ML030650102

E-Mail from Joe Waters on Questions Regarding NRC Order EA-03-009

ML030650102
Person / Time
Site:	Cook
Issue date:	02/20/2003
From:	Waters J American Electric Power Co
To:	Marshall M Office of Nuclear Reactor Regulation
References
EA-03-009
Download: ML030650102 (2)

Text

[.Steven Bloom - Questions Regqardingl NRC Order EA-3-009°§ Dn, J

From: <jrwaters@aep.com>

To: <mxm2@nrc.gov>

Date: 2/20/03 5:15PM

Subject:

Questions Regarding NRC Order EA-03-009 Mr. Marshall.

Please address the following questions regarding NRC Order EA-03-009 in the February 24, 2003 public meeting. Please document the responses to these questions in the meeting summary.

Thank you, Joe Waters, Licensing Engineer, D. C. Cook Nuclear Plant 269-697-5044

1)Section IV.F of the order states that, in the 20 day response required by Section V, licensees shall notify the Commission if: (1) they are unable to comply with any of the requirements of Section IV,or (2) compliance with any of the requirements of Section IV is unnecessary.Section IV.F also states that licensees proposing to deviate from any of the requirements of the order shall seek relaxation of the order by requesting that the Director, Office of Nuclear Reactor Regulation, relax or rescind the requirement in accordance with the process specified in Section IV.F.

It appears that these provisions require that the 20 day response identify those order requirements from which the licensee intends to subsequently request deviation. It appears that the 20 day response need only identify the requirement that can't be met or that is unnecessary, and need not provide an explanation or justification. The explanation or justification would be contained in the request for relaxation subsequently submitted to the Director, Office of Nuclear Reactor Regulation. Is this understanding correct?

2) If a licensee discovers, subsequent to submitting the 20 day response required by Section V, that a requirement in the order can't be met or is unnecessary, may the licensee still request relaxation from the Director, Office of Nuclear Reactor Regulation?

3) Since the order is a modification of the facility license, would a request for relaxation, as described in Section IV of the order, have to be submitted under 10 CFR 50.90 as a license amendment request?

4)Section IV of the order describes additional requirements (similar to those applied to 10 CFR 50.55a(a)(3) requests) that would be invoked for a relaxation regarding inspection of "specific nozzles." However, the additional requirements would also seem to be relevant to a relaxation request that affects inspection requirements for all nozzles on a reactor vessel head. Please explain the distinction intended by use of the term "specific nozzles."

Stve l-,, -,Questins Regr*. inq*RftC Order EA-03-009 Pa, This e-mail message and all attachments transmitted with it from the Nuclear Generation Group of American Electric Power are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.