ML20077M743

Comment Supporting Proposed Rule 10CFR50 Re Shutdown & Lower Power Operations for Nuclear Reactors

ML20077M743
Person / Time
Site:	Seabrook
Issue date:	12/27/1994
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR52707, RULE-PR-50 59FR52707-00011, 59FR52707-11, NYN-94141, NUDOCS 9501130157
Download: ML20077M743 (5)

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DOCKETED North Atlantic Energy Service Corporation A North USHRC P.O. Box 300

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DT JAN -3 P2 :01 The Northea.: utilities system Ted C. Feigenbaum

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NYN-94141

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Senior Vice President 8.

7 00Ci-Chief Nuclear Officer December 27,1994 DOCKET NUMBER PROPOSED RULE N 50 (5%W5CCfD United States Nuclear Regulatory Commission Washington, D.C. 20555

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Attention: Secretary, Docketing and Service Branch

Reference:

Facility Operating License No. NPF-86, Docket No. 50-443

Subject:

Comments on Proposed Rule,10 CFR 50.67, " Shutdown and Lower Power Operations for Nuclear Reactors"

Dear Mr. Secretary:

North Atlantic Energy Service Corporation (North Atlantic) provides in the Enclosure comments on the proposed rule, " Shutdown and Low Power Operations for Nuclear Reactors," noticed in the Federal Register dated October 19,1994 (ref. 59 Fed. Reg. 52707). In addition, North Atlantic endorses the comments provided by the Nuclear Energy Institute on behalf of the nuclear industry.

We trust these comments are constructive and beneficial to the NRC's ongoing consideration of shutdown and low power operations. Should you require any additional information regarding this matter p ase contact Mr. James M. Peschel, Regulatory Compliance Manager, at (603) 474-9521, ext. 3772.

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Very t

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Ted C. Feigen aum TCF:JMP/sm i

Enclosure i

l 9501130157 941227 PDR PR 50 59FR52707 PDR ysp

United States Nuclear Regulatory Commission December 27,1994 Attention:

Secretary, Docketing and Service Branch Page two ec:

Document Control Desk United States Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate I-4 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Richard Laura NRC Senior Resident Inspector P.O. Box i149 Seabrook, NII 03874 Mr. Thomas E. Tipton Nuclear Energy Institute (NEI)

Suite 400 Washington, DC 20006-3708 t

North Atlantic December 27,1994 ENCLOSURE 1 TO NYN-94141

a NORTH ATLANTIC COMMENTS ON THE PROPOSED EULE ENCLOSURE 10 CFR 50.67, " SHUTDOWN AND LOW POWER OPERATIONS" North Atlantic Energy Service Corporation / North Atlantic has reviewed the proposed rule 50.67 and offers the following comments:

Nonh Atlantic supports the Commission's willingness to allow licensees to use controlled procedures in lieu of Technical Specifications as addressed in NUREG-1449, " Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States" for controlling specific equipment relied upon during chutdown and low-power operations.

North Atlantic has reviewed the Commission's approach on the following rule points:

1) permitting non-safety as well as safety equipment

2) permitting reduced decay heat levels to be a factor in selection and availability criteria

3) allowing changes to the equipment availability requirements during the outage without prior NRC approval We believe that these criteria allow reasonable outage flexibility without compromising safety.

Ilowever, we believe that some additional flexibility, as outlined below, is warranted (in line with item 1) that will not reduce required levels of safety.

(c)(3)(ii)

Some offsite power credit should be allowed, rather than assuming all offsite power is lost. It can be demonstrated that a loss of offsite power due to external problems is very unlikely during any given outage. NS AC/203 (4/94) shows that there have been only 26 losses of offsite power longer than I hour in the last 13 years (>l400 reactor-years). IIalf of these events were weather related, where expected weather conditions could be accommodated in outage planning. This frequency

(~1e-3/ outage) is sufficiently small such that, if a licensee controls switchyard work by Technical Specifications or Outage Risk Management procedures (as specified in the proposed rule), they should be allowed to credit offsite power. Requiring at least one train of onsite AC power at all times, in addition to the single failure requirement would seem to be a reasonable compromise.

Draft Regulatory Guide in addition, there are two areas where the associated draft regulatory guide (dated June 6,1994) seems to go beyond the requirements of the proposed rule. These areas are:

The draft regulatory guide discusses administrative controls to ensure that a " controlled information system is present to provide critical safety parameters and equipment status on a real-time basis during the outage" The possible regional interpretations of " controlled" and "real-time" could result in significant cost without any increase in shutdown safety. This is well beyond any discussion or implication in the rule itself. We agree that a licensee should have reasonable confidence that the physical state of the plant and equipment is known throughout the outage. This can be accomplished without requiring " controlled" (in an Appendix B sense) programs.

The draft regulatory guide also mentions " supporting analyses" for contingency plans. There is no further discussion about the expected depth or rigor of these analyses. Again, possible regional

o NORTH ATLANTIC COMMENTS ON THE PROPOSED RULE ENCLOSURE

.10 CFR 50.67," SHUTDOWN AND LOW POWER OPERATIONS" interpretations of this requirement could result in licensees being forced to apply design basis standards to plans that, by their nature, must have a degree of flexibility. We are very much in favor of documentation considerations similar to the Commission's Maintenance Rule documentation policy. That is, efforts should be spent on workable plans, rather than elaborate documents. It is reasonable to expect licensees to be able to offer adequate assurance that any contingency plans being credited are in fact workable. The emphasis here is on reasonable.

In response to the Commission's request for information on current practices, we would be pleased to offer copies of our existing Outage Risk Management Program. This program has evolved as a result of usage during each of our three outages and currently incorporates active use of the EPRI ORAM software. An overview of this program was presented to various regional personnel prior to our last refueling outage, as well as to the resident inspectors.

We also applaud the Commission's continued use of PRA information. However, we would caution that like any calculational method, PRA is susceptible to questionable assumptions.

Specifically, the regulatory analysis assumes that no increases in outage duration will occur as a result of this rule. This assumption is questionable since the single failure basis of the new rule would almost certainly result in EDG maintenance time being added to the outage critical path.

Licensees can currently perform EDG maintenance on a single train where convenient in the outage plan. We continue to believe that some credit for offsite power availability, predicated on licensee measures to control switchyard work, provides adequate planning flexibility without increasing outage risk.