ML023110103
| ML023110103 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde, Wolf Creek, Diablo Canyon, Callaway, South Texas, Comanche Peak  |
| Issue date: | 10/25/2002 |
| From: | Woodlan D Strategic Teaming & Resource Sharing (STARS) |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 67FR47870 00003, DG-1099, STARS-02022 | |
| Download: ML023110103 (2) | |
Text
D. R Woodlan, Chairman Integrated Regulatory Affairs Group P.O. Box 1002, Glen Rose, Texas 76043 6
STARS-02022 October 25, 2002 Ref: DG-1099 C -7 Rules and Directives Branch, Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 STRATEGIC TEAMING AND RESOURCE SHARING (STARS)
COMMENTS ON DG-1099, "ANCHORING COMPONENTS AND STRUCTURAL SUPPORTS IN CONCRETE" Gentlemen:
This letter provides comments from the Strategic Teaming and Resource Sharing (STARS)'
nuclear power plants on draft Regulatory Guide DG-1099.
Because the design methodologies and acceptance criteria for anchoring components covered in this draft Regulatory Guide are significantly different than the current accepted design bases for the STARS plants, it is not anticipated that the Regulatory Guide will be adopted by many of the member plants. DG-1099 Section A, "Introduction," states that "implementation of this guidance by licensees will be on a strictly voluntary basis." It is recommended that Section D, "Implementation," include wording similar to that contained in Section A with regard to the voluntary adoption of DG-1099, such as:
Organizations holding a current operating license or construction permit may choose to continue to follow their current licensing basis or may select to follow the guidance of the regulatory guide to achieve compliance with the applicable regulatory requirements. No backfitting is intended or approved in connection with the issuance of this guide.
'STARS is an alliance of six plants (eleven nuclear units) operated by TXU Energy, AmerenUE, Wolf Creek Nuclear Operating Corporation, Pacific Gas and Electric Company, STP Nuclear Operating Company and Arizona Public Service Company.
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STARS 02022 Page 2 of 2 In addition, a section entitled "Backfit Analysis" should be provided with wording such as:
The regulatory guide does not require a backfit analysis as described in 10 CFR 50.109(c) because it does not impose a new or amended provision in the Commission's rules or a regulatory staff position interpreting the Commission's rules that is either new or different from a previous applicable staff position. In addition, this regulatory guide does not require the modification or addition to systems, structures, components, or design of a facility or the procedures or organization required to design, construct, or operate a facility. Rather, a licensee or applicant can select a preferred method for achieving compliance with a license or the rules or the orders of the Commission as described in 10 CFR 50.109(a)(7). This regulatory guide provides an opportunity to use industry-developed standards, if that is a licensee's or applicant's preferred method.
The STARS plants appreciate the opportunity to comment on this draft Regulatory Guide. If there are any questions regarding the above comments, please contact me at 254-897-6887 or email me at dwoodlal @txu.com.
Sincerely, D. R. Woodlan, Chairman Integrated Regulatory Affairs Group STARS