ML20058E025
| ML20058E025 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, Waterford  |
| Issue date: | 10/12/1990 |
| From: | Muench W ENTERGY OPERATIONS, INC. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR29964, RULE-PR-51 55FR29964-00002, 55FR29964-2, NUDOCS 9011060399 | |
| Download: ML20058E025 (3) | |
Text
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. o DOCKET NUMBER 2
PROPOSED RULE $ 5 /
Enterg!r (ss gc a,<fg,<
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Operat ons
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Ce,sid W. Muench
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8 00tcber 12, 1990 iM
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_m n Mr. Satuci J. Chilk Ph Sectetary of the Cormission
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U. S. Nuclear Regu'**ory Commission Wsshington, D. C.
20S55 Attention:
Docketing and Service Branch
Subject:
Proposed Nuclear Power Plant License Renewal Rule, SS Todotal Register No. 137, July 17, 1990 and 55 Federal Register No. 141, July 23, 1990
Dear Mr. Chilk:
Entergy Operations, Inc., tha licensee for Arkansas Nuclear Ono, Grand Culf Nuclear Gration und Waterford Steam Electric Station, Unit 3, has reviewod the proposed License Renewal Rule, and are pleased to provide the comments delineated in Attachment Ono.
We have discussed with the Nuclear Management and Resources Council (NUMARC) the proposed License Renewal Rule as well as evaluated the conxents prepared by NUMARC on behalf of the nuclear industry.
Entetgy Operations endorses the comments prepared by NUMARC on the proposed rule.
We appreciate the opportuulty to comment on this matter.
1 Please contact me or Robert J. Murillo, (504) 595-2831, should thate be any questions concernfng our comments.
Sincerely, p/
Th GWM/RJM/scp Attachment
~~
cc S. D. Ebneter, NRC Region II, 8. D. Martin, NRC Region IV, G. Sego, NRC-KRR, D. P. Cheary, NRC-NRR, D. L. Wigginton, NRC-NPR, T. V A~lexion, NRC-NRR, C. Poslusny, NRC-NRR, L. L. Kintner NRC'NRR, NRC Resident Inspectors Office (W-3), NRC Reoident Inspectors Office (GGNS), NRC Resident Inspectorn Office (ANO) 9011060394 401612 PDR PR 51 SSFR29964 PDR J113012'.NRC/JNAFLR-1 D$lD
- k ATTACKNENT ONE ENTERGY OPERATIONS COKNENTS ON PROPOSED RULEKAKING FOR LICENSE RENEWAL 1.
ProDosed Revisions to 10CFR2.109(a) and (b)
"Effect of Timelv Renewal Aeolication" and Proposed Revision to 10CFR50.54(bb)
" Conditions of License" These revisions introduce the terminology " sufficient application".
This terminology should be defined to give a clear indication of what constitutes " sufficient".
Replacement of this terminology with "acceotable for docketina" is suggested.
2.
Procosed Revision to 10CFR50.82(a)(1)(ii)
"Acolication for Termination of License" l
This section states that if " application for a renewed license is disapproved, an application for termination of license must be submitted within 1 year..."
This should only apply to those facilities which had ceased operations greater than 1 year prior to disapprn'tal, those which are within 1 year of license expiration, and those whose licenses have already expired.
There is no reason to require this provision for a facility that may have applied well before l
the expiration of the original license.
l l
3.
Proposed 10CFR54.17(c)
"Filina of Application" i
The maximum renewal term is 20 additional years of operation beyond the expiration of existing licenses, but not to exceed 40 years from date of issuance.
These limitations in and of themselves will limit when an application is submitted, which could be as early as 22 years before the expiration of current license (assuming that NRC will take two years for review, which is consistont with'the assumption used in 2. 09 1
proposed revisions).
l We do not see any benefits to be gained by regulating the date of applying for license renewal as proposed in 54.17(c).
i Rather, the date of issuance of the renewed license is the date to be regulated.
We recommend that 54.17(c) to be changed to str.te that a renewal application can not be submitted before 22 years of the expiration of the original license (that hs if there is a need to regulate that date) and a renewed license will not be issued before at least 20 years of the expiration of the original license..
4.
Procesed 10CFR54.21(a)(2)
" Contents of Aeolication -
Technical Infor1 nation" The term " constituent elements" needs to be defined.
5.
Proposed 10CFR54.23 - " Contents of ADplication -
Environmental Information" This section should be deferred until 10CTR51 is amended for license renewal.
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