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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20153G3141998-06-29029 June 1998 Transcript of 980629 Public Meeting Re Peach Bottom Unit 1, Decommissioning Status in Delta,Pa.Pp 1-65.Reporter Certificate Encl ML20249B9981998-06-22022 June 1998 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements. Exemption Authorized ML20247M8801998-05-19019 May 1998 Confirmatory Order Modifying Licenses Effective Immediately. PECO Energy Co Shall Complete Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Peach Bottom Atomic Power Station,Units 2 & 3 ML20216G0321998-03-0404 March 1998 Comment Re Draft RG DG-1071, Std Format & Content for Post- Shutdown Decommissioning Activities Rept. Recommends That Draft RG Be Revised to Accommodate Situations Similar to That Described for Unit 1 ML20198J0931997-12-18018 December 1997 Order Approving Application Re Merger Between Atlantic Energy Inc,& Delmarva Power & Light Co ML20113C6631996-06-24024 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20115H7061996-06-0404 June 1996 Submits Addl Info to Support Petition for Rulemaking PRM-72-3 Re Amend to SAR ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20059L3201993-11-24024 November 1993 Exemption from Training Requirements of 10CFR50.120 Re Establishment,Implementation & Maintenance of Training Program ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20247B6151989-07-19019 July 1989 Memorandum & Order.* Grants Commonwealth of PA Motion Requesting Order Confirming Commonwealth Withdrawal of Petition to Intervene & Proposed Contentions & Terminating Proceeding.W/Certificate of Svc.Served on 890720 ML20246N8071989-06-30030 June 1989 NRC Staff Fourth Status Rept Re Settlement Agreement.* NRC Responded to Agreement,Per Encl ,Advising Licensee That NRC Has No Objection to Agreement Between Licensee & Commonwealth of Pa.W/Certificate of Svc ML20246P2951989-06-29029 June 1989 Notice of Withdrawal & Motion to Terminate Proceeding.* Withdraws 880122 Petition to Intervene & Requests Termination of Proceeding,Per Agreement Between Parties Re Licensee Commitment to Take Actions.W/Certificate of Svc ML20248B4631989-06-0101 June 1989 NRC Staff Third Status Rept Re Settlement Agreement.* Final Agreement Being Prepared,Per 890428 Meeting Resolving Outstanding Issues.W/Certificate of Svc ML20245J2331989-04-28028 April 1989 NRC Staff Second Status Rept Re Settlement Agreement.* Next Status Rept Will Be Filed by 890601.Certificate of Svc Encl ML20247B0641989-04-17017 April 1989 Transcript of 890417 Discussion/Possible Vote in Rockville, MD Re Plant Restart.Pp 1-64.Viewgraphs Encl ML20247A2971989-04-0404 April 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246P6921989-04-0404 April 1989 Requests Party Brief on Support of Appeal of Denial of FOIA Request Re Records of Investigation Into Events Surrounding 870331 Shutdown of Plant ML20248F5411989-03-31031 March 1989 NRC Staff Status Rept Concerning Settlement Agreement.* NRC Informed Commonwealth of PA & Util of Certain Concerns Noted in Review of Settlement Documents Forwarded by .W/Certificate of Svc ML20247A8861989-03-27027 March 1989 Memorandum & Order.* Stays Util Obligation to Respond to Contentions,Per Ongoing Settlement Discussions Between Util & Commonwealth of Pa.Monthly Status Rept Requested.W/ Certificate of Svc.Served on 890327 ML20247A6541989-03-24024 March 1989 Philadelphia Electric Co consented-to Motion to Stay Responses to Commonwealth of PA Proposed Contentions.* Requests That ASLB Stay Util Obligation to Respond to Commonwealth of PA 880824 Contentions.W/Certificate of Svc ML20236B4551989-03-0808 March 1989 Transcript of ACRS GE Reactor Plants Subcommittee 890308 Meeting in Bethesda,Md Re Peach Bottom Restart.Pp 1-129 ML20236B4001989-03-0808 March 1989 Transcript of ACRS GE Reactor Plants Subcommittee 890308 Meeting in Bethesda,Md Re Plant Restart.Pp 130-280. Supporting Documentation Encl ML20235N2611989-02-21021 February 1989 Philadelphia Electric Co consented-to Motion for 30-day Extension to Respond to Commonwealth of PA Contentions.* Requests That Deadline for Response & NRC Response to 880824 Contentions Be Extended by 30 Days.W/Certificate of Svc ML20235J5451989-02-0606 February 1989 Transcript of 890206 Briefing in Rockville,Md Re Status of Plant.Pp 1-49.Supporting Info Encl ML20206L6081988-11-18018 November 1988 Exemption from Schedular Requirements of 10CFR50.54(w) Re Property Insurance Required to Be Carried by Reactor Licensees ML20205R4041988-11-0404 November 1988 Order.* Grants Applicant 881103 Unopposed Motion for 45-day Extension of Time to Respond to Commonwealth of PA Contentions.Served on 881107 ML20205R8161988-11-0303 November 1988 PECO consented-to Motion for 45-day Extension to Respond to Commonwealth of PA Contentions.* Certificate of Svc Encl ML20205Q2061988-10-28028 October 1988 Comment Opposing Petition for Rulemaking PRM 50-52 Re Exemption of Financial Qualifications of Applicants from Review of OL Applications.Petition Presents No Compelling Reason to Amend Current Rules ML20195E6501988-10-24024 October 1988 Comment Supporting Petition for Rulemaking PRM 50-52 Re NRC Reinstatement of Financial Qualifications of Util as Consideration in Operating Licensing Hearings for Electric Utils ML20155F1681988-10-0505 October 1988 Transcript of 881005 Public Meeting in Rockville,Md Re Status of Plant.Pp 1-56.Viewgraphs & Notes Encl ML20155E8931988-10-0303 October 1988 Comment on Proposed Rule 10CFR50.54(w)(5)(i) Re Amending Implementation Schedule for Stabilization & Decontamination Priority & Trusteeship Provisions of Property Insurance Regulations.Nrc Initiated Exemptions Expected Before 881004 ML20154R6491988-09-25025 September 1988 Requests Extension of Comment Period on Proposed Rule 10CFR52 Re Reactor Licensing ML20153H6781988-09-0202 September 1988 Order.* Grants Applicant Unopposed Motion for 60-day Extension of Time to Respond to Commonwealth of PA Contentions.Nrc Also Granted Extension of Time.Served on 880906 ML20153H6901988-09-0101 September 1988 Philadelphia Electric Co Consented to Motion for 60-day Extension to Respond to Commonwealth of PA Contentions.* Certificate of Svc Encl ML20153D0451988-08-24024 August 1988 Supplement to Petition & Statement of Contentions of Commonwealth of Pa.* Requests That Board Grant Petition to Intervene & Request for Hearing on Contentions.Certificate of Svc Encl ML20151U7821988-08-10010 August 1988 Order Modifying License DPR-44,DPR-56,NPF-39 & CPPR-107 for Violations Involving Licensed Operators Sleeping in Control Room,Reading Matls Not Directly Job Related & Otherwise Inattentive to Obligations of License ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons ML20151G0031988-07-19019 July 1988 Comment on Proposed Rule 10CFR50 Re Cooperation W/States at Commercial Nuclear Power Plants & Other Facilities. Suggests Rev to Policy to Grant Same Rights & Responsibilities to All States within 10 Miles of Plant ML20196B4521988-06-17017 June 1988 Motion for Third Extension of Time in Which to File Contentions.* Granting of Addl Extension of Time of 60 Days Until 880824 for Filing of Contentions in Matter Requested. W/Certificate of Svc ML20195D1681988-06-17017 June 1988 Motion for Third Extension of Time in Which to File Contentions.* Commonwealth of PA Requests That Board Grant Addl Extension of Time Until 880824 for Filing of Contentions.Granted for Licensing Board.Served on 880621 ML20196B9211988-06-0808 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20197E1071988-05-25025 May 1988 Second Motion for Extension of Time in Which to File Contentions.* Served on 880525.Granted for ASLB on 880520 ML20154H7821988-05-19019 May 1988 Second Motion for Extension of Time in Which to File Contentions.* Requests Extension for Filing Until 880620 Due to Continued Discussions Between Util & Commonwealth of Pa. Certificate of Svc Encl ML20151Y4781988-05-0303 May 1988 Order.* Grants Commonwealth of PA 880422 Motion Seeking 30- Day Extension of Time for Filing Contentions & Amends to Petition to Intervene in Proceeding.Served on 880503 ML20151T4841988-04-22022 April 1988 Request for Extension of Time in Which to File Contentions & Supplement to Petition to Intervence & Request for Hearing.* Thirty-day Extension Sought for Listed Reasons. Certificate of Svc Encl ML20151E9391988-04-0808 April 1988 Memorandum & Order (Setting Deadline for Filing of Contentions).* Alters Deadlines in Section 2.714 (a)(3) & (B) of Order to Provide for Filing of Commonwealth Contentions & Amends to 880425 Petition ML20153E7281988-04-0101 April 1988 Order Appointing Licensing Board to Determine If Commonwealth of PA 880122 Petition Has Identified Issues within Scope of License Amends on Which Hearing Requested. Served on 880401 ML20196F5941988-02-24024 February 1988 Comment Supporting Proposed Rule 10CFR62 Re Emergency Access to Low Level Radwaste Disposal Sites.Believes Proposed Criteria Well Developed & Will Be Effective in Maintaining Control of Amount of Radwaste Sent to Sites 1998-06-29
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20216G0321998-03-0404 March 1998 Comment Re Draft RG DG-1071, Std Format & Content for Post- Shutdown Decommissioning Activities Rept. Recommends That Draft RG Be Revised to Accommodate Situations Similar to That Described for Unit 1 ML20113C6631996-06-24024 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20115H7061996-06-0404 June 1996 Submits Addl Info to Support Petition for Rulemaking PRM-72-3 Re Amend to SAR ML20083N3971995-04-26026 April 1995 Comment Supporting Proposed GL, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20081B3811995-03-0101 March 1995 Comment Supporting Proposed Suppl 5 to GL 88-20, IPEEE for Severe Accident Vulnerabilities ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20247A2971989-04-0404 April 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20205Q2061988-10-28028 October 1988 Comment Opposing Petition for Rulemaking PRM 50-52 Re Exemption of Financial Qualifications of Applicants from Review of OL Applications.Petition Presents No Compelling Reason to Amend Current Rules ML20195E6501988-10-24024 October 1988 Comment Supporting Petition for Rulemaking PRM 50-52 Re NRC Reinstatement of Financial Qualifications of Util as Consideration in Operating Licensing Hearings for Electric Utils ML20155E8931988-10-0303 October 1988 Comment on Proposed Rule 10CFR50.54(w)(5)(i) Re Amending Implementation Schedule for Stabilization & Decontamination Priority & Trusteeship Provisions of Property Insurance Regulations.Nrc Initiated Exemptions Expected Before 881004 ML20154R6491988-09-25025 September 1988 Requests Extension of Comment Period on Proposed Rule 10CFR52 Re Reactor Licensing ML20151G0031988-07-19019 July 1988 Comment on Proposed Rule 10CFR50 Re Cooperation W/States at Commercial Nuclear Power Plants & Other Facilities. Suggests Rev to Policy to Grant Same Rights & Responsibilities to All States within 10 Miles of Plant ML20196B9211988-06-0808 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F5941988-02-24024 February 1988 Comment Supporting Proposed Rule 10CFR62 Re Emergency Access to Low Level Radwaste Disposal Sites.Believes Proposed Criteria Well Developed & Will Be Effective in Maintaining Control of Amount of Radwaste Sent to Sites JPN-87-051, Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl1987-09-28028 September 1987 Comment Opposing Draft NUREG-1150, Reactor Risk Ref Document. Reduced Uncertainty in Risk Assessment Found to Be Significant W/Respect to NUREG-1150.NUREG Also Does Not Consider Value of Operator Actions.Addl Comments Encl ML20235T0211987-09-25025 September 1987 Comments on NUREG-1150, Reactor Risk Ref Document. Detailed Review Should Be Performed to Assure That Statements Made in NUREG-1150 & Supporting Analyses Have Same Basis ML20235C0901987-09-15015 September 1987 Comment Opposing Util Request for Amends to Licenses DPR-44 & DPR-56 Which Would Excuse Util from Requiring Senior Operator Licenses for Plant Manager & for Superintendent of Operations ML20235T1391987-01-26026 January 1987 Comments on Draft NUREG/CR-4550,Vol 3 Re Accident Sequence Characterization.Believes Analysis Should Be Corrected to More Realistically Estimate Core Damage Frequency ML20235T0681986-09-0202 September 1986 Comments on Draft NUREG/CR-4696 Re Containment Venting Analysis for Plant.Rept Contains Number of Factual Errors & Misrepresents Info Provided by Util.Requests Opportunity to Review Revised Draft Before Final Rept Published ML20235T0851986-07-18018 July 1986 Comments on Draft NUREG/CR-4696 Re Containment Venting Analysis for Plant.Conclusion Re Zero Probability of Successfully Venting Following Station Blackout Totally Misleading 1998-03-04
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PHILADELPHIA 2301 M A R K ELECTRIC ET ST R E bbS 5 Cp0 7R NC F'.O. BOX F3699 DRR:A0 % BR PHILADEl.PH! A, PA.1910g N 30 P 1 :08 (215) a41 4 5o 2
- 5. J. KOW A LSK!
VIC E September 25. 1987
. . . . . . . ..-....,......n.
PRESIDENT Chief, Rules and Procsdures Branch Division of Rules and Records Offico of Administration U.S. Nuclear Regulatory Cannission e.ashington, DC 20555
SUBJECT:
Carments on Draf t NUREG-1150 Reactor Risk Reference Docunent
REFERENCES:
- 1) Letter, V. S. Boyer to M. L. Ernst, dated September 2, 1986 Coments on Draf t NUREG/CR-4696
- 2) Letter, V. S. Boyer to W, M. Morris, dated September 19, 1986
! Carments on Peach Bottom Containment Event Tree
- 3) Letter, S. J. Kowalski to W. M. Morris,
, dated January 26, 1987 Corments on Draf t NUREG/CR-4550, Volume 3
- 9) Letter,, R. F. Janecek (BWROG) to NRC, j dated August 21, 1987 Co,ments on NUREG-1150 i The PhlNduphia Electric Company (PECo) appreciates the opportunity tr cryment. on the subject document. The opportunity to !
work with your contracter personnel during preparation of supporting l
documentation for NUREG-1150 has been beneficial for us in ;
understanding the current issues and risks calculated for PECo's Peach Bottom Atav.*c Paa r S t.at ion. You were unable to incorporate most of our carments on orly draft reports (References 1, 2, S 3) due to schedule restraints.. We therefore include them by reference as NUREG 1150 comnents.
PECo participated in development of the BWROG conments on NUREG-1150 (Reference 4) and supports the conments therein.
Use of risk assessment as a logical f ranym.-k for regulatory decision making and examination of safety issues represents a step forward in the regulation process. However supporting probabilistic and phenonenological analyses contain sone extremely conservative assumptions and uncertainties that affect the perception of risk as appl 1ed to BWRs, specifIcal1y Peach Bottom.
I 8710090232 NUREG 870925 l PDR PDR l
1150 C k Mr fd ,I
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i Assumptions made because of uncertainty in phenomena or insufficient data drive the calculated risk at Peach Botton in the current draft. Camon cause battery failure for example is a significant contributor to the total core danege frequency and has been asserted to exist without the necessary technical support. We believe that the analysis does not reflect our surveillance testing program and separation of the batteries between the two, generating-units. Reference 3) provides PECo comnents on battery failure and station blackout in general for the Peach bottom analysis,. >
')
The polling of experts to define or bound the uncoctainty of..
phenomena not calculated or mechanistically nodeled is a valid approach. The expert opinion process has a significant impact on the l
risk results.. In this regard the results are highly dependont on the process used to select the experts and the nethod of solicitation of. ,
their opinions. In order to produce unblased results, a saapilng 94a l
representative population of experts is required and their opinions l solicited in a nenner which provides technically-accurate results.
Based on the expert review group composition, it is not clear that they represent an unbiased cross-section of the current severe accident community. It would be appropriate to recognize industry experts outside those in the national laboratories and repo11 the
" expert group" prior to the final NUREG-1150 report.
The analysis of external events at Peach Bottom will provide a ,
nore conplete picture of the risks associated with operation of a nuclear facility. External events wly,have an impact on the results of current analyses described Ire NUREG-1150 and should have PECo and pubile review prior to the final g<hlication of NUREG-1150. As evidenced by the references and Infornal contacts with your contractors, PECo is interested Ir. eisuring realistic and accurapa l modeling of Peach Bottom.
Caution should be exercised when applying the insights or results of NUREG-1150. As indicated many times in the report, significant contributors to core danage frequency as well as the l uncertainty range of the reference plants limit the applicabilltv e.f l the study to other plants.
Discontinultles exist between statenents nede in the neln report and those found in the Appendices and supporting doctnentation. A 1 detailed review should be perforned to assure that the statenents nede !
In NUREG-1150 and the supporting anal 43es have the sane basis.
The results of the NUREG-1150 studies nust be carefully and clearly presented in the main report in order to prevent mistndetotanding by the general pubile such as that which occurred with the draf t docunent.
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Our experience and continued interaction with your contractors u Indicates we are all interested in a doctment of high technical quality-whic'n accurately characterizes reactor risk. More realistic analysis will help to attain this goal and make the supporting NUREG-1150
, ).
analyses more useful for decision making.
q' l1 -'
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Very truly yours,
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l GAK/cb/09168704 Attachments Copy to: V. Stello - NRC F. Eltawila - NRC J. Murphy - NRC a- W. Russell - NRC (Region I) g 1
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