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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20134K5021995-02-24024 February 1995 Transcript of 950224 Enforcement Conference in King of Prussia,Pa Re C Vondra.Pp 1-136 ML20134K4511995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re Plant.Pp 1-93 ML20134K4791995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re V Polizzi.Pp 1-115 ML20134K4971995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re L Reiter.Pp 1-64 ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20132B2281994-08-0202 August 1994 Transcript of 940802 Enforcement Conference in Salem,Nj W/Salem Senior Nuclear Shift Supervisor Involved in 940407 Event ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20246H8141989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged 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 ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20207H6521986-07-21021 July 1986 Transcript of Commission 860721 Discussion/Possible Vote on Full Power OL for Facility in Washington,Dc.Pp 1-76. Supporting Documentation Encl ML20203D9661986-07-21021 July 1986 Corrected Page 5 to 860721 Transcript Re Facility ML20107A5261985-02-19019 February 1985 Joint Motion for Leave to Withdraw as Party to Proceeding & Dismissal of Admitted Contentions.Draft Order Approving Both Requests,Settlement Agreement & Certificate of Svc Encl ML20114A6911985-01-23023 January 1985 Response Opposing Intervenor,Public Advocate of State of Ny Notice of Deposition & Motion for Protective Order. Certificate of Svc Encl.Related Correspondence ML20113H7211985-01-22022 January 1985 Response Opposing Applicant Motion for Sanctions Re Discovery.Certificate of Svc Encl.Related Correspondence ML20113H7321985-01-21021 January 1985 Second Supplemental Response to Preliminary & First Sets of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20114B7361985-01-21021 January 1985 Applicant Response to Intervenor Third Set of Interrogatories & Request for Production of Documents Re Pipe Cracks.Related Correspondence ML20113H9441985-01-18018 January 1985 Notice of H Sonn 850130 Deposition in Trenton,Nj.Concurrent Depositions of Listed Applicant Employees Requested.Related Correspondence ML20113H9671985-01-18018 January 1985 Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20113H8091985-01-17017 January 1985 Response to Applicant 850114 Objections to Intervenor 850104 Third Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112J2841985-01-15015 January 1985 Second Set of Interrogatories Requesting Production of Documents Re Listed Definitions & Instructions to Public Advocate.Certificate of Svc Encl.Related Correspondence ML20112G3921985-01-14014 January 1985 Motion That ASLB Impose Sanction of Dismissal of Contentions Due to Intervenor Failure to Respond to ASLB 841121 Order to Show Cause Why OL Proceeding Should Not Be Dismissed. Related Correspondence ML20112G4171985-01-14014 January 1985 Applicant Objections to Intervenor 850107 Third Set of Interrogatories & Request for Production of Documents to Applicants & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112D8631985-01-10010 January 1985 Response Opposing Intervenor 850107 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20112C0001985-01-0707 January 1985 Joint Motion for Issuance of Protective Order Re Personnel Info.Draft Protective Order,Unexecuted Affidavit & Certificate of Svc Encl.Related Correspondence ML20112C9651985-01-0707 January 1985 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor 841213 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101Q7911985-01-0404 January 1985 Intervenors Supplemental Response to Applicants Preliminary & First Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101Q6111985-01-0404 January 1985 Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence 1998-09-15
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20246H8141989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning 1998-09-15
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. O PSEG 00CKETED Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit MAR 3 01998 c Or_
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i U.S. Nuclear Regulatory Commission Secretary Washington, DC 20555 DOCKETNUMBER os Attn: Rulemaking and Ajudications Staff PROPOSED RULE rn 60 ,
COMMENTS ON NRC PROPOSED CHANGES TO 10 CFR 50.55a SALEM AND HOPE CREEK GENERATING STATIONS 3/
DOCKET NOS. 50-272, 50-311 AND 50-354
Dear Sir:
Enclosed are the Public Service Electric & Gas (PSE&G) comments on the proposed' rule changes to 10 CFR 50.55a, Industry Codes and Standards. The comments address the use of Engineering Judgment, limitations on the use af later ASME III Code editions for weld leg dimensions and seismic analysis, use of ASME published code interpretations, use of NOA-1 and the six month accelerated implementation of ASME XI Appendix VIII with the proposed limitations on examination specimens.
If you have any questions or require additional information, please' contact Mr. Dennis V. Hassler at (609) 339-1989 Sincerely,
, o i I ctu uf l D. R. Powell Director - /
Licensing / Regulation and Fuels Attachment 9804070288 980330 PDR PR
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I MAR 30.mgg Secretary - NRC 2 LR-N980149 C Mr. H. J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Ms. M. Evans (X24)
USNRC Senior Resident Inspector - Salem Mr. S. Morris (X24)
USNRC Senior Resident Inspector - Hope Creek Mr. K. Tosch, Manager IV, Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 David J. Modeen Director, Engineering Nuclear Generation NEI Suite 400 1776 I Street, NW Washington, DC 20006-3708 i
C
r LR-N980149 ATTACHMENT 1 PSE&G COMMENTS ON PROPOSED CHANGES TO 10 CFR 50.55A 1
1 1
- 1. The proposed change that requires a Licensee to seek formal NRC approval when employing " Engineering Judgment" for every activity or evaluation that is not directly addressed by the ASME Code (i.e., ASME Section III or Section XI) is unreasonable. The Code intrinsically relies on the professional judgment of an engineer, based upon his knowledge, education and experience to apply the requirements of the Code in day-to-day situations.
Imposing regulation that mandates the attainment of formal NRC acceptance for engineering judgments that are essential in using the ASME Code, effectively stops activities in areas where the ASME Code has jurisdiction. The impacts of requestinc NRC approval for Engineering Judgments are potential schedule delays, additional burden on the NRC and Licensee staffs, as well as additional costs.
- 2. ASME Section XI requires that technical provisions (e . g . , design, fabrication, ?xamination, etc.) be reconciled when employing the use of later editions / addenda of the ASME Code (s). The reconciliation of technical Code requirements can be analytically resolved (e.g., load combinations, fatigue usage factors, allowable stresses, etc.); however, to impose Rulemaking which mandates reconciling administrative requirements (i.e., N Stamping, Authorized Inspection Agency involvement, Code Data Reports, etc.)
which is noted in the proposed rule as " Owner's Requirements" places the Owner in a situation where such decisions require subjective engineering judgment. Under the proposed rule, this would require NRC approval and would add a large administrative burden to utility and NRC resources. Administrative requirements do not directly contribute to the structural integrity, functional reliability or inherent safety margins of components or systems.
Expenditure of utility and NRC resources to address non-safety significant administrative matters is inappropriate and distracts efforts that should be focused on nuclear safety.
- 3. In the Summary of Proposed Revision to 50.55a, the NRC discusses proposed limitations on the use of ASME published interpretations.
However, the proposed rule does not contain information on the use of ASME published interpretations. The proposed rule is silent on this issue and creates a situation that is impracticable. Since the NRC has no formal mechanism to specifically identify which ASME interpretations are perceived as being in conflict with NRC "
regulation, it will be difficult enough for a Licensee to meet this propose'd rule. However, since the 10 CFR 50.55a Rule only applies 1
6 LR-N980149 ATTACHMENT 1 PSE&G COMMENTS ON PROPOSED CHANGES TO 10 CFR 50.55A to Licensees and Construction Permit Holders, the application of an ,
ASME interpretation by an ASME Certificate Holder, during the construction of'a component, will not be subject to this Rulemaking limitations. The use of an ASME interpretation by an ASME Certificate Holder is not required to be captured or documented in design or construction records. Consequently, additional controls i will need to be established to validate whether an ASME interpretation was utilized by a Certificate Holder to construct a replacement component for the Licensee use. These additional i controls will result in additional time and cost considerations for the Licensee without a defined benefit.
- 4. The proposed Rulemaking's limitation on the use of NOA-1, suggests that NOA-1 does not satisfy l'0 CFR 50 Appendix B Quality Assurance requirements. This condition will create procurement constraints throughout the industry. ASME Certificate Holders are obligated to meet the latest published Code for QA Program provisions (e.g.,
ASME Section III), under ASME Accreditation requirements, even though that Certificate Holder uses earlier versions of ASME Section III, approved for use by the NRC through 10 CFR 50.55 (a), l to construct items for a specific Licensee. Therefore, at the present time, an ASME Certificate Holder is already authorized to use NQA-1 provisions that the Rulemakir' suggests may not be acceptable.
Certificate Holders are not lawfully obligated to meet 10 CFR 50.55(a) limitations, since these rules apply only to Licensees and Construction Permit Holders. Consequently, to procure a replacement item or a safety related service from an ASME Certificate Holder will result in the Licensee imposing additional 10 CFR 50 Appendix B provisions on future procurements in order to meet the proposed regulations and satisfy Appendix B QA requirements. While this is possible, many ASME Certificate Holder QA Programs are presently qualified through efforts such as Nuclear Utility Procurement Committee (NUPIC). If the proposed Rulemaking i is' implemented as written, there is the potential that ASME :
accredited organizations that are presently presumed to be qualified, will require individual Licensees to review all.present l and near.past procurements to determine if an ASME Certificate l Holders' QA Program has been deemed as unacceptable, due to the limitations created by the Rulemaking. These reviews will result in i additional time and cost considerations for the Licensee without a ;
l defined benefit.
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6 LR-N980149 ATTACHMENT 1 PSE&G COMMENTS ON PROPOSED CHANGES TO 10 CFR 50.55A
- 5. The six month accelerated implementation of ASME Section XI and Appendix'VIII provisions, along with the proposed rule limitations to employ cracks and replicate micro-structure in test specimens will create severe hardships for the industry and specifically PSE&G. Only a small number of vendors / personnel currently meet the Appendix VIII criteria, and not all UT techniques governed by these Appendices have been qualified to date. Further, the proposed limitation to use actual cracks and replicate microstructure in test specimens will effectively reduce or eliminate many of the vendors / personnel presently qualified.
The lack of available qualified resources to perform UT examinations will result in ISI outage examination (s) delays. If the proposed rule is implemented as it is written, including the accelerated six month schedule for compliance, there will likely be no personnel qualified to perform the ISI UT examinations of the Hope Creek Core Reactor dissimilar welds which are scheduled to be performed during 1999 Hope Creek refueling outage. To avoid outage impacts, exemptions will be required which will impact NRC and Licensee staffs.
- 6. The proposed Rulemaking limitations to use the 1989 Edition of ASME Section III requirements for weld leg dimensions and seismic design (i.e., reversing dynamic loads), even though the remainder of the proposed rule will adopt up to the 1996 Addenda of ASME Section III is not consistent with the intent of the Code which is intended to be utilized as a complete set of requirements contained within one edition or addenda. The use of mixed versions of ASME Section III, that the rule mandates, promotes a poor practice in applying the Code, sometimes referred to as " cherry picking.
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