ML20083K034

Comment on Proposed Rule 10CFR50, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Endorses NEI Comments

ML20083K034
Person / Time
Site:	Cook
Issue date:	05/01/1995
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR9634, RULE-PR-50 60FR9634-00005, 60FR9634-5, AEP:NRC:0508AJ, AEP:NRC:508AJ, NUDOCS 9505090016
Download: ML20083K034 (2)

Text

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.}' in6ana Mictupaa Power Ces**ar i 1- O- P.O Box 16631 coueus. 0a c216 -

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USHRC ENDCANA 95 MY -5 P2 :26 ANCNf0AN  !

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OFFICE OF SECRETARY

, May 1, 1995 DOCKETING s SERVICE AEP:NRC:0508AJ BRANdh 1

Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 DCCKET NUMBER attn: Docketing and Service Branch PROPOSED RULE PR 5 o __ i Centlemen: N Donald C. Cook Nuclear Plant Units 1 and 2 COMMENTS ON THE PROPOSED RULES, PRIMARY REACTOR CONTAINMENT LEAKAGE TESTING FOR WATER-COOLED POWER REACTORS 1 FEDERAL REGISTER /VOL. 60, NO. 34 The purpose of this letter is to provide comments regarding the I subject proposed rulemaking. In evaluating the proposed rule, we have also reviewed and hereby endorse the comments prepared by the Nuclear Energy Institute (NEI). In that regard, we believe that the proposed amendments to Appendix J of 10 CFR 50 will lead to a substantial and supportable reduction in the frequency of containment system and component testing. We would, however, like to draw particular attention to two issues of concern that are addressed in the NEI comments and which we feel should be reconsidered prior to 1.esuing the final rule.

l 1. Reconsider the requirement to change Technical  !

Specifications due to the rule change. Requiring separate Technical Specification amendments prior to .icensee implementation of performance based criteria will place an unnecessary administrative burden on both the NRC and the licensees to implement a program that was designed to l eliminate prescriptive requirements in the first place. A l simple notification to the NRC regarding the Appendix J option that a licensee chooses to utilize should be sufficient and traceable because it will be part of the individual licensee's docket, and; l

2. Reconsider the requirement to perform containment visual inspections at shorter intervals than recommended for the i Type A test. The NRC analysis (Draft NUREC-1493) concluded l that Type A tests, including the visual inspections, are i burdensome and yield insignificant safety benefits.

Therefore, the proposed requirement to continue performance of such examinations three times every ten years seems unnecess:,ry to reasonably assure public health and safety.

9505090016 950501 PDR PR 50 60FR9634 PDR hh

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4 Secretary AEP:NRC:0508AJ We appreciate. this opportunity to offer our comments on the  !

proposed amendments to Appendix J of 10 CFR 50. I sincerely, 4

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1. E. E. Fitzpatrick  ;

Vice President i sah l cc: A. A. Blind l G. Charnoff l J. B. Martin - Region III  ;

NFEM Section Chief -!-

NRC Resident Inspector - Bridgman ,

J. R. Padgett l l

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