Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal| ML20058D483 |
| Person / Time |
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| Site: |
Point Beach  |
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| Issue date: |
10/15/1990 |
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| From: |
Fay C
WISCONSIN ELECTRIC POWER CO. |
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| To: |
Chilk S
NRC OFFICE OF THE SECRETARY (SECY) |
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| References |
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| FRN-55FR29043, FRN-56FR64943, RULE-PR-2, RULE-PR-50, RULE-PR-54 55FR29043-00096, 55FR29043-96, AD04-2-149, AD4-2, AD4-2-149, NUDOCS 9011060131 |
| Download: ML20058D483 (2) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20247H8981998-05-0707 May 1998
Exemption from Requirements of 10CFR50,App R,Section Iii.J for Emergency Lighting at Point Beach Nuclear Plant
ML20211L5921997-10-0606 October 1997
Exemption from 10CFR70.24,which Requires That Each Licensee Authorized to Possess Special Nuclear Matl Shall Maintain Criticality Accident Monitoring Sys in Each Area Where Such Matl Handled,Used or Stored.Commission Grants Exemption
NPL-97-0357, Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems1997-06-19019 June 1997
Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems
DD-97-15, Directors Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request1997-06-18018 June 1997
Directors Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request
ML20141B0451997-06-0909 June 1997
Requests Extension of Comment Period for NRC Bulletin 96-001,suppl 1 Re Control Rod Insertion Problems
ML20198R1511997-03-0505 March 1997
Transcript of 970305 OI Interview of Aj Cayia in Two Rivers, Wi Re NRC Investigation Case 3-97-008.Pp 1-70
ML20198R1281997-03-0404 March 1997
Transcript of 970304 OI Interview of T Malanowski in Two Rivers,Wi Re NRC Investigation Case 3-97-008.Pp 1-28
ML20198R1361997-03-0404 March 1997
Transcript of 970304 OI Interview of DF Johnson in Two Rivers,Wi Re NRC Investigation Case 3-97-008.Pp 1-37
ML20198R0931997-03-0404 March 1997
Transcript of 970304 OI Interview of Rj Harvey in Two Rivers,Wi Re NRC Investigation Case 3-97-008.Pp 1-28. Supporting Documentation Encl
ML20198R1111997-03-0404 March 1997
Transcript of 970304 OI Interview of E Ziller in Two Rivers, Wi Re NRC Investigation Case 3-97-008.Pp 1-33.Supporting Documentation Encl
ML20134B7371997-01-27027 January 1997
Exemption from Requirements of 10CFR50.60 to Determine That Setpoint for LTOP Events Will Not Present Undue Risk to Public & Safety.Exemption Granted
ML20095K0531995-11-28028 November 1995
Exemption from Requirements of App E of 10CFR50,allowing one-time Exemption from Annual Emergency Plan Exercise Requirement
NPL-95-0321, Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p)1995-07-11011 July 1995
Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p)
ML20085E6541995-06-13013 June 1995
Comment Re Draft NUREG/BR-0199, Responsiveness to Public. Expresses Concern on Dry Cask Storage W/Exemption Given to VSC-24 Cask & Procedures for Unloading & Transport at Plant
ML20078F4831994-12-20020 December 1994
Comment on Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Np Reactors.Informs That Util of Belief That NRC Already Has Appropriate Regulatory Authority Over Shutdown & low-power Operations,As Provided in Maint Rule
ML20077E8361994-12-0101 December 1994
Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low- Power Operations for Nuclear Power Reactors
ML20059E9331993-10-27027 October 1993
Comment Supporting Proposed Rule 10CFR171 Re Restoration of Generic Exemption from Annual Fees for Nonprofit Educational Institutions
ML20045D7331993-06-13013 June 1993
Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Recommends That NRC re-evaluate Proposed Testing Frequency Due to Random Testing Rate of 50% Sufficient to Provide Continued Detection Effectiveness
ML20127D7191992-09-0606 September 1992
Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule
ML20127D6371992-09-0303 September 1992
Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule & Urges NRC to Extend Comment Period in Order for Concerned Citizens to Prepare Thorough List of Objections
ML20114D2591992-08-24024 August 1992
Comment Opposing Proposed Rule 10CFR72 Re Proposal to Store Spent Nuclear Fuel in VSC-24 Storage Casks at Plant in State of Wi
ML20073N1141991-05-10010 May 1991
Comment Supporting Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery
ML20070F7501991-03-0505 March 1991
Exemption from 10CFR55.45(b)(2)(iii) to Permit Submittal of Simulation Facility Certification After 910326 Deadline in Rule But No Later than 910724
ML20058D4831990-10-15015 October 1990
Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal
ML20236A3081989-03-0808 March 1989
Exemption from 10CFR50,App K Re Injection of Low Pressure ECCS Into Upper Plenum of Reactor in Event of LOCA
ML20235S8381989-02-22022 February 1989
Comment Opposing Proposed Rules 10CFR50 & 55 Re Degree Requirement for Senior Reactor Operator (Sro).Unless Grandfathered in Next 4-5 Yrs Author to Be Locked Out of Job & Does Not Intend Spending 20 Plus Yrs as Reactor Operator
ML20235N8341989-02-17017 February 1989
Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants
ML20148K5591988-03-18018 March 1988
Comment Supporting Proposed Rule 10CFR50,App J Re Mass Point Method of Data Analysis.Recommends Test Duration Criteria in ANSI/ANS-56.8-1987,Section 5.4 Be Accepted in Revised Regulations
ML20236Q7991987-11-0909 November 1987
Comments on Proposed Rev 2 to Reg Guide 1.100 Re Seismic Qualification of Electrical & Mechanical Equipment for Nuclear Power Plants
ML20235V8231987-10-13013 October 1987
Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violations Noted During Special Physical Security Insp on 860718-0807
ML20212F3581986-12-31031 December 1986
Exemption to 10CFR50,App R,Section Iii.G Fire Protection Requirements,Per Licensee 830428 Request,As Supplemented by 831026,851211,860509 & 1010 Ltrs & Encl Franklin Research Ctr Technical Evaluation Rept
ML20136E0511985-11-20020 November 1985
Memorandum & Order Granting Licensee 850826 Request for Extension of Deadline for Environ Qualification of Electrical Equipment to 860525 for Unit 1 & 851231 for Unit 2.Served on 851120
ML20137C8601985-11-19019 November 1985
Transcript of Commission 851119 Affirmation/Discussion & Vote in Washington,Dc Re SECY-330(a) on Point Beach & SECY-225(a) on Sequoyah.Pp 1-5
ML20138M8711985-10-25025 October 1985
Transcript of 851025 Meeting in Washington,Dc Re Util Requests for Exemption from Environ Qualification.Pp 1-76
ML20129J0531985-07-0303 July 1985
Exemption from 10CFR50,App R,Subsection Iii.G Re Requirements for Fire Protection of Safe Shutdown Capability
ML20078L1661983-10-17017 October 1983
Response Opposing Wisconsin Environ Decade 830923 Petition for Review of ALAB-739 Re Steam Generator Tubes Repaired by Sleeving.Nexus Between Sleeving & Tube Failure Shown. Certificate of Svc Encl
ML20078C8801983-09-23023 September 1983
Petition for Review of Aslab 830907 Decision on Sleeving Degraded Steam Generator Tubes.Aslab Erroneously Denied Nexus Shown Between Sleeving & Tube Failure.Certificate of Svc Encl
ML20024F2901983-09-0707 September 1983
Decision ALAB-739,affirming ASLB 830204 Initial Decision LBP-83-4,authorizing Issuance of OL Amend to Allow Repair of Degraded Steam Generator Tubes by Sleeving.Wisconsin Environ Decade Failed to Link Sleeving to Tube Failures
ML20024F0001983-09-0606 September 1983
Order Extending Time Until 830921 for Commission to Act to Review ALAB-719
ML20076E1581983-08-22022 August 1983
Response Opposing Wisconsin Environ Decade 830811 Request to Respond to Hf Conrad Affidavit.Aslab Affirmed Dismissal of Decade Petition to Intervene.Decade Thus Lacks Party Standing.Certificate of Svc Encl.Related Correspondence
ML20024E3031983-08-0808 August 1983
Order Extending Time Until 830906 for Commission to Act to Review ALAB-719
ML20024D2151983-07-29029 July 1983
Affidavit of Hf Conrad in Response to Aslab Request Re NRC Assessment of Eddy Current Testing Techniques on Steam Generator Tubes in Transition Region.Prof Qualifications Encl
ML20024C3551983-07-0808 July 1983
Memorandum & Order Requesting NRC Assessment of Eddy Current Testing Techniques to Ensure Early Detection & Repair of Significant Degradation
ML20024C3981983-07-0808 July 1983
Order Extending Time Until 830807 for Commission to Act to Review ALAB-719
ML20204G3481983-04-29029 April 1983
Brief Opposing Wisconsin Environ Decade Exceptions to ASLB 830204 Initial Decision Authorizing full-scale Sleeving. Exceptions Waived for Failure to Brief or Arguments W/O Merits
ML20023C1441983-04-28028 April 1983
Exemption from Requirements of 10CFR50,App R,Section Iii.G Re Fixed Fire Suppression Sys in Control Room
ML20069K5951983-04-22022 April 1983
Answer Opposing Wisconsin Environ Decade 820407 Petition for Review of ALAB-719 Which Affirmed ASLB 821210 Special Prehearing Conference Order Dismissing Petition to Intervene.Matter Raised Not Reviewable.W/Certificate of Svc
ML20073D6991983-04-11011 April 1983
Request for Extension Until 830427 to File Opposition to Wisconsin Environ Decade Brief on Exceptions.Counsel Has Numerous Obligations Before ASLB & Aslab.Certificate of Svc Encl
ML20073B9701983-04-0707 April 1983
Petition for Review of Aslab 830322 Decision Denying Wisconsin Environ Decade 821220 Appeal of ASLB 821210 Prehearing Conference Order.Hearing on Steam Generator Tube Degradation Issue Should Be Held.Certificate of Svc Encl
ML20069F6491983-03-16016 March 1983
Brief Supporting Wi Environ Decade 830211 Exceptions to ASLB Initial Decision.Aslb Refused to Make Prerequisite Findings on Degree of Assurance Necessary to Protect Public Safety. Affidavit of Mailing Encl
1998-05-07
[Table view]
Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARNPL-97-0357, Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems1997-06-19019 June 1997
Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems
ML20141B0451997-06-0909 June 1997
Requests Extension of Comment Period for NRC Bulletin 96-001,suppl 1 Re Control Rod Insertion Problems
NPL-95-0321, Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p)1995-07-11011 July 1995
Comment on Proposed 10CFR50.54(p) Re Process for Changes to Security Plans W/O Prior NRC Approval.Supports Proposed Clarification of Language in 10CFR50.54(p)
ML20085E6541995-06-13013 June 1995
Comment Re Draft NUREG/BR-0199, Responsiveness to Public. Expresses Concern on Dry Cask Storage W/Exemption Given to VSC-24 Cask & Procedures for Unloading & Transport at Plant
ML20078F4831994-12-20020 December 1994
Comment on Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Np Reactors.Informs That Util of Belief That NRC Already Has Appropriate Regulatory Authority Over Shutdown & low-power Operations,As Provided in Maint Rule
ML20077E8361994-12-0101 December 1994
Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low- Power Operations for Nuclear Power Reactors
ML20059E9331993-10-27027 October 1993
Comment Supporting Proposed Rule 10CFR171 Re Restoration of Generic Exemption from Annual Fees for Nonprofit Educational Institutions
ML20045D7331993-06-13013 June 1993
Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Recommends That NRC re-evaluate Proposed Testing Frequency Due to Random Testing Rate of 50% Sufficient to Provide Continued Detection Effectiveness
ML20127D7191992-09-0606 September 1992
Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule
ML20127D6371992-09-0303 September 1992
Comment on Proposed Rule 10CFR72 Re Approval of Two Addl Dry Cask Storage Designs.Opposes Rule & Urges NRC to Extend Comment Period in Order for Concerned Citizens to Prepare Thorough List of Objections
ML20114D2591992-08-24024 August 1992
Comment Opposing Proposed Rule 10CFR72 Re Proposal to Store Spent Nuclear Fuel in VSC-24 Storage Casks at Plant in State of Wi
ML20073N1141991-05-10010 May 1991
Comment Supporting Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery
ML20058D4831990-10-15015 October 1990
Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal
ML20235S8381989-02-22022 February 1989
Comment Opposing Proposed Rules 10CFR50 & 55 Re Degree Requirement for Senior Reactor Operator (Sro).Unless Grandfathered in Next 4-5 Yrs Author to Be Locked Out of Job & Does Not Intend Spending 20 Plus Yrs as Reactor Operator
ML20235N8341989-02-17017 February 1989
Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants
ML20148K5591988-03-18018 March 1988
Comment Supporting Proposed Rule 10CFR50,App J Re Mass Point Method of Data Analysis.Recommends Test Duration Criteria in ANSI/ANS-56.8-1987,Section 5.4 Be Accepted in Revised Regulations
ML20236Q7991987-11-0909 November 1987
Comments on Proposed Rev 2 to Reg Guide 1.100 Re Seismic Qualification of Electrical & Mechanical Equipment for Nuclear Power Plants
1997-06-09
[Table view] |
Text
-
no0KET NUMBER
..eOSED RULE I0 ASHM e
Wisconsin
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$ch INY..Ni NRC-90 -104 H4NW October 15, 1990 Mr. Samuel Chilk, Secretary U. S. NUCLEAR REGULATORY COMMISSION Washington, D.
C.
20555 Attention: Docketing and Service Branch
Dear Mr. Chilk:
COMMENTS ON PROPOSED RULE - 10 CFR PARTS 2.
50.__AND S4 NUCLEAR POWER PLANT LICENSE RENEWAL Wisconsin Electric Power Company is owner and licensee for the Point Beach Nuclear Plant.
This letter is to transmit our comments l
on the NRC proposed rule on nuclear power plant license renewal as published in the Federal Reaister on July 17, 1990.
Wisconsin Electric considers the continued operation of Point Beach to be an essential alternative in providing a reliable and economical source of p9wer in Wisconsin.
Accordingly, we have 6
l participat~ed in the various industry efforts to address nuclear plant life extension.
We have previously participated on the NUPLEX Steering Committee and are current members of the NUMARC NUPLEX Working Group.
It is likely that we, as well as other utilities, will choose nuclear plant license renewal as the preferred option for supplying our customers with needed power I
during the early part of the 21st century.
This decision, however, I
will depend on the certainty and the costs. associated with this I
option.
It is clear that if the ultimate license renewal process is not predictable and does not result in the lowest cost of the replacement power options available, it will not be the option of choice for many utilities.
We trust the following comments will be of use to you in developing the final rule, and in formulating your 1
implementation policies for the rule.
First, we-endorse the comments submitted by the Nuclear Management and Resources Council (NUMARC) on the proposed rule.
We have participated in the discussion and development of the NUMARC comments within the NUMARC NUPLEX Working Group.
We endorse those comments and conclude they identify consensus industry concerns regarding the rule.
9011060131 901015 PDR PR 2 55FR29043 PDR
.4suMimofHkwm Exy avpvatim
t Mr. Samuel Chilk October 15, 1990 I
Page 2 We are concerned that the draft rule will introduce uncertainties and costs into the renewal process regarding the burden of submittals, public hearings, and ACRS review that are similar to original licensing proceedings.
While the renewal process is maybe an appropriate topic for limited hearings and ACRS review, we believe the scope of the plant specific evaluations identified in Section 54.21(a) are too broad and would add an unnecessary burden to the licensee and the NRC.
The systems, structures, and components (SSC) reviews required by this section are not limited to safety systems.
We suggest that the wording in the regulations should clearly state that the scope of the reviews should be limited to those safety related SCC subject to age related degradation only.
Components that are not required to function to satisfy the plant's safety analyses should not require formal assessments for aging concerns and should not require subsequent degradation control programs that were not necessary for the first 40 years of operation.
Finally, we believe the definition for " Established effective program" in Section 54.3(a) would require significant changes to existing programs.
Existing inspection, testing, repair and replacement, and environmental qualification programs may not, in many cases, meet the restrictive definition presented.
These programs, however, properly form the basis for current continued operation.
The definition should accept the licensing basis for existing programs that have been specifically submitted and reviewed by the NRC.
Disruption to significant ongoing programs, such as environmental qualification, that application of this definition"may require, would result in the development of entire new programs, along with substantial equipment replacements.
The definition should specifically recognize approved programs that are i
fulfilling the intent of the regulations.
As currently proposed, we conclude that most ongoing programs would not satisfy the restrictive requirements of this definition.
If you have any questions on these comments or require further l
clarifications, please do not hesitate to contact Mr. A. L. Reimer of my staff at 414-221-3957.
Very truly
- ours, i
.bs C. W.
Fay Vice President Nuclear Power PHK/pek Copies to:
NRC Regional Administrator, Region III NRC Resident Inspector
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