ML20045G360
| ML20045G360 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Crane |
| Issue date: | 07/09/1993 |
| From: | Mascari C GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| FRN-59FR5934 AE39-2-083, AE39-2-83, C311-93-2105, C312-93-2052, C321-93-2192, NUDOCS 9307130245 | |
| Download: ML20045G360 (2) | |
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i GPU Nuclear Coms.ouon arsi pan, t Jers y07054 201-316-7000 TELEX 136-482 Writers Direct Dial Number.
July 9, 1993 C311-93-2105 C312-93-2052 C321-93-2192 U. S. Nuclear Regulatory Commission Att: Document Control Desk Washington, DC 20555 Gentlemen:
Subject:
Three Mile Island Nuclear Station Unit 1 (TMI-1)-
DPR-50/ Docket 50-289 Three Mile Island Nuclear Station Unit 2;(TMI-2)
DPR-73/ Docket 50-320 Oyster Creek Nuclear Generating Station (OC)
DPR-16/ Docket 50-219 Proposed Rule Change to 10 CFR Part 55, " Operators' Licenses" We have. reviewed the proposed rule change and the following is our comment.
No purpose or benefit to requiring utility submittal of constructed annual or biennial examinations to the NRC "at least 30 days prior to conducting sur.h test" is provided. This requirement will add administrative burden and interfere with the utilities ability to modify the examinations in progress based on feedback from the examination process.
Examinations are typically spread over a 6 week period requiring multiple submissions. The codification also leaves many questions open regarding re-examination submittal and administration. The requirement should be deleted from the rule change.
If a need for a requirement exists in this area, then change 10 CFR 55.59 para. (c) wording to:
..shall submit a. copy.of each comprehensive requalification written examination or-annual operating test to the appropriate Regional Administrator within 90 days of the completion of the. facility examination annual or biennial examination period."
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Q GPU Nuclear Corporation is a subsidiary of General Public Utikties Corporation
C30.1 2105
/ C312-93-2052 C321-93-2192 Page 2 Additional submittal requirements to support specific inspections can be incorporated into the inspection procedures and need not be codified.
If you have any questions concerning our comments, please contact Mr. John Fornicola, Licensing and Regulatory Affairs Director at (201) 316-7334.
Sincerely, bs C. A. Mascari Vice President and Director, Nuclear Assurance CAM /JCF/ pip cc: Administrator, Region 1 Oyster Creek NRC Project Manager TMI NRC Project Manager Senior NRC Resident Inspector, OC Senior NRC Resident Inspector, TMI i
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