NRC-2024-0173, Comment (016) from Kimberly D. Hulvey on Behalf of Tennessee Valley Authority (TVA) on PRM-50-126 - Technical Specifications for Nuclear Power Reactors
| ML25042A566 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 02/10/2025 |
| From: | Hulvey K Tennessee Valley Authority |
| To: | NRC/SECY/RAS |
| References | |
| PRM-50-126, NRC-2024-0173, 89FR92853 00016, CNL-25-037 | |
| Download: ML25042A566 (1) | |
Text
1101 Market Street, Chattanooga, Tennessee 37402 CNL-25-037 February 10, 2025 10 CFR 50.4 Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391
Subject:
Tennessee Valley Authority Comments on Petition for Rulemaking, Technical Specifications for Nuclear Power Reactors, (Docket ID NRC-2024-0173)
References:
- 1. Federal Register Notice and Request for Comment, Petition for Rulemaking, Technical Specifications for Nuclear Power Reactors, 89 FR 92853
- 2. Technical Specifications Task Force Letter to NRC, "Petition to Amend 10 CFR 50.36, 'Technical specifications'," TSTF-24-07, dated September 13, 2024 (ML24274A209)
By Federal Register (FR) notice (89 FR 92853) dated November 25, 2024 (Reference 1), 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 (Reference 2) 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.
U.S. Nuclear Regulatory Commission CNL-25-037 Page 2 February 10, 2025 The Tennessee Valley Authority (TVA) owns and operates Browns Ferry, Sequoyah, and Watts Bar nuclear plants.
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. TVA 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.
TVA endorses the petition and requests that the NRC initiate rulemaking. TVA agrees with the problem statement and the proposed solution described in the petition. Additionally, TVA 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.
TVA also supports the petitioners proposed updates to Title 10 of the Code of Federal Regulations 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, TVA strongly encourages the NRC to include the changes in the rulemaking.
TVA also supports the suggested revision to the Commissions Final Policy Statement on Technical Specifications Improvements 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.
TVA urges the NRC to complete this rulemaking in a timely manner.
We appreciate the opportunity to provide our perspective on this important regulatory matter.
There are no new regulatory commitments in this letter. If you have questions or require additional information, please contact Amber V. Aboulfaida, Senior Manager, Fleet Licensing, at avaboulfaida@tva.gov.
Respectfully, Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs & Emergency Preparedness cc:
https://www.regulations.gov Digitally signed by Edmondson, Carla Date: 2025.02.10 17:47:07 -05'00'