ML20078L215

Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors

ML20078L215
Person / Time
Site:	Pilgrim
Issue date:	02/03/1995
From:	Boulette E BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-59FR52707, RULE-PR-50 59FR52707-00048, 59FR52707-48, 95-009, 95-9, NUDOCS 9502100238
Download: ML20078L215 (2)

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g 10CFR50.67 (propostd) 00CKETED nOSTON EDISON llSHRC Pdgrim Nuclear Power Staton Rocky Hdi Road Ptymouth, Massachusetts 02360 D FEB -9 P3 '9 OfflCF W u ar <-^

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E. T. Boulette, PhD cm.f ,

Senior Vice President-Nuclear PROPOSED RULE rn 50 .

February 3, 1995 (59msalo1) BECo Ltr. #95-009 Secretary U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Docket No. 50-293 License No. DPR-35 Comments on the Proposed Shutdown Rule Boston Edison Company (BECo) does not support the issuance of the proposed rule, " Shutdown and Low Power Operations for Nuclear Power Reactors", noticed in the Federal Register dated October 19,1994 (59FR52707). We endorse the comments provided to you by both the Boiling Water Reactor Owners Group (BWROG) and the Nuclear Energy Institute. BECo has participated with both groups on shutdown and low power safety issues and in preparing the comments.

In addition, BECo has voluntarily implemented internal and industry initiatives to improve the conduct of operations during shutdown and low power situations. We will continue to review our experiences and refine our processes based on our and industry's lessons leamed. However, we believe the imposition of the proposed rule has the potential to discourage innovation and industry initiatives.

We further believe this rule's implementation will extend the average refueling outage by several days without a significant improvement in safety. Therefore, imposition of this rule is inconsistent with the NRC's intention of helping industry control costs on issues where safety is not significantly improved or impaired. Its promulgation will hamper our efforts to constantly improve refueling outage performance and to enhance nuclear generation's attractiveness in a competitive environment.

SY LLALk E. T. Boulette, PhD ETB/PMK/nas/ Rap 94/ Shutdown cc: See next page

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cc: Mr. R. Eaton, Projset Mantgsr Division of Reactor Projects - 1/11 Mail Stop: 14D1 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Senior Resident inspector Pilgrim Nuclear Power Station d

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