ML121110264
| ML121110264 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/17/2012 |
| From: | Peterson A State of NY, Energy Research & Development Authority |
| To: | Boska J Plant Licensing Branch 1 |
| Boska J, NRR/DORL, 301-415-2901 | |
| References | |
| TAC ME7230, TAC ME7231 | |
| Download: ML121110264 (1) | |
Text
From:
Alyse L. Peterson [alp@nyserda.org]
Sent:
Tuesday, April 17, 2012 8:25 AM To:
Boska, John Cc:
Pickett, Douglas
Subject:
(1) State Comments: ME7230 Indian Point amendment on ASME codes Importance:
High Follow Up Flag:
Follow up Flag Status:
Flagged Good morning John, We offer the following comment on the referenced license amendment request; The second portion of the requested operating license amendment would change the scope and purpose of Surveillance Requirement 3.0.2 and would permit intervals not exceeding 2 years to be extended by 25%. This could result in a delay of up to 6 months for certain surveillances.
This proposed amendment and proposed standard is not written in clear, enforceable text. Instead, its wording and jargon could impede public understanding of the actual terms of the commitment and whether or not the commitment is measurable and enforceable. This lack of clarity could make enforcement by a federal regulator and the Department of Justice difficult. Stated differently, could this new proposed requirement be explained to a federal court jury and provide an unambiguous commitment for which there would be no doubt as to whether the operator was in compliance or not in compliance? Lack of clarity could frustrate and prevent enforcement.
New York State looks to the NRC, in its response to this application, to clarify what is understood by the Entergy proposal and provide the rationale for why deviating from the current license requirement will not result in degraded oversight or increased risks.
Sincerely, Alyse Peterson, P.E.
Senior Project Manager State Liaison Officer Designee Nuclear Coordination and Radioactive Waste Policy NYSERDA 17 Columbia Circle Albany, NY 12233-6399 t 518-862-1090 x3274 f 518-862-1091 From: Boska, John [1]
Sent: Thursday, March 29, 2012 10:20 AM To: Alyse L. Peterson Cc: Pickett, Douglas
Subject:
ME7230 Indian Point amendment on ASME codes, request for State comments by April 13
Alyse, we are close to issuing the amendment to both units at Indian Point to update their Technical Specifications (TS) to reference the updated ASME Code for inservice testing (IST) of pumps and valves. IST used to be covered in Section XI of the ASME Boiler and Pressure Vessel Code, but ASME has moved it to the ASME Code for Operations and Maintenance of Nuclear Power Plants (ASME OM Code). Changes to the NRCs Standard TS (NUREG-1431 for Westinghouse plants) were approved using our TS Task Force (TSTF) updating methods.
The changes are referred to as TSTF-479-A and TSTF-497-A. Now Indian Point is applying those changes to their plant-specific TS. Beside updating the ASME reference, it also specifies that the TS extension of 25% (SR 3.0.2) to provide flexibility in performing the tests is also applicable to IST tests if the test interval is less than or equal to 2 years.
Attached is the licensees submittal. There were no questions asked by the NRC or additional submittals. Please let me or Doug know by 4/13/12 if there are any State comments. Thanks.
John Boska Indian Point Project Manager, NRR/DORL U.S. Nuclear Regulatory Commission 301-415-2901 email: john.boska@nrc.gov