JPN-88-056, Comment Supporting Proposed Rule 10CFR50 Re Advanced Notice of Proposed Rulemaking Concerning Regulatory Options for Nuclear Plant License Renewal.Supports Comments Made by NUMARC Nuplex

Comment Supporting Proposed Rule 10CFR50 Re Advanced Notice of Proposed Rulemaking Concerning Regulatory Options for Nuclear Plant License Renewal.Supports Comments Made by NUMARC Nuplex

ML20195E774
Person / Time
Site:	FitzPatrick
Issue date:	10/28/1988
From:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR32919, FRN-55FR29043, RTR-NUREG-1317, RULE-PR-50 53FR32919-00043, 53FR32919-43, AD04-1-072, AD4-1, AD4-1-72, IPN-88-048, IPN-88-48, JPN-88-056, JPN-88-56, NUDOCS 8811110062
Download: ML20195E774 (3)

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6,,sOctober 28,1988 i

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Secretary of the Commission T *w.  :.- i- ,'jj g()

U.S. Nuclear Regulatory Commission ~" 3 Washington, D.C. 20555 h F /.3.2r//'

ATTN: Docketing and Senice Branch

Subject:

Indian Point 3 Nuclear Power Plant Docket No. 50-286 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 ,

Comments on NRC Advanced Notice of Proposed Rulemaking i on NUREG 1317,

• Regulatory Options for Nuclear Plant Ucense Renewal

• 53 FR 32919 (August 29,1988) Request for Comments

Dear Sir:

ne Nuclear Regulatory Commission published an Advance Notice of Proposed Rulemaking regarding the subject oflicense renewal on August 29,1988. This Advance Notice, and the NUREG

~ document to which it referred, posed a series of quest!ons and policy optiores for public comment. l NUREG 1317,

• Regulatory Options for Nuciear Plant Ucense Renewal," has been raiewed by the i NUMARC NUPLEX Working Group and by its Licensing Subcommittee. ney have prepared a set  ;

of detailed comments which the Authority supports. '

i Many nuclear utilities are now faced with the decision of whether or not to pursue extending the l life of their plants, nis decision mu:t be made in the near term for the following rmons: nuclear I power plant licenses begin expiring in the year 2000; the construction lead time for rer acement l capacity is approximately 12 years from the decision point; and, the anticipated time required for  !

utility preparation and NRC review of a license renewal application must be taken into account. It is  !

important that the major issues oflicense renewal policy be definitively resob ed so that utilities may ,

understand the characteristics of the renev.al process before committing to it. i ne policy issues of most importance to the industry have been identified by the NTMA RC NUPLEX Working Group in a position paper, *NUMARC NUPLEX Working Group Position on Key License Renewal Policy issues," submitted to the Director of NRC's Office of Research by letter dated September 20,1988 nree issues idendfied in this paper which the Authority considers I

important in the decision making process are:

8911110062 PDR PR 081028 50 D3FR32919 PDR NO D

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2 (1) Liceming Bmis . It is essential that the "Current Licensing Basis' be used as the fundamental judgement criterion for determination of adequacy for the ren wat license.

His is necessary to permit concentration 4 the work effort on those issues that affect the continued safe operatior_ ;f the plant.

(2) Scope of Review- The NRC's review should focus on safety significant components subject to age related degradation. This review should be limited to those issues that are not treated by routine inspection, refurbishment or repla;ement.

(3) Backfit Rede . He cost benefit criteria and disciplined process of the Backfit Rule must govern the license extension process. He Backfit Rule should apply to safety enhancements during the renewal period for the same reasons it has been applied to the original period of licensed operation.

He Authority is closely following the NUMARC NUPLEX Working Group's continuing work on technical and regulatory issues related to nuclear plant license renewal. We strongly support the effort by the NRC to focus ;n this very important topic and we intend to support the NRC's activities, as appropriate.

We appreciate the opportunity to comment on the NRC's Advanced Notice of Proposed Rulemaking and would be pleased to discuss our comments further with appropriate NRC staff personnel. Shou'J you have any questions regarding this matter, please contact Mr. P. Kokolakis or Mr. J. A. Gray, Jr. of my staff.

Very truly yours, h

[ ohn C. Brons y ecutive Vice President Nuclear Generation ec: U.S. Nuclear Regulatory Commission j 475 Allendale Road King of Prussia, PA 19406 Office of the Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming. New York 13093

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l Resident Inspector's Office l Indian Point 3

.; U.S. Nuclear Regulatory Commission P.O. Box 377 y Buchanan, New York 10511 I

O Mr liarvey Abelson Project Directorate I 1

Division of Reactor Projects I/II U.S. Nuclear Regulatory Commission ,

11555 Rockville Pike Rockville, MD 20852  !

Mr. J. D. Neighbors. Sr. Project Manager Project Directorate I l Division of Reactor Projects I/II  ;

U.S. Nuclear Regulatory Commission MailStop 14B2 -

Washington, D.C. 20555 i

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