ML20077M573

Comment on Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactors.Supports Comments Submitted by NEI & Combustion Engineering Owners Group

ML20077M573
Person / Time
Site:	Calvert Cliffs
Issue date:	01/04/1995
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR52707, RULE-PR-50 59FR52707-00024, 59FR52707-24, NUDOCS 9501130111
Download: ML20077M573 (2)

Text

I Ronzar E. DzwroN 00CKETED Baltimore Gas and Electric Cornpany Vice President USPRC Calven Ciffs Nuclear Power Plant 1650 Calvert Oiffs Parkway Nuclear Energy Lusby, Maryland 20657

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January 4,1995 Secretary U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Docketing and Service Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on Proposed Revisions to 10 CFR Part 50, Shutdown and Low-Power Operations for Nuclear Power Reactors (59FR52707)

We welcome the opportunity to comment on the Nuclear Regulatory Commission (NRC) proposal to amend 10 CFR Part 50 to address issues related to shutdown and low-power operations. We support the comments submitted by the Nuclear Energy Institute and Combustion Engineering Owners Group. We do expect the NRC to offer another opportunity for public comment when the revised regulatory analysis is available. We have the following additional comments.

This rulemaking is the culmination of a lengthy effort by NRC staff to regulate shutdown safety. It has covered several years, a variety of regulatory mechanisms (Information Notices, Generic Letters, and proposed nilemaking), and multiple concepts of how to improve safety (new equipment, more Technical Specifications, more planning controls, etc.). As preliminary products of the effort were developed, broad dissent has been voiced by the industry on the accuracy cf the key assumptions and the logic of the proposed fixes. Even the most recent efforts do not appear to be near agreement on major points.

Confronted with the goal ofimproving shutdown safety, the industry made a dedicated efrort to develop a meaningful approach which could improve performance in the near term. Early on it was recognized that the diversity of plants and organizations made prescriptive solutions unlikely, and so practical guidelines were developed which could be implemented at all plants. The result, NUMARC 91-06, has been an excellent example of the industry achieving what would have been hard to duplicate through compliance-based regulation. Further, the greatest area of improvement--better outage planning-has economic advantages for utilities, and thus creates a clear incentive for continuation exclusive of regulation.

9501130111 950104 PDR PR 50 59FR52707 PDR

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Document Control Desk January 4,1995 Page 2  ;

' As we look back on the four-year effort to develop this regulatory approach, the following points emerge:

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1. Absent specific regulation, the industry is safe with respect shutdown safety.

2. Major safety improvements have been made since the initiation of this NRC effort. ,

3. 'Ihe applicable regulatory framework'has already been strengthened by the adoption of the ;

Maintenance Rule.

L < 4. Despite cKorts to resolve key differences, there are still substantial disagreements between the major parties.

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We believe it is time for the Agency to discontinue its efforts to iteratively correct its approach to shutdown '

regulation and reconsider the fundamental question of whether this rulemaking actisity is justified at all.

Our conclusion is that further regulation on this issue is not appropriate.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, .

t RED /GLD/bjd ec: Document Control Desk, NRC l D. A. Brune, Esquire i J. E. Silberg, Esquire L. B. Marsh, NRC t D. G. Mcdonald, Jr., NRC l T. T. Martin, NRC l P. R. Wilson, NRC l R. I. McLean, DNR j J. H. Walter, PSC [

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