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| | m DOCKET NUMBER V PROPOSED RULE N 50 t/ |
| | 5 VERMONT YANKEE (Wgg,og) y NUCLEAR POWER CORS'URXTION 185 Old Ferry Road, Brattleboro, VT 05301-7002 - |
| | (802) 257 5271 .g g 3 g)) $4 March 24,1999 BVY 99-41 Secretary, U.S. Nuclear Regulatory Commission g Washington,DC 20555 Air |
| | * Attention: Rulemaking and Adjudications Staff ; |
| | |
| | ==References:== |
| | (a) Federal Register, Vol. 64, No. 35, pages 9030 through 9037,10CFR Part 50, RIN , |
| | 3150 AG-20," Changes to Quality Assurance Programs," dated February 23,1999. l |
| | |
| | ==Subject:== |
| | Vermoet Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271) |
| | Comments Regarding Proposed Amendmeets to 10CFR50.54(a)(3) |
| | Pursuant to instructions in Reference (a), Vermont Yankee (VY) is submitting the following comments and questions regarding the subject rulemaking, which is scheduled to become effective on April 26,1999. |
| | : 1. It is clear from the Section-by-Section Analysis on page 9032 of Reference (a) that section 10CFR50.54(aX3Xi) of the proposed rule is intended to apply to programmatic quality assurance standards, such as ANSI N45.2 and its daughter standards, endorsed by NRC Regulatory Guides. |
| | However, a licensee may have referred to other national codes or standards in its Quality Assurance (QA) program, either as primary references or approved alternatives, that contain specific QA guidance although they are not endorsed by Regulatory Guides. An example in VY's case would j be ANS-22," Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants," ! |
| | which includes criteria for safety classification of plant systems and which has been superseded by j ANS-52.1, a later standard with the same title. ANS-22 was approved for this purpose by the NRC for use at VY as an acceptable alternative to adherence to Regulatory Guide 1.26. |
| | Are such non-programmatic QA standards intended to come under the purview of section 10CFR50.54(aX3Xi) of the proposed rule if earlier editions are presently included by reference in a licensee's approved QA program? . |
| | 1 2.- Section 10CFR50.54(aX3(i) of the preposed rule allows later editions of QA standards currently referenced in a licensee's QA program to be adopted by that licensee if they have been found I |
| | acceptable by the NRC with respect to the requirements of 10CFR50 Appendix B. |
| | Does inclusion of a later edition by reference in a licensee's approved licensing bases constitute erspuis by the NRC for adoption by other licensees under 10CFR50.54(aX3Xi)? [ Note that O 10CFR50.54(aX3Xii) allows use of a QA alternative or exception approved by the NRC in a Safety Evaluation Report for another facility as long as applicability to the adopting licensee's facility is demonstrated; however, this is not addressed in 10CFR50.54(aX3Xi)] |
| | 9903290231 990324 PDR PR 50 64FR9035 PDR hI |
| | |
| | VERMONT YANKEE NUCLEAR POWER CORPORATION 4] |
| | 8 BVY 99-41\ Page 2 of 2 Please direct any questions regarding this correspondence to Mr. Wayne M. Limberger at (802) 258-4237. |
| | Sincerely, VERM YANKEE NUCLE POWER CORPORATION |
| | )ML L |
| | /Gauhn Sen / |
| | Licensing Manager cc: USNRC Region 1 Administrator USNRC Resident Inspector- VYNPS USNRC Project Manager-VYNPS Vermont Department of Public Service}} |
Latest revision as of 13:52, 30 December 2020
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20204H9901999-03-24024 March 1999 Comment on Proposed Rule 10CFR50.54(a)(3) Re Changes to Quality Assurance Programs ML20206T9731998-05-27027 May 1998 Citizens Awareness Network'S Formal Request for Enforcement Action Against Vermont Yankee.* Requests That OL Be Suspended Until Facility Subjected to Independent Safety Analysis Review,Per 10CFR2.206 ML20247G8501998-04-0909 April 1998 Petition Demanding That Commission Issue Order Stating That Administrative Limits of TS 88 Re Torus Water Temp Shall Remain in Force Until Listed Conditions Met ML20217P5481998-04-0606 April 1998 Comment Supporting Proposed Rule 10CFR50 Re Proposed Changes to Industry Codes & Stds ML20199A3121998-01-20020 January 1998 Exemption from Requirements of 10CFR70.24 Re Criticality Monitors to Ensure That Personnel Would Be Alerted If Criticality Were to Occur During Handling of Snm.Exemption Granted ML20198L1791997-12-29029 December 1997 Final Director'S Decision DD-97-26 Pursuant to 10CFR2.206, Granting in Part Petitioners Request in That NRC Evaluated All of Issues Raised in Two Memoranda & Suppl Ltr Provided by Petitioner to See If Enforcement Action Warranted ML20217G7151997-10-0808 October 1997 Director'S Decision DD-97-25 Re J Block 961206 Petition Requesting Evaluation of 961205 Memo Re Info Presented by Licensee at 960723 Predecisional Enforcement Conference & 961206 Memo Re LERs Submitted at End of 1996.Grants Request ML20140C2511997-03-31031 March 1997 Comment Opposing Proposed Rule 10CFR170 & 171 Re Rev of Fee Schedules ML20134L5701996-12-0606 December 1996 Petition for Commission & EDO Evaluation of Encl Documents Pursuant to 10CFR2.206 to See If Enforcement Action Warranted Based Upon Info Contained Therein DD-93-23, Director'S Decision DD-93-23 Re M Daley & J M Block Requesting Per 10CFR2.206,that NRC Reconsider Civil Penalty Assessed Against Vynp for Operating Station Outside TS from 921015-930406.Request Denied1993-12-28028 December 1993 Director'S Decision DD-93-23 Re M Daley & J M Block Requesting Per 10CFR2.206,that NRC Reconsider Civil Penalty Assessed Against Vynp for Operating Station Outside TS from 921015-930406.Request Denied DD-93-19, Final Director'S Decision DD-93-19 Under 2.206.Denies Request That NRC Take Immediate EA to Require That Reactor at Plant Remain in Cold Shutdown Until Licensee Could Provide Proof That EDGs at Plant Meet Safety Function1993-12-14014 December 1993 Final Director'S Decision DD-93-19 Under 2.206.Denies Request That NRC Take Immediate EA to Require That Reactor at Plant Remain in Cold Shutdown Until Licensee Could Provide Proof That EDGs at Plant Meet Safety Function ML20057C1321993-09-16016 September 1993 Memorandum & Order (CLI-93-20).* Reverses Board Conclusion That NRC Staff Action Had Effect of Terminating Proceeding. W/Certificate of Svc.Served on 930916 ML20045H3741993-07-0909 July 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses.Proposed Change Would Eliminate NRC Requirement to Conduct & Supervise Individual Operator Requalification Exams During Term of Opeerator 6-yr License ML20128P9821993-02-24024 February 1993 Affidavit of Rd Pollard Re New England Coalition on Nuclear Pollution Comments in Opposition to Proposed Finding of NSHC ML20128Q0101993-02-22022 February 1993 New England Coalition on Nuclear Pollution Request for Hearing on Proposed Amend to Vermont Yankee OL ML20128Q0041993-02-22022 February 1993 New England Coalition on Nuclear Pollution Comment in Opposition to Proposed Finding of NSHC BVY-91-106, Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT1991-10-23023 October 1991 Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT ML20085H8331991-10-23023 October 1991 Comment Supporting Proposed Rule 10CFR50 Re NRC Proposed Amend to Policy Statement Concerning Cooperation W/States at Commercial Nuclear Power Plants ML20082G8961991-08-0909 August 1991 Memorandum of State of Vermont Concerning Withdrawal of Contention.* Contentions Re Maint & Proferred late-filed Contention Re Qa.W/Certificate of Svc ML20082G9071991-07-30030 July 1991 Withdrawal of Contention & Intervention.* Withdraws Contention,Motion (Pending) for Admission of late-filed Contention & Intervention ML20066G9981991-02-0808 February 1991 Notice of Withdrawal of Appearance.* Requests Withdrawal of Jp Trout as Counsel for Applicant in Proceeding. W/Certificate of Svc ML20065U0421990-12-12012 December 1990 State of VT Reply to NRC Staff Response to Vermont Yankee Fifth Motion to Compel.* Motion Should Be Denied on Basis of NRC Misciting Cases.W/Certificate of Svc ML20062H6711990-11-0101 November 1990 NRC Staff Response to State of VT Motion to File Reply.* Staff Believes That Matter Should Be Resolved as Soon as Possible & Not Defer Resolution of Matter Until After Not Yet Scheduled Prehearing Conference.W/Certificate of Svc ML20065K4021990-10-29029 October 1990 Answer to State of VT Motion for Leave.* Unless State of VT Substantially Suppls,In Timely Manner,Prior Responses,Then Staff Citation to Stonewalling by Intervenors in Shoreham Proceeding Would Seem Well on Point.W/Certificate of Svc ML20065K3961990-10-29029 October 1990 Answer to State of VT Motion to Compel (Document Request Set 3).* Motion Should Be Denied.W/Certificate of Svc ML20062C2321990-10-22022 October 1990 Answer of Vermont Yankee Nuclear Power Corp to State of VT Motion to Compel (Interrogatories,Set 3).* Motion Should Be Denied.W/Supporting Info & Certificate of Svc ML20062C2371990-10-18018 October 1990 State of VT Motion for Leave to File Reply to NRC Staff Response to Vermont Yankee Motion to Compel.* Alternatively, State Requests That Licensee Motion Be Included for Oral Arqument in Prehearing Conference.W/Certificate of Svc ML20062C0221990-10-12012 October 1990 State of VT Motion to Compel Answers to Document Production Requests (Vermont Set 3).* W/Certificate of Svc ML20059N8671990-10-0404 October 1990 Motion to Compel Answers to Interrogatories (State of VT Set 3).* Requests That Board Enter Order Compelling Licensee to Give Proper Answers to Interrogatories.W/Certificate of Svc ML20059M6461990-10-0202 October 1990 NRC Staff Response to Licensee Motion to Compel Production of Documents.* Supports Licensee Motion Due to State of VT Objections Not Well Founded.Notices of Appearance & Withdrawals & Certificate of Svc Encl ML20059M5591990-09-27027 September 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Corp Fifth Motion to Compel & State of VT Application for Protective Order.* Protective Order Should Be Issued So State Need Not Suppl Responses.W/Certificate of Svc ML20059M5711990-09-26026 September 1990 Supplemental Response to Applicant Interrogatories by State of VT (Set 3).* W/Certificate of Svc.Related Correspondence ML20059M6301990-09-21021 September 1990 Transcript of 900921 Affirmation/Discussion & Vote Public Meeting Re Termination of Plant Proceedings & Motions on ALAB-919 & Amends to 10CFR40 in Rockville,Md.Pp 1-5 ML20059L8791990-09-21021 September 1990 Memorandum & Order.* Motion to Dismiss Proceeding Granted & Proceeding Terminated.W/Certificate of Svc.Served on 900921 ML20059M6221990-09-21021 September 1990 Notice.* Notifies That Encl Request for Clarification from Commission Will Be Reported in NRC Issuances. Certificate of Svc Encl.Served on 900924 ML20059L8721990-09-14014 September 1990 Responses of Vermont Yankee Nuclear Power Corp to Document Requests Propounded by State of VT (Set 3).* Util Objects to Request on Grounds That Request Not Relevant to Admitted Contention.W/Certificate of Svc.Related Correspondence ML20059L8241990-09-14014 September 1990 Answers of Vermont Yankee Nuclear Power Corp to Interrogatories Propounded by State of VT (Set 3).* Supporting Info Encl.Related Correspondence ML20059L7241990-09-12012 September 1990 Motion to Compel Production of Documents (Set 1).* State of VT Should Be Compelled to Produce,In Manner Requested,Documents Requested in Util Requests 1-15 ML20059L7431990-09-12012 September 1990 NRC Staff Response to State of VT Motion for Leave to File Reply.* Licensing Board Should Grant State Motion.W/ Certificate of Svc ML20059C4891990-08-28028 August 1990 Responses to Document Requests by State of VT to Vermont Yankee Nuclear Power Corp (Set 1).* Certificate of Svc Encl. Related Correspondence ML20059C5341990-08-27027 August 1990 Memorandum & Order (Motion to Compel Answers to Interrogatories,Set 3).* State of VT Need Not Answer Interrogatories 1,5,14 or 15 Presently But Obligated To,If Further Info Develops.Served on 900827.W/Certificate of Svc ML20059C5931990-08-23023 August 1990 State of VT Motion for Leave to File Reply to Vermont Yankee Nuclear Corp & NRC Staff Answers to State of VT late-filed Contention.* Requests Permission to File Written Reply to Filings of Util & Nrc.W/Certificate of Svc ML20059C5471990-08-22022 August 1990 Stipulation Enlarging Time.* Parties Stipulate That Time within Which Licensee May Respond to State of VT Third Interrogatories & Requests for Production of Documents Enlarged to 900910.W/Certificate of Svc ML20059A8641990-08-17017 August 1990 State of VT Answer in Opposition to Vermont Yankee Nuclear Power Corp Fourth Motion to Compel & State of VT Application for Protective Order.* Board Should Deny Util Motion to Compel & Issue Protective Order.W/Certificate of Svc ML20059A9151990-08-13013 August 1990 NRC Staff Response to Motion to Amend State of VT Suppl to Petition to Intervene & Accept & Admit Addl late-filed Contention.* Licensing Board Should Reject Proposed Contention X.W/Certificate of Svc ML20059A9491990-08-13013 August 1990 Notice of Postponement of Prehearing Conference.* Conference Scheduled for 900821 & 22 in Brattleboro,Vt Postponed to Date to Be Determined Later.Certificate of Svc Encl.Served on 900814 ML20059A9031990-08-13013 August 1990 Responses to Interrogatories by State of VT to Vermont Yankee Nuclear Power Corp (Set 5).* Related Correspondence. W/Certificate of Svc ML20056B2221990-08-0808 August 1990 Answer of Vermont Yankee to State of VT Motion for Leave to Submit late-filed Contention.* Motion of State of VT for late-filed Contention Should Be Denied.W/Certificate of Svc ML20056B2141990-08-0606 August 1990 Supplemental Responses to Applicant Interrogatories by State of VT (Set 2).* Clarification Re Scope of Term Surveillance Program as Used in Contention 7 Provided.W/Certificate of Svc.Related Correspondence 1999-06-15
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20204H9901999-03-24024 March 1999 Comment on Proposed Rule 10CFR50.54(a)(3) Re Changes to Quality Assurance Programs ML20217P5481998-04-0606 April 1998 Comment Supporting Proposed Rule 10CFR50 Re Proposed Changes to Industry Codes & Stds ML20140C2511997-03-31031 March 1997 Comment Opposing Proposed Rule 10CFR170 & 171 Re Rev of Fee Schedules ML20045H3741993-07-0909 July 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses.Proposed Change Would Eliminate NRC Requirement to Conduct & Supervise Individual Operator Requalification Exams During Term of Opeerator 6-yr License ML20128Q0041993-02-22022 February 1993 New England Coalition on Nuclear Pollution Comment in Opposition to Proposed Finding of NSHC ML20085H8331991-10-23023 October 1991 Comment Supporting Proposed Rule 10CFR50 Re NRC Proposed Amend to Policy Statement Concerning Cooperation W/States at Commercial Nuclear Power Plants BVY-91-106, Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT1991-10-23023 October 1991 Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT ML20235T3581989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Util Endorses Comments Filed by NUMARC & Nuclear Util Backfitting & Reform Group.Rule Fails to Provide Basis for Determining Effective Maint Program ML20206M5371988-11-18018 November 1988 Comments on Rule 10CFR26 Re Fitness for Duty Program Rule. Recommends That NRC Include Rule Stating That NRC Regulations Preempt State &/Or Local Laws & Regulations to Ensure No Conflict Over Jurisdiction Develops ML20151L9621988-07-26026 July 1988 Comment Opposing Proposed Rules 10CFR170 & 171 Re Revs of Fee Schedules.Requests That Commissioners Reexamine NRC Current Budgetary Processes in Order to Provide Greater Assurance of Reasonable Correlation Between Svcs & Costs ML20196E2401988-06-15015 June 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations 1999-03-24
[Table view] |
Text
.
m DOCKET NUMBER V PROPOSED RULE N 50 t/
5 VERMONT YANKEE (Wgg,og) y NUCLEAR POWER CORS'URXTION 185 Old Ferry Road, Brattleboro, VT 05301-7002 -
(802) 257 5271 .g g 3 g)) $4 March 24,1999 BVY 99-41 Secretary, U.S. Nuclear Regulatory Commission g Washington,DC 20555 Air
- Attention: Rulemaking and Adjudications Staff ;
References:
(a) Federal Register, Vol. 64, No. 35, pages 9030 through 9037,10CFR Part 50, RIN ,
3150 AG-20," Changes to Quality Assurance Programs," dated February 23,1999. l
Subject:
Vermoet Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Comments Regarding Proposed Amendmeets to 10CFR50.54(a)(3)
Pursuant to instructions in Reference (a), Vermont Yankee (VY) is submitting the following comments and questions regarding the subject rulemaking, which is scheduled to become effective on April 26,1999.
- 1. It is clear from the Section-by-Section Analysis on page 9032 of Reference (a) that section 10CFR50.54(aX3Xi) of the proposed rule is intended to apply to programmatic quality assurance standards, such as ANSI N45.2 and its daughter standards, endorsed by NRC Regulatory Guides.
However, a licensee may have referred to other national codes or standards in its Quality Assurance (QA) program, either as primary references or approved alternatives, that contain specific QA guidance although they are not endorsed by Regulatory Guides. An example in VY's case would j be ANS-22," Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants," !
which includes criteria for safety classification of plant systems and which has been superseded by j ANS-52.1, a later standard with the same title. ANS-22 was approved for this purpose by the NRC for use at VY as an acceptable alternative to adherence to Regulatory Guide 1.26.
Are such non-programmatic QA standards intended to come under the purview of section 10CFR50.54(aX3Xi) of the proposed rule if earlier editions are presently included by reference in a licensee's approved QA program? .
1 2.- Section 10CFR50.54(aX3(i) of the preposed rule allows later editions of QA standards currently referenced in a licensee's QA program to be adopted by that licensee if they have been found I
acceptable by the NRC with respect to the requirements of 10CFR50 Appendix B.
Does inclusion of a later edition by reference in a licensee's approved licensing bases constitute erspuis by the NRC for adoption by other licensees under 10CFR50.54(aX3Xi)? [ Note that O 10CFR50.54(aX3Xii) allows use of a QA alternative or exception approved by the NRC in a Safety Evaluation Report for another facility as long as applicability to the adopting licensee's facility is demonstrated; however, this is not addressed in 10CFR50.54(aX3Xi)]
9903290231 990324 PDR PR 50 64FR9035 PDR hI
VERMONT YANKEE NUCLEAR POWER CORPORATION 4]
8 BVY 99-41\ Page 2 of 2 Please direct any questions regarding this correspondence to Mr. Wayne M. Limberger at (802) 258-4237.
Sincerely, VERM YANKEE NUCLE POWER CORPORATION
)ML L
/Gauhn Sen /
Licensing Manager cc: USNRC Region 1 Administrator USNRC Resident Inspector- VYNPS USNRC Project Manager-VYNPS Vermont Department of Public Service