ML072000467: Difference between revisions
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{{#Wiki_filter:Comment CLIIPs 3. The Model Application states, "I declare under penalty of perjury under the laws of the United States of America that I am authorized by [LICENSEE] to make this request and that the foregoing is true and correct." | {{#Wiki_filter:Comment CLIIPs | ||
: 3. The Model Application states, "I declare under penalty of perjury TSTF-487 under the laws of the United States of America that I am authorized by TSTF-490 | |||
[LICENSEE] to make this request and that the foregoing is true and TSTF-448 correct." This statement is not consistent with the recommended statement given in RIS 2001-18, "Requirements for Oath or Affirmation." RIS 2001-18 recommends the statement, "I declare [or certify, verify, state] under penalty of perjury that the foregoing is true and correct." Note that RIS 2001-18 states that this statement must be used verbatim. We recommend that the Model Application be revised to be consistent with RIS 2001-18. | |||
: 4. In the Notice under "Applicability," the last two sentences state, TSTF-487 "Significant variations from the approach, or inclusion of additional TSTF-448 changes to the license, will result in NRC staff rejection of the TSTF-426 submittal. Instead, licensees desiring significant variations and/or TSTF-427 additional changes should submit a LAR that does not claim to adopt TSTF-487." Should a licensee submit an application that requests adoption of TSTF-487 but includes significant variations or additional changes (for example, as part of a license amendment request to convert to the Standard Technical Specifications), it would facilitate the NRC's review for the licensee to acknowledge that the change is based on TSTF-487 so that the NRC may use the model Safety Evaluation to the extent possible. We recommend revising the sentence to state, "Instead, licensees desiring significant variations and/or additional changes should submit a LAR that does not request to adopt TSTF-487 under the Consolidated Line Item Improvement Process." | |||
: 1. To be consistent with 10 CFR 50.91(a), the title of Criterion 2 TSTF-490 should be revised to add the word "Accident" before "Previously TSTF-448 Evaluated." Specifically, it should state, "The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated." , "Revised Technical Specification Pages," should be TSTF-426 shown as optional. Many licensees do not provide retyped technical TSTF-427 specification pages in their license amendment requests. TSTF-476}} | |||
Revision as of 04:28, 23 November 2019
| ML072000467 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 07/19/2007 |
| From: | Project Engineering Consultants, Ltd |
| To: | Office of Nuclear Reactor Regulation |
| Hamm, Matthew DIRS/ITSB 415-1472 | |
| References | |
| Download: ML072000467 (1) | |
Text
Comment CLIIPs
- 3. The Model Application states, "I declare under penalty of perjury TSTF-487 under the laws of the United States of America that I am authorized by TSTF-490
[LICENSEE] to make this request and that the foregoing is true and TSTF-448 correct." This statement is not consistent with the recommended statement given in RIS 2001-18, "Requirements for Oath or Affirmation." RIS 2001-18 recommends the statement, "I declare [or certify, verify, state] under penalty of perjury that the foregoing is true and correct." Note that RIS 2001-18 states that this statement must be used verbatim. We recommend that the Model Application be revised to be consistent with RIS 2001-18.
- 4. In the Notice under "Applicability," the last two sentences state, TSTF-487 "Significant variations from the approach, or inclusion of additional TSTF-448 changes to the license, will result in NRC staff rejection of the TSTF-426 submittal. Instead, licensees desiring significant variations and/or TSTF-427 additional changes should submit a LAR that does not claim to adopt TSTF-487." Should a licensee submit an application that requests adoption of TSTF-487 but includes significant variations or additional changes (for example, as part of a license amendment request to convert to the Standard Technical Specifications), it would facilitate the NRC's review for the licensee to acknowledge that the change is based on TSTF-487 so that the NRC may use the model Safety Evaluation to the extent possible. We recommend revising the sentence to state, "Instead, licensees desiring significant variations and/or additional changes should submit a LAR that does not request to adopt TSTF-487 under the Consolidated Line Item Improvement Process."
- 1. To be consistent with 10 CFR 50.91(a), the title of Criterion 2 TSTF-490 should be revised to add the word "Accident" before "Previously TSTF-448 Evaluated." Specifically, it should state, "The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated." , "Revised Technical Specification Pages," should be TSTF-426 shown as optional. Many licensees do not provide retyped technical TSTF-427 specification pages in their license amendment requests. TSTF-476