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| ML25024A008 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/22/2025 |
| From: | Dewhirst L Nebraska Public Power District (NPPD) |
| To: | NRC/SECY/RAS |
| References | |
| NRC-2024-0173, PRM-50-126, 89FR92853, NLS2025002 | |
| Download: ML25024A008 (1) | |
Text
From:
Olberding, Jodie Y.
To:
RulemakingComments Resource
Subject:
[External_Sender] Comments on Petition for Rulemaking, "Technical Specifications for Nuclear Power Reactors, "
(Docket ID NRC-2024-0173)
Date:
Wednesday, January 22, 2025 9:51:47 AM Attachments:
image001.png NLS2025002.pdf Please see attached from Nebraska Public Power District.
N Nebraska Public Power District Always there when you need us N152025002 January 22,2025 Secretary ATTN: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Comments on Petition for Rulemaking, "Technical Specifications for Nuclear Power Reactors" (Docket lD NRC-2024-0173)
Rulemakings and Adjudications Staff:
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. The petition was assigned Docket No. PRM-S0-126.
Nebraska Public Power District (NPPD) operates cooper Nuclear station.
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 yearc. NPPD agrccs 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.
NPPD endorses the petition and requests that the NRC initiate rulemaking. NPPD agrees with the problem statement and the proposed solution described in the petition. Additionally, NPPD 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 NRC's Strategic Plan.
NPPD also supports the petitioner's request to revise 10 CFR 50.36 to be consistent with the Commission's STS, and to remove information that is no longer applicable. While the petition proposes the changes on a "not-to-interfere" basis with the primary change to risk-inform the TS LCO selection criteria, NPPD strongly encourages the NRC to include the changes in the rulemaking.
COOPER NUCLEAR STATION P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 82s-3811 / Fax: (402) 825-5211 www.nppd.com
N1S2025002 Page 2 of 2 NPPD also supports the proposed changes to the Commission's "Final Policy Statement on Technical Specifications lmprovements for Nuclear Power Reactors." These changes update the Final Policy Statement to be consistent with the revised regulations and current terminology, and facilitate future licensing actions to take full advantage of the rule change.
NPPD urges the NRC to complete this rulemaking in a timely manner.
We appreciate the opportunity to provide our perspective on this important regulatory matter. lf you have questions or require additional information, please contact Linda Dewhirst, Regulatory Affai rs and Com pliance Manager at 402-825-541 6.
Sincerely, Brian Stander for Linda Dewhirst Regulatory Affairs and Compliance Manager ljo cc: CNS Records