L-HU-07-018, Comment (10) Submitted by Nuclear Management Company, LLC, Edward J. Weinkam on Proposed Rule Pr 50 Regarding Industry Codes and Standards; Amended Requirements
| ML071710485 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Point Beach, Prairie Island  |
| Issue date: | 06/19/2007 |
| From: | Weinkam E Nuclear Management Co |
| To: | NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 72FR16731 00010, L-HU-07-018, PR-50, RIN 3150-AH76 | |
| Download: ML071710485 (4) | |
Text
(72FR1673 DOCKETED c
Nuclear Management Company, LLC June 19,2007(4:50prn)
OFFICE OF SECRETARY RULEMAKINGSAND June 19% 2007 ADJUDICATIONS STAFF Secretary,U.S.Nuclear Regulatory Commission ATN: Rulemakings and Abjudicatians Staff Washington, DC 20555-0001 Comments on Proposed Rule "IOFR Part 50.55a, "industn/ Codes and Standards; Amended Reauiremen-Es,"RfN 3150-AH?@(Federa4 Rmister Vof, 72, No, 65, A ~ r i5,2007) l Nuclear Management Company, LLC (NWIC) appreciates the opportunity to comment on the proposed changes to 'I0 CFR 50,55a, Codes and Standards pubfished in the Federal Register on Aprif 5,2007, NMC is the ticensad operator of the Manticello Nuclear Generatirtg Ptant, the Paint Beach Nudear Piant Units Iand 2, and the Prairie Island Nuclear Generating Plant Units 1 and 2.
NMC has reviewed proposed comments from Performance Demonstration Initiative (PDI) Program, Malerials Refiabiliv Program (MRP) Inspection, and American Society of Mechanicai Engineers (ASME) Section Xi Commiaee. NMC agrees with the comments provided by these industry groups with the exception of itern 3 fram the ASME Section Xi Committee. This item is far a change to Paragraph 50.55a(b)f2)(xv),
which spe~ifies implementation of Appendix Vllf of Section XI, the 'I995 Edition through the 2001 Edition of the ASME B W Code with regard to ultrasonic examinatians oif piping systems. The proposed change would reference and aliow the use of the 2004 Edition d the ASME Code. The ASME Section XI Committee agrees with this change while PDl takes exception to this item. NMC agrees with PDI and also takes exception tu this item based on the fact that the proposed change ta Paragraph 50.55a(b)(2)(~91)is cantrary to the existing requirement in (xxiv). The existing requirement of (xxiv) is "Incorporation of the Performance Demcrnstratiofi Initiative and Addition of UItrasonic Ex~minafionCriteria. The use of Appendix Vtll and the supplements to Appendix Vlll and Attide 1-3000 of Seetion XI of the ASME BPV Code, 2002 Addenda through the latest edition and addenda incorporated by reference in paragraph (b)(2) of this section, is prohibited." There are no proposed changes .for (xxiv), therefore, the proposed rule uril t contain con#icting requirements.
Additionally, PDI identified that there were no proposed changes to the existing requirements In (xv) subparagraphs. Conflicts will exist in the examination or qualification requirements (e.g., Supplemerst 4 single sided access qualifications) since 700 First Street o Hudson. Wisconsin 54016 Telephone: 715.377.3300 "Tern I&teaSECJ-o67 P
US NRC Rulemakingsand Adjudications Staff Page 2 of 2 only portions of the (xv) subparagraph requirements have been incorporated inta the 2004 Edition of Appendix I and Appendix Vlll in modified form- NMG agrees with the PDI remmmendation that (xv) remain unchanged until the 2007 Edition of Appendix 1 and Vl ll are adopted on an expedita basis.
~ i r e c t o r ~ d eLicensing ar and Regulatory Services Nuclear Management Company, LLC cc: -
Michael D,Wadley Sit@Vice President, Prairie Island Nuclear Generating Plant Timothy 1,O'Cunnor Site Vice President, Monticello Nuclear Generating Plant Dennis 1.Kaehi Site Vice President, Point Beach Nuclear Piant
SECY - RIN 3150-AH76 - Comments on --~ r o p o s e d ~ u1l e0 ~ ~ ~ 5 0 . 5 5 a Page 1 1 From: "Gunderson, Lynne" <Lynne.Gunderson@ nmcco.com>
To: cSECY Bnrc.gov>
Date: Tue, Jun 19,2007 4:48 PM
Subject:
RIN 3150-AH76 - Comments on Proposed Rule 10CFR50.55a Nuclear Management Company, LLC (NMC) appreciates the opportunity to comment on the proposed changes to 10 CFR 50.55a, Codes and Standards published in the Federal Register on April 5, 2007 (RIN 3150-AH76). Our comment letter is attached.
Lynne Gunderson Nuclear Licensing Engineer Nuclear Management Company Hudson, WI (715) 377-3430
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Subject:
RIN 3150-AH76 - Comments on Proposed Rule 10CFR50.55a Creation Date Tue, Jun 19,2007 4:47 PM From: "Gunderson, Lynne" <Lynne.Gunderson@nmcco.com>
Created By: Lynne.Gunderson@nmcco.com Recipients nrc.gov TWGWP002.HQGWD001 SECY (SECY)
Post Office Route TWGWP002.HQGWD001 nrc .gov Files Size Date & Time MESSAGE 352 Tuesday, June 19,2007 4:47 PM TEXT.htm 38 10 L-HU-07-018 10 CFR 50-55a comments.pdf 330762 Mime.822 45895 1 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed
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