ML20237J864
| ML20237J864 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/23/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 8708260346 | |
| Download: ML20237J864 (4) | |
Text
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S A LTitAORE.
e GAS AND ELECTRIC l
CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JoscPH A.TscmwAN' VICC PatssetNT NOCLE AR ENCmOT '
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March 23,1987 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington,' DC 20555 ATTENTION:
Mr. Samuel J.- Chilk
SUBJECT:
. Comments on the Interim Policy Statement on Technical Specification Improvements for Nuclear Power Reactors t
Gentlemen:
The Baltimore. Gas and Electric (BG&E) Company appreciates the opportunity to comment on the: Interim ' Policy Statement on Technical Specification improvements.
BG&E hass actively ' supported industry efforts relating to Technical Specification.
. improvements. We have participated on both the Combustion Engineering Owners Group and the Atomic Industrial Forum's Technical Specification Subcommittees.
Detailed comments.:to the Interim Policy. Statement are enciesed as an Attachment.
The
. fo!!owing general comments are provided.
1 We support the overall language and intent of the Interim Policy Statement.
In particular, we agree with the Commission's position that Technical Specifications should focus the plant operator's attention on those plant conditions most important to safety.
Two aspects of the Interim Policy Statement merit particular attention. First, the policy statement does not address implementation by the NRC Staff. We are concerned that l
without an adequate plan for implementation, many utilities will be reluctant to commit to voluntarily apply the criteria to their existing Technical Specifications. We encourage the Commission to include in the policy statement guidance for implementation, particularly. In regard to the no significant hazards considerations determinations required by 10 CFR 50.91.
Secondly, the Commission requested comments as to whether it would be beneficial for licensees to be able to modify related portions of their Technical Specifications without having to apply all of the terms and provisions of the policy statement to all Technical Specifications. The criteria for screening Technical Specifications defined in the policy statement are valid for individual Limiting Conditions for Operation (LCOs). While the Commission should encourage individual licensees to implement all of the provisions of the policy statement, the application of the criteria to individual LCOs should not be Hoo f 8708260346 870323 PDR ADOCK 05000317 i
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o Mr. Samuel 3. Chilk
~ March 23,1987 Page 2 restricted.
Furthermore, we encourage the Commission to use these - criteria - in -
considering future generic additions to Technical Specification requirements.
Should you have any questions regarding our comments, please contact us.
Very truly yours,
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JAT/BEH/ dim Attachment-- --
cc:
D. A. Brune, Esquire
- 3. E. Silberg, Esquire A. C. Thadani, NRC rSPM;McNelli NRC T. E. Murley, NRC T. Foley/D. A. Trimble, NRC 1
O DETAILED COMMENTS ON THE INTERIM POLICY STATEMENT ON TECHNICAL SPECIFICATION IMPROVEMENTS 1.
Commission Policy:
The purpose of Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by establishing those conditions of operation which cannot be changed without prior Commission approval and by identifying those features which are of controlling importance to safety.
BG&E Comment:
We agree with the Commission policy and endorse the three criteria established to determine. the content of Technical Specifications.
2.
Commission Policy:
The NRC will give first priority in its Technical Specification improvement efforts to the review and approval of the revised Standard Technical Specifications and the plant-specific license amendment applications based on them.
BG&E Comment:
We do not feel it is the intent of the Technical Specification improvement Program to reduce staff support of individual licensee requests for Technical Specification amendments. Many of these amendments are needed in order to restart the plant, support necessary modifications, etc. As described in the policy statement, first priority will go to approval of revised Standard Technical Specifications and the plant-specific license amendment applications based on them. This position can be viewed as penalizing those licensees who elect not to amend their Technical Specifications utilizing the policy statement. We suggest this sentence be deleted from the policy statement.
The priority of review should be emphasized, but it should be reflected in the policy statement as a commitment by the Commission to provide the necessary staff to review the Owners Groups' Topical Reports and the plant-specific license amendment applications based on them. This commitment should be explicitly stated in the policy statement.
3.
Commission Policy:
Approved short-term Technical Specification improve-ments will be included in the revised Standard Technical Specifications.
BG&E Comment:
The short-term improvements should be included in the revised Standard Technical Specifications.
However, at this time, there have been no short-term improvements issued; although, an October 1,1985, Atomic Industrial Forum report identified six short-term' improvements and suggested regulatory actions. Overall, we have been discouraged with the Commission's response to these important short-term items (e.g., Definition of Operability,18-month Surveillance Requirements, Missed Surveillance, etc.) It is suggested that the NRC apply more effort to this area so short-y term improvements are available for inclusion in the revised Standard Technical Specifications. Licensees should also be permitted to adopt short-term improvements without committing to the other improvements identified in this policy statement. l
.e DETAILED COMMENTS ON THE INTERIM POLICY STATEMENT I
ON TECHNICAL SPECIFICATION IMPROVEMENTS 4
Commission Policy:
The policy statement identifies Probabilistic Risk.
Assessment (PRA) as an appropriate tool for defining requirements that i
should be retained in Technical Specifications.
Probabilistic Risk Assessments conducted to date have highlighted the four systems identified in the policy statement as significant risk contributors which may be excluded by the criteria, but on a risk basis are appropriate for inclusion in Technical Specification.
BG&E Comment:
We believe PRA is an effective tool for optimizing the content of individual LCOs and Surveillance Requirements in the Technical Specifications (e.g., Allowable Outage Times and Surveillance Test Inter-vals). However, using PRA to define which Technical Specification require-ments should be retained raises several concerns. First, the licensing basis for plants is deterministic. Secondly, potential costs associated with PRA may prohibit licensees from avalling themselves of the policy statement.
Finally,' PRAs are still in the developmental stage as an analytical tool with
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respect ' o determining which requirements should be~ retaine'd in Technical - -~ ~ ~
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Specifications. There is currently no threshold to define what constitutes sufficient risl< to merit inclusion in Technical Specifications. For the above reasons, we do not, in general, agree with using PRA for defining which LCOs should remain in the Technical Specifications Additionally, if the policy statement should recognize PRA as an appropriate, future tool for adding Technical Specifications, it should also allo.y for removal of Technical Specifications of low risk significance which would otherwise be retained by the criteria.
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