ML032470849

Comment (22) Submitted by Nuclear Management Company, Edward J. Weinkam on Proposed Rule PR-50 Re Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors

ML032470849
Person / Time
Site:	Monticello, Palisades, Kewaunee, Point Beach, Prairie Island, Duane Arnold
Issue date:	08/28/2003
From:	Weinkam E Nuclear Management Co
To:	NRC/SECY/RAS
Ngbea E S
References
+adjud/ruledam200505, 68FR26511 00022, PR-50
Download: ML032470849 (1)

Text

Coffed bNcerxeexe Nuclear Management Company, LLC 00Q W. H DOCKETED 00pobft ~~~~~~~~USNRC August 28, 2003 (gap ~ S -~ September3, 2003 (11:12AM)

OFFICE OF SECRETARY Atn: Rulemakings and Adjudications Staff RULEMAKINGS AND Secretary ADJUDICATIONS STAFF U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 COMMENTS ON NOTICE OF PROPOSED RULEMAKING FOR 10 CFR 50.69, RISK-INFORMED CATEGORIZATION AND TREATEMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS (68 FEDERAL REGISTER 2651 1, MAY 16, 2003)

Nuclear Management Company (NMC), LLC* appreciates the opportunity to comment on the NRC's proposed rulemaking for 10 CFR 50.69, Risk-Informed Categorization And Treatment of Structures, Systems and Components for Nuclear Power Reactors (68 Federal Register 26511, May 16, 2003).

NMC shares the concerns expressed by the Nuclear Energy Institute in their comments dated August 22, 2003. To reiterate, the proposed rule language and statements of consideration would impose prescriptive requirements and expectations for the treatment of low risk significant components that are impractical, not risk-effective, or actually exceed current regulatory requirements. In additon, the Federal Register notice raises the question of whether a NRC reviewed full scope, all modes PRA should be a prerequisite for Implementation of this rule. Such a requirement Is neither technically necessary, nor feasible and would eliminate 10 CFR 50.69 as a viable option for NMC.

Ed^f nkam retr, latory Services Nuclear Management Company, LLC

• NMC is the licensed operator of the Duane Arnold Energy Center, Kewaunee Nuclear Power Plant, Monticello Nuclear Generating Plant, Palisades Nuclear Plant, Point Beach Nuclear Plant Units 1 and 2, and Prairie Island Nuclear Generating Plant Units 1 and 2.

700 First Street

• Hudson, Wisconsin 54016 Telephone: 715.377.30 Temp loR, =sEcYko&1 sEc'Fo