ML023110103

Comment from D. R. Woodlan on DG-1099, Anchoring Components and Structural Supports in Concrete.

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

Strategic Teaming and Resource Sharing D. R Woodlan, Chairman Integrated Regulatory Affairs Group P.O. Box 1002, Glen Rose, Texas 76043 6 Ref: DG-1099 STARS-02022 October 25, 2002 Rules and Directives Branch, Office of Administration C -7 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:

Organizationsholding a current operatinglicense or constructionpermit 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 intendedor 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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Cailaway 0 Comanche Peak 0 Diablo Canyon Palo Verde

• South Texas Project

• Wolf Creek

STARS 02022 Page 2 of 2 In addition, a section entitled "Backfit Analysis" should be provided with wording such as:

The regulatoryguide does not requirea backfit analysis as describedin 10 CFR 50.109(c) because it does not impose a new or amendedprovision in the Commission's rules or a regulatorystaffposition interpretingthe Commission's rules that is either new or different from a previous applicablestaffposition. In addition, this regulatoryguide does not require the modification or addition to systems, structures,components, or design of a facility or the proceduresor organizationrequiredto design, construct, or operate a facility. Rather, a licensee or applicantcan select a preferredmethodfor achieving compliance with a license or the rules or the orders of the Commission as describedin 10 CFR 50.109(a)(7). This regulatoryguide provides an opportunity to use industry-developedstandards,if that is a licensee's or applicant'spreferredmethod.

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