ML20138J610

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Forwards Util Analysis of Status of Radiological Controls Program & Licensing Activities for 10-yr Inservice Insp at Conclusion of 1984 Refueling Outage,Per NRC Transmitting SALP Rept for Aug 1984 - Jul 1985
ML20138J610
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 11/13/1985
From:
CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To: Murley T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20138J435 List:
References
NUDOCS 8512170587
Download: ML20138J610 (2)


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ENCLOSURE 4 S

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Consolidated Edison Cornpany cf New York. Inc indian Point Staton Broadway & Bleakley Ave.

Buchanan. NY 10511 November 13, 1985 Telephone (914) 737-8116 Re:

Indian Point Unit No. 2 Docket No. 50-247 Dr. Thomas E. Murley Regional Adninistrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Murley:

Your letter of October 11, 1985 which transmitted NRC's Systematic Assess-ment of Licensee Performance report for the period August 1, 1984 to July 31,~1985, at the SALP meeting on October 25, 1985, invited Con Edison's written comments on the report.

Attached is Con Edison's analysis of the status of the radiological con-

. trols ' program and of licensing activities for the ten-year inservice inspection.at the conclusion of the 1984 refueling outage.

We look forward to the results of subsequent assessments and fully expect continued improvement in all areas.

Very truly yours, I

MB:vms Attachment cc: Senior Resident Inspector U.S. Nuclear Regulatory Commissior P.O. Box 38 Buchanan, NY 10511 Steven A. Varga, Chief Operating Reactor Branch No. 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 15.198.11.8.2 U/e3 /78 $"87 WAl./$

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November 13, 1985 Re: Indian Point Unit No. 2' Docket No. 50-247 ATTACHMENT

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Radiological Control As'we explained orally at the SALP meeting, significant progress has been made to improve radiological controls at Indian Point 2.

- We'do not feel:that the SALP rating recognizes the extent to which our performance has improved; however, we agree that the upcoming refueling outage. will clearly demonstrate the degree of effectiveness of the new procedures.

Licensing Activities

- During ' the. SALP meeting, Con Edison expressed concern with.the manner in which the discovery of an ultrasonic i'ndication in the reactor vessel was reported in.the-SALP report. Our concern is that in the absence of a full knowledge of the facts of the situation, the paragraph in the _SALP report could lead; to an erroneous conclusion that _ the licensee's actions were somehow improper or. insufficient and also that due to this, it was neces-sary to impose augmented inspection.

In fact the' licensee is bound by the industry codes imposed by the license and we followed ' those codes precisely. We believe that the staff agreed with us on this point'at the SALP meeting and that it was not the intent of.

the SALP report to imply differently.

We believe the staff also agreed with us that'the subject of " sufficiency" of. data is not defined in the codes which we are committed to and therefore should not-be the basis for evaluating licensing activities.

- With _ respect to the above we believe that the staff agreed that some revision to the fourth paragraph on page 30 would be appropriate. Also it is our understanding that the first sentence of the fourth' paragraph would be -relocated sitice it does not refer to the reactor vessel.

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