Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements.ML20006A548 |
Person / Time |
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Site: |
Grand Gulf ![Entergy icon.png](/w/images/7/79/Entergy_icon.png) |
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Issue date: |
01/08/1990 |
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From: |
Cottle W SYSTEM ENERGY RESOURCES, INC. |
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To: |
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
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References |
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FRN-54FR46624, RULE-PR-50 54FR46624-00007, 54FR46624-7, AD19-2-07, AD19-2-7, AECM-90-0002, AECM-90-2, NUDOCS 9001290091 |
Download: ML20006A548 (4) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20140J0731997-06-0505 June 1997 Affirmation Authorizing Jj Hagan to Sign & File W/Nrc, Response to GL 92-08 RAI for Facility ML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20098D0271995-10-0202 October 1995 Comment on Draft Reg Guide DG-1038 (Proposed Rev 2 to Reg Guide 1.82), Water Sources for Long-Term Recirculation Cooling Following Loca TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086N6551995-07-14014 July 1995 Comment on Proposed Generic Ltr Re 10CFR50.54 Process for Changes to Security Plans W/O Prior NRC Approval. Agrees W/ Proposed Clarification of Language & W/Provided Screening Criteria in Notice ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072S5431994-08-30030 August 1994 Comment Supporting Petition for Rulemaking 9-2 Re Public Access to Documents Maintained by Licensees But Not Submitted to NRC ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML20043D4781990-05-19019 May 1990 Comments on Notice Re Grand Gulf Document Collection ML20006A5481990-01-0808 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. AECM-89-0045, Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-25025 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants AECM-88-0229, Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program.Attachment to Ltr Provides Answers to Specific Questions Posed by Commission in Proposed Rule1988-11-18018 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program.Attachment to Ltr Provides Answers to Specific Questions Posed by Commission in Proposed Rule ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group 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 AECM-87-0187, Comments on Draft NUREG-1150, Reactor Risk Ref Document. Review of Document Indicates That Ability of Facility to Cope W/Severe Accidents Underestimated Due to Conservative Assumptions1987-10-0202 October 1987 Comments on Draft NUREG-1150, Reactor Risk Ref Document. Review of Document Indicates That Ability of Facility to Cope W/Severe Accidents Underestimated Due to Conservative Assumptions ML20214W8701986-12-0303 December 1986 Comments on Proposed Transfer of OL to Sys Energy Resources, Inc.No Objection Raised to Noted Request Re Transfer of Operating Responsibility.Certificate of Svc Encl ML20093N5291984-07-30030 July 1984 First Set of Interrogatories to Jacksonians United for Livable Energy Policies.Certificate of Svc Encl.Related Correspondence IA-84-665, Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted1984-07-26026 July 1984 Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted ML20134P2781984-07-26026 July 1984 Transcript of Commission 840726 Closed Meeting in Washington,Dc Re Discussion of Investigations & Possible Enforcement Actions.Pp 44-52.Portions Deleted ML20126D2731984-05-24024 May 1984 Transcript of 840524 Public Meeting in Washington,Dc Re Diesel Generator Insp Order.Pp 1-58.Supporting Documentation Encl ML20084S3251984-05-21021 May 1984 Motion for Reconsideration of ASLB 840423 Memorandum & Order Granting Jacksonians United for Livable Energy Policies Intervenor Status & Referral or Certification of Whether ASLB Properly Admitted Moot Contention.W/Certificate of Svc ML20084G1311984-05-0202 May 1984 Request for Extension of Time Until 840517 within Which to Appeal Assertion That Intervention Granted to Jacksonians United for Livable Energy Policies Should Have Been Wholly Denied.Certificate of Svc Encl ML20084E9811984-04-30030 April 1984 Answer Consenting to 840418 Order Restricting Conditions for Operation ML20084E0651984-04-30030 April 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20084B9601984-04-25025 April 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20088A2021984-03-29029 March 1984 Petition to Show Cause on Revocation of Low Power License & Denial of Full Power License Re Transamerica Delaval, Inc Generators.Summary of Generator Operation Experience Encl ML20087G4351984-03-16016 March 1984 Response to First Order Following Prehearing Conference Modifying Briefing Schedule.Aslb Should Deny Admission of Paragraphs 6,7 & 8 as Well as Contentions 1,2 & 3 & Dismiss Proceeding.Certificate of Svc Encl ML20087N6501984-03-0202 March 1984 Response to Licensee Response to First Order Following Prehearing Conference (Modifying Brief Schedule).Contentions 1-6 Should Be Considered in Proceeding.Certificate of Svc Encl ML20087N5651984-02-22022 February 1984 Testimony of Jm Mcconaghy,Lr Barner,Jp Akers,Je Cavender, Lw Rudasill,Jc Shropshire,Rp Ruth & Dh Llewellyn Re in Camera Witness Allegations Concerning Laminations ML20080Q4331984-02-21021 February 1984 Answer Opposing Suppl to Jacksonians United for Livable Energy Policies 831211 Amended Petition for Leave to Intervene.Certificate of Svc Encl ML20080R5951984-02-21021 February 1984 Answer Opposing Jacksonians United for Livable Energy Policies 840213 Supplemental Request for Hearing & Petition for Leave to Intervene.Proposed Contentions Speculative, Vague & Unspecific.Certificate of Svc Encl ML20080J7351984-02-13013 February 1984 Suppl to 731117 Request for Hearing & Petition for Leave to Intervene.Jacksonians United for Livable Energy Policies Contentions 1,2 & 3 Submitted.Certificate of Svc Encl ML20080A5941984-02-0202 February 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20079N1951984-01-24024 January 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20079F2891984-01-12012 January 1984 Response to NRC & Licensee Answers to Jacksonians United for Livable Energy Policies 831117 Petition to Intervene & Request for Hearing & 831211 Amended Petition.Certificate of Svc Encl ML20083D9971983-12-22022 December 1983 Response Opposing Jacksonians United for Livable Energy Policies 831211 Amended Petition to Intervene & Request for Hearing.Petition Fails to Satisfy Commission Requirements. Notice of Appearance & Certificate of Svc Encl ML20083A4981983-12-14014 December 1983 Answer Opposing K Lawrence & Jacksonians United 831117 Petition to Intervene & Request for Hearing on Liveable Energy Policies Re Amend 10 to License NPF-13.Petition Failed Requirements for Standing.W/Notice of Appearance ML20082T7031983-12-11011 December 1983 Amend to Jacksonians United for Livable Energy Policies Request for Adjudicatory Hearing on Amend 10 to License NPF-13 & Petition to Intervene.Procedural & Standing Requirements Met.Certificate of Svc Encl ML20082E4651983-11-17017 November 1983 Petition of Jacksonians United for Livable Energy Policies for Leave to Intervene & Request for Hearing on Licensee Application for Amend 10 to License NPF-13 ML20028A7371982-11-19019 November 1982 Brief Opposing State of La 821104 Appeal of ASLB 821020 Memorandum & Order Denying La 820726 late-filed Petition to Intervene.Aslb Correct in Deciding Petitioner Failed to Satisfy Requirements.Certificate of Svc Encl ML20027D8411982-11-0404 November 1982 Appeal of ASLB 821020 Order Denying State of La 820726 Petition to Participate as Interested State.Burden Re Untimeliness of Filing Met.Certificate of Svc Encl 1997-06-05
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20098D0271995-10-0202 October 1995 Comment on Draft Reg Guide DG-1038 (Proposed Rev 2 to Reg Guide 1.82), Water Sources for Long-Term Recirculation Cooling Following Loca TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086N6551995-07-14014 July 1995 Comment on Proposed Generic Ltr Re 10CFR50.54 Process for Changes to Security Plans W/O Prior NRC Approval. Agrees W/ Proposed Clarification of Language & W/Provided Screening Criteria in Notice ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072S5431994-08-30030 August 1994 Comment Supporting Petition for Rulemaking 9-2 Re Public Access to Documents Maintained by Licensees But Not Submitted to NRC ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML20043D4781990-05-19019 May 1990 Comments on Notice Re Grand Gulf Document Collection ML20006A5481990-01-0808 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. AECM-89-0045, Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants1989-02-25025 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants AECM-88-0229, Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program.Attachment to Ltr Provides Answers to Specific Questions Posed by Commission in Proposed Rule1988-11-18018 November 1988 Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Program.Attachment to Ltr Provides Answers to Specific Questions Posed by Commission in Proposed Rule ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group AECM-87-0187, Comments on Draft NUREG-1150, Reactor Risk Ref Document. Review of Document Indicates That Ability of Facility to Cope W/Severe Accidents Underestimated Due to Conservative Assumptions1987-10-0202 October 1987 Comments on Draft NUREG-1150, Reactor Risk Ref Document. Review of Document Indicates That Ability of Facility to Cope W/Severe Accidents Underestimated Due to Conservative Assumptions 1997-03-07
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JDOCKET NUMBER BD f() IL
?~ ' PROPOSED Rul.E 03
> = cocutico (s yERK9n.--naarm yp hese ooyoien, Jaramry 8,1990 so ami 23 a9:39
.U.S. Nuclear Regulatory Comeission OFilC(r DOCK ilNGOF SECRETARY
& SEHVICI.
- Mail. Station P1-137 BRANCH t Washington, D.C. 20l55 <
Attention: Document Control Desk-
. Gent 1emen:
SUBJECT:
Grand Gulf Nuclear-Station Unit 1: .
Docket No. 50-416 .!
License.No NPF-29 SERI Comments on NRC Proposed Amendmentto10CFRPart50.54(w)-
L AECM-gD/0002 The.following comments are being provided by system Ener
- (SERI) regarding the proposed amendment to 10CPR50.54(w)gy provided by theResources, Inc.
November 6 198g. Federal Register, for Stabilisation and Decontamination '
1
, Priority, trusteeship Provisions, and Amount of Property Insurance Requirements.. These comments.also. include SERI's consideration on the appropriate level of required insurance in view of inflation of
. decontamination and cleanup costs.
CODNINTS REGARDING THE PROPOSED AMEN 0 MENT TO 10CFR50.54(w) -
The four points.of contentien contained in the petitioners' proposal and-
, SERI's comments regarding.tte proposed NRC amendment are as follows:. <
o -- C'arification of the sc;g g_g u igina of the stabilisation nrocess .
- after an accident at a f,,gy,ggc reactor 1 1
-We agree with the petitioners that the stabilization process should ;
be defined and clarified in the rule. It is thought that the '
- existing priority on insurance proceeds, and because proceeds for the. decontamination but not stabilization are to be paid to an independent trustee, would cause confusion and unnecessary delays '
'l regarding stabilization-s when,hould be paid.to Alongwhen, andpetitioners, with the in what amounts we also.proceeds for believe that the stab (11 stion priority should not be invoked.until the estimated cost of stab 111:stion and decontamination exceeds a threshold of $100 million and this priority should only last for 30 days unless extended by the NRC.
9001290091 900100 46624 PDR
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In the proposed rule,-the $100 eillion threshold was accepted;' the proposed 30-day stab 1112ation period priority was extended to a 60-day priority on insurance proceeds; and tie petitioners _' examples- :
of stabilization action were modified somewhat by adding maintenance of sub-crittcality.
The modifications are appropriate and we are in agreement with this proposed amendment, ,
o Clarification of crocedures b.y which the NRC datormines and approves exoenditures of funds nectnLry for decontaminat' on and cleanus '
Consistent with the petitioners' proposal, language was adopted for post-accident cleanup plans, in order that the unplanned insurance proceeds may be used for activities other than those defined as stabilization and decontamination priority activities. Early access to these funds.would help licensees to better cope with any adverse financial affects of the accident and would reduce the itkelihood L that a licensee's financial hardship would have an adverse impact on the protection of the public. ,
zWe are in agreement with this proposed amendment, o A chance in the terminoloc.y of the renuirod innuranco from "crocerty" insurance to "decontim_nat< on tabi' ity" "nsurance In order to insulate the decontamination priority insurance proceeds i
-from indenture provisions and because all nuclear property insurers '
are now willing to offer hybrid policies, the proposal was adopted to require insurance.that clearly states'that any proceeds must'be payable first for stabt11 stion of'the reactor and next for decontamination of the reactor and the reactor station site.
L We are in agreement with'this proposed amendment.
L o Rescissica of the orovision that croceeds of the reoutred insurance l to be oatd to an indenenclent trustgi We agree with the petitioners that the trustee provision is
. unworkable, unnecessary and counterproductive. The requirement of a trustee added further burden to an already complex process.
Although the Commission retained the authority to impose such requirements in individual cases, if warranted, the NRC proposal to eliminate, at least-temporarily, the trustee requirement is appropriate.
AEC90103/$NLICFLR - 2
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E' AECM-90/0002 Page 3 COMENTS REGARDING THE APPROPRIATE LEVEL 0F REQUIRED INSURANCE-In addition to comments regarding the proposed amendment, the NRC also requested comments required amount regarding the appropriate level of indexing of the of insurance.
The NRC indicates that in the 1987 rulemaking, it had no effective means of determining future cost of accident stabilization, decontamination and cleanup other than by periodic updates of the Pacific Northwe,st Laboratory study from which the j current $1.06 billion requirement was derived.
The NRC solicitation for comments continues with suggestions that a mechanism stallar to the one used in itscleanup accident final decommissioning regulations may be appropriate for inflation. A s'gnificant component of the mechanism's formula would be reactor size and tyse. Additionally in its Regulatory Analysis, the NRC states, "Altnough the effect of the, formula, if :
developed and. adopted, would increase the required amount of insurance cost to licensees, there should be little impact on insurance cost to !
licensees because almost all licensees buy tie maximum amount of !
insurance available." We believe that the $1.06 billion presently
! required is as appropriate as any calculation generated by formulas, i including reactor size and type. The adequacy of the 41.06 billion would L have to be studied by running many accident scenarios and consequences of these would have to be developed, cost assigned and mitigation plans '
produced, in addition to methods for inflation indextng. It is quite probable that each reactor would require a different level of insurance, l
based on this assessment. Additionatly, the question of whether the
" indexing method should be similar to the method used in the decommissioning rule (10CFR50.75 decommissioning costs and acciden(c)(2)) appears arbitrary as equivalent. t clearup costs are not strictly p- The financial-impact statement made in the Regulatory Analysis may presently be true, as most licensees do purchase all available capacity, f However, for various reasons companies may not carry all that is ty available 1n the future. This commert suggests that utilities will.
y always' purchase all capacity cffered by tlie insurers, which indicated the n
insurers would determine how much capacity is adequate. This woulo force b utilities into taking the maximum coverage offered and would no longer u
allow them to economical, make tie etc.
reasonable, decision as te whether increases in limits were Jnsummary,ourcommentsarethatwe-areinagreementwiththeproposed amendments as written, and believe that the present requirement of $1.06-billion is appropriate and there is no need to create a mechanism for establishing base requirement amounts or escalation factors.
SERI appreciates the opsortunity to comment on the proposed 10CFR50.54Cw amendment and requests NRC consideration of these comments in the final )
rulemaking.
Yours truly, JGC:amm % *-
cet (See Next Page) b
")WTCOTT%8n AEC90103/5NLICFLR - 3
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- u:n P. 5/ 5 ABCM-90/0008 Page 4 cc: Mr. D. C. Hints Mr. T. H.'Cloninger
.Mr. R. 8. McGehoe Mr. N. 8.'Reynolds Mr. H. L. Thomas Mr. H. O. Christensen Mr. Stewart D. Ebneter Re U.gional Administrator S. Nuclear Regulatory Commission Region !!
101 Marietta St., W.W.
Atlante, Georgia 3032) Suite 2900 Project Manager Mr.
OfficeL.ofL. Kintner, Reactor Regulation Nuclear U.S. Neelear Regulatory Commission Mail 5 top 14820 Washington,D.C. 20555 AEC90103/SNLICFLR - 4
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