ML20077M618

Comment Re Proposed Rule 10CFR50 Re Low Power Operations for Np Reactors.Util Believes That Pr Will Have Higher Impact than Described in Regulatory Analysis,As Pr Will Extend Refueling Outages at All Plants

ML20077M618
Person / Time
Site:	Monticello, Prairie Island
Issue date:	12/30/1994
From:	Andersen R NORTHERN STATES POWER CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR52707, RULE-PR-50 59FR52707-00020, 59FR52707-20, NUDOCS 9501130121
Download: ML20077M618 (2)

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Office of the Secretary of the Commission Attn: Docketing and Service Branch U S Nuclear Regulatory Commission Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT PRAIRIE ISLAND NUCLEAR GENERATING PLANT Comments on Proposed Rule: Shutdown and Low-Power Operations for Nuclear Power Reactors Northern States Power Company has reviewed the proposed changes to 10 CFR Part 50, Section 50.67 " Shutdown and low-power operations", and would like to offer the following comments.

First, we have evaluated the impact of the rule on the operation of our plants and believe that the impact is significantly higher than that described in the regulatory analysis. Specifically, the rule will extend the refueling outages at all three of our units by 7 to 9 days (increasing replacement energy costs) and increase operations and maintenance expenses because of containment related restrictions. Additionally, this will result in increased personnel exposure.

Second, we have reviewed the comments to be submitted by the Nuclear Energy Institute (NEI) on this subject and endorse, in their entirety, their content.

We believe that the interest in reducing shutdown risks is commendable but that not enough credit is being given for the improvements which the industry is achieving outside the constraints of prescriptive regulations. Considering the significant cost increases that would be placed on licensees by the rule as currently proposed, not enough attention has been given to the possibCity that those recent industry improvements have significantly reduced the benefits available from implementation of the proposed rule.

I or WA Roger O Anderson Director l Licensing and Management issues c: (see next page)

I 9501130121 941230 PDR PR 50 59FR52707 PDR 3)sio

USNRC NORTHERN STATES POWER COMPANY December 30,1994 Page 2 i

c: Regional Administrator - Region Ill, NRC l Prairie Island Senior Resident inspector, NRC l' Prairie Island NRR Project Manager, NRC Monticello Senior Resident inspector, NRC Monticello NRR Project Manager, NRC  :

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