ML20206C866

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Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317 Concerning Regulatory Options for Nuclear Power Plant License Renewal.Renewal Processs Should Be Based on Plant Current Licensed Basis & Evaluation of Pertinent Components
ML20206C866
Person / Time
Site: Palo Verde  
Issue date: 10/27/1988
From: Karner D
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
References
FRN-53FR32919, RTR-NUREG-1317, RULE-PR-50 53FR32919-00055, 53FR32919-55, NUDOCS 8811160440
Download: ML20206C866 (1)


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Division of Safety Issue Resolution Office of Nuclear Regulation Research U. S. Nuclear Regulatory Commission Washington, D.C.

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Subject:

Comments on NUREG 1317 Regulatory Options for Nuclear Plant License Renewal File: 88-003-419.06 Gentlemen:

This letter is in response to your Advanced Notice of Proposed Rulemaking for the subject NUREG. While our three nuclear units at Palo Verde have just begun operation and we will not be applying for license renewal for a long time, resolution of the license reneral question is a very important industry issue. The NRC should proceed expeditiously in considering comments and completing rulemaking so that the industry requirements are clearly known.

We have reviewed the NUREG and wish to express our wholehearted endorsement of the comment letter issued by NUMARC.

In particular, we believe the license renewal process should be based on a plant's current licensed basis along with an evaluation of the pertinent components, systems and structures affected by age related degradation. We have serious concerns with the other two options.

Thank you for the opportunity to respond to the Advanced Notice.

Very truly yours, x

D. B. Karner Executive Vice President DBK/ACR/dlm l

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