ML20094Q642

Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs

ML20094Q642
Person / Time
Site:	Comanche Peak
Issue date:	11/28/1995
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR47716, RULE-PRM-50-62 60FR47716-00012, 60FR47716-12, NUDOCS 9512040020
Download: ML20094Q642 (2)

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00CKETED M USHRC EE Log # TXX 95296 File # 10010 3 3 883 '95 NOV 30 P2 :38 Ref # PRM 50 62 nlELECTRIC November 28, 6 CE OF SECRETAR'i, EllHG & SERVICE BRANCH C. Lance Terry Groep View PrenMunt. Nuclear DOCKET NUMBER Hr. John Hoyle PRM w ua Secretary. U. S. Nuclear Regulatory Commission PETrHON E Attn: Docketing and Service Branch (LOREWOh Washington, DC 20555-0001

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

REQUEST FOR PUBLIC COMMENT ON NUCLEAR ENERGY INSTITUTE (NEI) 10 CFR 50.54(a) PETITION f

REF: 1) Federal Register. Volume 60 47716 dated September 14, 1995

2) Nuclear Energy Institute (NEI) letter from l Mr. Thomas A. Tipton dated November 28, 1995 i to Secretary. Nuclear Regulatory Commission in response to 60 FR 47716 Gentlemen:

Per reference 1 Nuclear Regulatory Commission (NRC) requested public comment on the subject rulemaking petition filed by NEI. The petition requests NRC to amend its regulation regarding quality assurance (QA) programs to permit nuclear power plant licensees to change the quality program referred / described in the Safety Analysis Report (SAR) without prior NRC approval if an evaluation determines that the changes do not present a potential to degrade safety or do not result in a change to the plant Technical Specifications (TS).

Reference 2 provided the NEI response to the NRC addressing the specific eight NRC issues in the federal register notice. Based on TU Electric's review of the proposed amendment to 10 CFR 50.54(a) contained in the NEI petition, we find the proposed wording and changes to be appropriate and responsive to licensee needs.

Regulatory acce)tance of the proposed changes in the subject petition would improve t1e consistency in QA program changes submitted for NRC approval, by eliminating the ambiguity in the existing wording of 10 CFR 50.54(a). It should be noted that words such as " decrease in QA program effectiveness" are also vague and open to interpretation and offer little or no real relief to a licensee. The proposed changes in the subject petition utilize a recognized NRC process (10 CFR 50.59) to evaluate changes to QA programs for impact on safety, which was the intended purpose of the initial rulemaking in 1983. The proposed changes satisfy the original intent of the regulation and eliminate differences 9512040020 951120 PDR PRM

1. 50-62 PDR Energy Plaza 1601 Bryan Street Dallas Texas 75201 3411

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2 TXX-95296 Page 2 of 2 in opinion between licensees and the NRC Staff. These changes would encourage licensees to focus on ways to further improve their quality programs without the resource uncertainties of the current change process and also enable licensees to focus attention / resources to safety significant matters, enhancing public health and safety.

Sincerely, C. L. Terry By:

D. R. Woodlan Docket Licensing Manager JMK/jak c- Mr. T. E. Tipton, NEI s

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