NRC-2019-0058, Comment (1) of Anonymous on Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations
| ML19088A143 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/28/2019 |
| From: | - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 84FR6176 00001, NRC-2019-0058 | |
| Download: ML19088A143 (2) | |
Text
Page 1 of 2 SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 As of: 3/29/19 7:36 AM ADD: Thi Herrera, Gregory Suber, Lynn Ronewicz Received: March 28, 2019 Status: Pending_Post PUBLIC SUBMISSION COMMENT (1) Tracking No. 1k3-991c-dohl PUBLICATION DATE: Comments Due: March 28, 2019 2/26/2019 CITATION 84 FR 6176 Submission Type: Web Docket: NRC-2019-0058 Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations Comment On: NRC-2019-0058-0001 Biweekly Notice; Applications and Amendments To Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations Document: NRC-2019-0058-DRAFT-0001 Comment on FR Doc # 2019-02934 Submitter Information Name: Anonymous Anonymous General Comment RE: NRC-2019-0058; Doc 2019-02934; Citation 84 FR 6176 Susquehanna (the licensee) requests NRC approval (ref. ADAMS Accession ML19009A431) of a temporary change in requirements for Limiting Conditions for Operation (LCOs) to extend the completion time for planned maintenance to correct piping degradation that was not included in the original evaluated design/or configuration for their station. Their changes in LCO requirements of an extended completion time for this type of maintenance/piping replacement work should be made permanent by the licensee and NRC through the period of extended operation that remains for both units, and Aging Management Program use and the design/or configuration information of the facility are needing to be evaluated to more properly reflect these changes to the station are permanent to allow this corrective maintenance to be safely performed in the future.
If no evaluation of the design/or configuration information necessary to safely do this work under these changes in the LCO requirements is in place, either reject the Susquehanna proposal, or place Conditions on its use with an approval of the requested amendments as appropriate to allow this work to be safely performed when it is needing to be performed throughout the period of extended operation for both units. Extensive reference to beyond-design-basis, Fukushima/FLEX and severe accident management strategies for defense-in-depth are not reassuring if project and maintenance work instructions, procedures, compensatory measures, functional equipment group usage and other design/or configuration information is not evaluated and maintained in quality uses for permanent uses at the facility to allow safely doing required maintenance, or repairs on any portions of these safety systems and in connection with use of any issued amendments to their Renewed Facility Operating Licenses. A licensee that is unreasonably deferring essential work to evaluate changes to the design/or configuration information in use by an operating facility without a compensating https://www.fdms.gov/fdms/getcontent?objectId=0900006483b42136&format=xml&showorig=false 03/29/2019
Page 2 of 2 benefit to the safer operation of their units in furtherance of the safety of the public or facility, or in any manner that does not properly and materially disclose the status of that essential work until after requesting NRC approval of new requirements for LCOs is improperly using licensing documents.
The NRC should request from the licensee, (i.e., perhaps off docket for inspection, the scope of engineering/design change evaluations associated with this proposal, and their documented proof of evaluation related to use of their work instructions, station procedures and compensatory measures associated with their planned uses of this work, details/drawings regarding piping segments/components that would be within evaluated use of these LCOs extended completion times, and which require proper references of quality subject to a codified change evaluation process to reflect this design/or configuration information in use as evaluated under their aging management programs as well as a permanent change to their facility to allow this work to be safely performed in the future, through the period of extended operation of this facility.
The required design/or configuration information not yet permanently evaluated for use as established by the licensee under proper parent design/engineering controls, and by NRC review of this proposal should be considered for inclusion in new Conditions issued on their respective use of amendments to these Renewed Facility Operating Licenses before the extended completion times of these changes to LCO requirements are made effective for the remainder of the period of extended operation for both units at this facility. In this manner, the changes in the LCO requirements that are limited to these purposes can be made permanent, consistent with the licensees citation of industry precedence as reflecting the evaluated use of design/or configuration information in use by the facility, providing credibility to the determination on having No Significant Hazards Considerations (NSHCs) and reducing the risks being taken with safety of the public and facility that are unnecessary when relying upon a temporary licensing change process and regulatory correspondence descriptions of the licensees intentions to perform this maintenance safely over several years.
https://www.fdms.gov/fdms/getcontent?objectId=0900006483b42136&format=xml&showorig=false 03/29/2019