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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20216F5591998-03-13013 March 1998 Application for Review of Combustion Engineering Ssar Design Certification Amend X, in Matter of C-E,Inc Std Plant Design ML20133D1201996-12-16016 December 1996 Requests Authorization for GE to Conduct narrowly-focused Review of Design Certification Rule for ABWR Before It Is Sent to Ofr & to Urge That Staff Rule Issuance Activities Be Expedited to Max Extent Feasible,All Re 10CFR52 ML20116C3331996-07-25025 July 1996 Comment Supporting Proposed Rule 10CFR52 Re Draft Final Design Certification Rules for ABWR & Sys 80+ Std Designs ML20116C2501996-07-24024 July 1996 Comment on Proposed Rule 10CFR52 Re Std Design Certification for Us Advanced BWR & Sys 80+ Std Designs ML20115J6731996-07-23023 July 1996 Comment Supporting Pr 10CFR52 Re Design Certification for Sys 80+ Std Plant Design ML20115J6831996-07-23023 July 1996 Comment on Supplementary Notice of Proposed Rulemaking for Design Certification of ABWR Under 10CFR52.GE Concerned About Lack of Design Finality Inherent in Identified Draft Rule Provisions ML20092B5721995-08-31031 August 1995 Comment Supporting Pr 52 60FR17902 Re Standard Design Certification for Us Advanced BWR Design ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H8501995-08-15015 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for Us ABWR Design & Sys 80+ Design. Supports NEI Comments L-95-015, Comment Supporting Proposed Rule 10CFR52 Re ABWR Design & Sys 80+ Design1995-08-15015 August 1995 Comment Supporting Proposed Rule 10CFR52 Re ABWR Design & Sys 80+ Design ML20087F8181995-08-12012 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for Us Advanced Boiling Water Reactor Design. Recommends That Staff Require Use of Armored Electrical Cable in Advanced LWRs ML20087H8301995-08-10010 August 1995 Comment on Proposed 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20092D2691995-08-10010 August 1995 Corrected Comment on Proposed Rule 10CFR52 Re Proposed Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20092D2961995-08-10010 August 1995 Correction to Comment on Proposed Rule 10CFR52 Re Proposed Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20087H8221995-08-10010 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20087F9161995-08-0707 August 1995 Comment Supporting Proposed Rule 10CFR52 Re Proposed Advanced Reactor Design Certification Rules ML20087F7611995-08-0707 August 1995 Comment Opposing Pr 10CFR52 Re Proposed Advanced Reactor Design Certification Rules ML20087F8201995-08-0707 August 1995 Comment Supporting Proposed Rule 52 Re Standard Design Certification for Us ABWR Design & Standard Design Certification for Sys 80+ Design ML20087F7951995-08-0707 August 1995 Comment Supporting Proposed Rule 10CFR52 Re Standard Design Certification for Us Boiling Water Reactor Design & Standard Designing Certification for Sys 80+ Design ML20087C0411995-08-0707 August 1995 Comment Supporting Proposed Rule 10CFR52 Re Std Design Certifications for Us Advanced BWR & Sys 80+ Designs ML20087C1971995-08-0707 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certifications for Us Advanced Boiling Water Reactor & Sys 80+ Designs.Doe Believes That Such Designs Can Significantly Complement Nation Energy Strategy ML20087C7671995-08-0606 August 1995 Comment Supporting Pr 10CFR42 Re Std Design Certification for Us Advanced BWR Design & for Sys 80+ Design ML20087C0691995-08-0404 August 1995 Comments on Proposed Rule 10CFR52 Re Std Design Certification of Us Advanced BWR & Sys 80+ Designs.Urges Commission to Carefully Consider Recommendations for Correcting Process Deficiencies Inherent in Noprs ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations L-95-225, Comment Supporting Proposed Rule 10CFR52 Re, Std Design Certification for Us ABWR Design & Std Design Certification for Sys 80+ Design1995-08-0404 August 1995 Comment Supporting Proposed Rule 10CFR52 Re, Std Design Certification for Us ABWR Design & Std Design Certification for Sys 80+ Design ML20087C2611995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re ABWR & Sys 80+ Designs. Goal of Safer,More Reliable New Nuclear Plant Designs Has Been Emphatically Achieved ML20087C0901995-08-0404 August 1995 Comment Supporting Pr 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors ML20087C2021995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification Rules for General Electric ABWR & Abb/Combustion Engineering Sys 80+ Standard Plant Designs ML20087C1711995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification for Standardized Advanced Reactors.Supports Comments Made by NEI ML20087C0981995-08-0404 August 1995 Comment Supporting Pr 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors ML20087C1051995-08-0404 August 1995 Comments on Proposed Rule 10CFR52 Re Std Design Certification for Advanced BWR Design.Urges Commission to Modify Proposed Rules as Recommended by NUMARC to Ensure Stability & Certainty of Part 52 Licensing Process ML20087C1631995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors.Supports Comments Submitted by NEI ML20087C1091995-08-0404 August 1995 Comment Supporting Pr 10CFR52 Re Std Design Certifications for Us Advanced Boiling Water Reactor & Sys 80+ Std Designs ML20087C1531995-08-0404 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for Sys 80+ Advanced Pressurized Water Reactor ML20087C1261995-08-0404 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for General Electric ABWR & Abb/Combustion Engineering Sys 80+ Advanced Pressurized Water Reactor ML20087C1481995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certifications for Us Advanced BWR & Sys 80+ Std Designs. Endorses & Supports Positions Set Forth in NEI Comments ML20087C1351995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Proposed Design Certification Rules for GE ABWR & ABB/C-E Sys 80+ Std Plant Designs.New Process Must Greatly Reduce Financial Risks of Unwarranted & Uncontrollable Delay Characteristics ML20087C0781995-08-0303 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for Sys 80+ Advanced Pressurized Water Reactor ML20087C3071995-08-0303 August 1995 Comment Supporting Proposed Rule 10CR52, Std Design Certification of Us ABWR Design ML20087C1321995-08-0303 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Rulemaking for Std Design Certification for Sys 80+ Design ML20087C0851995-08-0202 August 1995 Comments on Proposed Rule 10CFR52 Re Design Certification Rules for Std Advanced Reactors.Urges Commission to Carefully Consider Industry Comments & to Adopt Recommendations ML20087C1451995-08-0202 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Design Certification for Standardized Advanced Reactors ML20087C2891995-08-0202 August 1995 Comment Supporting Proposed Rule 10CFR52, Design Certification for Standardized Advanced Reactors & Sys 80+ ML20087C0761995-08-0202 August 1995 Comment on Proposed Design Certification Rule 10CFR52 Re Standardized Advanced Reactors.Urges Commission to Carefully Consider Industry Comments & to Adopt Recommedations Therein ML20087D5401995-08-0101 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for ABWR & Sys 80+ Designs ML20087D5111995-08-0101 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for ABWR & Sys 80+ Designs ML20087C2291995-07-31031 July 1995 Comment Supporting Proposed Rule 10CFR52 Re, Std Design Certification for Us ABWR Design ML20087C0971995-07-31031 July 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for Sys 80+ Advanced Pressurized Water Reactor ML20059L2041994-01-26026 January 1994 Transcript of 940126 Briefing by GE in Rockville,Md Re Status of ABWR Application for Design Certification.Pp 1-45. Supporting Documentation Encl 1998-03-13
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20133D1201996-12-16016 December 1996 Requests Authorization for GE to Conduct narrowly-focused Review of Design Certification Rule for ABWR Before It Is Sent to Ofr & to Urge That Staff Rule Issuance Activities Be Expedited to Max Extent Feasible,All Re 10CFR52 ML20116C3331996-07-25025 July 1996 Comment Supporting Proposed Rule 10CFR52 Re Draft Final Design Certification Rules for ABWR & Sys 80+ Std Designs ML20116C2501996-07-24024 July 1996 Comment on Proposed Rule 10CFR52 Re Std Design Certification for Us Advanced BWR & Sys 80+ Std Designs ML20115J6731996-07-23023 July 1996 Comment Supporting Pr 10CFR52 Re Design Certification for Sys 80+ Std Plant Design ML20115J6831996-07-23023 July 1996 Comment on Supplementary Notice of Proposed Rulemaking for Design Certification of ABWR Under 10CFR52.GE Concerned About Lack of Design Finality Inherent in Identified Draft Rule Provisions ML20092B5721995-08-31031 August 1995 Comment Supporting Pr 52 60FR17902 Re Standard Design Certification for Us Advanced BWR Design ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H8501995-08-15015 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for Us ABWR Design & Sys 80+ Design. Supports NEI Comments L-95-015, Comment Supporting Proposed Rule 10CFR52 Re ABWR Design & Sys 80+ Design1995-08-15015 August 1995 Comment Supporting Proposed Rule 10CFR52 Re ABWR Design & Sys 80+ Design ML20087F8181995-08-12012 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for Us Advanced Boiling Water Reactor Design. Recommends That Staff Require Use of Armored Electrical Cable in Advanced LWRs ML20087H8301995-08-10010 August 1995 Comment on Proposed 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20092D2691995-08-10010 August 1995 Corrected Comment on Proposed Rule 10CFR52 Re Proposed Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20092D2961995-08-10010 August 1995 Correction to Comment on Proposed Rule 10CFR52 Re Proposed Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20087H8221995-08-10010 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors.Supports NEI Comments ML20087C1971995-08-0707 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certifications for Us Advanced Boiling Water Reactor & Sys 80+ Designs.Doe Believes That Such Designs Can Significantly Complement Nation Energy Strategy ML20087F7611995-08-0707 August 1995 Comment Opposing Pr 10CFR52 Re Proposed Advanced Reactor Design Certification Rules ML20087F8201995-08-0707 August 1995 Comment Supporting Proposed Rule 52 Re Standard Design Certification for Us ABWR Design & Standard Design Certification for Sys 80+ Design ML20087F9161995-08-0707 August 1995 Comment Supporting Proposed Rule 10CFR52 Re Proposed Advanced Reactor Design Certification Rules ML20087F7951995-08-0707 August 1995 Comment Supporting Proposed Rule 10CFR52 Re Standard Design Certification for Us Boiling Water Reactor Design & Standard Designing Certification for Sys 80+ Design ML20087C0411995-08-0707 August 1995 Comment Supporting Proposed Rule 10CFR52 Re Std Design Certifications for Us Advanced BWR & Sys 80+ Designs ML20087C7671995-08-0606 August 1995 Comment Supporting Pr 10CFR42 Re Std Design Certification for Us Advanced BWR Design & for Sys 80+ Design ML20087C1351995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Proposed Design Certification Rules for GE ABWR & ABB/C-E Sys 80+ Std Plant Designs.New Process Must Greatly Reduce Financial Risks of Unwarranted & Uncontrollable Delay Characteristics ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML20087C2021995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification Rules for General Electric ABWR & Abb/Combustion Engineering Sys 80+ Standard Plant Designs ML20087C1711995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification for Standardized Advanced Reactors.Supports Comments Made by NEI L-95-225, Comment Supporting Proposed Rule 10CFR52 Re, Std Design Certification for Us ABWR Design & Std Design Certification for Sys 80+ Design1995-08-0404 August 1995 Comment Supporting Proposed Rule 10CFR52 Re, Std Design Certification for Us ABWR Design & Std Design Certification for Sys 80+ Design ML20087C1631995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors.Supports Comments Submitted by NEI ML20087C1531995-08-0404 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for Sys 80+ Advanced Pressurized Water Reactor ML20087C2611995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re ABWR & Sys 80+ Designs. Goal of Safer,More Reliable New Nuclear Plant Designs Has Been Emphatically Achieved ML20087C1481995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certifications for Us Advanced BWR & Sys 80+ Std Designs. Endorses & Supports Positions Set Forth in NEI Comments ML20087C0691995-08-0404 August 1995 Comments on Proposed Rule 10CFR52 Re Std Design Certification of Us Advanced BWR & Sys 80+ Designs.Urges Commission to Carefully Consider Recommendations for Correcting Process Deficiencies Inherent in Noprs ML20087C0901995-08-0404 August 1995 Comment Supporting Pr 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors ML20087C0981995-08-0404 August 1995 Comment Supporting Pr 10CFR52 Re Design Certification Rules for Standardized Advanced Reactors ML20087C1051995-08-0404 August 1995 Comments on Proposed Rule 10CFR52 Re Std Design Certification for Advanced BWR Design.Urges Commission to Modify Proposed Rules as Recommended by NUMARC to Ensure Stability & Certainty of Part 52 Licensing Process ML20087C1091995-08-0404 August 1995 Comment Supporting Pr 10CFR52 Re Std Design Certifications for Us Advanced Boiling Water Reactor & Sys 80+ Std Designs ML20087C1261995-08-0404 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for General Electric ABWR & Abb/Combustion Engineering Sys 80+ Advanced Pressurized Water Reactor ML20087C0781995-08-0303 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for Sys 80+ Advanced Pressurized Water Reactor ML20087C3071995-08-0303 August 1995 Comment Supporting Proposed Rule 10CR52, Std Design Certification of Us ABWR Design ML20087C1321995-08-0303 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Rulemaking for Std Design Certification for Sys 80+ Design ML20087C0761995-08-0202 August 1995 Comment on Proposed Design Certification Rule 10CFR52 Re Standardized Advanced Reactors.Urges Commission to Carefully Consider Industry Comments & to Adopt Recommedations Therein ML20087C0851995-08-0202 August 1995 Comments on Proposed Rule 10CFR52 Re Design Certification Rules for Std Advanced Reactors.Urges Commission to Carefully Consider Industry Comments & to Adopt Recommendations ML20087C2891995-08-0202 August 1995 Comment Supporting Proposed Rule 10CFR52, Design Certification for Standardized Advanced Reactors & Sys 80+ ML20087C1451995-08-0202 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Design Certification for Standardized Advanced Reactors ML20087D5401995-08-0101 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for ABWR & Sys 80+ Designs ML20087D5111995-08-0101 August 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for ABWR & Sys 80+ Designs ML20087C0971995-07-31031 July 1995 Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for Sys 80+ Advanced Pressurized Water Reactor ML20087C2291995-07-31031 July 1995 Comment Supporting Proposed Rule 10CFR52 Re, Std Design Certification for Us ABWR Design 1996-07-25
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p Commcawerith F11ison Osmpany g
1409 Opus Place Downers Grove,1140515 00CKETED USHRC
'95 E 17 CFFICE OF SECRETARY 00CKET!NG 2 SERVICE August 10,1995 MANCd DOCKET NUMBER ,
Secretary of the Commission PROPOSED RULE --
U. S. Nuclear Regulatory Commission gg g 11555 Rockville Pike 4 Rockville, Maryland 20852-2738 -
J Attention Docketing and Services Branch
Subject:
Proposed Design Certification Rules for Standardized Advanced Reactors (60 Federal Register 17902 and 17924) i
Dear Sir:
The Nuclear Regulatory Commission (NRC) published on April 7,1995, proposed Design Certification Rules for General Electric's Advanced Boiling Water Reactor and ABB's System 80+ standard designs and invited comments from the stakeholders.
Comed offers the following in that regard.
NRC is to be commended for undertaking the effort to establish an improved regulatory process under 10CFR Part 52. This improved regulatory process with the stated Commission goals of early resolution of safety issues, enhanced safety and reliability of fuhxe nuclear power plants, a more predictable and stable licensing process, and Stendardization of future plants, is also a key building block in the industry's Strategic l Plan for Building New Nuclear Power Plants. The industry has expended significant I resources on development of standardized designs for utilization of this improved l licensing process and in working with the NRC in developing details of the implementation process for 10CFR Part 52. Issuance of these Proposed Design Rules marks a major milestone towards completion of that effort.
However, Comed has serious concems regarding many details of the implementation process as embodied in the Proposed Rules or as understood by us from preceding discussions between the Nuclear Energy Instituts (NEI) and the NRC staff. Without a l satisfactory resolution of these concems regarding the implementation process, the l objective of a stable and predictable licensing environment may be compromised to a l point where the usefulness of design certification in licensing a new nuclear power 9500180214 950810 PDR 4
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The Design Certification Rules do not contain explicit provisions to ensure that NRC l will have a stable and predictable process for making its finding that the ITAAC have l been met. Without a clearly understood basis for making such a finding, the whole foundation of the part 52 process may be in question.
The proposed rules do not provide sufficient finality for resolved issues and permitted changes. For example, sufficiency of the standard designs, i.e. the lack of need for additional safety features is not explicitly included as a resolved issue and thus has no s finality. Additionally, changes permitted under 50.59 process are not accorded finality.
Such lack of finality on resolved issues and on changes under 50.59 process create major uncertainties and risks for potential future owners.
s The staff proposal for consideration of Severe Accident Probatiilistic Analyses in 50.59 safety evaluations are overty burdensome. The Rules seem to require that any 50.59 evaluation consider all of the extensive analyses contained in Chapter 19 of the Design Control Documents. Furthermore, any change - even the most insignificant - in the PRA results contained in Chapter 19 is considered an unreviewed safety question.
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These requirements are unnecessarily burdensome.
The Design Certification rules do not allow Design Certification applicant to make 50.59 type changes after Design Certification. Such a provision is necessary to allow the industry to incorporate lessons teamed. Without such a provision, the owner licensee will be left with the burden to justify all such changes on a plant by plant basis with consequent risks and potential departures from standardization.
New " Applicable Regulations" are unnecessary and will create a destabilizing effect through potential backfits. The design certification applicants have voluntarily agreed to incorporate design features that satisfy various staff positions. The staff has found
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these design features to be a satisfactory implementation of these positions, inclusion of these new " Applicable Regulations" creates uncertainty as to how these
" regulations" will be interpreted and applied in the future.
The foregoing is a very brief synopsis of some of our major concems. Industry has additional concems regarding many of the details of the proposed rules. NEl has prepared, with input and consultation from the nuclear utility industry, consolidated detailed comments on the Proposed Rules. These comments have been submitted to you on behalf of the nuclear industry, directly by NEl. Comed fully supports these comments.
Resolution of these comments can ensure that the Proposed Rules will achieve its basic objective of reducing the regulatory uncertainties to a point where a potential licensee can have the confidence to invest the resources necessary to build a new nuclear plant using the standardized design and the Part 52 licensing process.
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We strongly urge the NRC to give careful consideration to the comments provided by NEl on behalf of the nuclear industry.
Sincerely, ,
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,q Michael J. Wallace * '
O Senior Vice President Chief Nuclear Officer ec: Phillip Bayne, Nuclear Energy institute 1
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