ML20095A846
| ML20095A846 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/28/1995 |
| From: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-60FR47716, RULE-PRM-50-62 60FR44716-00017, 60FR44716-17, NUDOCS 9512080043 | |
| Download: ML20095A846 (2) | |
Text
.
6 DOCKETED llSNRC Arizona Public Service se s Ju^@a"s's"us'o"s"o'Ao"To'wWs?4%iEnfe"5354-7629'95 DEC -7 P3 :20 102-03558-WLS/AKK/ACR moet sTowAa7
'"7?cie'll"*'"'
November 28,1995 0FFICE UF SECRETARY 00CKETitiG 1 SFW:E BRANCH Mr. John C. Hoyle Secretary of the Commission Attention: Docketing and Service Branch 4
U. S. Nuclear Regulatory Commission PumM4 RULE _
dooFR.A11N @
Washington, DC 20555-0001
Dear Mr. Hoyle:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3 Docket Nos. STN 50-528/5291530 Comments on Petition for 10CFR50.54 Rulemaking (60 Federal Register 47716)
On September 14,1995, the Nuclear Regulatory Commission (NRC) requested public comment on a petition for rulemaking filed by the Nuclear Energy Institute (NEI) on behalf of the nuclear power industry. The notice in the Federal Register pertained to proposed changes to 10CFR50.54 which would achieve more consistency in the regulations by making 50.54 more like 10CFR50.59.
Arizona Public Service Company (APS) participated in activities that resulted in NEl submitting the petition. APS is an active member of the Appendix B Working Group.
The Appendix B Working Group initiated the NEl's activities that focused on the need for changes in 50.54. The Appendix B Working Group provided oversight, fostered comments, and contributed guidance as NEl drafted the petition.
APS endorses the industry petition and the response to the petition provided by NEl.
Of specific interest to APS is that the proposed rule focuses both utility and regulatory resources on changes which have the greatest potential to impact safety. The petition proposes a change which eliminates the use of a poorly defined reduction in commitment" philosophy to determine the need for NRC review of proposed changes prior to implementation. Instead, the petition provides a method which ensures the NRC is periodically informed of changes to a licensee's OA Program, that safety significant changes receive appropriate evaluation, and that those changes that have the potential to degrade safety (i.e., unreviewed safety questions as determined using existing 10 CFR 50.59 regulation and industry guidance) will receive the appropriate level of NRC review and approval prior to implementation.
9512000043 951128 PDR PRM 50-62 pon f*
,k.'
e 2
l Mr. John C. Hoyle.
[
j U. S. Nuclear Regulatory Commission Comments on Petition for 10CFR50.54 Rulemaking j
Page 2 The petition also interfaces well with recently endorsed guidelines related to
- management of NRC commitments which allow for licensees to evaluate and modify i
i commitments using criteria that eliminates unnecessary regulatory interface, yet provides for periodic notification of changes to commitments so that appropriate regulatory oversight can be applied. Provisions to add a " reduction in effectiveness l
clause" or other NRC guidance, as implied in the Federal Registrar "6p6cific Areas for.
)
Public Comment" items 4, 5,6, and 7, would not address the root cause of the problems experienced in implementing the regulation, nor would they support our 2
]
mutual goals of improving consistency and efficiency of the regulatory process.
. NEl has included in the industry response suggeste ad t ona gu ance w chi h is d
dii l
id j
intended to supplement the NSAC-125 guidance for 50.59 Evaluations. This additional guidance is based on the NRC's comment that "...NSAC-125 deals principally with evaluating changes associated with nuclear plant equipment and not programmatic l
centrols." The NRC should recognize that many 50.59 Screenings and Evaluations j
[
involve proposed procedure changes. Procedure changes can and often do require i
research of programmatic commitments that may be found in the Safety Analysis Report or other Licensing Basis documents. Therefore, based on the fact that programmatic changes have been made using 50.59 since it became a regulation, APS j
believes that application of a similar process for quality assurance program changes i
could be done without additional programmatic guidance. The addition of a guidance j_
document would detract from the goal of consistency in the change process, i
Should you have any questions, please contact Ms. Angie Krainik at t
(602) 393-5421.
V l
Sincerely,
/7 A-h i
1 WLS/AKK/ACR/rv i
l cc:
W. H. Rasin - NEl h'
1-s w.
,.-...._.n
--