ML20077G348
| ML20077G348 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/08/1994 |
| From: | Quinn S CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-59FR46574, FRN-60FR22461, RULE-PR-2, RULE-PR-51, RULE-PR-54 59FR46574-00027, 59FR46574-27, AF05-2-030, AF5-2, AF5-2-30, NUDOCS 9412200089 | |
| Download: ML20077G348 (2) | |
Text
M DOCKET NUMBER y7 Stephen E. Quino gggg gg $ yf/ pH vic. e,..io.ni G'lFfl'l65W) 00CYE 10 Consolidated Edison Cornpany of New York. Inc.
y
- y inWan Point Station December 8,1994 "
. Broadway & Bleakley Avenue Buchanan, NY 10511 Telephone (914) 734-5340 94 DT 12 P312 Mr. John C. Hoyle OFF.J F " r TARY o
Office of the' Secretary of the Commission DOM NhG n_
af,, ;r" US Nuclear Regulatory Commission BRM'a Washington, DC 20005
SUBJECT:
Nuclear Power Plant License Renewal; Proposed Amendments 59 Fed. Reg. 46574 (September 9,1994)
Dear Mr. Hoyle:
Consolidated Edison Company of New York, Inc., owner and operator of Indian Point Unit No. 2,is pleased to comment on the proposed amendments to 10 CFR Part 54 pertaining to license renewal as set forth at 59 Federal Register 46574 (September 9,1994). Con Edison commends the efforts of the Conunission to further develop a license renewal regulatory program which will provide a technically justifiable approach to extended plant operation and assure a more efficient, stable, and predicable regulatory process.
Con Edison respectfully submits that in connection with its revisitation of Part 54 the commission should supplement its Statement of l
Considerations to explicitly acknowledge the full applicability of the backfit rule,10 CFR 50.109, to the Part 54 process. The " compliance" (10 CFR 50.109 (a)(4)(1)) and " adequate protection" (10 CFR 50.109 (a)(4)(ii)) provisions of the backfit rule provide ample assurance that license renewals and post renewal facility operations will occur in full accordance with the requirements of the Atomic Energy Act. An omission of 10 CFR 50.109 applicability to the Part 54 process, on the other hand, would fall to recognize the efficacy of programs to manage the effects of aging during the initial license term, and could in practice be at odds with the goal of a stable and predictable regulatory process in this important area. Existing licensee programs, maintenance activities and associated Commission oversight, and in-service inspections in various ways and degrees all address equipment aging effects during the initial 40 years of operation, and recognize that aging requires attention and management at times other than the 41st year of operation. Regulatory oversight of these activities during the initial license term is subject to the discipline of 10 CFR 50.109, and particularly with the deletion ARDUTLR (age related degradation unique to license renew) there is no logic for creating a hiatus in the otherwise consistent and uniform application of this important rule.
Directing the uninterrupted application of 10 CFR 50.109 is also entirely censistent with the principle shared by licensees and the Commission that equipment aging management must occur throughout the service life of a facility.
9412200089 941200 PDR PR 2 59FR46574 PDR O
3.3 I
e t
ji 3
, y[
y,
- \\
L 's Con Edison also wishes to identify itself with the comments on the subject proposed amendments as submitted by the Nuclear Energy Institute (NEI),' which we support and endorse. ' Con Edison appreciales the opportunity to comment on an important regulatory program
.q affecting the nation's energy supply in the decades to come.
i 1
' Very, ly youn, -
/
j./
cc:
- Document Control Desk '
US Nuclear Regulatory Commission l
Mall Station P1-137.~
~
- Washington, DC 20555 i
Mr. Thomas T. Martin 1
Regional Administrator - Region I US Nuclear Regulatory Commission 475 Allendale Road.
j King of Prussia, PA 19406 Mr. Francis J. Williams, Jr., Project Manager Project Directorate I-1 Division of Reactor Projects I/II US Nuclear Regulatory Commission Mall Stop 148 2 Washington, DC. 20555 Senior Resident inspector...
US Nuclear Regulatory Commission PO Box 38 Buchanan,-NY 10511.
9
'%t e
-