View source for JPN-88-002, Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed

{{Adams
| number = ML20195K290
| issue date = 01/25/1988
| title = Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed
| author name = Brons J
| author affiliation = POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
| addressee name = 
| addressee affiliation = NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000000, 05000286, 05000333
| license number = 
| contact person = 
| case reference number = FRN-52FR45344, RULE-PR-50
| document report number = 52FR45344-00006, 52FR45344-6, IPN-88-002, IPN-88-2, JPN-88-002, JPN-88-2, NUDOCS 8802040127
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 2
}}

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JPN-88-002N6-IPN-88-002 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.        20555 ATTN:      Docketing and Service Branch

==Subject:==
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Indian Point 3 Nuclear Power Plant Docket No. 50-286 Comments on NRC Proposed Policy Statement on Integrated Schedules for Implementation of Plant Modifications

==Dear Sir:==

This letter provides the Power Authority's comments on the proposed policy statement "Integrated Schedules for Implementation of Plant Modifications", published in the Federal Register, dated November 27, 1987 (52 FR 45344).
The Authority agrees with the proposed policy that integrated schedules for regulatory requirements and other improvements should be established on a voluntary basis.
The integrated schedule is an excellent tool for resource allocation.       It prioritizes activities necessary for safe, reliable, and efficient power generation. The Authority also agrees with the major elements to be addressed in an integrated schedule plan. The list of elements contained in the policy statement is inclusive without being unduly prescriptive.
The Authority has concerns about the integrated schedule as a license amendment. According to the proposed policy, the intent of the integrated schedule license amendment is to assure the timely scheduling and completion of regulatory modifications. The policy states l
that if a new NRC requirement is imposed, no schedule f                    exemption would be required.        This statement requires elaboration. The policy statement should clearly state 8802040127 880125 PDR   PR p/3              ,
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that new regulatory requirements will not impose an implementation date on plants having an integrated schedule license amendment. The policy statement should also say that new regulatory requirements will specify that these plants should propose a date in accordance with their integrated schedule, for NRC approval.
Plants with an integrated schedule plan submitted to the NRC, but without a license amendment, can have implementation dates imposed. These plants can use the integrated schedule as a negotiating tool, but they would still require schedule exemptions if they could not meet the imposed dates. Gr' dance, regarding the amount of information or the lei     of detail required to support a schedular exemption, should be included in the policy statement.
Should you have any questions regarding this matter, please contact Mr. J. A. Gray, Jr. of my staff.
Very truly yours,
                                  /I b     w d(o n  . Brons
                                 /   Executive Vice President Ruclear Generation
(
cc:  U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA     19406 l          Office of the Resident Inspector l          U.S. Nuclear Regulatory Commission i          P.O. Box 136 l          Lycoming, New York    13093 Mr. Harvey Abelson Project Directorate I-1 Division of Reactor Projects-I/II U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014 l
Resident Inspector's Office Indian Point 3 U.S. Nuclear Regulatory   Commission P. O. Box 377 Buchanan, New York    10511 Mr. J. D. Neighbors, Sr. Project Manager Project Directorate I-1 Division of Reactor Projects - I/II U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014}}