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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARNG-99-1232, Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 7901011999-09-24024 September 1999 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101 NG-99-1296, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration NG-99-1263, Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide NG-99-0616, Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures1999-04-30030 April 1999 Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures NG-98-2045, Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments1998-12-18018 December 1998 Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments NG-98-2056, Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself1998-12-14014 December 1998 Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself NG-98-0926, Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement1998-05-22022 May 1998 Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement NG-98-0329, Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment1998-02-20020 February 1998 Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment NG-98-0065, Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping1998-01-0909 January 1998 Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping NG-97-2036, Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 19711997-11-25025 November 1997 Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 1971 NG-97-1213, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments)1997-07-0303 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments) NG-95-2723, Comment Supporting Revised NRC SALP Program1995-09-0505 September 1995 Comment Supporting Revised NRC SALP Program NG-95-1404, Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation1995-04-11011 April 1995 Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation NG-95-0464, Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors1995-02-0303 February 1995 Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors NG-94-4468, Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures1994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process NG-93-3257, Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses1993-08-12012 August 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses ML20045F8561993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Endorses NUMARC Comments ML20086K0431991-12-0202 December 1991 Comment on Draft Reg Guide DG-8003 & NUREG-1400, Air Sampling in Workplace. Licensee Feels That Concept Could Be Useful Tool in Determining When Air Sampling Is Warranted But Feels Hazard Index Level Needs Clarification NG-91-1144, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 19911991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 1991 NG-91-0222, Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept1991-01-28028 January 1991 Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept NG-90-2541, Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program1990-10-30030 October 1990 Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program NG-90-1446, Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements1990-07-0202 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements ML20195J9001988-11-29029 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Detailed Comments on Rule Encl 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 1999-09-24
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARNG-99-1232, Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 7901011999-09-24024 September 1999 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101 NG-99-1296, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration NG-99-1263, Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide NG-99-0616, Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures1999-04-30030 April 1999 Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures NG-98-2045, Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments1998-12-18018 December 1998 Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments NG-98-2056, Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself1998-12-14014 December 1998 Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself NG-98-0926, Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement1998-05-22022 May 1998 Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement NG-98-0329, Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment1998-02-20020 February 1998 Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment NG-98-0065, Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping1998-01-0909 January 1998 Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping NG-97-2036, Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 19711997-11-25025 November 1997 Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 1971 NG-97-1213, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments)1997-07-0303 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments) NG-95-2723, Comment Supporting Revised NRC SALP Program1995-09-0505 September 1995 Comment Supporting Revised NRC SALP Program NG-95-1404, Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation1995-04-11011 April 1995 Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation NG-95-0464, Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors1995-02-0303 February 1995 Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors NG-94-4468, Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures1994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process NG-93-3257, Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses1993-08-12012 August 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses ML20045F8561993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Endorses NUMARC Comments ML20086K0431991-12-0202 December 1991 Comment on Draft Reg Guide DG-8003 & NUREG-1400, Air Sampling in Workplace. Licensee Feels That Concept Could Be Useful Tool in Determining When Air Sampling Is Warranted But Feels Hazard Index Level Needs Clarification NG-91-1144, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 19911991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 1991 NG-91-0222, Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept1991-01-28028 January 1991 Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept NG-90-2541, Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program1990-10-30030 October 1990 Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program NG-90-1446, Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements1990-07-0202 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements ML20195J9001988-11-29029 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Detailed Comments on Rule Encl 1999-09-24
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- DO ti ~iD 1 ALLI ANT 'T" lEN 1"c-UTluTIES Duane Arnold Energy Wnter IES Utilities 9g gygg gDgi Offwe: 319 IGIIM i Fax:319.831398t>
www.alhant energttom December 14,1998 NG-98-2056 #s-Mr. John C. Hoyle' Secretary of the Commission DOCKET N Attention: Rulemakings and Adjudication's Staff PM M N 50 U. S. Nuclear Regulatory Commission [63FR5ppo/)
Mail Station 0-PI-37 Washington, D. C. 20555-0001 ,
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Subject:
Duane Arnold Energy Center l Docket No: 50-331 Op. License No: DPR-49 Comments on Proposed Rule Making to 10 CFR 50.65
Reference:
63 Fed. Rec. 52201 - September 30,1998 (Proposed Rulemaking to 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants)
File: A-119 The Duane Arnold Energy Center (DAEC, Alliant Energy) has reviewed the proposed rulemaking for 10 CFR 50.65 (the Maintenance Rule, i.e. the " Rule"), which would explicitly apply the Rule to normal shutdown operations, modify a recommendation for an assessment of equipment out of service to a regulatory requirement for an assessment of plant configuration prior to any maintenance activity, and require consideration of the above assessment result to ensure the plant is not placed in a risk-significant condition or that configurations occur that would degrade the performance of safety functions to an unacceptable level.
The purpose of the above proposal is clearly to ensure acceptable plant configuration control during power and shutdown operations, which is a concept DAEC wholeheartedly supports. DAEC has always treated the existing Rule language for such reviews as a requirement, and currently has configuration assessment programs for both online and refueling outage conditions to ensure plant risk is minimized.
9812300000 981214 1 PDR PR 50 63FR52201 PDR \
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. Mr. John C. Hoy el _
- December 14,1998 NG-98-2056 ,
Page 2 0f 3
- We do, however, have some concerns regarding the proposed Rule language itself. At DAEC, when a safety system, train or large component is taken out of service, many maintenance tasks may be performed concurrently on it or its supporting components in order to limit the total time during which the item is unable to perform its function. Prior to removing the system, etc. from service, our plant considers the effect of the action on plant risk, based on the current plant configuration and the ongoing availability of other systems, trains, and large components. This approach is in accordance with the current recommendation of paragraph (a)(3) of the Rule.
In contrast to the approach outlined above, the proposed Rule addition of paragraph (a)(4) could be understood to imply that for the scores of maintenance activities undertaken during any given week (generally on a few select systems) a documented and uniform description of the effect of each and every individual activity on overall safety function performance and on plant risk must be performed using established risk analysis techniques such as Probabilistic Risk Assessment. To require this level of discreet, detailed analysis would be burdensome, would provide little additional information with respect to limiting risk, and could be viewed as counterproductive to safety in that it would distract resources and attention from more important activities. The performance of a single analysis for the effect of removing a system, train or large component from service, regardless of what specific maintenance actions are to be undertaken on it, provides the same safety benefit with far less burden. We would recommend the proposed Rule language be clarified in this regard.
In addition, within the proposed paragraph (a)(4) modification, the precise meaning of the new phrases " risk-significant configurations" and " configurations that would degrade the performance of safety functions to unacceptable level" are not clear, and could be subject to interpretation. The meaning of such phrases should be explicit prior to the revised Rule's implementation.
We would also like to point out that the Rule in its current form already contains a
. provision which requires a performance-based assessment of the effectiveness of a plant's maintenance program. Adjustments are to be made if there is not an acceptable balance between the equipment out-of-service time (often for preventive maintenance) and the reliability of the equipment. This ongoing ba!ancing activity helps ensure that equipment is not taken out-of-service for excessive periods, which also serves to reduce risk.
The Nuclear Energy Institute (NEI) has also provided comments regarding the NRC's
, proposal, and DAEC would like to take this opportunity to endorse NEl's i recommendations regarding both the proposal's specifics and the general concept of making the Maintenance Rule more risk-informed, and we encourage their close review.
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Mr. John C. Hoyle December 14,1998 NG-98-2056 Page 3 of 3
- We agree that staff guidance for inspection and enforcement of the proposed Rule modifications should also be available for consideration prior to approval of the Rule change. Also of note is NEI's comment with respect to 10 CFR 50.65 scoping
- implementation and an apparent regulatory emphasis, thus far, on components oflow risk significance. This current emphasis has a considerable impact when examining the potential effect of proposed Maintenance Rule changes. In DAEC's case,107 of 170 l systems in the plant are within the scope of the current Rule. Of these 107 in-scope systems,56 are safety-related,51 are considered to be risk-significant, and 36 are both safety-related and risk-significant. Thus, fully one third of the systems which are l considered within the scope of the current Rule (36 of 107) are neither risk-significant nor
- safety-related. This does not appear to place application of the Rule in a very risk-i informed setting.
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, If you have any questions regarding this inatter, please feel free to contact this office.
Sincerely, i
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l Ken Peveler Manger, Regulatory Performance cc: R. Murrell E. Protsch J. Franz
- D. Wilson R. Laufer (NRC-NRR)
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