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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217N5481999-10-28028 October 1999 Memorandum & Order (Intervention Petition).* Petitioners May File Amend to Their Petition with Contentions by No Later than 991117.With Certificate of Svc.Served on 991028 ML20217N4821999-10-26026 October 1999 NRC Staff Response to Petition to Intervene Filed by Connecticut Coalition Against Millstone & Long Island Coalition Against Millstone.* Licensing Board Should Deny Petition.With Certificate of Svc ML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20217N6651999-10-21021 October 1999 Northeast Nuclear Energy Co Answer to Request for Hearing & Petition to Intervine.* Petition Should Be Denied,For Listed Reasons.With Certificate of Svc ML20217E9031999-10-19019 October 1999 Establishment of Atomic Safety & Licensing Board.* Board Being Established to Preside Over Northeast Nuclear Energy Co,For Hearing Submitted by Listed Groups.With Certificate of Svc ML20217F0431999-10-14014 October 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer,Union of Concerned Scientists,Concerning Technical Issues & Safety Matters Involved in Millstone Nuclear Power Station,Unit 3 License Amend for Sf Storage.* with Certificate of Svc ML20217G9631999-10-14014 October 1999 Exemption from Requirements of 10CFR50,App E,Section IV.F.2.c Re Conduct of full-participation Exercise in Sept 1999 B17891, Comment Supporting Proposed Rule 10CFR50 Re Use of Requirements Cited in 10CFR50.55a Concerning ASME References with Respect to Edition & Addenda of ASME Boiler & Pressure Vessel Code1999-10-0606 October 1999 Comment Supporting Proposed Rule 10CFR50 Re Use of Requirements Cited in 10CFR50.55a Concerning ASME References with Respect to Edition & Addenda of ASME Boiler & Pressure Vessel Code ML20217F0231999-10-0606 October 1999 Petition to Intervene.* Petitioners Request to Be Permitted to Intervene in Listed Proceedings B17889, Comment on Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Util Supports NEI Comments on Subj Rules1999-09-23023 September 1999 Comment on Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Util Supports NEI Comments on Subj Rules ML20211P5541999-09-13013 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Planning ML20216F3801999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20216F3821999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20216F3901999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20216F4461999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20216F5891999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20216F5921999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20212A1171999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20212A1511999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Eps.Urges That EP Regulation Be Amended to Require Availability of Postassium Iodide for Public in Event of Nuclear Accidents ML20212A1381999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20212A1601999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Eps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20212B9581999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20212B9761999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20212G2341999-09-12012 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20212G2371999-09-12012 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20212G9711999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Ki in Emergency Plans ML20207H9131999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Eps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20212A1711999-09-11011 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Requests That Potassium Iodide Be Made Available in State of Connecticut ML20212A1781999-09-10010 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Urges That Potassium Iodide Be Made Available in Connecticut for at Leas Min of Protection ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210S9671999-08-0606 August 1999 Comment on Proposed Rule 10CFR50 Re Stockpiling of Ki.Pros & Cons of Stockpiling or Predistribution of Ki to Households Difficult to Assess & There Will Be two-year-trial Period in Connecticut to Address Practical Issues Involved ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20210A0311999-07-20020 July 1999 Motion of Clp & Wmec for Leave to Intervene & Petition for Hearing.* Requests Permission to Intervene in Proceeding & That Hearing Be Granted on Issues Presented.With Certificate of Svc & Notices of Appearances ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer CY-99-076, Comment Supporting Proposed Rules 10CFR1,2,4,7,9,15,16,76 & 110 Re Initiative to Implement New Document Mgt Sys That Would Permit Electronic Storage,Retrieval & on-line Ordering of Publicly Available NRC Official Records1999-05-20020 May 1999 Comment Supporting Proposed Rules 10CFR1,2,4,7,9,15,16,76 & 110 Re Initiative to Implement New Document Mgt Sys That Would Permit Electronic Storage,Retrieval & on-line Ordering of Publicly Available NRC Official Records ML20206U9341999-04-14014 April 1999 Petition Pursuant to 10CFR2.206 for Suspension of Operating License at Millstone Nuclear Power Station.Petitioners Request That NRC Conduct Hearing on Issues Raised in Submitted Petitions ML20205R8381999-04-14014 April 1999 Transcript of 990414 Public Briefing on Remaining Issues Re Proposed Restart of Millstone Unit 2.Pp 1-180 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20205F9581999-03-16016 March 1999 Exemption from Requirements of 10CFR50,App R,Section Iii.J, to Extent That Requires Emergency Lighting with 8-hour Battery Supply for Access & Egress Routes to Safe Shutdown Equipment.Request Granted,Per 10CFR50.12(a)(2)(ii) ML20207K6391999-03-0101 March 1999 Transcript of 990301 Public Hearing in Riverhead Town Hall, Riverhead,Ny Re Proposed Restart of Millstone Unit 2 Commercial Nuclear Reactor.Pp 1-136.Supporting Documentation Encl ML20204B6631999-02-22022 February 1999 Comment on Recommended Improvements to Oversight Process for Nuclear Power Reactors.Forwards 5th Edition of Nuclear Lemons Assessment of America Worst Commerical Nuclear Power Plants ML20205D7761999-02-0909 February 1999 Transcript of 990209 Millstone Unit 1 Decommissioning Public Meeting in Waterford,Ct.Pp 1-89.Supporting Documentation Encl ML20199K2511999-01-19019 January 1999 Transcript of 990119 Meeting on Status of Third Party Oversight of Millstone Station Employee Concerns Program & Safety Conscious Work Environ in Rockville,Maryland.Pp 1-159.With Supporting Documentation ML20204F2261999-01-11011 January 1999 Transcript of Verbatim Proceedings on 990111 in Waterford, CT in Matter of Northeast Utils,Millstone Units 2 & 3 ML20195J4791998-11-19019 November 1998 Exemption from Certain Requirements of 10CFR50.54(w) & 10CFR140.11 Re Reduction in Amount of Insurance Required for Facility ML20195E2361998-11-16016 November 1998 Director'S Decision 98-12,granting Petitioner Request to Investigate Licensee Proposal to Air Cool SFP & Denying Request to Suspend Operating License of Plant ML20155J8631998-11-12012 November 1998 Memorandum & Order (Ruling on Contentions).* Contentions of Citizens Regulatory Commission Are Outside Scope of Instant Amend Proceeding for Listed Reasons.Petitioner Contentions Must Be Rejected.With Certificate of Svc.Served on 981112 1999-09-23
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARB17891, Comment Supporting Proposed Rule 10CFR50 Re Use of Requirements Cited in 10CFR50.55a Concerning ASME References with Respect to Edition & Addenda of ASME Boiler & Pressure Vessel Code1999-10-0606 October 1999 Comment Supporting Proposed Rule 10CFR50 Re Use of Requirements Cited in 10CFR50.55a Concerning ASME References with Respect to Edition & Addenda of ASME Boiler & Pressure Vessel Code B17889, Comment on Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Util Supports NEI Comments on Subj Rules1999-09-23023 September 1999 Comment on Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Util Supports NEI Comments on Subj Rules ML20211P5541999-09-13013 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Planning ML20207H9131999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Eps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20212G9711999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Ki in Emergency Plans ML20212G2371999-09-12012 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20212G2341999-09-12012 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20212B9761999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20212B9581999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20212A1601999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Eps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20212A1381999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20212A1511999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Eps.Urges That EP Regulation Be Amended to Require Availability of Postassium Iodide for Public in Event of Nuclear Accidents ML20212A1171999-09-12012 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Urges That EP Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20216F5921999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20216F5891999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans ML20216F4461999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20216F3901999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accident ML20216F3821999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20216F3801999-09-12012 September 1999 Comment Supporting Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Emergency Plans.Urges That Emergency Planning Regulation Be Amended to Require Availability of Potassium Iodide for Public in Event of Nuclear Accidents ML20212A1711999-09-11011 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Requests That Potassium Iodide Be Made Available in State of Connecticut ML20212A1781999-09-10010 September 1999 Comment on Proposed Rule 10CFR50 Re Use of Potassium Iodide for Emergencies at Npps.Urges That Potassium Iodide Be Made Available in Connecticut for at Leas Min of Protection ML20210S9671999-08-0606 August 1999 Comment on Proposed Rule 10CFR50 Re Stockpiling of Ki.Pros & Cons of Stockpiling or Predistribution of Ki to Households Difficult to Assess & There Will Be two-year-trial Period in Connecticut to Address Practical Issues Involved CY-99-076, Comment Supporting Proposed Rules 10CFR1,2,4,7,9,15,16,76 & 110 Re Initiative to Implement New Document Mgt Sys That Would Permit Electronic Storage,Retrieval & on-line Ordering of Publicly Available NRC Official Records1999-05-20020 May 1999 Comment Supporting Proposed Rules 10CFR1,2,4,7,9,15,16,76 & 110 Re Initiative to Implement New Document Mgt Sys That Would Permit Electronic Storage,Retrieval & on-line Ordering of Publicly Available NRC Official Records ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20204B6631999-02-22022 February 1999 Comment on Recommended Improvements to Oversight Process for Nuclear Power Reactors.Forwards 5th Edition of Nuclear Lemons Assessment of America Worst Commerical Nuclear Power Plants ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry B17475, Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Agrees with Extending non-emergency Prompt Notifications to Eight Hours, Which Would Help to Eliminate Unnecessary Repts1998-09-29029 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Agrees with Extending non-emergency Prompt Notifications to Eight Hours, Which Would Help to Eliminate Unnecessary Repts CY-98-139, Comment on Draft NUREG-1625, Proposed Standard TSs for Permanently Defueled Westinghouse Plants1998-09-0101 September 1998 Comment on Draft NUREG-1625, Proposed Standard TSs for Permanently Defueled Westinghouse Plants ML20216B5661998-03-31031 March 1998 Comment Supporting NRC Draft RG DG-1071, Std Format & Content for Post-Shutdown Decommissioning Activities Rept ML20199A1631997-10-28028 October 1997 Forwards Final Page of Exhibit 2,P Gunter Ltr to Commission on Behalf of Nirs Re Prs 10CFR2,50 & 51 Involving Immediate Recission of Current Decommissioning Rules,Conducting Site Specific Health Study & EA &/Or EIS ML20199A1351997-10-24024 October 1997 Comment Opposing Proposed Rules 10CFR2,50 & 51 Re Immediate Rescission of Current Decommissioning Rules & Provision for Hearing on Decommissioning Plan for Plant.W/Nirs & Affidavits of M Resnikoff,S Mangiagli & R Bassilakis B16526, Comment on Proposed Suppl to NRC Bulletin 96-001 Re Control Rod Insertion Problems1997-06-18018 June 1997 Comment on Proposed Suppl to NRC Bulletin 96-001 Re Control Rod Insertion Problems ML20134P0681996-11-14014 November 1996 Comment on Draft RG DG-1051, Monitoring Effectiveness of Maint at Npp ML20134H0741996-11-0404 November 1996 Comments on Stakeholder Input for DSI-11, Strategic Assessment Issue Paper Response for Operating Reactor Program Oversight ML20059F7761994-01-0303 January 1994 Comment on Proposed Rule 10CFR73 Re Proposal to Amend Its Physical Protection Regulations for Operating Nuclear Power Reactors by Modifying Design Basis Threat for Radiological Sabotage B14644, Comment on Proposed Rules 10CFR30,40,50,60,70 & 72 Re Whistleblower Protection for Nuclear Power Plant Employees.Supports Rules1993-10-14014 October 1993 Comment on Proposed Rules 10CFR30,40,50,60,70 & 72 Re Whistleblower Protection for Nuclear Power Plant Employees.Supports Rules ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process B14346, Comment Supporting Draft RG DG-1020, Monitoring Effectiveness of Maint at Nuclear Power Plants1993-01-15015 January 1993 Comment Supporting Draft RG DG-1020, Monitoring Effectiveness of Maint at Nuclear Power Plants HL-2928, Comments on Review of Reactor Licensee Reporting Requirements.Util Agrees W/Numarc Comments1992-09-29029 September 1992 Comments on Review of Reactor Licensee Reporting Requirements.Util Agrees W/Numarc Comments ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting B13722, Comments Supporting Proposed Rule Re SECY-90-347, Regulatory Impact Survey Rept1991-01-29029 January 1991 Comments Supporting Proposed Rule Re SECY-90-347, Regulatory Impact Survey Rept ML20059P0631990-10-15015 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC B13567, Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Endorses NUMARC Position That Rule Challenges Licensed Operators Trustworthiness W/O Justification & Would Affect Morale of Licensed Operators1990-07-0202 July 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Endorses NUMARC Position That Rule Challenges Licensed Operators Trustworthiness W/O Justification & Would Affect Morale of Licensed Operators B13572, Comment Opposing Petition for Rulemaking PRM-50-55 Re Periodicity of Submissions of FSAR Revs1990-07-0202 July 1990 Comment Opposing Petition for Rulemaking PRM-50-55 Re Periodicity of Submissions of FSAR Revs ML20011E4861990-02-0707 February 1990 Comment on Proposed Rule 10CFR71 Re Compatibility of Pu Air Transport Regulations W/Iaea Stds.Supports EEI-UWASTE/NUMARC Comments to Be Provided to NRC by 900209 B13367, Comment on Proposed Rules 10CFR30,40,50,60,70,72 & 150 Re Preserving Free Flow of Info to Commission.Nrc Made Wise Choice to Not Impose Any Obligation on Private Parties to Include Affirmative Statement in Employment Agreements1989-09-20020 September 1989 Comment on Proposed Rules 10CFR30,40,50,60,70,72 & 150 Re Preserving Free Flow of Info to Commission.Nrc Made Wise Choice to Not Impose Any Obligation on Private Parties to Include Affirmative Statement in Employment Agreements ML20245G0721989-08-0303 August 1989 Comment on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Recommends That NRC Recommendation on Trust Agreement Wording Be Deleted or NRC Should Grandfather Existing Trusts Such as for Plants ML20248B6201989-08-0202 August 1989 Comments on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. NRC Should Permit Use of Potential Tax Refund as Source of Decommissioning Funds ELV-00674, Comment Opposing Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. 10CFR72.6(c) Should Be Revised to Provide for Storage W/O ISFSI Requirement1989-07-0707 July 1989 Comment Opposing Proposed Rules 10CFR50,72 & 170 Re Storage of Spent Nuclear Fuel in NRC-Approved Storage Casks at Nuclear Power Reactor Sites. 10CFR72.6(c) Should Be Revised to Provide for Storage W/O ISFSI Requirement ELV-00679, Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Agrees W/Numarc Comments Provided to NRC on 8906261989-07-0505 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Agrees W/Numarc Comments Provided to NRC on 890626 1999-09-23
[Table view] |
Text
E DOCKET NUMBER ey num ~ ~p .-DR , -gd /o w act 13- 95 n3(yggl3 9.zeg}
NM 8F#tCEe ef' SE M99eF*l offic88
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m . w we w-1 r-l, I' October 13, 1987 x
' Docket Nos. 50-213' '
i 50-2.45 50-336 E 50-423 B12706 Q . q$ ,
Re: 10CPR50.109 y 2: :
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d Mr. Samuel 3. Chilk Secretary -i U. S. Nuclear Regu!.atory Commission l Washingtea, D.C. 20555 ;
Attn Docketing and Service Branch Dear Mr. Chilkt Haddam Neck Plant Mllistone Nuclear Power Station, Unit Nos.1,2, and 3 Proposed Rules Revision of Backfitting Process For Power Reactors,52 Federal Register 34224 (September 10. 1987) 3 i
Connecticut Yankee Atomic Power Company (CYAPCO), on behalf of the r3 $ Haddam Neck Plant, and Northeast Nuclear Energy Company (NNECO), on g a- behalf of Ml!! stone Nuclear Power Station, Unit Nos.1, 2, and 3, hereby submit g the following comments on the Nuclear Regulatory Commission's proposed rule e r3 entitled " Revision of Backfitting Process for Power Reactors," '52 Federal 9, Q Register 34224 (September 10, 1987).
N a:r l $e@ In general, CYAPCO and NNECO consider the proposed rule to be sufficient to
-a conform the Commission's backfitting rule,10CFR50.109, to the decision of the
$ .u.
[$ U.S. Court of Appeals for the D. strict of Columbia Circuit in Union of 2 Concerned Scientists vs. . Nuclear Regulatory Commission. Nos. 85-1757 and 86-b"N III'9 (D.C. Circuit August 4,1987). CYAPCO and NNECO therefore urge the Commission to adopt the proposed revisions (subject to the comments suggested).
Ib p'g 5.62ckfl Hac8'i
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1 Mr. Samual Chi!k l B12706/Page 2 i October 13,1987 l
i However, CYAPCO and NNECO do recommend some changes to the proposed rule, in the nature of clarifications, particularly with respect to the new exceptions in proposed Section 50.109(a)(4)(ii) and (iii).
The backfitting rule adopted in 1985 culminated an important effort by the Commission to enhance NRC management control over the modification of power reactors caused by the regulatory process. The rulemaking proceeding involved two rounds' of public comments and over three years of Commission .
deliberation. l The backfitting rule established procedures to rationalize the process and ensure q that before a backfit is imposed, the need for and effectiveness of the proposed modifications are considered in a systematic and documented manner. An important aspect of the rule is the requirement that the NRC take into account the economic costs to licensees and ratepayers when it imposes backfits to ,
achieve incremental safety improvements at facilities that already provide an I acceptable level of protection. As the Commission noted, without consideration 4 of costs., the regulatory process would become a quest for risk-free plants not l l
contemplated by the Atomic Energy Act. l i
CYAPCO and' NNECO have closely followed the implementation of the backfit- j ting rule since it was promulgateriin 1985. It is our belief that the rule has had a
{
positive effect in that it has heightened Staff and industry awareness of changes m requirements that may constitute backfits and has led to greater scrutiny of the actual safety impact of such changes. For this reason, we urge the Commission to move forward expeditiously with the promulgation of a revised J final rule. j1 CYAPCO and NNECO are active participants in the Nuclear Utility Backfitting and Reform Group (NUBARG). NUBARG is comprised of 28 nuclear utilities and q
the Edison Electric Institute and was formed in the early 1980s. In its comments ;
on the proposed rule, NUBARG provided specific comments and proposed some '
specific changes in the proposed rule to clarify the circumstances under which the exceptions will apply. In particular,'we believe that the adequate protection l exception of 50.109(a)(4)(li) is redundant to the compliance exception of i 30.109(a)(4)(1) and should therefore be eliminated. We refer you to NUBARG's '
rationale for the bases supporting this suggestion. Because existing regulatory )
requirements form the baseline level of adequacy, the " adequate protection" 1 exception in subsection (a)(4)(ii) should be entirely subsumed under the :
" compliance" exception in subsection (a)(4)(i). We believe there can be no cases
)
in which a facility that complies with all applicable regulatory requirements I would fall below the existing baseline level of adequate protection. The l Commission has long recognized that compliance with regulatory requirements is-sufficient to establish that a facility provides adequate protection. 1 i
CYAPCO and NNECO endorse NUBARG's comments and agree with the proposed changes. We believe that the proposed revisions to Section 50.109 1 submitted by NUBARG represent a preferred response to the D. C. Circuit's i decision.
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~.g Mr. Samual Chilk B12706/Page 2 October 13,1987 i
We also urge that the Staff proceed with modifications to Manual Chapter 0514.
to conform to the new rule. CYAPCO and NNECO appreciate the opportunity to ,
comment on the Commission's proposed rule.
Very truly yours, CONNECTICUT YANKEE' ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY
%<h l E.yMtoczka (/
l Senior Vice President l
l cc: W. T. Russell, Region I Administrator
} M. L. Boyle, NRC Project Manager, Millstone Unit No.1 l
W. 3. Raymond, Resident Inspector, Millstone Unit Nos.1,2 and 3 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 ,
R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3 F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant
- 3. T. Shedlosky, Resident Inspector, Haddam Neck Plant l
l i
l l
l I
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