94333 .

Page 3 of 4 i

2) limit the ability to stage equipment in containment because the Equipment !

Hatch cannot be removed; and, 3) extend the core offload because components and testing normally worked and performed prior to the core offload (Safety Injection Pumps, ECCS Accumulators, ECCS forward flow testing, etc.) will need to be performed during the core offload time period because of the  ;

increased requirements to maintain this equipment when level is < 23 feet in ,

the refueling cavity.

2. Requiring two trains of reactor coolant system ' shutdown cooling' until the refueling cavity is filled to 23 feet water level would extend the duration of core offload because components and tecting normally worked and performed prior to the core offload (Safety Injection Pumps, ECCS Accumulators, ECCS forward flow testing, etc.) will need to be performed during the core offload time period because of the increased requirements to maintain this equipment when level is < 23 feet in the refueling cavity and entry into Active Technical Specification LCO's to support local leak rate testing of shutdown cooling isolation valves.

3. Requiring two diesel generators until the refueling cavity is filled to 23 feet water level with no allowance for offsite power would narrow the possible work windows for maintenance for the diesel generators, thus increasing the overall outage length.

4. Requiring the Emergency Core Cooling Systems until the reactor vessel head is removed and the refueling cavity is filled to 23 feet water level will also narrow the possible work window for these systems, thus extending the overall outage. In addition, this will result in additional entry into Technical Specifications LCO's to support local leak rate testing and ECCS forward flow testing because of the increased requirements to maintain this equipment when level is < 23 feet in the refueling cavity.

5. TU Electric maintains Fire Protection controls in place during outages according to current programs. Requiring a re analysis of Fire Protection with applicability in MODES 5 and 6 specifically will require additional resources at Comanche Peak with unknown benefits (e.g. increase in nuclear safety.) TU Electric believes that adequate administrative controls are already in place.

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i TXX 94333 Page 4 of 4 l TU Electric believes the NRC should reconsider the proposed rule in light of the i

fact that the impact on plant operations is significant with marginal safety-benefit. ' As identified above, the proposed rule will significantly impact the overall cost for plant operation. TU Electric does not believe that the proposed rule is warranted or necessary. l Sincerely, e.1. g C. L. Terry By: @

Roger D. Walker Regulatory Affairs Manager i JDS/grp c- Mr. L. J. Callan, Region IV Mr. D. D. Chamberlain, Region IV Resident Inspectors Mr. T. J. Polich, NRR NEI i

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