ML20059P063

Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC

ML20059P063
Person / Time
Site:	Millstone, Haddam Neck  File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/15/1990
From:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-55FR29043, FRN-56FR64943, RULE-PR-2, RULE-PR-50, RULE-PR-54 55FR29043-00064, 55FR29043-64, AD04-2-117, AD4-2, AD4-2-117, B13656, NUDOCS 9010250088
Download: ML20059P063 (2)

Text

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l u a 55'FR b i Re Request for Consents Mr. Samuel J. Chilk, Secretary Docketing and Service Branch U.S.' Nuclear Regulatory Comission Mail Stop 16 815 Washington.-DC 20585 ri li

Dear Nr. Chilk:

Haddam Neck Plant Millstone Nuclear Power station. Unit Nos. 1.t. and 8 Nuclear Power Plant License Renewal Compants an Peenenad Rula ConnecticutL Yankee Atomic Power Company (CYAPCC)' and Nsrtheast Nuc1 ear Energp Company (NNECO)'. submit the following coments in-response to the request-ed the NRC for comments on the proposed rule relative 'to nuclear.' power: Blant,

license renewal (55 FR 29043). Atditionally, these comments:are'a licable the principle supporting documents NUREG-1412, " Foundation for t e Adequ.to acy of tne Licensing Bases ;- NUREG 13d8, ' Environmental Assessment for: Pro sed Rule on Nuclear Power. Plant License Renewal' and NUREG-1362

'Regul tory Analysis for Proposed Rule on Nuclear Power Plant License Renewal'.'

CYAPCOandNNECOwish In addition to-the comments >rovided in this letter, Nuclear Utility Group,te endorse:those comments prov' dad to the. NRC the-on Equipment - Qualification :(NUGEQ),v the Nuclear : tility Backfitting and-Reform Group -(NUBARG),. and: the Nuclear Management = and Resources. Council:NU on this : issue.E -Additionally, combined efforts of all utilities licensed by the N8tC to construct or operate nuclear power plants in all matters involvine this proposed rule as well. as matters involving' generic regulatorv p:my issues affecting the nuclear powsP.

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. NUMARC has artic' atedln licensee renewal activities on behalf of-the_nue ear industry f r the est 3 years.

Ovarall, CYAPC0 and NNECO support the NRC's development of this rulemaking. '

The importance of and the benefits derived from'this rulemaking will ensure

-the continued viability of the nuclear option-and represents a stabilizine factor in: an-often unpredictable regulatory environment.

It' is CYAPC0; ena NNECO's belief that the NRC Staff has developed the framework for a werkable, go2goBe901015

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'Mr. Samuel J. Chilk 813688 Octobe/Page2 r 15 1990 practicable and demonstrable renewal process that' focuses en continued safety 1

and adequate protection of the public health and safety. With respect to thia l

position, however, we would like to emphasiae our concern that the within thess perspectives that comments pursuit of license rene itself does not become a barrier to the It 1s.

are offered on the NRC's proposed rule.

y NUMARC,'NUGEQ, and NUBARO have-provided the NRC with.an.in depth evaluation j

and justification for the comments they have submitted on-behalf of the I

nuclear = industry. ~1n addition to1 endorsing-those comments submitted by the above utility groups CYAPC0 and NNECO offer the following 1-CYAPC0 and NNEC0 agree with the NRC staff's conclusion' that the public i

health and safet will-be adequately-protected by utilizing the current 1

licensing basis. CLB) as the criteria.for determining whether' operating licenses should renewed..Our most significant concern with the use of 1

the license r,enewal application.CLBs. however is the. proposed freeze of-tho' CLB.during the pendency of Because CL8s continually change over-i time to accommodate new safety information: and to comply: with. new l

requirements, a moratorium on such changes during the-license renewal application review introduces an artificial and ill-advised constraint.

2.

The proposed rule would require age-related degradation of the facility's -

j systems. -structures, and components to be ?dentifled,- evaluated and 1

accounted for as needed to. ensure the CLE remains valid /through the renewal period.

This is to be done utilizins an integrated plant assess-ment (IPA)have concerns that the IPA as(4? of the proposed rule.

contained in Section 54,21

.CYApC0 and NNECO tetailed in the proposed rule may be too broad and the-depth of evaluations may. be:more extensive.than necessary to ensure' that age related degradation. is being-effectively With respect to this, We endorse-NUMARC's position that the managed.

methodology developed by the industry entitled'%thodology-to Evaluate Plant Systems, Structures, and Components-for License Renewal ' previ-l ously submitted to the NRC ~$taff for review and comment, is a: sere appropriate mechanism and a more acceptable method of completing the l

integrated plant assessment.

3.

With respect to the applicability-of the backfit rule as presented in'the statement of considerations, CYAPC0 and NNEC0 believe the madority of the Staff'st views are in line with our thinking.

The Staff siouls not be l

encumbered by additional-justification requirements. en matters truly related to adequate protection or~ compliance.

It does seen-reasonable however differen,t.but equivalent ways, that the choice of the most cost e option should - be permitted.

It is also reasonable that proposed'new requirements which may go beyond matters of adequate protection or com111ance with the Ticensing' basis should be fu'1y justified under 20CfR50.109.

As previously discussed, the proposed rule " freezes' the CLB for the duration of Staff review and could result in-imposing

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Mr. Samse'l J. Chilk Bil655 Octobe/Page 3:

r15,1990 comply with regulations-and operate t-plant. safely changes to the CLB.

i We appreciate the opportunity to consent on this proposed rule and.supportin documents and we trust you will-find.these comments valuable in establishing final regulation a

--you at _your conve.- As always, we remain. available to discuss this matter with nience.

i Very truly yours, CONNECTICUT YANKtt ATONIC POWER COMPANY NORTHEAST NUCLEAR ENERGY CONRANY FOR:

E, J. Mroeska Senior Vice President BY1 g, F, 3sart i

Vice Presid%At T. T. Martin Region 1 Administra cc M.L.Boyle,,NRCProjectManager, tor k

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4. S. Vissing, NRC Pro.iect Manager,illstone Unit Me. 1-Millstone Unit No.it' A. B. Wang,,NRC Project Manager,,Haddam Neck PlantD. H.

W. J. Raymond Senior Resident Inspector, Millstone-Unit Nos. 1, 8, and 8 J.-T. Shedios

, Senior. Resident Inspector, Haddam Neck Plant

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