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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20216F5021999-09-20020 September 1999 Comment Opposing Proposed Rules 10CFR50 & 10CFR72 Re Reporting Requirements for Nuclear Power Reactors.Supports Comments Provided by NEI ML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ ML20137C4261997-03-18018 March 1997 Director'S Decision Under 10CFR2.206 Re Petition Re Allegation of Illegal Transfer of OLs to Southern Nuclear Operating Co.Petitions Filed by Mb Hobby & AL Mosbaugh Denied ML20137C2581997-03-18018 March 1997 Summary of Director'S Decision Under 10CFR2.206 of Mb Hobby & AL Mosbaugh, HL-5268, Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols1996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols ML20133H1131996-11-25025 November 1996 Petition for Enforcement,Per 10CFR2.206,to Revoke Northeast Utils Operating Licenses for CT Nuclear Power Stations Due to Chronic,Systemic Mismanagement Resulting in Significant Violations of NRC Safety Regulations ML20129J5481996-10-30030 October 1996 Order.* Extends Time within Which Commission May Take Sua Sponte Review of Memorandum & Order LBP-96-16 to 961129. W/Certificate of Svc.Served on 961030 ML20129K4291996-10-0202 October 1996 Comment Supporting Proposed Rule 10CFR25 & 95, Access to & Protection of Classified Info HL-5247, Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations1996-10-0101 October 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20128K2791996-09-30030 September 1996 Order.* Time within Which Commission May Take Sua Sponte Review of Memo & Order LBP-96-16 Extended Until 961030. W/Certificate of Svc.Served on 960930 ML20116J8431996-08-0202 August 1996 Intervenor Response to Georgia Power Motion for Reconsideration.* Intervenor Supports Motion for Reconsideration.W/Certificate of Svc & Svc List ML20116J8551996-08-0202 August 1996 Joint Notice of Termination.* AL Mosbaugh Voluntarily Withdrew Intervention,Opposition & Contentions in Proceeding.W/Certificate of Svc & Svc List ML20116J8921996-08-0202 August 1996 Withdrawal of AL Mosbaugh.* AL Mosbaugh Voluntarily Withdraws Intervention,Opposition & Contention in Proceedings.W/Certificate of Svc & Svc List ML20116N5881996-07-31031 July 1996 Comment Re Proposed Rule 10CFR26, Mods to Fitness-For-Duty Program Requirements. Supports NEI Comments ML20116A4931996-07-15015 July 1996 Georgia Power Company Motion for Reconsideration of 960628 Memorandum & Order Or,In Alternative,For Certification.* Gpc Requests That Board Not Require Submittal or Approval of Settlement Between Gpc & Mosbaugh.W/Certificate of Svc ML20115H2671996-07-0808 July 1996 Comment Supporting Final Rule 10CFR51, Environ Review of Renewal of Nuclear Power Plant Operating Licenses HL-5195, Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20114E6491996-06-20020 June 1996 Joint Motion to Defer Issuance of Initial Decision.* Requests That ASLB Defer Issuance of Decision in Proceeding Until 960920,in Order to Allow Gpc & Mosbaugh to Reach Settlement Agreement.W/Certificate of Svc ML20129H7151996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 IA-95-211, Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-391996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 HL-5103, Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use1996-02-0606 February 1996 Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use ML20096A4911995-12-22022 December 1995 Georgia Power Co Reply to Intervenor & NRC Staff Proposed Findings of Facts & Conclusions of Law.* W/Certificate of Svc ML20095D9821995-12-12012 December 1995 Georgia Power Co Motion to Correct Record of Exhibits of Diesel Generator Reporting Issues Allegation Hearing.* W/Certificate of Svc ML20095D9771995-12-0808 December 1995 Comment on Proposed Generic Ltr Boraflex Degradation in Spent Fuel Pool Starage Racks. Request for Licensees to Demonstrate Subcriticality Margin in Unborated Water,Seems Inconsistent W/Stated Benefit of Borated Water ML20094S2751995-11-30030 November 1995 Intervenor Final Statement of Fact & Conclusions of Law.* Board Finds That Util & Applicant Failed to Meet Burden of Proof Re Ultimate Issue of Character,Competence & Integrity. W/Svc List ML20094S2411995-11-22022 November 1995 Georgia Power Co Response to Intervenors Motion for Continuance.* Intervenor Motion Unjustified & Prejudicial & Should Be Denied.W/Certificate of Svc & Svc List ML20094S2931995-11-21021 November 1995 Intervenor Motion for Continuance for Good Cause.* Requests Deadline for Filing Post Hearing Brief Be Extended Until 951130.W/Certificate of Svc & Svc List ML20094K1161995-11-0909 November 1995 Intervenor Motion to Admit Supplementary Exhibits.* Moves That Naslp Admit Encl Documents Into Evidence for Listed Reasons.W/Certificate of Svc & Svc List ML20094J9281995-11-0606 November 1995 Gap Proposed Findings of Fact & Conclusions of Law on Diesel Generator Reporting Issues.* Findings of Fact & Conclusion Accepted.W/Certificate of Svc ML20094J9301995-11-0606 November 1995 Georgia Power Company Motion to Correct Record of Diesel Generator Reporting Issues Allegation Hearing.* Moves Licensing Board to Order That Corrections Be Made to Transcript.W/Certificate of Svc & Svc List 1999-09-20
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20216F5021999-09-20020 September 1999 Comment Opposing Proposed Rules 10CFR50 & 10CFR72 Re Reporting Requirements for Nuclear Power Reactors.Supports Comments Provided by NEI ML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ HL-5268, Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols1996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols ML20129K4291996-10-0202 October 1996 Comment Supporting Proposed Rule 10CFR25 & 95, Access to & Protection of Classified Info HL-5247, Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations1996-10-0101 October 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116N5881996-07-31031 July 1996 Comment Re Proposed Rule 10CFR26, Mods to Fitness-For-Duty Program Requirements. Supports NEI Comments ML20115H2671996-07-0808 July 1996 Comment Supporting Final Rule 10CFR51, Environ Review of Renewal of Nuclear Power Plant Operating Licenses HL-5195, Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors HL-5103, Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use1996-02-0606 February 1996 Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use ML20095D9771995-12-0808 December 1995 Comment on Proposed Generic Ltr Boraflex Degradation in Spent Fuel Pool Starage Racks. Request for Licensees to Demonstrate Subcriticality Margin in Unborated Water,Seems Inconsistent W/Stated Benefit of Borated Water HL-4880, Comment on Proposed Generic communication,10CFR50.54(p), Process for Changes to Security Plans W/O Prior NRC Approval1995-07-10010 July 1995 Comment on Proposed Generic communication,10CFR50.54(p), Process for Changes to Security Plans W/O Prior NRC Approval HL-4879, Comment on Review of NRC Insp Rept Content,Format & Style. Util Feels That Use of Boilerplate Phrases Seldom Appropriate & That Less Boilerplate Wording Should Be Used1995-06-28028 June 1995 Comment on Review of NRC Insp Rept Content,Format & Style. Util Feels That Use of Boilerplate Phrases Seldom Appropriate & That Less Boilerplate Wording Should Be Used HL-4862, Comment Supporting NEI Comments on Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/ Containment Access Control1995-06-0606 June 1995 Comment Supporting NEI Comments on Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/ Containment Access Control HL-4840, Comment on Proposed Rule 10CFR50, Primary Reactor Containment Leakage Testing for Water-Cooled Power. Requests That NRC to Expedite Promulgation of Option B Rule1995-05-0505 May 1995 Comment on Proposed Rule 10CFR50, Primary Reactor Containment Leakage Testing for Water-Cooled Power. Requests That NRC to Expedite Promulgation of Option B Rule HL-4823, Comment on Draft Policy Statement Freedom of Employees to Raise Safety Concerns W/O Fear of Retaliation. Endorses NEI Comments1995-04-10010 April 1995 Comment on Draft Policy Statement Freedom of Employees to Raise Safety Concerns W/O Fear of Retaliation. Endorses NEI Comments ML20078J8221995-02-0303 February 1995 Comment Supporting NUMARC Comment Re Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactors HL-0477, Comment Supporting Proposed Rule 10CFR21 Re Procurement of Commercial Grade Items by NPP Licensees1995-02-0101 February 1995 Comment Supporting Proposed Rule 10CFR21 Re Procurement of Commercial Grade Items by NPP Licensees HL-4747, Comments on Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util in Total Agreement W/Numarc Comments Provided to NRC1994-12-0606 December 1994 Comments on Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util in Total Agreement W/Numarc Comments Provided to NRC ML20077F6521994-12-0202 December 1994 Comment on Proposed Generic Ltr Re Reconsideration of NPP Security Requirements for Internal Threat.Util in Total Agreement W/Nei Comments HL-4719, Comment on Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Gap in Total Agreement W/Nei Comments to Be Provided to NRC1994-10-21021 October 1994 Comment on Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Gap in Total Agreement W/Nei Comments to Be Provided to NRC ML20072T6911994-09-0101 September 1994 Comment Re Proposed Rule 10CFR51 Re Environ Review for Renewal of OLs HL-4669, Comment Supporting Petition for Rulemaking PRM-9-2 Filed by Ohio Citizens for Responsible Energy,Inc1994-08-17017 August 1994 Comment Supporting Petition for Rulemaking PRM-9-2 Filed by Ohio Citizens for Responsible Energy,Inc ML20072B4431994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re Random Drug Testing Requirements in FFD Rule HL-4634, Comment on Petition for Rulemaking PRM-50-60 Re Amend to NRC Emergency Preparedness Program to Change Frequency of Licensee Independent Reviews of Program from Annually to Biannually.Util in Agreement W/Nei Comments1994-06-27027 June 1994 Comment on Petition for Rulemaking PRM-50-60 Re Amend to NRC Emergency Preparedness Program to Change Frequency of Licensee Independent Reviews of Program from Annually to Biannually.Util in Agreement W/Nei Comments ML20069J5821994-06-0909 June 1994 Comment Supporting Proposed Rule 10CFR170 & 171 Re Rev of Fee Schedules;100% Fee Recovery,FY94 HL-4578, Comment Supporting Proposed Rule 10CFR50 Re Codes & Stds for Npps;Subsection IWE & Iwl1994-04-25025 April 1994 Comment Supporting Proposed Rule 10CFR50 Re Codes & Stds for Npps;Subsection IWE & Iwl HL-4549, Comment Supporting NEI Comments Re Draft NUREG-1022,rev 1, Event Reporting Sys Clarification of NRC Sys & Guidelines for Reporting1994-04-0505 April 1994 Comment Supporting NEI Comments Re Draft NUREG-1022,rev 1, Event Reporting Sys Clarification of NRC Sys & Guidelines for Reporting HL-4529, Comment Supporting Proposed Amends to 10CFR20 Re Radiological Criteria for Decommissioning of NRC Licensed Facilities1994-03-11011 March 1994 Comment Supporting Proposed Amends to 10CFR20 Re Radiological Criteria for Decommissioning of NRC Licensed Facilities HL-4494, Comment on Draft NUREG/CR-5884 & Draft NUREG/CR-6054 Published in Fr on 931021.Util in Total Agreement W/Numarc Comments1994-02-11011 February 1994 Comment on Draft NUREG/CR-5884 & Draft NUREG/CR-6054 Published in Fr on 931021.Util in Total Agreement W/Numarc Comments ML20063L9551994-01-24024 January 1994 Comment Supporting Evaluation of Reactor Pressure Vessels W/Charpy Upper Shelf Energy Less than 50 Ft-Lb, & DG-1025, Calculational & Dosimetry Methods for Determining Pressure Vessel Fluence, in Accordance W/Numarc Comments 1999-09-20
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AUG-27-1993 14:45 FROM SOUTHERN.NJCLEAR.DPER.CO. TO 913015043200 P.02
- Georgia Power co-ca9y 40 inver ess Center Pcrowey --
Post Offee Box 1295 Bermnram. t.iabama 35201 -,!'K 4g IcieDhone 205 B77-7*22 C.K.uecoy OiB'FR 3'1716)
Georgia Power n{
Vce Pee?' Cent, Nsciear vore P'on August 27, 1993 "*"""**'"
Docket Nos. 50-321 50-424 HL-3446 50-366 50-425 LCV-0134
{l .- 1, -
Mr. Samuel J. Chilk c Secretary of the Comission ccy.m '.-
U.S. Nuclear Regulatory Comission -d.
Washington, D.C. 20555 ,- 'M
- ,;,a : 0 <-.m Attn: Docketing and Service Branch . 3MQ.[cy ['
'"Wome ,
Comments Regarding the NRC Staff's Review of the .
10 CFR Section 2.206 Process -'
(58 Federal Recister 34726 of June 29. 1993)
Dear Mr. Chilk:
- 1. INTRODLETION On June 29, 1993, the Nuclear Regulatory Comission (NRC) invited coments on its review of the 10 C.F.R. Section 2.206 process. 58 Fed.
Reg. 34,726. The Nuclear Utility Management and Resources Council (NUMARC) has submitted coments in response to the NRC's invitation.
Georgia Power Company endorses NUMARC's comments and herein provides supplemental coments based on Georgia Power's experience, as a licensee, with the 10 C.F.R. Section 2.206 petition process.
In sum, we believe the NRC's current process for receiving and addressing Section 2.206 petitions strikes the appropriate balance between (1) affording interested members of the public an opportunity to raise potential safety issues and request enforcement action associated with licensed activities, and (2) providing the NRC with the flexibility necessary to carry out its statutory mandate to protect public health and safety.
Initially, while we believe it is appropriate for the NRC to examine the Section 2.206 process and consider methods for enhancing public participation, based on our experiences and the information contained in the Comission's Background Discussion Paper (NRC Paper), there is insufficient evidence to warrant substantial changes to 10 C.F.R.
Section 2.206 or the NRC policies and procedures implementing that rul e.
In particular, the NRC Paper, as well as the Federal Reaister notice, state that the review was undertaken most notably because of the "long-standing criticism by citizens groups and some members of Congress, primarily because most Section 2.206 petitions are denied."
NRC Paper at 2: 58 Fed. Reg. at 34,726. Considering the primary goal 9309030029 930827' PDR PR f)h IJ 2 5BFR34726 PDR m
- f(G-27-1993 14:46 FRO!1 SOUTHERN. NUCLEAR.OPER.CO. TO 913015043200 P.03 ;
l' L
t l Georgia Powerkh l
U. S. Nuclear Regulatory Comission Page Two ,
of the Section 2.206 proct ,s -- the icentification and correction of safety deficienciesl -- it does not follow that the process is flawed l
merely because a small percentage of the petition; are granted. One
. would expect few safety deficiencies to be uncovered by such getitions ;
I when the NRC and licensees havo extensive programs and methoos for ;
ensuring public health and safety. Indt ?:1, it should be a rare j occurrence when thesa processes fail to identify and resolve conditions ,
that could create a cubstantial safety question.
, Nevertheless, Georgia Power Company strongly supports the Section 2.206 ;
i process' goal of providing interested members of the public with an .
opportunity to raise potential safety issues with the NRC and to !
request that action be tak;n tr.areon. To that end, we offer below our !
specific observations regarding the curent Section 2.206 process. !
j l II. DISCUSSION l l
1 As a preliminary matter, we note that the NRC Paper gives no j consideration to the po',antial resource burden upon licensees which !
might arise from changes to the Section 2.206 process. While 1 recognizing that "the reality of shrinking rather than expanding [NRC] l l
re+1rces" mandates that the evaluation result in a "more effective Seaton 2.206 process with equal or fewer resources" (NkC Paper at 3-4), the NRC Paper does not express an interest in ensuring that the !
costs of any proposed changes be justified based on an increase in l l nuclear plant safety. As discussed in Georgia Power Company's coments ,
below, '.he current Section 2.206 process already incorporates many of i the suggestions discussed in the NRC Paper. Georgia Power submits that l further modificatien to the Section 2.206 process to increase public :
particfpation is not warranted as it will increase costs for plant !
operators, as well as the NRC Staff, without a comensurate increase in l safety.
l 1Based on the coments at the NRC's July 28, 1993, workshop on the Section 2.206 process, it appears that some public citizen groups I consider the primary goal of Section 2.205 to provide a mechanism for 1 any member of the public to obtain a full adjudicatory hearing on the safety concerns they raise. We submit that such a position mischaracterizes the purpose of the rule and evidences an inappropriate agenda - one based on a philosophical opposition to nuclear power in general.
! I i I
AUG-27-1993 14:47 FROM SOUTHERN. NUCLEAR.OPER.CO. TO 913015343200 P.04 t
4 !
Georgia Povaer ezL6 U. S. Nuclear Regulatory Commission Page Three A. Increasino Interaction B_etween the Petitioner and the NRC Staff ;
The NRC Paper offers several options for increasing interaction between the Staff and petitioners. The suggestions, for the most part, can be implemented without any formal change to the existing Section 2.206 process. This has been demonstrated in the case of a Section 2.206 petition filed with respect to Georgia Power's Plant Vogtle. In that case, there was (and continues to be) extensive interaction with the petitioners including, for example, the following:
- 1. Petitioner was interviewed on several occasions (some of which were transcribed) by the NRC with respect to a number of allegations which he brought to the NRC. (Because the petitioner raised safety issues with the NRC which were later incorporated into a Section 2.206 petition, his concerns were initially handled as <
allegations.) l
- 2. Georgia Power Company was required to response, in writing and l under oath, to the Section 2.206 petition and its supplements. !
1
- 3. Petitioner was provided a copy of each of Georgia Power Company's responses. {
This process directly resulted in the petitioners I filing a supplemental petition.
Thus, as the NRC Paper notes, procedures for increasing the interaction !
between the Staff and petitioner are currently in use. It follows that i no formal change to the current process is necessary for the NRC Staff j to continue this practice in appropriate cases. Indeed, the NRC Staff should have some flexibility to decide which Section 2.206 petitions are necessary and appropriate for such increased interaction techniques.
Of course, Georgia Power Company discourages any increased interaction techniques which would impose a substantial burden on licensee resources. For example, the NRC Paper notes that a disproportionate amount of NRC Staff time and resources are spent coordinating Section 2.206 petition responses. In response to this, the NRC Paper, at 10-11, discusses shifting responsibility to the licensee to respond to extensive information requests, and perhaps meet with the petitioner in
" informal public discussions," without regard for the time and resource burdens placed on the licensee. As in the case of NRC Staff resources, this practice would be inappropriate to the extent it would require an inordinate amount of licensee time and resources. This is especially true for the majority of Section 2.206 petitions which raise issues that are either already known to, and being resolved by, the NRC and the licensee or are unsupported and frivolous.
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AUG-27-1993 14:47 FROM SOUTHERN. NUCLEAR.OPER.CD. TO 913015043200 P.05 P
Georgia Powerkh i
U. S. Nuclear Regulatory Comission page Four j B. Eocusino on Resolution of Safety issues Rather Than on Recuested Enforcement Action l This area of inquiry is, in our opinion, the most important contained [
in the NRC Paper. Section 2.206 provides the public with a mechanism t of raising potential safety issues for prompt action by the NRC. As ;
stated above, its fundamental purpose is the identification and !
resolution of potenti..1 safety issues. Under limited circumstances, an adjudicatory proceeding may result. However, as stated above in n.1, based on some coments of public citizen groups at the NRC's July 28, 1993 Section 0.206 Workshop, it would appear that these groups are more r interested in the latter rather than the former.2 Increasing the ,
opportunity for a full adjudicatory hearing in the Section 2.206 !
process will wreak havoc on the licensee, as well as NRC Staff ;
resources. This, rather than the resolution of safety issues, would appear to be the goal of those who insist on adjudicating any safety issue raised in a Section 2.206 petition, no matter how small. An ,
appropriate focus on the resolution of safety issues will achieve the l purposes of Section 2.206 while minimizing the perception that petitioner's safety concerns are being sumarily dismissed by the :
Staff. ;
One problem with the current Section 2.206 process is that petitioners !
often ask for extreme sanctions (e.g., shutdown of the plant) based on alleged improper actions by a licensee. Such " requested relief" is often out of line with the alleged safety deficiencies, even if such 4 allegations were 100% accurate. The result is often a denial of the <
petitioner's requested relief because the petition did not raise a significant public health and safety issue. Nonetheless, the NRC Staff ;
and the licensee would have addressed and resolved any of the safety ;
issues raised in the petition which are found to be substantiated. Of '
course, any decision regarding enforcement action with respect to those :
allegations which were substantiated, appropriately rests exclusively I; with the NRC.
l 25 ee e.g., coments by Ms. Susan Hiatt, Director of the Ohio Citizens for Responsible Energy, to the effect that meaningful public participation under Section 2.206 can only be achieved through citizen-initiated adjudicatory hearings (Tr. at 95-96) and coments by Mr. Martin Malsch, NRC Deputy General Counsel, sumarizing a Union of Concerned Scientist study that concluded the appropriate purpose of Section 2.206 should be to provide the public with a formal, public hearing on any matter or safety issue raised by a petition (Tr. at 55).
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AU3-27-1993 14:48 FROM SOUTHERN. NUCLEAR.OPER.CD. TO 913015043200 P.06 Georgia Powerkn U. S. Nuclear Regulatory Comission Page Five Georgia Power Company agrees with the suggestion of the NRC Paper that the NRC decision on a Section 2.206 petition should focus on the safety issues raised by the petition. In this regard, the Director's Decision could de-emphasize the granting or denying of the specific enforcement action requested by the petitioner. For example, instead of concluding that a petitioner's request for the NRC to order a plant shutdown is denied, the responsible NRC director could simply state that the petition's allegation was either substantiated or not substantiated and then state that the NRC will take enforcement action, if applicable, consistent with NRC's enforcement policy.
C. Catecorizine Petitions __and__Allocatino More Resources Accordina to
_the Importance of Issues Raised Categorizing petitions as suggested by the Staff (NRC Paper at 12-13) appears to be the current, albeit iniormal, approach to allocating Staff resources. We recomend that the Staff continue with this informal approach, without adopting specific procedures and inflexible criteria for segregating petitions.
Additionally, in Georgia Power's opinion, there is room for improvement in the length of time required by the NRC Staff to resolve Section 2.206 petitions. The Staff is to complete its review in a " reasonable time." However, the Staff view of what is a " reasonable time" does not necessarily coincide with that of the licensee or, for that matter, the petitioner. The length of the Staff's review time directly impacts licensee resources and has an effect on the public's perception of the licensee's competence. In order to further conserve licensee (and HRC Staff) resources, as well as to ensure timely resolution of the petitioner concerns, the NRC Staff should consider what is a
" reasonable time" for all concerned, and strive to meet that time frame. This approach would avoid extended periods of inaction which frustrate licensees and, in some cases, inadvertently provide the petitioner with an unintended remedy. In other cases, extended periods of inaction apparently frustrate petitioners.3 D. Providino For a Formal peview Process for Director's Decisions The NRC's existing procedures, whereby the Comission has the authority to review Director's Decisions, provide adequate review of such decisions. Judicial review is inappropriate because it invades the authority of the NRC to take appropriate enforcement action which it 3T his issue was raised as a concern at a July 15, 1993 hearing held by the Senate Subcomittee on Clean Air and Nuclear Regulation.
AUS-27-1993 14:49 FROM SOUTHERN. NUCLEAR.OPER.CO. TO 913015043200 P.07 Georgia Power b U. S. Nuclear Regulatory Commission Page Six deems necessary, within its sole discretion. This would disturb a fundamental precept of agency enforcement authority applicable to all government agencies with enforcement authority. See Heckler v. Chaney, 470 U.S. 821 (1985). As aptly discussed at length in that case, an agency's decision not to prosecute or enforce . . . is a decision generally committed to an agency's absolute discretion.
This is attributable . . to the general unsuitability for judicial review of agency decisions to refuse enforcement.
The reasons for this general unsuitability are many. First an agency decision not to enforce often involves a complicated balancing of a number of factors which are peculiarly within its expertise. Thus, the agency must not only assess whether a violation has occurred, but whether agency resources are best spent on this violation or another, whether the agency is likely to succeed if it acts, whether the particular enforcement action requested best fits the agencies overall policies, and indeed, whether the agency has enough resources to undertake the action at all. An agency generally cannot act against each technical violation of the statute it is charged with enforcing. The agency is far better equipped than the courts to deal with the many variables involved in the proper ordering of its priorities. . . .
Lda, at 831-32.
Furthermore, there is no credible evidence to suggest that judicial review will improve upon the disposition of issues raised in the current Section 2.206 process, while it is certain that it will increase cost' and create substantial delays in ultimate resolution of the issues raised.
111. CONCLUSION Georgia Power Company submits that, on the whole, the current Section 2.205 process has served as a credible, equitable and effective mechanism for the public to raise potential safety concerns to the NRC
. A!_G-27-1933 ~ 14:49 FROM . SOUTHERN. NUCLEAR.OPER.CD.
- TO 913015043260 P.08 t
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Georgia Power u( j U. S. Nuclear Regulatory Comission Page Seven j for resolution. The process allows any person to raise any issue to I the NRC, without regard for the petitioner's legal standing or his l basis for the concern, for NRC investigation and resolution. NRC experience to date demonstrates that the current process is serving its l goal of identifying, and causir.g the resolution of, safety issues which j had not previously been addressed by either the licensee or the NRC. .,
While few petitions have identified significant safety questions, this j is an indication that licensees and the NRC Staff. are adequately protecting the public health and safety rather than an indication that j the Section 2.206 process is broken. l t
Concerns about the Section 2.206 process which have been expressed to l the NRC appear to be grounded in a desire for more public involvement ;
in the process. As discussed above, informal procedures are available {
within the current Section 2.206 process which will enhance public j participation in the Section 2.206 process without creating a i~
significant increase in the resource burdens on the NRC Staff and licensees. Sibstantial modifications to the process to provide for :
increased public participation will not yield a significant safety !
benefit and are, therefore, not warranted. l l
Should you have any questions, please advice. j Respectfully submitted. l C. K. McCoy CKM/CRP cc: Georcia Power Comoany J. T. Beckham, Jr., Vice President - Plant Hatch J. B. Beasley, General Manager - Vogtle Electric Generating Plant H. L. Sumner, Jr., General Manager - Plant Hatch U. S. Nuclear Reaulatory Comission. Washinoton. DC K. N. Jabbour, Licensing Project Manager - Hatch D. S. Hood, Licensing Project Manager - Vogtle U. S. Nuclear Reculatory Comission. Reaion II S. D. Ebneter, Regional Administrator L. D. Wert. Senior Resident Inspector - Hatch B. R. Bonser, Senior Resident Inspector - Vogtle ;
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HL-3446 LCV-0134 TOTAL P.08-
AUS-27-1993 14:45 FROM _ SOUTHERN. NUCLEAR.OPED.CD. TO 913215043200 P.01 Sov:nem wcsar Oscrxcp C ~e:S P st O*kce Bc 1895 j kmeng'am, Aagama 35201 1295 Te'ephone 205 BCS 5000 i
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Southem Nuclear Operating Company ,
the southern electiscsystem REGULATORY, ENGINEERING, AND ENVIRONNDRAL SERVICES i
DATE: S[2'7[93 l
NUMBER OF PAGES: _ 9 (Excluding Cover Page) !
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