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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20134K5021995-02-24024 February 1995 Transcript of 950224 Enforcement Conference in King of Prussia,Pa Re C Vondra.Pp 1-136 ML20134K4511995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re Plant.Pp 1-93 ML20134K4791995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re V Polizzi.Pp 1-115 ML20134K4971995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re L Reiter.Pp 1-64 ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20132B2281994-08-0202 August 1994 Transcript of 940802 Enforcement Conference in Salem,Nj W/Salem Senior Nuclear Shift Supervisor Involved in 940407 Event ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection 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 ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20246H8141989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged 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 ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20207H6521986-07-21021 July 1986 Transcript of Commission 860721 Discussion/Possible Vote on Full Power OL for Facility in Washington,Dc.Pp 1-76. Supporting Documentation Encl ML20203D9661986-07-21021 July 1986 Corrected Page 5 to 860721 Transcript Re Facility ML20107A5261985-02-19019 February 1985 Joint Motion for Leave to Withdraw as Party to Proceeding & Dismissal of Admitted Contentions.Draft Order Approving Both Requests,Settlement Agreement & Certificate of Svc Encl ML20114A6911985-01-23023 January 1985 Response Opposing Intervenor,Public Advocate of State of Ny Notice of Deposition & Motion for Protective Order. Certificate of Svc Encl.Related Correspondence ML20113H7211985-01-22022 January 1985 Response Opposing Applicant Motion for Sanctions Re Discovery.Certificate of Svc Encl.Related Correspondence ML20113H7321985-01-21021 January 1985 Second Supplemental Response to Preliminary & First Sets of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20114B7361985-01-21021 January 1985 Applicant Response to Intervenor Third Set of Interrogatories & Request for Production of Documents Re Pipe Cracks.Related Correspondence ML20113H9441985-01-18018 January 1985 Notice of H Sonn 850130 Deposition in Trenton,Nj.Concurrent Depositions of Listed Applicant Employees Requested.Related Correspondence ML20113H9671985-01-18018 January 1985 Fourth Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20113H8091985-01-17017 January 1985 Response to Applicant 850114 Objections to Intervenor 850104 Third Set of Interrogatories & Request for Production of Documents & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112J2841985-01-15015 January 1985 Second Set of Interrogatories Requesting Production of Documents Re Listed Definitions & Instructions to Public Advocate.Certificate of Svc Encl.Related Correspondence ML20112G3921985-01-14014 January 1985 Motion That ASLB Impose Sanction of Dismissal of Contentions Due to Intervenor Failure to Respond to ASLB 841121 Order to Show Cause Why OL Proceeding Should Not Be Dismissed. Related Correspondence ML20112G4171985-01-14014 January 1985 Applicant Objections to Intervenor 850107 Third Set of Interrogatories & Request for Production of Documents to Applicants & Motion for Protective Order.Certificate of Svc Encl.Related Correspondence ML20112D8631985-01-10010 January 1985 Response Opposing Intervenor 850107 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20112C0001985-01-0707 January 1985 Joint Motion for Issuance of Protective Order Re Personnel Info.Draft Protective Order,Unexecuted Affidavit & Certificate of Svc Encl.Related Correspondence ML20112C9651985-01-0707 January 1985 Motion to Compel Responsive Answer to Interrogatory III.7 of Intervenor 841213 Second Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101Q7911985-01-0404 January 1985 Intervenors Supplemental Response to Applicants Preliminary & First Set of Interrogatories & Requests for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20101Q6111985-01-0404 January 1985 Third Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence 1998-09-15
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML20056G4121993-08-31031 August 1993 Comment Supporting Proposed Rule 10CFR2 Re Review of 2.206 Process ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection 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 ML20095B2411992-04-10010 April 1992 Comment on Draft NUREG-1449, Shutdown & Low-Power Operation at Commercial Nuclear Power Plants in Us ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20246H8141989-07-0505 July 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning 1998-09-15
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) ' O PSEG DOCKETED Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 080NNb Nuclear Business Unit g
LR-N980284 'h, ~ 7 .
ADJUQ -
i'F U.S. Nuclear Regulatory Commission <
Secretary l Washington, DC 20555 !
Attn: Rulemakings and Adjudications Staff .D M gN g go
Dear Sir:
bNOI l COMMENTS ON NRC PROPOSED RULE ON lEEE STANDARD 603-1991 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272,50-311 AND 50-354 l
Enclosed are the Public Service Electric & Gas (PSE&G) comments on the proposed rule revising 10CFR50.55a(h) as published in the Federal Register on April 23,1998, 63FR20136 submitting a direct rule to amend the Commissions rules in 10 CFR Part 50.55a(h). The enclosed comments were provided to Mr. S. Aggarwal of the NRC via E-Mail on May 27,1998.
If you have any questions or require additional information, please contact Mr. Vic Fregonese at (609) 339-1607.
Sincerely, h.$,leedf l D. R. Powell l Director -
Licensing / Regulation and Fuels Attachment
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9806190186 980612 PDR PR I 50 63FR20136 PDR l
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Document Control Desk 2 LR-N980284 l
1C Mr. H. J. Miller, Administrator - Region l l l
U. S. Nuclear Regulatory Commission 475'Allendale Road '
King of Prussia, PA 19406
! L Mr. P. Milano, Licensing Project Manager - Salem ,
U. S. Nuclear Regulatory Commission 1 One White Flint North Mail Stop 14E21 11555 Rockville Pike
. Rockville, MD ' 20852 '
l Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission ;
- One White Flint North
- Mail Stop 14E21' 11555 Rockville Pike ~
Rockville, MD 20852 '
Mr. S. Morris .(X24)
USNRC Senior Resident inspector - Salem Mr. S. Pindale ~ (X24) -
USNRC Senior Resident inspector - Hope Creek Mr. K. Tosch, Manager IV, Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625
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- LR-N980284 ATTACHMENT 1 i a
PSE&G COMMENTS ON PROPOSED RULE ON IEEE STANDARD 603-1991
- 1. Endorsement of other referenced IEEE standards Within the proposed rules published in the Federal Register as noted above, the NRC in its response to significant comment #1, PSE&G does not believe the NRC has fully addressed the outright endorsement of other IEEE standards. The statement that IEEE 603 - 1991 does not imply endorsement of later versions of IEEE Standards is not technically substantiated within the proposed rule by the NRC if IEEE 603 - 1991 is to be endorsed by rule and not regulatory guidance. The NRC states that it did not seek for any other standards referenced in IEEE 603 - 1991 to be approved for incorporation by reference, even going so for as to state the referenced standards in IEEE 603 - 1991 are not mandatory requirements, although IEEE 603 - 1991 invokes the referenced standards by the 3 use of "shall". PSE&G believes the NRC position has not been clarified due to "shall"in the !
IEEE 603 -1991 standard; once IEEE 603 -1991 becomes part of 10 CFR 50.55a , then l IEEE 603 -1991 becomes part of the license commitment. I
- 2. Definition of System Level Replacement The term " system level" replacement is not clearly defined and likely cannot specifically be established regarding what constitutes a system-level replacement versus an upgrade or modification to components and subsystems. The proposed NRC interpretation would require compliance with IEEE-603 -1991 for system level replacement / upgrades of protection systems / subsystems that require replacement due to age or obsolescence. Currently, this can be performed under 10CFR50.59 guidance, using design criteria (IEEE standards and
{
Reg Guides) that are part of the plants design and licensing basis. Imposition of IEEE-603 -
1991 in this situation appears to be a backfit. The NRC's perceived impact of incorporating IEEE-603 in this manner is understated.
- 3. IEEE 603 - 1991 Industry Acceptance PSE&G disagrees that IEEE-603 and RG 1.153 represent a general public concensus position. The NRC's statement that they believe the RG was appropriate due to lack of negative comment on the draft RG (proposing to endorse IEEE 603 -1991) should have considered that the majority of operating plants are not required to meet IEEE-603 -1991 or ,
RG 1.153. The lack of adverse comments (to the draft RG) should not have been construed as an endorsement of IEEE 603 -1991.
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