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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARJPN-99-029, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors JPN-99-022, Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds1999-06-22022 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds JPN-98-052, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects JPN-98-050, Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal JPN-98-021, Comment Opposing Proposed Rule 10CFR50 Re Codes & Stds1998-05-26026 May 1998 Comment Opposing Proposed Rule 10CFR50 Re Codes & Stds JPN-97-037, Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated1997-12-0101 December 1997 Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated ML20029C5771994-03-11011 March 1994 Comment on Proposed Rule 10CFR20 Re Draft Rule on Decommissioning.Informs That 15 Mrem/Yr Unreasonably Low Fraction of Icrp,Ncrp & Regulatory Public Dose Limit of 100 Mrem/Yr ML20045F2451993-06-28028 June 1993 Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Opposes Proposed Criteria ML20128B0581993-01-29029 January 1993 Order Imposing Civil Monetary Penalties in Amount of $300,000.Violations Indicate Significant Breakdown in Mgt & Administrative Control of Licensed Activities at Plant JPN-02-034, Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl1992-07-0606 July 1992 Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl ML20079P9961991-11-0404 November 1991 Response of PASNY to Objections of DM Manning to Settlement Agreement.* Concludes That DM Manning Request That NRC Deny PASNY & NRC Joint Motion for Approval of Settlement Agreement Should Be Denied.W/Certificate of Svc ML20086B9681991-06-0606 June 1991 Affidavit of RA Locy Re DM Manning Refusal to Provide Second Urine Sample on 901009 ML20086B9351991-06-0606 June 1991 Affidavit of W Fernandez Re DM Manning Refusal to Provide Second Urine Sample on 901009 ML20086B8931991-06-0606 June 1991 Affidavit of DM Manning,Senior Reactor Operator,Being Duly Sworn,Response to Order Suspending License & Order to Show Cause Why License Should Not Be Revoked ML20086B9891991-06-0606 June 1991 Affidavit in Support of DM Manning Application to Have Certain Records Withheld from Public Disclosure,Per 10CFR2.790 JPN-91-021, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants1991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants JPN-91-005, Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended1991-01-28028 January 1991 Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended JPN-90-068, Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS1990-10-22022 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS JPN-90-067, Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC1990-10-15015 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC JPN-90-052, Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR1990-07-0909 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR JPN-90-050, Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary1990-07-0202 July 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary JPN-89-008, Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants JPN-88-063, Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments1988-11-18018 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments JPN-88-056, Comment Supporting Proposed Rule 10CFR50 Re Advanced Notice of Proposed Rulemaking Concerning Regulatory Options for Nuclear Plant License Renewal.Supports Comments Made by NUMARC Nuplex1988-10-28028 October 1988 Comment Supporting Proposed Rule 10CFR50 Re Advanced Notice of Proposed Rulemaking Concerning Regulatory Options for Nuclear Plant License Renewal.Supports Comments Made by NUMARC Nuplex ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons JPN-88-015, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site1988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site ML20154G6131988-04-0101 April 1988 Comment Supporting Proposed Rule 10CFR50 Re Alternative Method for Leakage Rate Testing.Believes Method Accurately Calculates Containment Leakage Rate W/Less Statistical Uncertainty than Total Time Method 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 Expressed1988-01-25025 January 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed JPN-87-062, Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex1987-12-31031 December 1987 Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex JPN-87-053, Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection1987-10-15015 October 1987 Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection JPN-87-051, Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl1987-09-28028 September 1987 Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl ML20039G7411981-12-0707 December 1981 Affidavit Supporting NRC Motion to Dismiss Ucs & Ny Pirg Petitions for Review of NRC Decision Re Status of Offsite Radiological Emergency Response Plan.Emergency Planning Evaluation Process Incomplete.Related Correspondence ML20038B9421981-12-0404 December 1981 Petition to Enforce & Modify License Conditions.Director of NRR Should Find Util in Violation of License Conditions. Conditions Should Be Modified to Prevent Anticompetitive Activities.Apps & Certificate of Svc Encl ML19262C1121980-01-22022 January 1980 Response to Show Cause Order Re Implementation of Lessons Learned Task Force Category a Requirements.Util Has Complied W/All Requirements Except 2.1.4.2,due to Unavailability of Equipment.Affirmation of Pj Early & Certificate of Svc Encl ML20064C9411978-10-0606 October 1978 Requests Hearing on Application for OL Amend Filed on 780726.Amend Would Authorize Increase in Spent Fuel Storage Capacity & Revise Design Features & Operating Limits 1999-09-20
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARJPN-99-029, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirement for Nuclear Power Reactors JPN-99-022, Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds1999-06-22022 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Requirements for Industry Codes & Stds JPN-98-052, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Util Endorses & Supports Position Presented by NEI & Commends Commission for Initiative to Address Disconnects JPN-98-050, Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Encourages NRC Staff to Withdraw Proposed Change & to Work with Nuclear Power Industry & Other Stakeholders to Accomplish Goal JPN-98-021, Comment Opposing Proposed Rule 10CFR50 Re Codes & Stds1998-05-26026 May 1998 Comment Opposing Proposed Rule 10CFR50 Re Codes & Stds JPN-97-037, Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated1997-12-0101 December 1997 Comment on Final Direct Rule Changes to Paragraph (H) of 10CFR50.55a Codes & Standards. Effective Date of New Rule Should Be Delayed Until Listed Concerns Can Be Resolved & Appropriate Changes Incorporated ML20029C5771994-03-11011 March 1994 Comment on Proposed Rule 10CFR20 Re Draft Rule on Decommissioning.Informs That 15 Mrem/Yr Unreasonably Low Fraction of Icrp,Ncrp & Regulatory Public Dose Limit of 100 Mrem/Yr ML20045F2451993-06-28028 June 1993 Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Opposes Proposed Criteria JPN-02-034, Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl1992-07-0606 July 1992 Comment Supporting Proposed Rule 10CFR50.54 Re Receipt of Byproduct & Special Nuclear Matl JPN-91-021, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants1991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments. Approx 300% Increase in NRC Fees for FY91 Will Have Major Impact Upon Operating & Maint Budgets of Plants JPN-91-005, Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended1991-01-28028 January 1991 Comment Re SECY-90-347, Regulatory Impact Survey Rept. Util Concurs W/Numarc Comments.Analysis of Info from NUREG-1395 Insufficient to Complete Evaluation.Root Cause Analysis of Seven Themes Listed in SECY-90-347 Recommended JPN-90-068, Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS1990-10-22022 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS JPN-90-067, Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC1990-10-15015 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Endorses Comments Submitted by NUMARC JPN-90-052, Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR1990-07-0909 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR JPN-90-050, Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary1990-07-0202 July 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Mod for fitness-for-duty.Proposed Rule Will Place More Stringent Restrictions on Licensed Operators & Unnecessary JPN-89-008, Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants JPN-88-063, Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments1988-11-18018 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Util Has Constitutional Concerns Re Proposed Random Testing Which Should Be Fully Addressed Prior to Rule Being Promulgated.Endorses NUMARC & EEI Comments JPN-88-056, Comment Supporting Proposed Rule 10CFR50 Re Advanced Notice of Proposed Rulemaking Concerning Regulatory Options for Nuclear Plant License Renewal.Supports Comments Made by NUMARC Nuplex1988-10-28028 October 1988 Comment Supporting Proposed Rule 10CFR50 Re Advanced Notice of Proposed Rulemaking Concerning Regulatory Options for Nuclear Plant License Renewal.Supports Comments Made by NUMARC Nuplex JPN-88-015, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site1988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Rule Includes Requirement Contrary to Mgt Notification Practices.Rule Should Clarify Length of Time Applicable Once Inspector Arrives on Site ML20154G6131988-04-0101 April 1988 Comment Supporting Proposed Rule 10CFR50 Re Alternative Method for Leakage Rate Testing.Believes Method Accurately Calculates Containment Leakage Rate W/Less Statistical Uncertainty than Total Time Method 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 Expressed1988-01-25025 January 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods.Concerns Re Schedule as License Amend Expressed JPN-87-062, Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex1987-12-31031 December 1987 Comment on Proposed Rules 10CFR4,11,25,30,31,32,34,35,40,50, 60,61,70,71,73,74,75,95 & 110 Re Retention Period for Records.Proposed Changes Ineffective in Reducing Record Vol & Rule Remains Inconsistent & Complex JPN-87-053, Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection1987-10-15015 October 1987 Comment Supporting Proposed Rule 10CFR50 Re Revising Backfitting Process for Power Reactors.Minor Alterations Urged Re Conditions Under Which Backfit Needed to Assure Adequate Protection JPN-87-051, Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl1987-09-28028 September 1987 Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl 1999-09-20
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123 Ma:n Street White Plains. New York 10601
. 914 681.6840 914 287.3309 FAX) 'gp 00CKETED JVED ussc l998 tuy y M 9 08 y 3 _3 t g p a g 's,,e,1 ,,,
- > NewYorkPbwor w weam 4# Authority RULES & Ca. yp;pgH US NRn" OFFICE ?r- a RULL ADJUO' 7 DOCKET N(20ER PROPOSED BlH.E S SO (4,3FRaol36) M*Y26 1998 JPN-98-021 IPN-98-062 Chief, Rules and Directives Branch Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Indian Point 3 Nuclear Power Plant Docket No. 50-286 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 COMMENTS ON PROPOSED RULE CHANGES TO PARAGRAPH (h) OF 10 CFR 50.55a " CODES AND STANDARDS"
REFERENCES:
See below.
Dear Sir:
The Authority has reviewed the proposed rule (Reference 1) published April 23,1998 amending 10 CFR 50.55a(h). The rule is similar to a final direct rule published in October 1997 (Reference 2) by the NRC in that it proposes to incorporate a reference to IEEE Std.
603-1991 (Reference 3) to replace IEEE Std. 279 (Reference 4). The Authority expressed several concerns (Reference 5) regarding the final direct rule. While the latest proposed rule includes many changes to address the industry's comments on the earlier version of this rule, several concerns remain. These concerns are detailed below, Safety Bases Not Enumerated The NRC staff has not provided information that demonstrates that the new standard would result in an increased level of protection to the public health and safety, for either 1 now or currently licensed plants.
0 The FR notice and draft Regulatory Analysis focus on three reasons why the 1991 standard should be incorporated into the regulations. The three reasons cited are: (1) standard IEEE 279-1971 is no longer in effect and has been withdrawn by the IEEE: (2) IEEE 603-1991 standard reflects " current technology;" and, (3) the adoption of IEEE 603-1991is consistent -
with the provisions of the National Technology Transfer and Advancement Act of 1995.
9806050071 980526 PDR PR 50 63FR20136 PDR g
l .
i*
i Neither the FR notice, nor the Regulatory Analysis, provides a technical or safety basis for the proposed rule.
The fact that an outdated standard is referred to in federal regulations does not alter the fact that it remains ar, integral part of the licensing basis for many of currently operating US nuclear power plants. IEEE 279-1971 is, and will continue to be, part of the licensing basis for many operating plants.
The development of new standards does not diminish the value, or validity, of older industry standards. They were the basis upon which Operating Licenses were issued and continue to be the basis upon which adequate protection of the public health and safety is assured. The mere existence of a new industry standard does not, by itself, provide sufficient basis for its enforcemer^ as a regulatory requirement.
l Industry codes and standards should be adopted by the NRC wherever practical and judicious. Clearly, that was the purpose and intent of the Technology and Transfer Act, and the ?..:thority endorses the use of 7w standards when appropriate. However, the intent of the act was not to suggest that new standards be made mandatory without compelling justification.
l In summary, the reasons enumerated in the FR notice or regulatory analysis do not outline
! why the new standard is technically superior to it's 1971 equivalent. The FR notice or regulatory analysis do not demonstrate why this change to 10 CFR 50.55a(h) will improve l safety at US nuclear power plants. At a minimum, the old and new standards should be compared to demonstrate the extent to which the public health and safety might be improved through the adopticn of this rule. The comparison should include an estimate of l
the magnitude of risk reduction associated with the application of IEEE 603-1991 to new and operating nuclear power plants.
Definition of " System-Level Replacement" I
a While the FR notice defines a system, the rule itself doe not define what constitutes a
" system-level replacement." As a result, the threshold for the mandatory use of IEEE 603-1991 could be interpreted as the replacement of two components. This is much too low a I l- threshold for operating plants. l i
While the FR notice implies that modifications or changes to components and subsystems
! are not " system-level replacements," other portions of the FR notice could be interpreted to I I
conflict with this statement. In particular, the notice defines a "sy: tem" 3: c " con ~.bination of two or more interrelated components." The Authority is concerned that this "two component" language could be interpreted to require the introduction of IEEE 603-1991 l when only two components are being replaced or modified. I J
The language of the rule should be clarified to define what constitutes a " system-level replacement." Any rule made final should make it clear that that modifications or changes to components and subsystems are not " system-level replacements." It should establish a high threshold for the introduction of IEEE 603-1991 into an otherwise IEEE-279 qualified system.
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This letter does not contain any new commitments. If you have any questions regarding this matter, please contact the Director - Nuclear Licensing, Ms. C. D. Faison.
Very truly yours,
.f
.Knubel l
Senior Vice President and I
Chief Nuclear Officer
References:
- 1. April 23,1998 FEDERAL REGISTER, Vol. 63, No. 78, pages 20136-20139, " Nuclear l
Regulatory Commission Proposed Rule, Codes and Standards; IEEE National Consensus Standard"
- 2. October 17,1997 FEDERAL REGISTER, Vol. 62, No. 20, pages 53932-53935, ' Nuclear Regulatory Commission Final Direct Rule, Codes and Standards; IEEE National Consensus Standard"
- 3. IEEE Std. 603-1991, " Criteria for Safety Systems for Nuclear Generating Stations"
- 4. IEEE Std. 279, " Criteria for Protection Systems for Nuclear Power Generating Stations"
- 5. NYPA letter, J. Knubel to USNRC, dated December 1,1997 (JPN-97-037/IPN-97-164) regarding comment on Final Direct Rule, Changes to Paragraph (h) of 10 CFR 50.55a
" Codes and Standards" cc: next page 4
I i
O cc: Regional Administrator U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 1
Office of the Resident inspector U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Office of the Resident inspector U.S. Nuclear Regulatory Commission Indian Point 3 P. O. Box 337 Buchanan, NY 10511 Mr. George F. Wunder, Project Manager Project Directorate I-1 Division of Reactor Projects 1/11 U. S. Nuclear Regulatory Commission Mail Stop 14B2 Washington, DC 20555 Mr. Joseph Williams, Project Manager Project Directorate 1-1 Division of Reactor Projects I/ll U. S. Nuclear Regulatory Commission Mail Stop 1482 Washington, DC 20555