ML25024A009
| ML25024A009 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 01/22/2025 |
| From: | Scott S Northern States Power Co, Xcel Energy |
| To: | NRC/SECY/RAS |
| References | |
| NRC-2024-0173, PRM-50-126, 89FR92853 00006, L-XE-25-001 | |
| Download: ML25024A009 (1) | |
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414 Nicollet Mall Minneapolis, MN 55401 L-XE-25-001 NRC-2024-0173 January 22, 2025 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Comments on Petition for Rulemaking, Technical Specifications for Nuclear Power Reactors, (Docket ID NRC-2024-0173) By Federal Register (FR) notice (89 FR 92853) dated November 25, 2024, the Nuclear Regulatory Commission (NRC) requested comments on a petition for rulemaking submitted by Brian D. Mann on behalf of the Technical Specifications Task Force, the Pressurized Water Reactor Owners Group, and the Boiling Water Reactor Owners Group. The petition, dated September 13, 2024, requested that the NRC revise its regulations to apply risk insights to the selection of technical specifications (TS) Limiting Conditions for Operation (LCOs) and to update the regulation to be consistent with the guidance in the NRC's Standard Technical Specifications (STS). The petition was assigned Docket No. PRM-50-126. Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), operates the Monticello and Prairie Island Nuclear Generating Plants. The TS are the most visible and pervasive aspect of the NRC's regulatory oversight of nuclear power plants. The NRC and the industry have developed and implemented many risk-informed initiatives to improve the TS over the last 30 years. NSPM agrees with the petitioner that additional improvements to plant safety and operation can be made by the application of risk to the TS LCO selection criteria, which requires a change to the regulation. NSPM endorses the petition and requests that the NRC initiate rulemaking. NSPM agrees with the problem statement and the proposed solution described in the petition. Additionally, NSPM agrees that the proposed rule change supports congressional direction in the "Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024" (the "ADVANCE Act of 2024"), and the NRCs Strategic Plan. NSPM also supports the petitioners request to revise 10 CFR 50.36 to be consistent with the Commissions STS, and to remove information that is no longer applicable. While the petition proposes these changes on a "not-to-interfere" basis with the primary change to risk-inform the TS LCO selection criteria, NSPM strongly encourages the NRC to include these changes in the rulemaking.}}