ML20062B084

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

ML20062B084
Person / Time
Site:	Kewaunee
Issue date:	10/15/1990
From:	Evers K WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-90-120, FRN-55FR29043, FRN-56FR64943, RULE-PR-2, RULE-PR-50, RULE-PR-54 55FR29043-00078, 55FR29043-78, AD04-2-131, AD4-2, AD4-2-131, NUDOCS 9010240028
Download: ML20062B084 (2)

Text

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i October 15, 1990 Secretary of the Commission Attention Docketing and Service Branch U. S. Nuclear Regulatory' Commission Washington, D.C. 20555 Gentlemen:

Docket 50-305 Operating License DPR-43 f Kewaunee Nuclear Power Plant Comments on Proposed Rule 10 CFR Part 54 Nuclear Power Plant License Renewal i

References:

1) 55 FR 29043, Nuclear Power Plant License Renewal

2) NUREG-1362, " Regulatory- Analysis for Proposed Rule in Nuclear Power Plant License Renewal"

3) NUREG-1398, " Environmental Assessment for Proposed Rule on.

Nuclear Power Plant License Renewal"

4) NUREG-1412, " Foundation for the Adequacy of the Licensing Basis"

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5) Letter from Joe F. Colvin (NUMARC) to Samuel J. Chilk (NRC),

dated October 15, 1990.

Wisconsin Public Service Corporation (WPSC) has- reviewed the above referenced Federal Register Notice, principal supporting documents and the comments sub-mitted by the Nuclear Management and Resource Council (NUMARC). WPSC is in sup-port of NUMARC's comments and requests that you consider them carefully when <

formulating the final rule. '

Two areas that we would like to stress are NUMARC's discussion on the extent and depth of the integrated plant assessment and the requirement to compile the plant's current licensing basis (CLB). We add our concern to NUMARC's that the integrated plant assessment requirement as presently stated in Section 54.21(a) '

l of the proposed rule is too broad in scope. The existing wording will require -

evaluations more extensive than necessary to support-the conclusion that aging-

• is being managed during the renewal term.

9010240028 901015 PDR PR ,

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F Secretary of the Commission

' October 15, 1990 Page 2-The-criteria for screening systems, structures'and components (SSCs) to be evaluated is vague and could be interpreted.to include _ secondary systems which while capable of accident mitigation, are not required to perform a' safety func-tion to maintain the plant within the envelope of analyzed . conditions. The cr.iteria for determining which SSCs are to be evaluated should be set at a level to ensure that those systems whose primary purpose is to perform a safety func- '

tion are considered. Additionally, the rule should recognize that the same level of extensive evaluation.is not required to be performed on every component.

The focus of the evaluation should be to verify the ability of a component to perform its safety function. Varying levels of evaluation and documentation should be required based on the complexity of the component and the degradation mechanisms.

The second area about which we are concerned is the requirement to compile the pl. ant's CLB. The license renewal process, as'we understand it, is limited. ,

in scope to age-related degradation issues. Requesting a compiled CLB may lead ' '

to the introduction of-other issues.beyond the scope.of license renewal. Since the Commission has determined that a finding of- compliance with the plant to its CLB is not required for issuance of a renewed license, there is no basis for compiling and providing this information. Moreover, the documents which are a part of the formal NRC docket are readily available and have provided a-suf-ficient licensing basis to safely operate the plant over the original licensing term, therefore, a compilation of the plant's CLB is unnecessary.

In summary, we believe that the NRC and utilities must work towards a practical j method of license renewal which will ensure continued safe operation of the '

plants, and will be economically feasible for the utilities. An overly burden-some rule or too many uncertainties in the renewal process will- not accomplish this goal. These same factors could result in utility management not electing the license renewal option.

We appreciate the opportunity to conment on this very important proposed rule and supporting documents.

Sincerely, A

K. H. Evers Manager - Nuclear Power SLB/cjt cc - Mr. Patrick Castleman, US NRC -

US NRC, Region Ill US NRC, Document Control Desk l

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