ML25024A010: Difference between revisions

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{{Adams
#REDIRECT [[NRC-2024-0173, Comment (007) from A.M. Richards, Jr. on Behalf of STP Nuclear Operating Company on PRM-50-126 - Technical Specifications for Nuclear Power Reactors]]
| number = ML25024A010
| issue date = 01/23/2025
| title = Comment (007) from A.M. Richards, Jr. on Behalf of STP Nuclear Operating Company on PRM-50-126 - Technical Specifications for Nuclear Power Reactors
| author name = Richards A
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name =
| addressee affiliation = NRC/SECY/RAS
| docket = 05000498, 05000499
| license number =
| contact person =
| case reference number = NRC-2024-0173, PRM-50-126, 89FR92853 00007, NOC-NOC-25038346, STI: 35699492
| document type = Rulemaking-Comment
| page count = 1
}}
 
=Text=
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January 23, 2025 NOC-NOC-25038346 10 CFR 50.36 STI: 35699492 ATTN: Rulemakings and Adjudications Staff Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Comments on Petition for Rulemaking, Technical Specifications for Nuclear Power Reactors, (Docket ID NRC-2024-0173)
 
==Reference:==
Federal Register Notice (89 FR 92853) dated November 25, 2024 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.
South Texas Project Nuclear Operating Company (STPNOC) operates South Texas Project Electrical Generating Station (STPEGS) Units 1 and 2.
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. STPNOC 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.
STPNOC endorses the petition and requests that the NRC initiate rulemaking. STPNOC agrees with the problem statement and the proposed solution described in the petition. Additionally, STPNOC 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.
STPNOC 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 the changes on a "not-to-interfere" basis with the primary change to risk-inform the TS LCO selection criteria, STPNOC strongly encourages the NRC to include the changes in the rulemaking.
STPNOC also supports the proposed changes to the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors. These changes update
 
NOC-NOC-25038346 Page 2 of 2 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.
STPNOC urges the NRC to complete this rulemaking in a timely manner.
We appreciate the opportunity to provide our perspective on this important regulatory matter. If you have questions or require additional information, please contact Zachary Dibbern at zedibbern@stpegs.com or at 361-971-4336.
Sincerely, A.M. Richards, Jr.
Manager of Regulatory Affairs STP Nuclear Operating Company SIGN}}

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