ML20198R208
| ML20198R208 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/08/1998 |
| From: | Dewhirst L NEBRASKA PUBLIC POWER DISTRICT |
| To: | Carol Gallagher NRC |
| References | |
| FRN-62FR63825, FRN-62FR63911, RULE-PR-50, RULE-PR-70 62FR63825-00006, 62FR63825-6, NUDOCS 9801230246 | |
| Download: ML20198R208 (3) | |
Text
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PROPOSED RULE N So 4 70 4
(G a M Gas ar)
DOCKETED (G a fit s s 9 n)
USHRC Froms
- Dewhirst, Linda R.* <lrdewhi9nppd.com>
j To:
- CAG0nrc. gov <CAGGnre. gov >
Date:
1/8/98 6:53pm
% g.Q P4:25 subjects Additional Comments on Final Rule 10 CFR 50.68 Ms. Gallagher OFR._ i a: m. t.
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a Recognizing the below comments are after the requested time but I Abdt(!; %i to share them anyway and ask for reedback if possible.
I've heard that other utilities have similar issues.
(I'm having trouble with my web browser recently so I thought I would take the email route). Thank you.
Comments on 100FR50.68, 10CFR70.24 Direct Final Rulemakir;,5 50.68(bl is unclear. What is the definition of transportation? Does this mean as soon as the truck which is hauling the numerous bundles of new fuel enters the restricte* (protected) area (fuel is in an approved
?.ransportation conceiner at this point)? The regulation does not Lay.
It would be'ridiculces for us to perform a determination on this truck
- under the most adverse moderation conditions feasible by unborated water
- if the bundles are still in their *.ransportation container. Has the GE container truly been analyzed under the most adverse conditions feasible _up to the point the bundle is unloaded from the box? What does handling *at any one time
- mean? Does this mean that I can't unload o.;e box from the truck on one elevation while operators are inspecting a bundle in the inspecti a stand on the refuel floor because I don't have a
- determination
- rovering the most adverse moderation conditions? How is the 'most udverse moderation conditions feasible by unborated water defined." What is considered an acceptable " determination?"
50.58 (b) (2) and (3) are silent about storing the new fuel on the refueling floor rather than in the new fuel storage vault (we do not use ours and when ITS goes into effect, it's prohibited). How will we be affected?
50.68 (b) (5) is very vague. Under the right conditions (i.e.,
in a laboratory environment) very small quantitles of SNM could be made critical. Laborat -
conditions are not applicable in our case but yet we are limited to han the quantity necessary for a critical team s.
- Why didn't the NRC add the criteria from Reg Guide 10.3 which ir very specific in its definition and is more applicable to power reactors (which are the intended audience for this regulatior)?
50.60 'b) (7)--why are we limiting enrichment? Why not keep it to Keff being less than our limit?
Th3 regulation is ei'.ent regarding licensces who already have an approved exemotion request to 10CFR70.24 from the NRC.
In addition, several utilities received an exemption before the seven c.riteria were puolished in IN 97-77 (CNS is not among them however, nor do we have an exemption at this time)
\\
h We are in the process of developing our exemption request; however if L/
50.68 is promulgated as planned, then is this necessary (providing we meet the requirements of the rule,.see the issues above).
Happy New Yeari 9901230246 900109
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PDR PR L
I 62FR63825 50 PDR I S/6
e Linda R. Dewhirst' Licensing Engineer--
Cooper Nuclear Station Tel 402.825.5009..
Faxt: 402.825.5827 emails :1rdewh19nppd.com V
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