ML20058D475
| ML20058D475 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/19/1990 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR29043, FRN-56FR64943, RULE-PR-2, RULE-PR-50, RULE-PR-54 55FR29043-00097, 55FR29043-97, AD04-2-150, AD4-2, AD4-2-150, NUDOCS 9011060125 | |
| Download: ML20058D475 (2) | |
Text
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Mr. Samuel J. Chilk Serial No.:
90 465 Secretary of the Commission NL&P/DLDM:Jmj U,S. Nuclear Regulatory Commission Washington, D.C. 20555 VIRGINIA ELECTRIC AND POWER COMPANY NUCLEAR PQWER PLANT LICENSE RENEWAL PROPOSED RULE. 55 FR 29043
Dear Mr. Chilk:
Virginia Electric and Power Company endorses the Commission's efforts to codify in its regulations the process for renewing current operating licences. We have reviewed the proposed regulations, and endorse the comments submitted by NUMARC on behalf of the utility industry. Virginia Electric and Power Company also endorses the comments submitted by the Utility Decommissioning Group.
In particular we want to support the principle, on which the proposed rule is founded, that the levels of safety provided by the current licensing basis are adequate and acceptable for the renewed license. Thus, the license renewal process should be limited to the review of activities addressing age related degradation of safety systems and components needed to maintain the current licensing basis safety levels. The a
license renawal process should not offer the opportunity to review anew the bases or adequacy of the current licensing basis, or to impose new requirements on the licensees. Any such extension of the license renewal process would not only be unwarranted from the safety and regulatory points of view, but would also severely affect the economic benefits of license renewal.
Virginia Electric and Power Company also supports changing current NRC regulations (10 CFR 51.20(b)(2)) that require the preparation of an environmental impact statement (EIS) for each renewed license. There is no persuasive argument to conclude that all, or even most, license renewals will result in significant environmentalimpacts. This requirement is also at odds with previous NRC practice of I
I first preparing an environmental assessment (EA) and then, if necessary, an EIS.
Changing the regulations to allow for the preparation of an EA would be consiste,it with the National Environmental Policy Act (NEPA) requirements, and would save resources spent preparing unnecessary analyses that could delay the license renewal process.
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O Should you have any questions, please contact us.
Very truly yours,
/ lth tckM lf W. L. Stewart Senior Vice President Nuclear oc: U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station Mr. W. E. Holland NRC Senior Resident inspector Surry Power Station Mr. W. A. Horin Utility Decommissioning Group Winston & Strawn 1400 L. Street, N.W.
Washington, D.C. 20005 Mr. J. F. Colvin NUMABC e
1776 Eye Street, N.W.
Suite 300 Washington, D.C. 20006 l
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