L-99-106, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Standards

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Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Standards
ML20209E038
Person / Time
Site: Beaver Valley
Issue date: 06/29/1999
From: Jain S
DUQUESNE LIGHT CO.
To: Vietticook A
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR22580, RULE-PR-50 64FR22580-00027, 64FR22580-27, L-99-106, NUDOCS 9907140127
Download: ML20209E038 (1)


Text

g Beav Valley Power Station Shippingport, PA 15077-0004 June 29,1999 l,

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Nuclear Power Division DOCKET NUMBER Ms. Annette L. Vietti-Cook PROPOSED RULE PR so U. S. Nuclear Regulatory Commission Rulemaking and Adjudications Staff (p/pgpaggo]d a Washington, DC 20555-0001 'c:

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Subject:

Beaver Valley Power Station, Unit No. I and No. 2 h M i BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 iG o

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Amended Requirements s Duquesne Light Company (DLC), operating company for Beaver Valley Units 1 and 2, is providing comments on the subject proposed rule announced in the Federal Register April 27,1999 at page 22580. We have supported the efforts of the Nuclear Energy Institute (NEI) to consolidate industry comments that have been submitted to you under NEI letterhead on June 25,1999, and endorse the NEI submittal.

DLC supports elimination of the 120-month update requirement. The mandatory adoption of the Appendix VIII criteria is opposed because the rulemaking inappropriately relies on the compliance exception permitted in the 10 CFR 50.109 backfit rule.

The rulemaking identified ten associated issues that the NRC stafT would consider as part of the final rulemaking decision. NEI developed responses to these issues with input from licensees, the NEI 50.55a Task Force, and insights gained during the May 27,1999 public workshop. DLC also supports the NEI responses to these ten issues provided in ,

Enclosure 1 of the NEI response letter. In DLC recommends that the NRC continue to work with the industry, through the Nuclear Energy Institute (NEI), to further clarify applications of the subject requirements.

Sincerely, Sushil C. Jain c: Mr. D. S. Collins, Project Manager Mr. D. M. Kern, Sr. Resident Inspector DEWERmG Mr. H. J. Miller, NRC Region I Administrator A U A L1iV Mr. Anthony R. Pietrangelo, NEI ENERGY 9eO7140127 r 990629 PDR PR 50 64FR22500 PDR p /0