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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLIC-99-0094, Comment Supporting Proposed Rule 10CFR50 Re Eliminating Requirement for Licensees to Revise Their Inservice Insp & Testing Programs Beyond Baseline Edition & Addenda of ASME Code1999-10-0101 October 1999 Comment Supporting Proposed Rule 10CFR50 Re Eliminating Requirement for Licensees to Revise Their Inservice Insp & Testing Programs Beyond Baseline Edition & Addenda of ASME Code ML20216F6761999-09-17017 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & NUREG-1022,Rev 1 LIC-99-0082, Comment Opposing Proposed Rule 10CFR50 Re Rev to NRC Emergency Preparedness Regulations on Use of Potassium Iodide in Emergency Plans1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Rev to NRC Emergency Preparedness Regulations on Use of Potassium Iodide in Emergency Plans LIC-98-0168, Comment Opposing Proposed Rule 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Concerns Raised by NEI Well Founded & Endorses NEI Comments1998-12-0909 December 1998 Comment Opposing Proposed Rule 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Concerns Raised by NEI Well Founded & Endorses NEI Comments ML20248C0491998-05-21021 May 1998 Exemption from Requirements of 10CFR50,App R for Plant, Unit 1.Exemption Re Unpressurized Leakage Sites in RCP Lube Oil Collection Sys Granted LIC-98-0052, Comment Supporting Proposed Generic Communication Re Lab Testing of Nuclear-Grade Activated Charcoal1998-03-27027 March 1998 Comment Supporting Proposed Generic Communication Re Lab Testing of Nuclear-Grade Activated Charcoal LIC-97-0034, Comment on Proposed Rev to RG 5.62, Reporting of Safeguards Events. Generally Draft Suggests More Stringent Reporting Requirements than Industry Now Following in Generic Ltr 91-03.No Analysis Performed to Determine Cost/Benefit1998-03-0202 March 1998 Comment on Proposed Rev to RG 5.62, Reporting of Safeguards Events. Generally Draft Suggests More Stringent Reporting Requirements than Industry Now Following in Generic Ltr 91-03.No Analysis Performed to Determine Cost/Benefit LIC-98-0025, Comment on Proposed Communications Re Year 2000 Readiness of Computer Sys at NPP1998-02-24024 February 1998 Comment on Proposed Communications Re Year 2000 Readiness of Computer Sys at NPP ML20203B2031998-02-0606 February 1998 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements. Exemption Granted ML20199E2941997-11-19019 November 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effectively Immediately).Fs Bandy Prohibited from Involvement in Activities Licensed by NRC for Period of 5 Yrs LIC-97-0136, Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Preparedness Programs, Safeguards Contingency Plans & Security Programs for Nuclear Power Reactors1997-08-28028 August 1997 Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Preparedness Programs, Safeguards Contingency Plans & Security Programs for Nuclear Power Reactors ML20151L9901997-07-24024 July 1997 Comments on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments) ML20217J6521997-07-22022 July 1997 Demand for Info Re NRC Question Re Arrest Info Supplied to OPPD in Mar 1993 for Unescorted Access to Plant ML20141B8821997-05-0606 May 1997 Comment on Proposed Rule 10CFR73 Re Changes to NPP Security Requirements.Rule Should Not Be Limited to Designated Licensee or licensee-owned Vehicles,For Listed Reasons LIC-97-0052, Comment Opposing Proposed safety-conscious Work Environ Strategies1997-04-17017 April 1997 Comment Opposing Proposed safety-conscious Work Environ Strategies ML20128F6571996-09-26026 September 1996 Comment on Proposed Generic Communication Re Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations LIC-96-0110, Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements1996-08-0505 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20117P0961996-06-18018 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Any Addl Costs Imposed on Licensee Due to Change in Decommissioning Funding Will Aggravate Potential Investment LIC-96-0069, Comment Opposing Proposed Rule 10CFR50.76, Reporting Reliability & Availability Info for Risk-Significant Sys & Equipment1996-06-11011 June 1996 Comment Opposing Proposed Rule 10CFR50.76, Reporting Reliability & Availability Info for Risk-Significant Sys & Equipment LIC-95-0193, Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning of NPPs1995-10-11011 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning of NPPs LIC-95-0165, Comments Supporting Revised Salp1995-08-29029 August 1995 Comments Supporting Revised Salp ML20086T3911995-07-20020 July 1995 Comments on Proposed Generic Communications Re Testing of safety-related Logic Circuits LIC-95-0116, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-05-25025 May 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control LIC-95-0106, Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial1995-05-22022 May 1995 Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial LIC-94-0236, Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Feels Proposed Change Would Be Beneficial in Terms of Cost Savings1994-11-11011 November 1994 Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Feels Proposed Change Would Be Beneficial in Terms of Cost Savings LIC-94-0137, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Changes to 10CFR50 & 73 Concerning Frequency for Conducting Independent Reviews & Audits of Safeguards Contingency Plan & Security Program1994-07-18018 July 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Changes to 10CFR50 & 73 Concerning Frequency for Conducting Independent Reviews & Audits of Safeguards Contingency Plan & Security Program LIC-94-0072, Informs That Implementation of Proposed Rulemaking at Plant Would Require Numerous Procedure Changes,Addl Dosimetry for Members of Public, & Changes to Chemical Effluent Release Software Due to Deletion of Term Controlled Area1994-03-31031 March 1994 Informs That Implementation of Proposed Rulemaking at Plant Would Require Numerous Procedure Changes,Addl Dosimetry for Members of Public, & Changes to Chemical Effluent Release Software Due to Deletion of Term Controlled Area LIC-94-0047, Comment on Draft NUREG-1482, Guidelines for IST Programs at Npps. Licensee Should Not Have to State in IST Program Methods of Ensuring Code Compliance,If Licensee Complying W/ Code1994-02-18018 February 1994 Comment on Draft NUREG-1482, Guidelines for IST Programs at Npps. Licensee Should Not Have to State in IST Program Methods of Ensuring Code Compliance,If Licensee Complying W/ Code LIC-94-0035, Comments on Proposed GL Guidance for Mod of Tech Specs to Reflect Revs to 10CFR20 & 10CR50.36,related Current Industry Initiatives & Miscellaneous Related Editorial Clarifications1994-02-0404 February 1994 Comments on Proposed GL Guidance for Mod of Tech Specs to Reflect Revs to 10CFR20 & 10CR50.36,related Current Industry Initiatives & Miscellaneous Related Editorial Clarifications LIC-93-0300, Comment Opposing Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at NPPs1993-12-20020 December 1993 Comment Opposing Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at NPPs ML20045H3231993-07-0606 July 1993 Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Supports Rule ML20096A0351992-05-0101 May 1992 Comment on Petition for Rulemaking, Elimination of Requirements Marginal to Safety ML20094K7831992-03-17017 March 1992 Comments Supporting Petition for Rulemaking PRM-50-57 Re Insurance Requirements for Shutdown Reactors ML20092D2791992-01-31031 January 1992 Comment Supporting & Endorsing Positions Submitted by NUMARC & BWR Owners Group Re Rev 1 to NUREG-1022, Event Reporting Sys ML20086F8931991-11-11011 November 1991 Comment Opposing Petition for Rulemaking PRM-30-59 Re Rev of Decommissioning Regulations to Provide for Means of self-guarantee of Decommissioning Funding Costs by Licensees Meeting Stringent Financial Assurance Requirements ML20085K1581991-10-23023 October 1991 Supports Proposed Rule 10CFR50,requiring That NRC Evaluate Decommissioning Funding Plans for Power Reactors That Shut Down Prematurely on case-by-case Basis LIC-91-0063, Comment Opposing Proposed Rule 10CFR50 Incorporating 1986- 1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-15015 April 1991 Comment Opposing Proposed Rule 10CFR50 Incorporating 1986- 1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a LIC-91-0046, Comment Supporting Proposed Rule (Misc 90-10), Regulatory Impact Survey Rept1991-01-25025 January 1991 Comment Supporting Proposed Rule (Misc 90-10), Regulatory Impact Survey Rept LIC-90-0820, Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Power Plant License Renewal.Endorses NUMARC Comments1990-10-12012 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Power Plant License Renewal.Endorses NUMARC Comments ML20012C6471990-03-12012 March 1990 Comment on Proposed Rule 10CFR50, Fracture Toughness Requirements for Protection Against Thermal Shock Events. Recommends That Use of Credible Surveillance Data Be Allowed to Establish Consistent Calculational Method W/Reg Guide ML19353B2091989-11-30030 November 1989 Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Supports NUMARC Position ML20246K2441989-07-0505 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Enactment of Generic Ltr 89-02 Requirements & Info Sharing Would Achieve Desired Results LIC-88-1031, Comment on Proposed Rule 10CFR26 Re Fitness for Duty. Endorses NUMARC Comments.Believes That 100% Annual Testing Frequency Appropriate as Adequate Deterrent & More than 100% Would Install Burden of Excess for Certain Employees1988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty. Endorses NUMARC Comments.Believes That 100% Annual Testing Frequency Appropriate as Adequate Deterrent & More than 100% Would Install Burden of Excess for Certain Employees ML20206C1081988-11-0404 November 1988 Requests for Renewal or Extension of Exemption from 10CFR50.54(w)(i) Re Property Insurance Regulations ML20204C1721988-10-14014 October 1988 Corrected Page 1 of Exemption from 10CFR50.54(w)(5)(i), Increasing Amount of Onsite Property Damage Insurance Required by NRC Licensees ML20155F7021988-09-30030 September 1988 Temporary Exemption from 10CFR 50.54(w)(5)(i) Requirements Until Completion of Pending Rulemaking Extending Implementation Date Specified But Not Later than 890401 ML20236X6881987-11-25025 November 1987 Exemption from 10CFR50.54(w)(1) Requirements Re Util Maint of Min Insurance Coverage for Operating Plants.Exemption Extends Date for Acquiring Full Amount of Property Insurance Required to No Later than 881205,per Util 851005 Request ML20206C1341987-11-0202 November 1987 Requests for Exemption from Requirements of 10CFR50.54(w)(i) Re Property Insurance Requirements Due to Licensees Inability to Provide Equivalent Protection in Lieu of Purchasing Nuclear Electric Insurance Ltd Coverage ML20236F7601987-10-0202 October 1987 Request for Exemption from Requirements of 10CFR50.54.Util Will Not Be Able to Comply W/Requirements by Effective Date or within 60 Days Thereafter ML20238E0891987-09-10010 September 1987 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violations Identified During Insps on 850916-20, 1001-08,1106-08,18-22 & 1209-17 1999-09-17
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARLIC-99-0094, Comment Supporting Proposed Rule 10CFR50 Re Eliminating Requirement for Licensees to Revise Their Inservice Insp & Testing Programs Beyond Baseline Edition & Addenda of ASME Code1999-10-0101 October 1999 Comment Supporting Proposed Rule 10CFR50 Re Eliminating Requirement for Licensees to Revise Their Inservice Insp & Testing Programs Beyond Baseline Edition & Addenda of ASME Code ML20216F6761999-09-17017 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & NUREG-1022,Rev 1 LIC-99-0082, Comment Opposing Proposed Rule 10CFR50 Re Rev to NRC Emergency Preparedness Regulations on Use of Potassium Iodide in Emergency Plans1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Rev to NRC Emergency Preparedness Regulations on Use of Potassium Iodide in Emergency Plans LIC-98-0168, Comment Opposing Proposed Rule 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Concerns Raised by NEI Well Founded & Endorses NEI Comments1998-12-0909 December 1998 Comment Opposing Proposed Rule 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Concerns Raised by NEI Well Founded & Endorses NEI Comments LIC-98-0052, Comment Supporting Proposed Generic Communication Re Lab Testing of Nuclear-Grade Activated Charcoal1998-03-27027 March 1998 Comment Supporting Proposed Generic Communication Re Lab Testing of Nuclear-Grade Activated Charcoal LIC-97-0034, Comment on Proposed Rev to RG 5.62, Reporting of Safeguards Events. Generally Draft Suggests More Stringent Reporting Requirements than Industry Now Following in Generic Ltr 91-03.No Analysis Performed to Determine Cost/Benefit1998-03-0202 March 1998 Comment on Proposed Rev to RG 5.62, Reporting of Safeguards Events. Generally Draft Suggests More Stringent Reporting Requirements than Industry Now Following in Generic Ltr 91-03.No Analysis Performed to Determine Cost/Benefit LIC-98-0025, Comment on Proposed Communications Re Year 2000 Readiness of Computer Sys at NPP1998-02-24024 February 1998 Comment on Proposed Communications Re Year 2000 Readiness of Computer Sys at NPP LIC-97-0136, Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Preparedness Programs, Safeguards Contingency Plans & Security Programs for Nuclear Power Reactors1997-08-28028 August 1997 Comment on Proposed Rules 10CFR50 & 73, Frequency of Reviews & Audits for Emergency Preparedness Programs, Safeguards Contingency Plans & Security Programs for Nuclear Power Reactors ML20151L9901997-07-24024 July 1997 Comments on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments) ML20141B8821997-05-0606 May 1997 Comment on Proposed Rule 10CFR73 Re Changes to NPP Security Requirements.Rule Should Not Be Limited to Designated Licensee or licensee-owned Vehicles,For Listed Reasons LIC-97-0052, Comment Opposing Proposed safety-conscious Work Environ Strategies1997-04-17017 April 1997 Comment Opposing Proposed safety-conscious Work Environ Strategies ML20128F6571996-09-26026 September 1996 Comment on Proposed Generic Communication Re Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations LIC-96-0110, Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements1996-08-0505 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20117P0961996-06-18018 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Any Addl Costs Imposed on Licensee Due to Change in Decommissioning Funding Will Aggravate Potential Investment LIC-96-0069, Comment Opposing Proposed Rule 10CFR50.76, Reporting Reliability & Availability Info for Risk-Significant Sys & Equipment1996-06-11011 June 1996 Comment Opposing Proposed Rule 10CFR50.76, Reporting Reliability & Availability Info for Risk-Significant Sys & Equipment LIC-95-0193, Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning of NPPs1995-10-11011 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning of NPPs LIC-95-0165, Comments Supporting Revised Salp1995-08-29029 August 1995 Comments Supporting Revised Salp ML20086T3911995-07-20020 July 1995 Comments on Proposed Generic Communications Re Testing of safety-related Logic Circuits LIC-95-0116, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-05-25025 May 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control LIC-95-0106, Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial1995-05-22022 May 1995 Comment Supporting Proposed Rule 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial LIC-94-0236, Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Feels Proposed Change Would Be Beneficial in Terms of Cost Savings1994-11-11011 November 1994 Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Feels Proposed Change Would Be Beneficial in Terms of Cost Savings LIC-94-0137, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Changes to 10CFR50 & 73 Concerning Frequency for Conducting Independent Reviews & Audits of Safeguards Contingency Plan & Security Program1994-07-18018 July 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Changes to 10CFR50 & 73 Concerning Frequency for Conducting Independent Reviews & Audits of Safeguards Contingency Plan & Security Program LIC-94-0072, Informs That Implementation of Proposed Rulemaking at Plant Would Require Numerous Procedure Changes,Addl Dosimetry for Members of Public, & Changes to Chemical Effluent Release Software Due to Deletion of Term Controlled Area1994-03-31031 March 1994 Informs That Implementation of Proposed Rulemaking at Plant Would Require Numerous Procedure Changes,Addl Dosimetry for Members of Public, & Changes to Chemical Effluent Release Software Due to Deletion of Term Controlled Area LIC-94-0047, Comment on Draft NUREG-1482, Guidelines for IST Programs at Npps. Licensee Should Not Have to State in IST Program Methods of Ensuring Code Compliance,If Licensee Complying W/ Code1994-02-18018 February 1994 Comment on Draft NUREG-1482, Guidelines for IST Programs at Npps. Licensee Should Not Have to State in IST Program Methods of Ensuring Code Compliance,If Licensee Complying W/ Code LIC-94-0035, Comments on Proposed GL Guidance for Mod of Tech Specs to Reflect Revs to 10CFR20 & 10CR50.36,related Current Industry Initiatives & Miscellaneous Related Editorial Clarifications1994-02-0404 February 1994 Comments on Proposed GL Guidance for Mod of Tech Specs to Reflect Revs to 10CFR20 & 10CR50.36,related Current Industry Initiatives & Miscellaneous Related Editorial Clarifications LIC-93-0300, Comment Opposing Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at NPPs1993-12-20020 December 1993 Comment Opposing Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at NPPs ML20045H3231993-07-0606 July 1993 Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Supports Rule ML20096A0351992-05-0101 May 1992 Comment on Petition for Rulemaking, Elimination of Requirements Marginal to Safety ML20094K7831992-03-17017 March 1992 Comments Supporting Petition for Rulemaking PRM-50-57 Re Insurance Requirements for Shutdown Reactors ML20092D2791992-01-31031 January 1992 Comment Supporting & Endorsing Positions Submitted by NUMARC & BWR Owners Group Re Rev 1 to NUREG-1022, Event Reporting Sys ML20086F8931991-11-11011 November 1991 Comment Opposing Petition for Rulemaking PRM-30-59 Re Rev of Decommissioning Regulations to Provide for Means of self-guarantee of Decommissioning Funding Costs by Licensees Meeting Stringent Financial Assurance Requirements ML20085K1581991-10-23023 October 1991 Supports Proposed Rule 10CFR50,requiring That NRC Evaluate Decommissioning Funding Plans for Power Reactors That Shut Down Prematurely on case-by-case Basis LIC-91-0063, Comment Opposing Proposed Rule 10CFR50 Incorporating 1986- 1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-15015 April 1991 Comment Opposing Proposed Rule 10CFR50 Incorporating 1986- 1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a LIC-91-0046, Comment Supporting Proposed Rule (Misc 90-10), Regulatory Impact Survey Rept1991-01-25025 January 1991 Comment Supporting Proposed Rule (Misc 90-10), Regulatory Impact Survey Rept LIC-90-0820, Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Power Plant License Renewal.Endorses NUMARC Comments1990-10-12012 October 1990 Comment on Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Power Plant License Renewal.Endorses NUMARC Comments ML20012C6471990-03-12012 March 1990 Comment on Proposed Rule 10CFR50, Fracture Toughness Requirements for Protection Against Thermal Shock Events. Recommends That Use of Credible Surveillance Data Be Allowed to Establish Consistent Calculational Method W/Reg Guide ML19353B2091989-11-30030 November 1989 Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Supports NUMARC Position ML20246K2441989-07-0505 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Enactment of Generic Ltr 89-02 Requirements & Info Sharing Would Achieve Desired Results LIC-88-1031, Comment on Proposed Rule 10CFR26 Re Fitness for Duty. Endorses NUMARC Comments.Believes That 100% Annual Testing Frequency Appropriate as Adequate Deterrent & More than 100% Would Install Burden of Excess for Certain Employees1988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty. Endorses NUMARC Comments.Believes That 100% Annual Testing Frequency Appropriate as Adequate Deterrent & More than 100% Would Install Burden of Excess for Certain Employees 1999-09-17
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0 00CKETED USFRC me ammy Omaha PublicPowerDistrict 444 South 16th Street Mau 5 0U0 \3 A 9 ;05 Omaha NE68102-2247 0FFi% ~ RE.aFY June l', 1996 00CE hL , .:E M-LIC-96-0069 T ?
I DOCKET M l U. S. Nuclear Regulatory Commission ATTN: Docketing and Service Branch g g%g_ -
i l
Washington, D.C. 20555-0001 NWO%
References:
- 1. Docket No. 50-285
- 2. Federal Register, Vol . 61, No. 29, dated February 12, 1996, !
l (61 FR 5318)
- 3. Draft Fina1 Report, Pilot Study on Implementation of Proposed ;
Reliability Data Rule Reporting Guidelines
- 4. Draft Regulatory Guide DG-1046, Guidelines for Reporting Reliability and Availability Information for Risk-Significant :
Systems and Equipment in Nuclear Power Plants
SUBJECT:
Comments on Notice of Proposed Rulemaking,10CFR50.76, Reporting Reliability and Availability Information for Risk-Significant Systems and Equipment The Omaha Public Power District (OPPD) has reviewed Reference 2 regarding the proposed rulemaking on reporting reliability and availability information for risk-significant systems and equipment. Specifically, the proposed rulemaking requires reporting of detailed information on demands, failures, unavail-abilities and operation associated with basic systems and those systems / equipment detennined to be risk-significant by th utility. The purpose of this letter is to express OPPD's continued concerns with regard to this proposed rulemaking.
In August of 1995, OPPD volunteered for participation in an NRC sponsored Pilot Study conducted by Scientific Applications International Corporation (SAIC) to identify the problems, issues and concerns associated with implementation of the regulatory guidance document associated with this rulemaking. OPPD supplied comments which were included in the Draft Final Report (Reference 3). Review of this rulemaking and the associated Regulatory Guide indicates that OPPD's comments which were included in the Pilot Study were not given adequate consideration in the development process. In addition, to our knowledge, the SAIC final report has yet to be made public, which would substantially improve the knowledge of other utilities regarding this issue.
9606140056 960611 PDR PR 50 61FR5318 PDR 45.5124 Employment wim Equal Opportunity p@
U. S. Nuclear Regulatory Commission LIC-96-0069 Page 2-OPPD concurs with the comments previously submitted by the Nuclear Energy Institute (NEI)intheirMarch 12, 1996 letter regarding the significant burden which the rulemaking will place on the industry if the rule is implemented in its present form.
The Maintenance Rule (10CFR50.65), which is effective July 10, 1996, is designed to improve plant perfonnance through monitoring of equipment performance against established performance criteria. There is some concern that the Data Rule will increase the focus on the accuracy of the data being reported, rather than on the use of the data to improve plant performance. The establishment of a specific list of equipment for which data is reported will result in an increased focus on these systems rather than on the poor performers identified by the Maintenance Rule processes.
OPPD understands that the NRC perceives a need for the gathering of industry-wide performance data to support risk-based regulation. However, the NRC has not yet made it clear to the industry what the NRC plans to do with the data collected under the proposed Data Rule. It is inappropriate for the NRC and utili;y resources to study data without a clear pcblished objective. There is the danger that raw data, manipulated by the NRC or being publicly available to other agencies, could provide erroneous conclusions with respect to safety, causing utilities .to apply resources to address such issues and potentially taking attention away from real safety issues.
As the proposed rulemaking does not eliminate existing data gathering requirements but rather proposes additional data gathering burdens, the proposed Data Rule is not cost beneficial / effective. Because of OPPD's methods chosen for '
Probabilistic Risk Assessment (PRA) and the Maintenance Rule, the Data Rule would provide an additional unnecessary reporting requirement. The NRC has seriously underestimated the number of labor-hours required for information gathering under the Data Rule. Also, the definitions provided in the proposed Data Rule for trains, failures, demands and other items (as defined in the draft Regulatory Guide) are different than the already developed and accepted terminology of the Maintenance Rule. This apparent lack of coordination between the Maintenance Rule and the proposed Data Rule demonstrates that the Data Rule is premature.
As a result, the overall impact on Maintenance Rule implementation efforts would be negative in that the proposed requirements would hamper programs currently in place by requiring significant and costly changes in established data gathering techniques.
The Maintenance Rule currently requires that data be kept to determine the placement of component groups or trains into one of two categories:
- 1) Category (a)(1), structure, system or component (SSC) that does not meet its prescribed performance criteria, or
- 2) Category (a)(2), SSC that does meet its prescribed performance criteria and is subject to nonnal preventive maintenance monitoring.
U. S. Nuclear Regulatory Commission LIC-96-0069 Page 3 i
OPPD considers the FCS plant-specific implementation of the Maintenance Rule and living PRA program sufficient for nearterm and future risk-based regulation applications. If the NRC expects all plants to perform data collection as 0 PPD l does, there are more efficient ways other than the Data Rule to make these expectations clear.
OPPD has the following specific conments with regard to the proposed rulemaking:
10CFR50.76(b)(1)(1)
I Each licensee will submit an annual report containing "the number of demands, the number of failures to start associated with such demands, and the dates of such failures, characterized according to the identification of the train affected, the type of demand (test, inadvertent / spurious, or actual need), and the plant mode at the time of the demand (operating or shutdown);"
OPPD's Comments:
Early in the implementation process for the Maintenance Rule there was extensive discussion among the affected utilities regarding the collection of " demand" information to support the SSC's performance assessment and associated PRA applications. Development efforts in this area found that collection of this data was extremely difficult and not cost beneficial.
Specific demand data as required by the proposed Data Rule is not current-ly being gathered by many operating facilities. Since this additional information would have to be gathered by Control Room personnel, there is much concern that the data collection efforts required would distract the Operations personnel from their primary focus, which is the safe operation of the plant. During the performance of the Data Rule Pilot Study, it was found that the PRA could be adapted to achieve the same risk assessment objective using failure to start on demand and unavailability information currently recorded in support of Maintenance Rule objectives.
It is OPPD's position that the proposed rulemaking should require reporting ;
of data only on " demand failures" as already collected in support of the Maintenance Rule and avoid additional burden on control room personnel.
10CFR50.76(b)(1)(iii) l Each licensee will submit an annual report containing "the number of hours equipment is unavailable, characterized according to the identification of the train affected, the plant mode at the t,me equipment is unavailable ;
(operating or shutdown), characteriz.dicu of the unavailable period l (planned, unplannea. or support system unavailable), and, if due to a ;
support system being unavailable, identification of the support system;" i I
l
.V .
U. S. Nuclear Regulatory Commission LIC-96-0069 '
Page ~
OPPD's Comments:
This section. of- the proposed' rulemaking requires the. collection and characterization of unavailability information during both operating and .
shutdown time ~ periods. The proposed rule does not:take.into account the fact that certain' plant. systems that are' risk-significant. during' operation i: are not risk-significant during shutdown. . Likewise, systems such as Shutdown Cooling (or Residual Heat Removal) which.are not risk-significant at power are indeed risk-significant during shutdown.
In addition to the above comments, OPPD takes serious issue with the artificial -
designation of. system trains proposed by the draft Regulatory Guide. During the
- Data Rule Pilot Study, it was detemined that functional. groups were a much more efficient way to monitcr equipment than artificially produced trains. Use of functional grouping would allow for comparisons among different plants. _The
-train definitions' proposed in the current draft Regulatory Guide will not~ yield useful data.for.a. specific plant or allow comparisons between. plants.
In conclusion, the Data Rule, as proposed, tis premature, costly and .not sufficiently justified. The cost estimates for compliance with the Data Rule are inaccurate and without sound adequate-technical basis. OPPD encourages.the NRC to carefully reconsider the promulgation of the Data Rule. Furthermore, OPPD l- encourages the NRC to look closer'at industry initiatives, such as theLInstitute 4
. of Nu:: lear Power Operations' (INP0) proposed functional database system, as -
alternatives to the Data Rule. This system could supply'the data needed by the'- '
industry and the NRC for risk-based regulation.
If you _should. have any questions, please contact me.
Sincerely, jap"--
~
< T. L. Patterson i -Division' Manager Nuclear Operations
, TLP/dll c: Winston & Strawn L. J. Callan, NRC Regional Administrator, Region IV L. R. Wharton, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector A. R. Pietrangelo, Nuclear Energy Institute i Document Control Desk
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