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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML17313A9791999-05-20020 May 1999 Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML20081B5721995-03-0808 March 1995 Motion of Plains Electric Generation & Transmission Cooperative,Inc to Withdraw,W/Prejudice,Petition for Leave to Intervene,Request for Finding of Significant Change & for Antitrust Hearing & Comments.* W/Certificate of Svc ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML17310B1911994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc ML17310B2041994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Tx ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data 1999-09-28
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML17313A9791999-05-20020 May 1999 Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data ML20055F4531990-06-29029 June 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Modified for fitness-for-duty.Rule Unnecessary & May Adversely Affect Morale of Licensed Operators ML19327B1631989-09-0707 September 1989 Comment on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Recommends That NRC Should Not Attempt to Dictate Standardized Form of Decommissioning Trust Agreement ML20235V7101989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Rule Will Not Improve Maint,Reliability or Safety of Arizona Nuclear Power Project Plants 1999-09-28
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, o?5 00 ~, LJ u James M. Lev,ne TEL 502)393-5300 /31 Stat on 7602 Pa;o Verde Nuclear Semor Vice Prescent FAX >60'J P O Gen 52034 Generatrng Stat;on 'auc;ey g { 22 $:?3f27 i UJ Nemx. AZ e5072 2024 102-04221-JML/SAB/MLG December 11,1998 Secretary of the Commission A.,
U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 00CKEF NOW8E8 Attention: Rulemaking and Adjudication's Staff PROPOSED R H N 50
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2 and 3 Docket Nos. STN 50-528/529/530 Comments on NRC Proposed Changes to 10 CFR 50.65, Requirements For Monitoring The Effectiveness Of Maintenance At Nuclear Power Plants.
In the September 30,1998 Federal Register (63 FR 52201-52206), the NRC solicited comments on the proposed changes to 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants. APS has reviewed the proposed changes to 10 CFR 50.65 and is providing the attached comments for consideration.
APS also endorses the NEl comments on this subject. Specifically, APS supports the position that the rulemaking should be withdrawn and renoticed with a corresponding change to risk-inform the scope of the maintenance rule as described in 10 CFR 50.65(b). APS is also in agreement with the NEl position that the rulemaking should not proceed until the industry and the NRC reach an understanding of the undefined, subjective terminology used in the proposed rule, and make appropriate revisions to the rule language to codify this understanding.
APS would also recommend that Regulatory Guide 1.160 Revision 3 be issued prior to the completion of rulemaking. The regulatory guide is referenced in the proposed rule but is not available for review.
Additional comments are provided in the enclosure to this letter.
No commitments are being made to the NRC by this letter.
9812300172 981211 )
PDR PR ,
50 63FRS2201 PDR l
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3 Secretary of the Commission '
U. S. Nuclear Regulatory Commission
- Comments on NRC Proposed Changes to 10 CFR 50.65, Requirements For Monitoring i The Effectiveness Of Maintenance At Nuclear Power Plants.
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- - Please contact Mr. Scott Bauer at (602) 393-5978 if you have any questions or would like additional information regarding this matter. ;
4 Sincerely, l , ;
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! Attachment cc: E. W. Merschoff M. B. Fields J. H. Moorman W- g -.-.__m._,...s .... . . . - . , . ,. . .,, , ,.y- .-- -- , , y - - , -. -, -
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ENCLOSURE i
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l Comments on the Proposed Rulemaking i 10 CFR 50.65 i
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$ 0 Comments on the Proposed Rulemaking to 10 CFR 50.65 CHANGE 1.
Add an introductory paragraph to 10 CFR 50.65 clarifying that the proposed rule applies
- under all conditions of operation, including normal shutdown.
Prior to paragraph (a)(1), add the following wording: "The requirements of this section are applicable during all conditions of plant operation, including normal ;
shutdown operations." The intent of this paragraph is to ensure that safety assessments are performed before maintenance activities when the plants are shut
- down as well as when the plants are at power. The shutdown condition may be defined in a plant's technical specifications, but the intent of this paragraph is that shutdown is i generally considered as a time when all control rods are inserted and the average reactor coolant temperature is below 200 deg. F.
l APS COMMENT .
- 1. Although this does not conflict significantly with Palo Verde's definition of " Cold 1 Shutdown," it adds a potential regulatory expectation that will be left open to j interpretation. The proposed wording applies to Mode 5 (Cold Shutdown), as j well as Mode 6 (Refueling). The " general" statement made in the SECY 98-165 l
letter is not consistent with the real scope of concern. The proposed change should better define what " normal shutdown operations" includes. There may be significant potential for finding utilities in violation of 10 CFR 50.65 while i remaining in full compliance with Technical Specifications if this language is i adopted in 10 CFR 50.65, NUMARC 93-01 or Regulatory Guide 1.160.
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Comments on the Proposed Rulemaking to 10 CFR 50.65 CHANGE 2.
Delete the last sentence of paragraph (a)(3) and create a new paragraph, (a)(4), that requires the performance of safety assessments.
The proposed rule would remove the last sentence of paragraph (a)(3) and would add a l new paragraph, (a)(4), as follows in its entirety: "Before performing maintenance I activities on structures, systems, or components within the scope of this section I (including, but not limited to, surveillance testing, pcst-maintenance testing, corrective maintenance, performance / condition monitoring, and preventive maintenance), an assessment of the current plant configuration as well as expected changes to plant configuration that will result from the proposed maintenance activities shall be conducted to determine the overall effect on performance of safety functions. The results of this assessment shall be used to ensure that the plant is not placed in risk-significant configurations or configurations that would degrade the performance of safety functions to an j unacceptable level." Deleting the current last sentence in paragraph (a)(3) will !
remove the recommendation for performing safety assessments from the paragraph that contains the periodic, programmatic, long-term review considerations of the rule.
Creating a new paragraph, (a)(4), specifically for the safety assessment requirements would cause the assessment concept to stand as a separate entity within the maintenance rule.
APS COMMENTS
- 1. The proposed change addresses the concern that facilities were only looking at monitoring and preventive maintenance activities within the scope of 10 CFR 50.65 as being subject to the safety assessments. The term " maintenance activities" differs among utilities. APS currently refers to maintenance activities as work orders and specific maintenance jobs. In this case, the scope of the NRC use of maintenance activities correlates more closely to what Palo Verde would describe as work types (Corrective Work Orders, Surveillance Test Work Orders, Preventive Maintenance Work Orders, Deficiency Work Orders, etc.).
APS reviews all maintenance activities (i.e., work types) on System, Structures, and Components (SSCs) scoped within 10 CFR 50.65 for effects on plant operations. This is an important concept to understand if we are to consistently and correctly understand and interpret the scope of the proposed changes.
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Comments on the Proposed Rulemaking to 10 CFR 50.65
- 2. SECY 98-165 makes the following Statements:
A. The Commission believes it is necessary to explicitly require licensees to perform safety assessments prior to removing equipment from service for maintenance during all conditions of plant operations including normal shutdown.
APS Comment:
The reference to removing equipment from service is very general in nature and deviates from the normal language found in 10 CFR 50.65.
Replacing the term " equipment" with "SSCs within the scope of the rule" in this phrase would change the complexion of the entire statement and more clearly states the NRC's intent.
B. The Commission desires to clarify that the rule does apply during shutdown conditions. Regarding which activities would be preceded by a safety assessment, the Commission has recognized that, although definitions regarding maintenance activities are fairly consistent from organization to organization, there is some variation in the definition of corrective maintenance.
APS Comment:
The Palo Verde definition of activities differs significantly from the NRC's l as noted in comment #1 above. l l
- 3. The proposed change does not address situations where failure to perform l
i maintenance would have a greater impact on risk or safety functions than performing the risk significant maintenance activities.
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l l Comments on the Proposed Rulemaking to 10 CFR 50.65 i
CHANGE 3.
Define in paragraph (a)(4) the scope of the requirement for performing those assessments to be all conditions of operation including normal shutdown. The ;
proposed rule would add the following in paragraph (a)(4) to define the scope of pre-maintenance safety assessments: "Before performing maintenance activities on structures, systems, or components within the scope of this section (including, ;
but not limited to, surveillance testing, post-maintenance testing, corrective maintenance, performance / condition monitoring, and preventive maintenance),
an assoasment * *
- shall be conducted * * * ." The NRC's intent is that licensees pedorm safety assessments before all planned maintenance activities that require ,
removing from service equipment that is within the scope of the maintenance rule, as defined in 10 CFR 50.65(b) and (a)(1). The safety assessments required in this paragraph need not be sophisticated probabilistic risk assessment analyses in all '
cases. Licensees would have the flexibility to use probabilistic and/or deterministic methods, as appropriate, when performing the safety assessments required by paragraph (a)(4).
1 APS COMMENTS
- 1. The 10 CFR 50.65 proposed change does not address the quality of safety assessment tools required for the two types of safety assessments (i.e., at-power and shutdown conditions). The quality and sophistication of the safety assessment tools are important to assure appropriate analyses of plant configurations for risk management purposes.
- 2. The proposed change should consider providing guidance on documenting the limitations of assessment tools, and when operator judgment can be relied upon for safety assessment.
- 3. The proposed change does not specify if documentation of the assessment is required. If specific documentation is required to be maintained it should be discussed in the rule.
- 4. The proposed change does not define what constitutes an acceptable assessment. .;
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I Comments on the Proposed Rulemaking to 10 CFR 50.65 CHANGE 4.
Specify in paragraph (a)(4) that the safety assessments are to examine the extant plant condition and the condition expected during the planned maintenance activity. The proposed rule would include the following wording in paragraph (a)(4): "... an assessment of the current plant configuration as well as expected changes to the plant configuration that will result from the proposed maintenance activities . . .". The NRC's intent is that a reasonable safety assessment be performed The assessment may range from simple and streightforward to complex. However, notwithstanding the degree of sopnistication required for the assessment, the NRC intends that the assessment will examine the plant condition existing prior to the commencement of the maintenance activity and examine the changes expected by the proposed maintenance activity.
APS COMMENTS
- 1. The proposed rule does not provide for emergent work that, if not completed immediately, would place the plant at greater risk.
- 2. An assessment of the plant configuration may need to be updated in the event emergent work results in a configuration different from the one assessed. In such cases, the revision to the assessment must be weighted against the ur0ency of the emergent work. The proposed rule does not address expectations for revising the assessment. Such expectations would most appropriately belong in Regulatory Guide 1.160 or NUMARC 93-01.
- 3. The plant configuration should be defined as Maintenance Rule SSCs in the scope of 10 CFR 50.65.
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Comments on the Proposed Rulemaking to 10 CFR 50.65 CHANGE 5.
Specify in paragraph (a)(4) that the objective of performing the safety assessments is to ensure that the plant is not placed in risk-significant configurations or configurations that would degrade the performance of safety functions to an unacceptable level. The proposed rule would add in paragraph (a)(4) the wording to specify the NRC's expectations regarding the use of each safety assessment, as follows: "The results of this assessment shall be used to ensure that the plant is not placed in risk-significant configurations or configurations that would degrade the performance of safety functions to an unacceptable level." The NRC's intent is to require that each licensee perform a safety assessment before undertaking each planned maintenance activity and be aware of the risk issues associated with that maintenance activity. The guidance to be developed for licensees and promulgated in Regulaton/ Guide 1.160, Revision 3 (proposed), is expected to assist the industry in implementing this provision of the proposed rule, providing guidance regarding risk-significant configurations and unacceptable levels of safety function degradation.
APS COMMENTS
- 1. The 10 CFR 50.65 revision has undefined terms, such as " risk-significant configurations" and " unacceptable level" of degradation. The rulemaking should not proceed untilindustry and the NRC reach an understanding of these terms.
- 2. The proposed Regulatory Guide 1.160 Revision 3 has not been issued for comments. It needs to be available for comments in parallel with the proposed rule change. The Regulatory Guide should endorse NUMARC 93-01.
- 3. " Performance of t,afety functions" needs to be defined. The degradation of performance should be evaluated by its impact on Core Damage Frequency and Large Early Release Frequency.
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