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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
[Table view] |
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March 2, 1998 US N"*
LIC-97-0034 Rules and Directives Branch Office of Administration U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
References:
- 1. Docket No. 50-285
- 2. Federal Register Volume 63 dated January 5, 1998 (63 FR 275)
Subject:
Comments on Proposed Revision to Regulatory Guide 5.62, Reporting of Safeguards Events The Omaha Public Power District (0 PPD) has reviewed the subject proposed revision of Regulatory Guide (RG) 5.62. In general, the draft suggests more stringent reporting requirements than the industry is now following in Generic Letter 91-03, Reporting of Safeguards Events. If the proposed RG is published as drafted, more one-hour reports will certainly result. No analysis has been performed to determine the cost / benefit of such an apparent backfit.
Detailed comments may be found in the attechment to this letter Please contact me if you have any questions.
Sincerely.
I f M \
3 S. K. Gambhir Division Managtr Engineering & Operations Support Attachment 5803060105 980302 TCM/tcm $$R06 PDR c: E. W. Merschoff NRC Regional Administrator, Region IV L. R. Wharton, NRC Project Manager W. C. Walker NRC Senior Resident Inspector Document Control Desk Winston & Strawn llllfffllfff!!Ijlll ffllfffflj!!lll c5 5124 Employment with EqualOpportunity
s LIC-98-0034 Attachment Page 1 Omaha Public Power District Comments on Regulatory Guide 5.62 Section_2.L_Last_ paragraph The second sentence in the above paragraph requires amplification. While the centence does use the words "significant flaws," a corresponding qualifiei needs to precede the words " reduction in overall protection." Without such clarification, a gray area exists with respect to what should or should not be reported to the NRC within one hour. As written, any compensated reduction in protection would have to be reported within one hour.
Section_2.2._Examp.le_2 The word " credible" should be inserted at the beginning of the above example as is currently the case in Revision 1 of the Regulatory Guide. By reporting all threats without regard to assessing credibility, licensees would fall prey to any person who is looking for publicity. The reportability system should not encourage such a situation. Appendix G addresses only credible threats.
Sect _1on_2.2._ Example _4 Delete "or loss" since loss of safeguards is covered by Section 2.4. Example 12.
Section_2.2 _ Example _9 Change the word " safety" to " safety related" in the first sentence. This is necessary to tvoid any confusion between industrial safety and nuclear safety issues.
Appendix G requires tampering to be reported only when it results in the
" interruption of normal operation of a licensed nuclear power reactor. ."
Example 9 should either be withdrawn or modified to more clearly state that the one hour clock starts when tampering has been confirmed to be of malevolent intent. Reference to " suspicious" origin is too broad a term and should be deleted.
LIC-98-0034 Attachment Page 2 Section_2.2_ Example _.11 Change the first sentence to read. " Discovery of intentionally falsified identification badges or key cards that could allow unauthorized or undetected access to the protected or vital areas." This change would. provide a clearer example.
. Section_2.2._ Example _12 Appendix C does not provide recommended compensatory measures for this example.
. Sectionl.2._ Example _12_anL16 Examples 12 and 16 s.aculd be combined for clarity.
Sect 1on_2.2._Examp.)e_12
- Add after the words " background information." the words. "with the intent to attempt to commit or cause events idewified in paragraphs I(a) and (d) of Appendix G to Part 73 " This would require reporting of deceptive and malevolent 4
acts specifically. identified in Appendix G. This change would exempt from reporting those acts of deception . intended for the purpose of simply gaining employment. Reference should be made to a May,1995 letter from the NRR.
bafeguards Branch to Regional Branch Chiefs.
Section_2.2_ Example 29
-Change the word "onsite" to " Protected Area." Several sites define onsite to include'the Owner Controlled Area. There appears to be no regulatory basis for reporting this event. ,
Section_2.3_Last_patagraph Add the words "or nuisance" after the word " false" in the first sentence.
Normally the frequency rates of nuisance and false alarms are combined when system reliability is questioned.
-LIC-98-0034=
Attachment Page 3 Section_2d_ Example _1 Change this sentence to read. " Loss of all AC power supply to security systems, or loss of all computer _ systems provided adequate compensatory measures can be maintained until systems are restored. Further, if a power loss or computer fai_ lure could not enable unauthorized or undetected access, no report or log entry is required. For example, a computer failure would not require reporting.
if as designed, it automatically switched over to a functioning backup computer without a time delay." This change gives credit for backup computers and power supplies which are considered compensation for primary losses.
Section_2A._ Example _2 This should be deleted. The event is adequately defined in Section 2,4. Example 18.8 and Section-2.5. Example 10.
SectiorL2AExample_3 Examples 3 and 4 are confusing and need clarification. In addition, a definition is needed for "short period of time" in Example 3 and " considerable time" in Example 4.
Section 2.4 _ Example _6 In the second sentence 9d the words "outside the Protected Area" after the word "keycard." Because of the validation step in the process, the badge is rendered useless once outside the protected area.
Sectiort2.4._ Example _8 Delete "have the pctential to" and combine Example 8 with Example 1. Any system perturbation has the 'otential for creating more progressively serious events.
If it doesn't resul' a degradation on loss of effectiveness, it is burdensome to_ require reportirs Section_2.L_ExampleJ Delete Example 9. since this is adequately covered in Examples 1. 8. and 14.
y LIC-98-0034~
Attachment, Page 4 Section:2.4_ Example _13 There-appears to be'no regulatory _ basis for reporting this event.
Section 2 A l xample_14
-Change the sentence to read. " Properly compensated loss of capabili.ty to remotely -
assess alarms while the intrusion detection system remains operational." Other means of assessment may be used.
Section_LA_ExampleJ8.2 l There needs to'be a clear definition of what is considered a "short peri < d of- ;
l time." '
L Section_L4_Examp.lela.3 Add to this paragraph, the words. "If an individual separates from his or her escort to use a rest room which has limited means of egress, and the escort' remains nearby and has full view of the egress area no report or 100 entry is required." This' change would ensure _this practice meets the intent of the escorting-requirements, Section_2..A.._ExampleJ8 4
; Add to'this paragraph, the words "This event can be logged even if the employee
.was.not authorized access to a VA if the improper entry was inadvertent or without malevolent intent." Generic Letter 91-03 clearly exempts an innocent or unintentional act'from being considered a reportable occurrence.
Section_2A_ Example _1830 LAdd a new Example 11. " Contraband which is not a significant threat, e.g. , rounds of ammunition innocuously left in a coat or vehicle " This change will eliminate unnecessary logging for actions that are void of malevolent intent.
LIC-98-0034 Attachment Page '
{
l l
Append 1LA l In the definition of Tampering, " Altering for improper purposes or in an improper I manner " add the words, "with malevolent intent" at the end of the senter.ce.
Reporting events prior to determining their validity and whether the action has or wuld have interrupted normal operation, detracts from licensees' ability to properly investigate the event. Intent and consequences are two key elements in making a reportability datermination. Human error is unintentional, whereas vandalism -is with intent, but does normally not affect safe operations.
Tampering must be with intent and affect operations and safety.
In the definition of Unauthorized person, de'ete the last sentence because it is l inconsistent with current guidance in Generic Letter 91-03.
AppendiLC
, Referring to the compensatory measures examples for Loss of all power to security l
systems, the posting of security officers has been an industry wide practice for loss of security system for many years. If compensatory posting occurs within a reasonable time, there should be no need for a one hour report. Therefore, add the following paragraph:
The overall .,,.9ctive is to provide compensation within ten minutes of discovery. If extenuating circumstances prevent compensation within ten minutes, the event need not be reported promptly provided that there was no malevolent intent, nothing adverse resulted from the delay, and the iicensee takes appropriate measures tc ensure a more timely response or other necessary action in the future.
The objective of compensatory action is to provide comparable security measures within a reasonable timeframe to ensure no loss or degradetion of effectiveness occurs. Ten minutes is a conservative goal, but should ret be the overriding factor in determining whether adequate compensation was achieved. If compensatory actions took twelve instead of ten minutes, due to an electrical storm and safety concerns for compensatory personnel, for example, the requirement to report such an occurrence would be burdensome and provide no appreciable benefit.
ulC-98-0034 Attachment Page 6 In the last section, Vital area card readers, the words "through which access is permitted" should be added to the last sentence. If a card reader is out of service and the associated door remains lor.ked and alarmed, there is no apparent need for compensation,
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