ML20198Q631

Comment on Proposed Rule 10CFR50 & 70 Re Criticality Accident Requirements. Trojan Staff Recommends Proposed Rule Be Revised to Clarify Applicability for Plants That Received NRC Staff Actions

ML20198Q631
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/13/1998
From:	Stephenson C PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR63825, FRN-62FR63911, RULE-PR-50, RULE-PR-70 62FR63825-00009, 62FR63825-9, NUDOCS 9801230102
Download: ML20198Q631 (2)

Text

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00CKETED USNRC

'98 JAN 15 P4 :55 January 13,1998 Trojan Nuclear PlantOFRC: 7 5F , . : r.m Docket 50-344 [NN. [(,:p License NPF-1 Secretary, U. S. Nuclear Regulatory Commission Attention: Rulemakings and Adjudications Staff DOCKET MMER Washington, DC 20555-0001 PROPOSED RULE N 50+7o (G2FA! 63 F.t 6)

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Dear Sirs:

Proposed Rule Chanee issues

"[

The following are current rulemaking issues that may have an impact on the Trojan Nuclear Plant operations, procedures, and insurance requirements:

RIN 3150-A F87 (FR 62, No. 232, page 63825, dated December 3,1997)

" Criticality Accident Requirements" The final rule is stated to become effective February 17,1997, if no significant adverse comments are received.

Comment: A surface reading of this rule change implies that the prop sed rule would be applicable to Trojan. By letter dated, February 16,1993, PGE, however, had requested an exemption to the requirements of Part 70.24(a) and by letter, dated March 24,1993 the NRC Staff responded that an exemption was not required because the requiements of Part 70.24(a) did not apply to the Trojan Plant.

Since the previous actions by the NRC Staff relate to the applicability of the current rule to the Trojan facility, and the rule change is forward looking, to reduce the level of NRC Staff actions for plant specific exemptions to 10 CFR 70.24, the Trojan stafTis of the opinion that the rule change is not intended to apply to plants similar to Trojan. It is recommended that the proposed' rule be revised to clarify applicability for plants that have received NRC Staff actions (e.g.,

exemptions or other clarifying letters). Specifically, the final rule should have a provision that excludes from the scope of the rule any facility that has received NRC S'aff action related to the application of 10 CFR 70.24(a).

It should 1.e noted that the criteria for determining

• hat the Part 70.24(a) requirements did not I apply to Trojan in the March 24,1993 NRC letter are slightly different than the new 0

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50 62FR63925 PDR

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- requirements included in the proposed 10 CFR 50.68 that would form the basis for making Part

-70.24(a) not applicable for shutdown and operating plants.

-: .The new criteria are not particularly difficult to implement (if we understand them correctly to -

not relate to cask movement evolutions), but they would require some procedure revisions and :-

- implementation of additional controls that are not currently required (e.g., items b.1, b.5, and b.6 of the proposed 50.68). The 'backfit analysis' section of the proposed rule making does not -

i reflect these addition costs. The Trojnn facility is interested in minimizing cost for changes, ,

. particularly ones that have limited safety implications, since additional costs may impact the funds available for the decommissioning of the facility.' -

If thsee are any questions related to these comments, please contact Mr. H. R. Pate at (503) 556-

- 7480 or Mr. C. J. Stephenson at (503) 556-7465.

s

.(Retrieved from interactive rulemaking website -- ATB)

Commenter:

Carl Stephenson Portland General Electric 71760 Columbia River Highway Rainier, OR 97048 Fi i

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