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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20148M6511997-06-18018 June 1997 Comment Opposing Proposed Suppl to Bulletin 96-001 That Would Request Licensees to Take Action to Ensure Continued Operability of Control Rods L-95-045, Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors1995-10-19019 October 1995 Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors ML20080M1121995-02-27027 February 1995 Comment Re Proposed Suppl 5 to GL 88-20 IPEEE for Severe Accident Vulnerabilities. Proposed GL Suppl Should Indicate That Licensees Can Use Llnl Hazard Results of NUREG-1488 Re Revised Hazard Estimates Instead of NUREG/CR-5250 ML20073M0751994-09-23023 September 1994 Comment on Proposed Rules 10CFR30,40,70 & 72 Re Clarification of Decommissioning Funding Requirements. Permitting Access to Funds Only on Semiannual Basis Seems Unnecessarily Restrictive ML20069L5291994-06-13013 June 1994 Comment Supporting Proposed Rulemaking 50-60 Re Petition for Rulemaking & Changes to 10CFR50.54 ML20029D8251994-04-29029 April 1994 Comment Supporting Elimination of Proposed 5-yr Implementation Schedule & Believes That Current Programs Adequate to Maintain Containment Integrity ML20044G1971993-05-24024 May 1993 Comment Supporting Draft Insp Procedure Re Commercial Grade Procurement & Dedication ML20044E5721993-05-19019 May 1993 Comment Supporting Proposed Generic Ltr for Relocation of TS Tables on Instrument Response Time Limits ML20044D3271993-05-0707 May 1993 Comment Opposing Proposed GL Availability & Adequacy of Design Bases Info ML20125B6141992-12-0303 December 1992 Exemption from Requirements of 10CFR50,app a Re GDC-2 & 10CFR50.49 Re Environ Qualification of Electric Equipment Important to Safety for Nuclear Power Plants ML20095J6881992-04-23023 April 1992 Comment Opposing Draft Reg Guide DG-1022, Emergency Planning & Preparedness for Nuclear Power Plants ML20077R5161991-08-14014 August 1991 Comment Supporting Petition for Rulemaking PRM-20-20 Re Reduced Total Effective Dose Equivalent to Individual Members of Public from 0.5 Rem (5 Msv) to 0.1 Rem (1 Msv) ML20235N8531989-02-14014 February 1989 Comment Supporting Chapter 1 Re Policy Statement on Exemptions Below Regulatory Concern.Policy Development for Criteria for Release of Radioactive Matl Needed for Development of Consistent Waste Mgt Practices ML20235P3311989-02-0808 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20236P5851987-11-0909 November 1987 Transcript of 871109 Briefing in Washington,Dc Re Facility Steam Generator Tube Rupture Event.Pp 1-56.Supporting Documentation Encl ML20138N5311985-11-0101 November 1985 Memorandum & Order Affirming ASLB 850903 Initial Decision Authorizing Director of NRR to Issue License Amend for North Anna to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry Power Station.Served on 851101 ML20133K7171985-10-18018 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20133K6801985-10-18018 October 1985 Forwards Notice of Withdrawal of Appearance in Proceeding. Requests Svc List Be Revised to Include Client Under Listed Address.W/O Encl ML20133F4241985-10-0909 October 1985 Order Stating That ASLB 850903 Initial Decision Authorizing NRR to Amend OL to Permit Receipt & Storage of Spent Fuel Should Not Be Deemed Final,Pending Further Order. Served on 851009 ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20134N6981985-09-0303 September 1985 Initial Decision LBP-85-34 Authorizing NRR to Issue Amends to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies from Surry.Initial Decision Effective Immediately.Served on 850904 ML20134N4381985-09-0303 September 1985 Order Granting Licensee 850621 Request to Correct Transcript.Proposed Transcript Corrections & Certificate of Svc Encl.Served on 850904 ML20129K1251985-07-18018 July 1985 Brief in Support of NRC 850718 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing Issuance of Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129K1281985-07-18018 July 1985 Proposed Findings of Fact & Conclusions of Law in Form of Initial Decision Authorizing NRR to Issue Amend to Licenses NPF-4 & NPF-7 to Permit Receipt & Storage of 500 Spent Fuel Assemblies ML20129F8231985-07-12012 July 1985 Reply Opposing Concerned Citizens of Louisa County post- Hearing Brief.Licensee Proposed Findings of Sabotage & Human Error Not Addressed.Challenge of NRC EIS Conclusion Unnecessary.Certificate of Svc Encl ML20209F0021985-07-0808 July 1985 Post-hearing Brief Re Issues Raised at ASLB 850521 & 22 Evidentiary Hearings.Nrc Required by NEPA to Evaluate Alternative of Constructing & Operating Dry Cask Storage Facility,But Failed to Perform Even Cursory Review ML20209F2041985-07-0808 July 1985 Proposed Findings of Fact & Conclusions of Law Re Application for Amend to Ol,Authorizing Licensee to Ship 500 Spent Nuclear Fuel Assemblies from Surry Power Station to North Anna Station.Certificate of Svc Encl ML20128H0791985-07-0808 July 1985 Order Granting Concerned Citizens of Louisa County 850627 Motion for 7-day Extension Until 850708 to File Proposed Findings of Fact & Conclusions of Law.Served on 850708 ML20128G9471985-06-27027 June 1985 Motion for Extension of 850701 Deadline to File Proposed Findings of Fact & Conclusions of Law.Addl Wk Required Due to Addl Legal Duties.Certificate of Svc Encl ML20127F0511985-06-21021 June 1985 Proposed Findings of Fact & Conclusions of Law Re Util 820713 Application to Amend Ol,Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.Unsigned,Undated Order & Certificate of Svc Encl ML20127F0451985-06-21021 June 1985 Post-hearing Brief Requesting Board Find in Util Favor Re Proposed OL Amend Authorizing Receipt & Storage of Up to 500 Spent Nuclear Fuel Assemblies.No Basis from Sabotage or Human Error Considerations for Denying Proposed Amend ML20128A7731985-05-22022 May 1985 Transcript of 850522 Hearing in Charlottesville,Va.Pp 313-364.Supporting Documentation Encl ML20125C4081985-05-21021 May 1985 Applicant Exhibit A-H-11,consisting of Undated,Untitled Photograph H ML20125C3601985-05-21021 May 1985 Applicant Exhibit A-B-5,consisting of Undated,Untitled Photograph B ML20125C4221985-05-21021 May 1985 Applicant Exhibit A-J-13,consisting of Undated,Untitled Photograph J ML20125C3471985-05-21021 May 1985 Applicant Exhibit A-3,consisting of SAND82-2365, Assessment of Safety of Spent Fuel Transportation in Urban Environs, Dtd June 1983 ML20125C4301985-05-21021 May 1985 Applicant Exhibit A-K-14,consisting of Undated,Untitled Photograph K ML20125C3941985-05-21021 May 1985 Applicant Exhibit A-F-9,consisting of Undated,Untitled Photograph F ML20125C4361985-05-21021 May 1985 Applicant Exhibit A-L-15,consisting of Undated,Untitled Photograph L ML20125C3101985-05-21021 May 1985 Staff Exhibit S-1,consisting of Undated Environ Assessment & Finding of Proposed No Significant Impact Re 820713 & 0820 Applications for Amends to Licenses DPR-32,DPR-37,NPF-4 & NPF-7,allowing Receipt & Increased Storage of Spent Fuel ML20125C3411985-05-21021 May 1985 Applicant Exhibit A-2,consisting of 830915 Procedure 1-OP-4.19, Receipt & Storage of Spent Fuel TN-8L Shipping Cask Unloading & Handling Procedures ML20125C3291985-05-21021 May 1985 Staff Exhibit S-3,consisting of Forwarding NMSS Apr 1985 Environ Assessment Re 821008 Application for Authority to Construct & Operate Dry Cask ISFSI at Surry Power Station ML20125C4001985-05-21021 May 1985 Applicant Exhibit A-G-10,consisting of Undated,Untitled Photograph G ML20125C3381985-05-21021 May 1985 Applicant Exhibit A-1,consisting of 831104 Procedure OP-4.3, Shipping of Spent Fuel TN-8L Shipping Cask Loading & Handling Procedures, for Surry Power Station ML20125C3711985-05-21021 May 1985 Applicant Exhibit A-C-6,consisting of Undated,Untitled Photograph C ML20125C3791985-05-21021 May 1985 Applicant Exhibit A-D-7,consisting of Undated,Untitled Photograph D ML20125C3821985-05-21021 May 1985 Applicant Exhibit A-E-8,consisting of Undated,Untitled Photograph E ML20125C3501985-05-21021 May 1985 Applicant Exhibit A-A-4,consisting of Undated,Untitled Photograph a ML20125C3191985-05-21021 May 1985 Staff Exhibit S-2,consisting of Undated Safety Evaluation Re Increasing Spent Fuel Storage Capacity.Proposed Mods to Spent Fuel Pool & Transshipment/Storage of Spent Fuel Acceptable ML20125C4131985-05-21021 May 1985 Applicant Exhibit A-I-12,consisting of Undated,Untitled Photograph I 1997-06-18
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20148M6511997-06-18018 June 1997 Comment Opposing Proposed Suppl to Bulletin 96-001 That Would Request Licensees to Take Action to Ensure Continued Operability of Control Rods L-95-045, Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors1995-10-19019 October 1995 Comment on Proposed Rules 10CFR2,50 & 51 Re Decommissioning of Nuclear Power Reactors ML20080M1121995-02-27027 February 1995 Comment Re Proposed Suppl 5 to GL 88-20 IPEEE for Severe Accident Vulnerabilities. Proposed GL Suppl Should Indicate That Licensees Can Use Llnl Hazard Results of NUREG-1488 Re Revised Hazard Estimates Instead of NUREG/CR-5250 ML20073M0751994-09-23023 September 1994 Comment on Proposed Rules 10CFR30,40,70 & 72 Re Clarification of Decommissioning Funding Requirements. Permitting Access to Funds Only on Semiannual Basis Seems Unnecessarily Restrictive ML20069L5291994-06-13013 June 1994 Comment Supporting Proposed Rulemaking 50-60 Re Petition for Rulemaking & Changes to 10CFR50.54 ML20029D8251994-04-29029 April 1994 Comment Supporting Elimination of Proposed 5-yr Implementation Schedule & Believes That Current Programs Adequate to Maintain Containment Integrity ML20044G1971993-05-24024 May 1993 Comment Supporting Draft Insp Procedure Re Commercial Grade Procurement & Dedication ML20044E5721993-05-19019 May 1993 Comment Supporting Proposed Generic Ltr for Relocation of TS Tables on Instrument Response Time Limits ML20044D3271993-05-0707 May 1993 Comment Opposing Proposed GL Availability & Adequacy of Design Bases Info ML20095J6881992-04-23023 April 1992 Comment Opposing Draft Reg Guide DG-1022, Emergency Planning & Preparedness for Nuclear Power Plants ML20077R5161991-08-14014 August 1991 Comment Supporting Petition for Rulemaking PRM-20-20 Re Reduced Total Effective Dose Equivalent to Individual Members of Public from 0.5 Rem (5 Msv) to 0.1 Rem (1 Msv) ML20235N8531989-02-14014 February 1989 Comment Supporting Chapter 1 Re Policy Statement on Exemptions Below Regulatory Concern.Policy Development for Criteria for Release of Radioactive Matl Needed for Development of Consistent Waste Mgt Practices ML20235P3311989-02-0808 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants 1997-06-18
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File # 920 10g5 m 16 PS :02 E C Ref, # Fe r. Reg. 17499 (1994) 1UELECTRIC es
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UIIU5 " A gge" June 13, 94 BRANCH William J. Cahill Jr. ,
Group Vice President Mr. Samuel J. Chilk Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, DC 20555 '
Attn: Docketing and Service Branch
SUBJECT:
VIRGINIA ELECTRIC AND POWER COMPANY; PETITION FOR RULEMAKING.
59 FED. REG. 17499 (1994) ,
Dear Mr. Chilk:
These comments are submitted by TU Electric in response to the above referenced notice and invitation to comment on Virginia Electric and Power Company's petition for rulemaking to amend 10 CFR Part 50.54(t).
TV Electric supports the petition and believes that the proposed change to 10 CFR Part 50.54(t) is warranted.
Power reactor licensee effectiveness in emergency preparedness has improved steadily to the point where annual independent audits no longer provide a l significant benefit, let alone a benefit commensurate with their cost in i dollars and diverted resources. For the nuclear power industry, emergenc'/
preparedness audit deficiencies over the past few years have been largely absent or narrowly focussed. Furthermore, adequate safeguards exist to ensure that the effectiveness of licensee emergency preparedness does not deteriorate during the proposed two-year interval for audits.
The proposed relaxation of the annual audit requirement compliments VEPCo's March 1993 rulemaking petition -- still pending before the Commission -- to '
reduce the frequency of mandatory emergency preparedness exercises from annually to biennially. By alternating the mandatory emergency preparedness t audit and exercise, the NRC will still maintain a formal mechanism to annually verify emergency preparedness program effectiveness.
9406200051 940613 PDR PR 50 59FR17499 PDR
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400 N. Olive Street L.B. 81 Dallas. Texas 75201
e TXX-94161 Page 2 of 2 TV Electric agrees with VEPCo that annual audits are no longer necessary to ensure an adequate level of emergency response capability. Biennial audits would allow licensees to concentrate available audit resources in areas of observed weakness based on performance. Because the costs associated with the annual audit requirement are not commensurate with its safety benefits, amending the emergency preparedness rules to permit biennial audits could provide a net safety benefit.
Sincerely, Willi
By: ' dI ' '
J. S. Marshall Generic Licensing Manager CLW/grp