ML071710639

Comment (14) Submitted by Strategic Teaming and Resource Sharing (Stars), T. Moser, on Proposed Rules Pr 50 Regarding Industry Codes and Standards; Amended Requirements

ML071710639
Person / Time
Site:	Palo Verde, Wolf Creek, Diablo Canyon, Callaway, South Texas, Comanche Peak
Issue date:	06/19/2007
From:	Moser T Strategic Teaming & Resource Sharing (STARS)
To:	Annette Vietti-Cook NRC/SECY/RAS
SECY RAS
References
72FR16731 00014, PR-50, RIN 3150-AH76, STARS-07004
Download: ML071710639 (5)

Text

Strateg~cTeaming and Resource Sharing T Moser, Chairman PR 50 STARS integrated Regulatory Affairs Group (72FR16731) P.0 Box 620, Fulton, miss our^ 65251 Ref: 10 CFR 50, RIN 3150-AH76 DOCKETED USNRC June 19,2007 June 20,2007 (10:15am)

Ms. Annette L. Vietti-Cook OFFICE OF SECRETARY Secretary, U. S. Nuclear Regulatory Commission RULEMAKINGS AND Washington, DC 20555-0001 ADJUDICATIONS STAFF ATTN: Rulemakings and Adjudications Staff STRATEGIC TEAMING AND RESOURCE SHARING (STARS)

COMMENTS ON PROPOSED AMENDMENT OF INDUSTRY CODES AND STANDARDS, 10 CFR 50, RIN 3150-AH76

Dear Ms. Cook,

The Strategic Teaming and Resource Sharing (STARS)' nuclear power plants would like to take advantage of this opportunity to comment on the subject proposed rulemaking. STARS has reviewed the letter being submitted by the American Society of Mechanical Engineers (ASME) on the proposed rulemaking and STARS strongly endorses the comments provided by ASME.

While STARS believes all of the comments are important, one merits specific mention in this letter based on its significance.

The proposed change to ASME Section XI, item 8, 10 CFR 50.55a(g)(6)(ii)(D) - Augmented Inspection of PWR Reactor Vessel Heads Endorsement of Code Case N-729-1. The NRC requested the ASME to develop a Code Case to cover this issue. ASME spent several years of its volunteer resources to complete this effort as a top priority task. During this time ASME met several times with the staff to address concerns related to cracking in Alloy 600 materials. This proposed rulemaking with the added conditions will make Code Case N-729-1 equivalent to the existing NRC Order EA-03-09, rendering all of the ASME work worthless. We are disappointed that the NRC has taken this position given that Code Case N-729-1 was developed and approved using the latest available technical information under an ANSI-approved consensus process. We request the NRC address and resolve this concern as a top priority issue as part of this proposed rulemaking.

1 STARS is an alliance of six plants (eleven nuclear units) operated by TXU Power, AmerenUE, Wolf Creek Nuclear Operating Corporation, Pacific Gas and Electric Company, STP Nuclear Operating Company and Arizona Public Service Company.

Calfaway

• Comanche Peak Diabio Canyon Pa10 Verde

• South Texas Project

• Wolf Creek

STARS-07004 Page 2 of 2 We encourage the Commission to permit the industry and ASME to work with the staff to resolve the comments and develop a rule that will be beneficial to all parties.

The STARS plants appreciate the opportunity to comment on the proposed rule. If there are any questions regarding this comment, please contact me at 573-676-4775, or tmoser@ameren.com, or Ted Koser at 361-972-8963, or tckoser@stpegs.com.

Sincerely, T. Moser, Chairman STARS Integrated Regulatory Affairs Group

SECY - STARS ~etteronProposed *~ulemaking ww -*A, -, -

Page 1 1 From: eccorbinl @txu.com>

To: cSECY @nrc.gov>

Date: Tue, Jun 19,2007 11:39 PlM

Subject:

STARS Letter on Proposed Rulemaking See attached letter. Letter is also sent via mail.

Thanks, Carl Corbin STARS Regulatory Affairs ccorbinl @txu.com cmailto:ccorbinl @txu.com> office 254-897-0121 -- home 972-775-8418 -- cell 972-841-8872 CC:

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STARS Letter on Proposed Rulemaking Creation Date Tue, Jun 19,2007 11:39 PM From: cccorbin 1@ txu.com>

Created By: ccorbin 1@txu.com Recipients nrc.gov TWGWP002.HQGWDOO 1 SECY (SECY) ameren.com tmoser CC stpegs.com tckoser CC Post Office Route TWGWP002.HQGWD001 nrc.gov ameren .corn stpegs.com Files Size Date & Time MESSAGE 223 Tuesday, June 19,2007 11:39 PM TEXT.htm 2626 STARS 07004 5055a.pdf 31932 Mime.822 49434 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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