ML20012C649
| ML20012C649 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/09/1990 |
| From: | Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-54FR52946, RTR-REGGD-01.099, RTR-REGGD-1.099, RULE-PR-50 54FR52946-00016, 54FR52946-16, NUDOCS 9003220323 | |
| Download: ML20012C649 (2) | |
Text
DOCKET NUMBER si.ph.n s. eram -
PROPOSED RULE M 60 N
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Consolidatu Edison Company of New York, Inc.
g, Indian Point Station gggg I {. Broadway & Bleakley /wenue March 9, 1990 Bochanan, NY 10511 f
Indian Point Unit No. 2% MR 15 P5 :02 Telephone (914) 737-8116 Re:
Docket No. 50-247 OfffCf Of SECRETARv DUCKCDNGr y y m BRANCH Secretary US Nuclear Regulatory Commission Vashington, DC -20555 Attentions-Docketing and Service Branch
SUBJECT:
NRC Proposed Rule Amending Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events Dear Sirs Consolidated Edison Company of New York, Inc.,
as owner and operator of Indian Point Nuclear Generating Station Unit No.
2, provides the following comments on the subject proposed rule.
Regulatory Guide 1.99 provides guidance to licensees for complying with the requirements of 10 CFR 50 Appendix G, regarding normal heatup and cooldown limitations for iterations within the control of the operator.
The Pressurized Thermal Shock (PTS) rule (10 CFR 50.61), however, is intended to address limits associated vith hypothetical accident transient conditions.
- Thus, the calculational methods and criteria differ significantly for the normal versus accident situations.
Application of nev, more conservative calculational-techniques to the normal heatup and cooldovn limitations addressed by Regulatory Guide 1.99, as contemplated by the proposed rule, vill necessarily cause a further narrowing of the operating vindov, as recognized by Generic Letter 88-11.
For this reason, any utilization of the NRC's proposed application of Regulatory Guide 1.99, Rev.
2 in the calculation of RT for compliance with the PTS rule for hypothetical 1-accidents vouldbeIbappropriatewithouta concurrent re-evaluation by the p
NRC of the cumulative and additive effects of the overall conservatisms underlying the analytical bases for the PTS rule. This re-evaluation should also consider appropriate revisions to the PTS screening criteria.
Only then can a valid re-evaluation of remaining vessel service life be conducted.
l Ve appreciate this opportunity to provide comments on the proposed rule.
Very truly yours, if f
9003220323 900309 g
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cc: Document Control Desk US Nuclear Regulatory Commission Hall Station PI-137 Vashington, DC. 20555 Mr. Villiam Russell Regional Administrator - Region I
'JS Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Donald S. Brinkman, Senior Project Manager Project Directorate I-1 Division of Reactor Projects I/II US Nuclear Regulatory Commission Hail Stop 14B-2 Vashington, DC 20555 Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511
-.