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Category:Rulemaking-Comment
MONTHYEARNL-16-0432, Comment (125) of Charles R. Pierce on Behalf of Southern Nuclear Operating Co, Inc., on ANPR-26, 50, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors2016-03-17017 March 2016 Comment (125) of Charles R. Pierce on Behalf of Southern Nuclear Operating Co, Inc., on ANPR-26, 50, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors NRC-2010-0135, Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 AP1000 Design Certification Amendment2011-09-0909 September 2011 Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 AP1000 Design Certification Amendment ML1125210392011-09-0909 September 2011 Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 AP1000 Design Certification Amendment ML1125211062011-09-0909 September 2011 Commission Memorandum and Order (CLI-11-05) Regarding Pr 52 ESBWR Design Certification Amendment ML11138A2312011-05-12012 May 2011 2011/05/12-Comment (5) of Trent Sikes on Petition for Rulemaking PRM-50-96 Regarding NRC Amend Its Regulations Regarding the Domestic Licensing of Special Material NL-09-1658, Comment (15) of M. J. Ajluni, on Behalf of Southern Nuclear Operating Company, on ANPR 50 Regarding Performance-Based Emergency Core Cooling System Acceptance Criteria2009-10-27027 October 2009 Comment (15) of M. J. Ajluni, on Behalf of Southern Nuclear Operating Company, on ANPR 50 Regarding Performance-Based Emergency Core Cooling System Acceptance Criteria ML0929406192009-10-20020 October 2009 2009/10/20-Comment (42) of Christopher E. Boone on Behalf of Southern Nuclear Operating Company, on Proposed Rules Pr 50 & 52, Enhancements to Emergency Preparedness Regulations NL-09-0513, Comment (9) of Mark J. Ajluni, on Behalf of Southern Nuclear Operating Company, Inc., on Pr 170 and 171 - Revision of Fee Schedule; Fee Revovery for Fy 20092009-03-31031 March 2009 Comment (9) of Mark J. Ajluni, on Behalf of Southern Nuclear Operating Company, Inc., on Pr 170 and 171 - Revision of Fee Schedule; Fee Revovery for Fy 2009 ML0907003322009-02-10010 February 2009 Comment (155) of Moanica M. Caston, on Behalf of Southern Nuclear Operating Co., Re Pr 51, Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation and Related Waste Confidence. NRC-2008-0482, 2009/02/04-Comment (136) of Joan Mumaw on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update2009-02-0404 February 2009 2009/02/04-Comment (136) of Joan Mumaw on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update NRC-2008-0404, Comment (136) of Joan Mumaw on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update2009-02-0404 February 2009 Comment (136) of Joan Mumaw on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update NL-08-0751, Comment (28) of David H. Jones, on Behalf of Southern Nuclear Operating Company, Supports Nei'S Comments on Proposed Rules PR-20, 30, 40, 50, 70 and 72 Regarding Decommissioning Planning2008-05-0808 May 2008 Comment (28) of David H. Jones, on Behalf of Southern Nuclear Operating Company, Supports Nei'S Comments on Proposed Rules PR-20, 30, 40, 50, 70 and 72 Regarding Decommissioning Planning ML0736105962007-12-19019 December 2007 Comment (30) of Dale M. Lloyd on Behalf of Southern Nuclear Operating Company Re Proposed Rules Pr 52, Consideration of Aircraft Impacts for New Nuclear Power Reactor Designs. ML0719201582007-06-27027 June 2007 Comment (23) of Charles A. Tomes on Proposed Rules Pr 50 Regarding Industry Codes and Standards; Amended Requirements NL-07-1232, Comment (21) of L. M. Stinson on Behalf of Southern Nuclear Operating Company, Inc., on Proposed Rule Pr 50 Regarding Industry Codes and Standards; Amended Requirements2007-06-22022 June 2007 Comment (21) of L. M. Stinson on Behalf of Southern Nuclear Operating Company, Inc., on Proposed Rule Pr 50 Regarding Industry Codes and Standards; Amended Requirements ML0717702482007-06-15015 June 2007 Comment (16) Submitted by Charles A. Tomes on Proposed Rule Pr 50 Regarding Industry Codes and Standards; Amended Requirements NL-07-1229, Comment (16) Submitted by Southern Nuclear Operating Company, L. M. Stinson, on Pogo and Ucs PRM-50-83 Re Amend 10 CFR Part 50 Concerning Design Basis Threat2007-06-12012 June 2007 Comment (16) Submitted by Southern Nuclear Operating Company, L. M. Stinson, on Pogo and Ucs PRM-50-83 Re Amend 10 CFR Part 50 Concerning Design Basis Threat ML0716300542007-06-11011 June 2007 Comment (5) Submitted by George L. Fechter on Proposed Rules PR-50 Regarding Industry Codes and Standards; Amended Requirements NL-07-0681, Comment (40) Submitted by Southern Nuclear Operating Company, L. M. Stinson on Proposed Rulemaking PR-50, PR-72 & PR-73 Re Power Reactor Security Requirements2007-03-26026 March 2007 Comment (40) Submitted by Southern Nuclear Operating Company, L. M. Stinson on Proposed Rulemaking PR-50, PR-72 & PR-73 Re Power Reactor Security Requirements NL-07-0010, Comment (3) Submitted by Southern Nuclear Operating Co., Jeffrey T. Gasser on Proposed Rules PR-2, 30, 40, 50, 52, 60, 63, 70, 71, 72, 73, 76 & 150 Regarding Protection of Safeguards Information2007-01-0202 January 2007 Comment (3) Submitted by Southern Nuclear Operating Co., Jeffrey T. Gasser on Proposed Rules PR-2, 30, 40, 50, 52, 60, 63, 70, 71, 72, 73, 76 & 150 Regarding Protection of Safeguards Information L-HU-05-029, Comment (51) Submitted by Nuclear Management Company, LLC, Edward J. Weinkam on Proposed Rule PR-26 Regarding Fitness for Duty Programs2005-12-22022 December 2005 Comment (51) Submitted by Nuclear Management Company, LLC, Edward J. Weinkam on Proposed Rule PR-26 Regarding Fitness for Duty Programs ML0414501742004-05-20020 May 2004 Comment (2) Submitted by Southern Nuclear Operating, John O. Meier, Re Proposed Interim Enforcement Policy for Pilot Program on the Use of Alternative Dispute Resolution in the Enforcement Program Request for Comments NL-04-0317, Comment (4) Submitted by Southern Nuclear Operating Company, J. B. Beasley Jr., on Proposed Rules PR-170 & PR-171 Regarding Revision of Fee Schedules; Fee Recovery for FY20042004-03-0202 March 2004 Comment (4) Submitted by Southern Nuclear Operating Company, J. B. Beasley Jr., on Proposed Rules PR-170 & PR-171 Regarding Revision of Fee Schedules; Fee Recovery for FY2004 NL-03-1751, Comment (16) Submitted by Southern Nuclear Operating Co., J. B. Beasley on Proposed Rule PR-50 Re Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2003-08-28028 August 2003 Comment (16) Submitted by Southern Nuclear Operating Co., J. B. Beasley on Proposed Rule PR-50 Re Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors NL-03-1017, Comment (8) Submitted by Southern Nuclear Operating Company, Jeffrey T. Gasser, on Proposed Rules PR-170 & PR-171, Re Revision of Fee Schedules; Fee Recovery for Fy 20032003-05-0202 May 2003 Comment (8) Submitted by Southern Nuclear Operating Company, Jeffrey T. Gasser, on Proposed Rules PR-170 & PR-171, Re Revision of Fee Schedules; Fee Recovery for Fy 2003 ML0213701042002-05-16016 May 2002 Comment (2) Submitted by Southern Nuclear Operating Co., D. N. Morey, on Petition for Rulemaking PRM 50-75 Regarding Amendment of the Nrc'S Emergency Core Cooling System (ECCS) Regulations to Allow the Use of Anl Alternative Maximum Pipe Br 2016-03-17
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MAY. 16.2002 8:46RM SOUTHERN NUCLEAR (205)992 6108 NO. 691 P. 1 DOCKETED Dave Morey Southern Nuclear. USNRC Vice President Operaling Company, Inc.
Farley Project Post Office Box 1295 May 16, 2002 (1:25PM)
Birmingham, Alabama 35201 Tei 25.9825131OFFICE OF SECRETARY Tel 205.992,5131 RULEMAKINGS AND ADJUDICATIONS STAFF ST SOUTHERNA SPP 50o.75 COMPANY a 1() Energy to Serve Yovr World' Annette L. Vietti-Cook, Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Comments on NEI Petition for Large Break LOCA Redefinition Proposed Rulemaking (PRM-50-75 dated April 8, 2002)
Dear Ms. Vietti-Cook:
Southern Nuclear Operating Company (SNC), the licensed operator for the Joseph M, Farley Nuclear Plant, the Edwin I. Hatch Nuclear Plant and the Vogtle Electric Generating Plant, has reviewed the NEI Petition for Large Break LOCA Redefinition Proposed Rulemaking. SNC suppoi zs the proposal in the petition as an important element in creating a regulatory structure that reflects today's state of knowledge and operating experience.
The double-ended design basis large break required by the current regulations has far-reaching effects on plant design and operation; however, over 30 years of operating experience and improvements in engineering knowledge and methods have shown that a double-ended break of the largest reactor coolant system piping should no longer be a dominant LWR safety criterion.
Adoption by the NRC of the proposed petition would enable more regulatory and industry energy to be focused on areas that are of more benefit to the safe and reliable operation of the nation's nuclear power plants.
Also, as described in the petition, the existing regulations are inconsistent in their treatment of the dynamic effects and other design effects of a postulated design basis pipe break. Adoption of the proposed petition would allow the NRC to make the regulations more consistent, which would be expected to increase confidence in the regulatory process.
The industry and its various owners groups have collectively worked together to develop this NEI petition. This change to risk-inform Part 50 has been identified by industry as the single broadest improvement that can be made to Part 50. To date, this effort has had significant technical and financial support from the industry. However, we believe that we must achieve success with LBLOCA redefinition; otherwise, other important risk informed changes may not generate such active support or participation. The NRC's response to this petition Will provide a clear indication to industry of your interest in real risk informed changes.
"e n phor5S 0o6 SECY-062t
MAY. 16.2002 8:47AM SOUTHERN NUCLEAR (205)992 6108 NO.691 P.2 U.S. Nuclear Regulatory Commission Page 2 It is recognized that there are technical issues to be resolved related to the implementation of the revised rule. We believe that the resolution of these implementation issues should occur in parallel with rulemaking, and that rulemaking should not hinge on the prior resolution of all implementation issues.
SNC views the regulatory change proposed in the NEI petition as a cornerstone in the NRC's process to improve the regulatory structure. From the senior management level down, the industry has actively supported redefinition of the maximum break size and frequently encouraged the NRC to move forward with it as the highest priority for risk-informing the technical requirements in the regulations. In addition, SNC has provided leadership within the industry to develop program consensus for the proposed approach and associated rulemaking.
We recognize that there are challenges associated with changing a requirement that has existed for so long and which has such far-reaching effects, but it is clear the time has come. We do not want to see this opportunity for improvement pass unanswered.
We concur with recent statements of one Commissioner that "...the Large Break LOCA is obsolete now, a true anachronism in today's safety envelope. It needs to be abandoned in favor of what really affects safety and is risk significant." We believe that the NEI proposed rule will enable us to move toward this objective.
If you have any questions, please contact Lewis Ward at 205-992-7105.
Respectfully submitted,/
D. N. Morey Southern Nuclear Operating Company DNM/LAW/JMG cc: Southern Nuclear Operating Company Mr. J. B. Beasley, Vice President - Vogtle Mr, H. L. Sumner, Jr., Vice President - Hatch