JPN-98-052, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects

Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects

ML20198L248
Person / Time
Site:	Indian Point, FitzPatrick
Issue date:	12/21/1998
From:	James Knubel POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-63FR56098, RULE-PR-50, RULE-PR-52, RULE-PR-72 63FR56098-00049, 63FR56098-49, FACA, IPN-98-142, JPN-98-052, JPN-98-52, NUDOCS 9901040115
Download: ML20198L248 (3)

Text

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December 21,1998 l JPN-98-052 IPN-98-142 i Mr. John C. Hoyle Secretary of the Commission DW M Attention: Rulemakings and Adjudications Staff N 86 84/74. l U. S. Nuclear Regulatory Commission (G3Fk6(,o 9g)  ;

Washington, D. C. 20555-0001 l l

SUBJECT:

Indian Point 3 Nuclear Power Plant Docket No. 50-286 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 l Comments on Proposed Rulemaking Concerning 10 CFR 50.59 " Changes, Tests and Experiments" 63 Fed. Rea. 56098 - October 21,1998

REFERENCES:

1. Comments on Proposed Rulemaking Concerning 10 CFR 50.59, j Changes, Tests and Experiments,63 Fed. Reg. 56093 October 21,1998 l

2. Nuclear Energy Institute (NEI) letter to USNRC dated December 21,1998 regarding the same subject.

Dear Sir:

The Authority has reviewed the notice soliciting comments on the subject proposed rule change (Reference 1). The Authority has also reviewed the comments being submitted on behalf of the nuclear power industry by the Nuclear Energy Institute (NEI) (Reference 2). The Authority endorses and supports the position presented in NEl's letter.

Together with NEl, we commend the Commission for its initiative to address disconnects between the rule and accepted industry practice, to restore intended flexibility to licensees for t

making changes that have little or no impact on plant design or operation without prior NRC 3 approval, and to expedite rule changes to restore regulatory stability in this important area.

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As indicated in NEl's comments, the industry supports many of the proposed changes to 10 g CFR 50.59. In other areas, NEl has provided important comments and recommendations for ,

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Commission consideration, Most significantly, NEl has recommended a new approach to margin of safety that complements the other 10 CFR 50.59 evaluation criteria by focusing on design parameters associated with the integrity of fission product barriers (fuel cladding, RCS 1

~ pressure boundary and containment). I l

' The Authority looks forward to working with the Commission, NRC staff and NEl on the resolution of rulemaking issues, revision and endorsement of NEl 96-07 and a smooth transition to the new rule requirements. In addition, the Authority. encourages the Commission to pursue

longer-term improvements to 10 CFR 50.59, including better focusing its scope of applicability,

. making the rule more risk-informed and other improvements identified in Section V of the I

'- industry comments.

This letter does not contain any new commitments. If you have any questions, please contact E the Director - Nuclear Licensing, Ms. C. Faison.

Very truly yods,

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,/ . Senior Knubel Vice President and l

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/ Chief Nuclear Officer j i

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U.S. Nuclear Regulatory Commission

- 475 Allendale Road

' King of Prussia, PA 19406 l U.S. Nuclear Regulatory Comm;ssion Attn: Document Control Desk

- Mail Stop P1-137

' Washington, DC 20555 Office of the Resident inspector l U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511  !

Mr. J. Williams, Project Manager .

Project Directorate I-1 Division of Reactor Projects-l/II U.S. Nuclear Regulatory Commission Mail Stop 14 82 l . Washington, DC 20555 Mr. George F. Wunder, Project Manager l Project Directorate 1-1 Division of Reactor Projects-ll!I U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 i

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