ML041410049

Comment (1) of Scott A. Bauer on Model Safety Evaluation on Technical Specification Improvement to Eliminate Requirements to Provide Monthly Operating Reports & Occupational Radiation Exposure Reports

ML041410049
Person / Time
Site:	Palo Verde
Issue date:	05/06/2004
From:	Bauer S Arizona Public Service Co
To:	NRC/ADM/DAS/RDB
References
102-05103-SAB/TNW/GAM, 69FR23542 00001
Download: ML041410049 (2)

Text

Scott A. Bauer Department Leader Regulatory Affairs Tel: 623/393-5978 Mal Station 6 Palo Verde Nuclear Fax: 6231393-5442 P.O. Box 52034 Generating Station e-mail: sbauer@aps2r¶ iam IPgoelr A35g7c-2034 102-05103- SAB/TNW/GAM May 6, 2004 Rules and D1r-ctives Branch 0'S!r Chief, Rules and Directives Branch, 6 7f anc1Ii Division of Administrative Services, Office of Administration, Mail Stop T-6-D59, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Sirs:

El

Subject:

Palo Verde Nuclear Generating Station (PVNGS) Units 1 2 Wind 3; m

Docket Nos. STN 50-528, 529, and 530 - ' __ 0 Comments on Model Safety Evaluation on Technical Soecificati6i m Improvement to Eliminate Requirements to Provide Monthly, -

Operating Reports and Occupational Radiation Exposure Reports m Inthe April 29, 2004 Federal Register (69 FR 23542), the NRC requested public 'O comments on a model safety evaluation (SE) on a technical specification (TS) improvement to eliminate requirements to provide monthly operating reports (MORs) and occupational radiation exposure reports (ORERs) using the consolidated line item improvement process. Arizona Public Service Company (APS) is providing the following comments on the model SE.

Comment 1:

APS supports the removal of the two reporting requirements from the TSs because, as pointed out in the model SE, these reporting requirements are not required to be in TSs by 10 CFR 50.36(c)(5) and are not needed for plant safety. The removal of the reporting requirements from TSs will reduce regulatory burden with no reduction in plant safety.

Comment 2:

The model SE states that licensees who request license amendments to remove the MOR requirements from their TSs must make a commitment to provide to the NRC, using an industry database, the operating data (for each calendar month) that is described in Generic Letter 97-02 by the 21st of the month following the end of each calendar quarter.

APS suggests that as an alternative to committing to provide the operating data to the A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

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-Mffs6J Chief, Rules and Directives Branch U. S. Nuclear Regulatory Commission Comments on Model Safety Evaluation Page 2 NRC, licensees be allowed to commit to placing the reporting criteria in a licensee-controlled document, such as the Updated Final Safety Analysis Report (UFSAR) or the Technical Requirements Manual (TRM). The reporting criteria would then be highly visible to the licensee and to the NRC and, in many cases, more easily accessed as part of the plant's licensing basis documents. The reporting criteria in a licensee controlled document would be controlled under 10 CFR 50.59 instead of the licensee's commitment management program. If desired by the NRC, the model SE could specify that license amendment applications to remove the MOR requirements from TSs include a copy of the proposed licensee-controlled document changes for informational purposes.

Suggested revised Model Safety Evaluation Section 4.1 4.1 Each licensee should either commit to the following reporting criteria, or commit to add the following reporting criteria to a licensee-controlled document such as the

-;A Updated Final Safety Analysis Report (UFSAR) or the Technical Requirements Manual (TRM):

Using an industry database (such as the industry's Consolidated Data Entry AI-A[CDE] program), provide to the NRC the operating data (for each calendar month) that is described in Generic Letter 97-02, "Revised Contents of the Monthly Operating Report," by the 21st of the month following the end of each calendar quarter. This coincides with the schedule for the submission of performance indicator data associated with the Reactor Oversight Process.

The licensee has made a regulatory commitment [to add to a licensee-controlled document the criteria] to provide the requested operating data via an industry database (i.e., the CDE) by the 21st of the month (coinciding with the schedule for the submission of performance indicator data associated with the Reactor Oversight Process) following each calendar quarter.

No commitments are being made to the NRC by this letter. Should you have any questions, please contact Thomas N.Weber at (623) 393-5764.

Sincerely, SABrrNW/GAMI/ TAJW3QI.F a a cc: B.S. Mallett NRC Region IVRegional Administrator M.B. Fields NRC NRR Project Manager N.L.Salgado NRC Senior Resident Inspector for PVNGS