ML20083M870

Comment on Proposed Rule 10CFR50 Re Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactor

ML20083M870
Person / Time
Site:	Davis Besse
Issue date:	05/10/1995
From:	Jain S TOLEDO EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR9634, RULE-PR-50 60FR9634-00021, 60FR9634-21, RAS-95-00518, RAS-95-518, NUDOCS 9505220101
Download: ML20083M870 (2)

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31 DOCKETED USNRC EDISON A centenor Energy company

% MAY 15 P3:06 4 0 3eNIxxn 0FFICE OF SECRETARY 00CKETING & SERVICE BRANCH Hay 10, 1995 DOCKET NUMBER RAS-95-00518 PROPOSED RULE PR 50 United States Nuclear Regulatory Commission Secretary

-Vashington, D. C. 20555 Attn: Docketing and Service Branch Subj ect : Comments on Proposed Rule; 10 CFR 50 Appendix J, Primary Reactor Containment Leakage Testing for Vater-Cooled Power Reactors Ladies and Gentlemen:

The Toledo Edison Company, operator of the Davis-Besse Nuclear Power Station, has reviewed the proposed rule, " Primary Reactor Containment Leakage Testing for Vater-Cooled Power Reactors," published in the February 21, 1995 Federal Regis-ter (60 FR 9634). Toledo Edison supports such NRC initiatives to eliminate requirements marginal to safety and to reduce regulatory burden.

Toledo Edison offers the following comments for consideration:

1. The proposed rule notice describes the intent to provide a non-mandatory alternative to current Appendix J requirements, that is, to allow voluntary adoption of the new regulation, either in whole or by parts. Toledo Edison supports this approach since it allows the licensees flexibility in phasing in a new program as resources permit, and in concert with overall specific plant priorities.

2.Section V.B.2 of the proposed rule states that a licensee "... can adopt Option B, or parts thereof ... by submitting a notification of its implemen-tation plan and request for revision to technical specifications to the Director of the Office of Nuclear Reactor Regulation." However, on Federal Register page 9641, under item 2 of " Specific Areas for Public Comment," It is stated that:

Furtner, the NRC proposes to require that plant technical specifica-tions provide a general reference to the regulatory guide or other implementation document to ensure the prior review and approval by the NRC of licensee deviations from approved methods. This vill help main-tain a common understanding in the implementation of the performance -

based rule, and ensure adequate basis for licensee deviations.

9505220101 950510 y}j/O ,

PDR PR 50 60FR9634 PDR .

a:

. fRAS-95 00518-r '

. ^ May~10, 1995'

-Page 2 q In. order to. implement' Option B, or parts'thereof, it is likely thatsa l

' plant's existing Technical Specifications vill require revision _in order'to q avoid exceeding current TS test intervals as established by Option A (e.g., l

-24 months for Type B tests). However, to add a new requirement to the Tech- '

l nical Specifications which is already referenced in the rule itself (as pro--

posed footnote number 7).is contrary to the reduction of regulatory burden j under the Regulatory Improvement Program. ,

'The proposedLaddition to the technical specifications is contrary to the TechnicallSpecification Improvement Program as evidenced by the NRC's efforts to remove items from the technical specifications which are address-ed within regulations. For' example,'NRC Generic Letter 93-07, " Modification; of the Technical Specification Administrative Control Requirements for Emer -

' = gency and Security Plans," dated December 28, 1993,' recommended the removal of the audit of these plans and implementing procedures from the technical specifications because 10 CFR Parts 50 and 73 already contained these items.

In lieu of technical specification requirements referencing the regulatory guide or other. implementation document, Toledo Edison suggests that licen-sees add this reference into their Updated Final Safety Analysis Reports (UFSAR) for control per 10 CFR 50.71(e). Existing NRC inspection and en-forcement programs enable the NRC Staff to monitor facility changes and-licensee adherence to UFSAR commitments and take any remedial action.which may be appropriate.

3. The proposed rule notice indicates the intent to move details of Appendix J tests to a regulatory guide as guidance and also-to endorse in a regulatory  ;

guide an approved industry guideline (NEI 94-01) on the' conduct of contain- '

ment tests. The proposed rule notice further states that the NRC has in-cluded an exception to the extension of Type C test intervals up to 10 years that is proposed in the NEI industry guideline, and will limit such exten-sions to 5 years. An extension of Type C test intervals to only 5 years would be of only limited benefit to licensees operating on a 24 month fuel cycle. Consideration should be given to at least a 6 year test. interval for-Type Cl testing.

Should you have any questions or require additional information, please contact Mr. William T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.

Very truly yours, gdhusvastsj[l>fj}P**^ ,

S. C. Jain Director - Engineering and Services MKL/laj cc: L. L. Gundrum, DB-1 NRC/NRR Project Manager  ;

J. B. Martin, Regional Administrator, NRC Region'III S. Stasek, DB-1 NRC Senior Resident Inspector

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