ML20245K194
| ML20245K194 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/16/1989 |
| From: | Bram S CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-54FR19379, RULE-PR-170, RULE-PR-50, RULE-PR-72 54FR19379-00208, 54FR19379-208, NUDOCS 8907050047 | |
| Download: ML20245K194 (2) | |
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Coneohdated Edison Company of New York, Inc.
OP.y[.E' Indian Point Station h Nra.
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y Broadway & Blealdey Avenue I
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Bur.hanan, NY 1D511 To'ephone (914) 737 8116
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. June 16, 1989 Orrn. - D
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Re:
Indian Point Unit N6V@E DC e. S IW Docket No. 50-247 Secretary US Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch
SUBJECT:
Comments on Proposed Changes to 10 CFR Parts 50, 72 and 170 Regard'.ng Storage of Spent Nuclear Fuel in NRC Approved Storage Casks tt Nuclear Power Reactor Sites Consolidated Edison Company of New York, Inc. (Con Edison), as owner and operator of the Indian Point Nuclear Generating Station Units 1 and 2, is pleased to submit comments on the proposed revisions to 10 CFR Parts 50, 72 and 170 as published in the May.5, 1989 Federal Register (54 Fed Reg 19379).
In the second paragraph of the " Safeguards" discussion (page 19382), it is stated that "no specific safeguards measures to protect against theft are preposed other than maintaining accounting records and conducting periodic inventories of the special nuclear material contained in the spent fuel." The term " periodic inventories" is unclear. This statement could be interpreted as requiring periodic opening of the casks, which is not the intent of storing spent fuel in casks.
This statement should be changed to clarify the intended requirement.
In addition, Section 72.236, item (c) of the proposed rule states:
"(c) The cask must be designed and fabricated so that the spent fuel is maintained in a subcritical condition under credible conditions."
The term " credible conditions" should be defined and examples and/or references provided.
9907050047 890616 PDR PR g4h19379
i' We appreciate the opportunity to comment on the proposed changes.
If you
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or your staff have any questions on the above comments, please contact Mr. Jude G. Del Percio, Manager, Regulatory Affairs.
1 Very truly yours, d
<A cc:. Document Control Dest US Nuclear Regulatory Commission Mail Station F1-137 Washington, DC 20555 Mr. William Russell Regional Administrator - Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1498 i
Mr. Donald S. Brinkman, Project Manager Project Directorate I-1 Division of Reactor Projects I/II US Nuclear Regulatory Commission Mail Stop 14B-2 Washington, DC 20555 l
Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511 i
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