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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARNG-99-1232, Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 7901011999-09-24024 September 1999 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101 NG-99-1296, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration NG-99-1263, Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide NG-99-0616, Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures1999-04-30030 April 1999 Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures NG-98-2045, Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments1998-12-18018 December 1998 Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments NG-98-2056, Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself1998-12-14014 December 1998 Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself NG-98-0926, Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement1998-05-22022 May 1998 Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement NG-98-0329, Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment1998-02-20020 February 1998 Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment NG-98-0065, Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping1998-01-0909 January 1998 Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping NG-97-2036, Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 19711997-11-25025 November 1997 Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 1971 NG-97-1213, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments)1997-07-0303 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments) NG-95-2723, Comment Supporting Revised NRC SALP Program1995-09-0505 September 1995 Comment Supporting Revised NRC SALP Program NG-95-1404, Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation1995-04-11011 April 1995 Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation NG-95-0464, Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors1995-02-0303 February 1995 Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors NG-94-4468, Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures1994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process NG-93-3257, Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses1993-08-12012 August 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses ML20045F8561993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Endorses NUMARC Comments ML20086K0431991-12-0202 December 1991 Comment on Draft Reg Guide DG-8003 & NUREG-1400, Air Sampling in Workplace. Licensee Feels That Concept Could Be Useful Tool in Determining When Air Sampling Is Warranted But Feels Hazard Index Level Needs Clarification NG-91-1144, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 19911991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 1991 NG-91-0222, Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept1991-01-28028 January 1991 Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept NG-90-2541, Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program1990-10-30030 October 1990 Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program NG-90-1446, Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements1990-07-0202 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements ML20195J9001988-11-29029 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Detailed Comments on Rule Encl 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 1999-09-24
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARNG-99-1232, Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 7901011999-09-24024 September 1999 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101 NG-99-1296, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration NG-99-1263, Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide NG-99-0616, Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures1999-04-30030 April 1999 Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures NG-98-2045, Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments1998-12-18018 December 1998 Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments NG-98-2056, Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself1998-12-14014 December 1998 Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself NG-98-0926, Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement1998-05-22022 May 1998 Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement NG-98-0329, Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment1998-02-20020 February 1998 Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment NG-98-0065, Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping1998-01-0909 January 1998 Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping NG-97-2036, Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 19711997-11-25025 November 1997 Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 1971 NG-97-1213, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments)1997-07-0303 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments) NG-95-2723, Comment Supporting Revised NRC SALP Program1995-09-0505 September 1995 Comment Supporting Revised NRC SALP Program NG-95-1404, Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation1995-04-11011 April 1995 Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation NG-95-0464, Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors1995-02-0303 February 1995 Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors NG-94-4468, Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures1994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process NG-93-3257, Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses1993-08-12012 August 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses ML20045F8561993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Endorses NUMARC Comments ML20086K0431991-12-0202 December 1991 Comment on Draft Reg Guide DG-8003 & NUREG-1400, Air Sampling in Workplace. Licensee Feels That Concept Could Be Useful Tool in Determining When Air Sampling Is Warranted But Feels Hazard Index Level Needs Clarification NG-91-1144, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 19911991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 1991 NG-91-0222, Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept1991-01-28028 January 1991 Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept NG-90-2541, Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program1990-10-30030 October 1990 Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program NG-90-1446, Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements1990-07-0202 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements ML20195J9001988-11-29029 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Detailed Comments on Rule Encl 1999-09-24
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, IES UTILITIES INC. DOCKETED USHRC February 3,1995 i NG-95-0464 '95 FEB 13 P4 :11 l Mr. John C. Iloyle, Acting Secretary -
U. S. Nuclear Regulatory Commission Attn: Docketing and Sersices Branch h-k_[ ,
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Washington, DC 20555-0001 DOCKET NUMBER PROPOSED RULE N Kb -
Subject:
Duane Arnold Energy Center (DAEC) (5CW9-S=YLO$
Docket No: 50-331 Op. License No: DPR-49 Y IES Utilities' Comments on the Proposed Rule for Shutdown and Low-Power Operations for Nuclear Power Reactors
References:
- 1) Federal Register Notice 59 FR 52707
- 2) W. Rasin (NEI) to J. Iloyle (NRC), Comments Regarding Proposed Rulemaking on Shutdown and Low Power Operations for Nuclear Power Reactors, January 24,1995,
- 3) R. Pinelli(BWROG) to USNRC, "BWR Owners' Group Comments Regarding Proposed Rulemaking to Address Shutdown Safety Issues," BWROG-94166, r December 23,1994. ;
File: A-106
Dear Mr. Secretary:
In response to the Reference 1 request for comments, IES Utilities would like to offer the following comments on the proposed nile, in addition to endorsing those comments filed by the Nuclear Energy Institute (NEI) in Reference 2 and the BWR Owners' Group (BWROG) in Reference 3.
Specifically, our concerns mirror those of NEl and the BWROG that in many instances the specific wording of the proposed rule is too vague, which will lead to inconsistent inspections and enforcement actions. For example, phrases such as, " provide reasonable assurance... " "as ,
necessary to accomodate unforeseen contingencies...," "any departure from the outage plan . I shall be evaluated k the manner also described above and appropriate measures implemented
[ emphasis added} 11 is this a example that is perhaps the most troubling. Most outage plans have literally tens of thousands of work activities in them. The proposed wording implies that any ,
change in any one of those activities would require a formal, documented evaluation for its impact on the fire risk during shutdown. The rule does not appear to allow for any type of screening for risk significance in complying with this requirement. Not only will this greatly increase the manpower, with expertise in fire analysis and mitigation, needed during outages to perform the hundreds of such evaluations that would be needed, we do not see any commensurate increase in ;
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NG-95-0464 February 3,1995 Page 2 plant safety from such a requirement. We recommend that a threshold for risk be established such that activities below this threshold would not require any formal evaluation when changed during the course of the outage.
We were active industry participants in the development of NUMARC 91-06 (Guidelines for Industry Actions to Assess Shutdown Management) and have used the guidance for outage planning for each of our three refueling outages since the draft guidelines were published in early 1991. We believe that to codify that guidance would reduce the flexibility that we currently have to properly plan our outages in the most safe and eGicient manner possible. Given the fact that almost no two refuel outages have the exact same scope of work, to be held to rigid requirements for system availability compromises the ability to tailor the outages to the work that needs to be performed while ensuring the availability of the proper safety systems in support of that specific workscope. The amount of redundancy of safety systems required by the rule ollen goes well beyond what is actually needed to ensure plant safety. The rule does not acknowledge or give proper credit for the lower decay heat loads present later in the outage. Consequently, preventative maintenance essential to maintaining the reliability of these safety systems must be scheduled during very specific " windows" during the outage when they would not be required to be available under the rule. These windows are most ollen critical-path times. The result is a ,
needless extension of outages due to having to extend these windows sufliciently to do the preventative maintenance. This overly conservative approach has a significant economic impact, without a commensurate increase in plant safety. The rule, if finalized, should allow the same flexibility as the current NUMARC guidelines, which the StafThas acknowledged has led to improvements in the industry in managing risk during plant shutdown.
A point was made in passing in the BWROG comments that we would like to amplify. The reference plant for the cost-benefit analysis for BWRs was Grand Gulf, a BWR of a much newer design than the Duane Arnold Energy Center (DAEC). Specifically, Grand Gulf has a much larger containment building (i.&, Mark Ill) and has more redundancy in its design (eg, four divisions vs. two divisions of electrical power). These difTerences allow n aintenance activities to be performed under the rule at Grand Gulf with mu6 tess impact than at o! der plants, like the DAEC. In particular, the required plant safety systems are spatially compartnentalized in the Mark III, which means that the impact of the fire prmection requirements unoer the rule are easier to implement. While these design differences do not nave an appreciable diflbrence in the safety benefit to be gained from the rule', they do have a significant difference in the cost of implementing the rule for older plants such as ours that does not have the same flexibility in numbers of systems / divisions that can be used fot " backups" in complying with the requirements !
of the proposed rule. Thus, the cost to us to impl(ment this rule would be substantially higher than that estimated for Grand Gulf. !
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' Comparison of outage risk, as measured by the risk of reactor coolant boiling. using the NSAC-175L study (Safety Assessment of BWR Risk During Shutdown Operations. August 1992) as a reference, indicates that the shutdow n risk at the DAEC is compara' ole to other BWRs, and in fact, is lower than the risk at Grand Gulf. The calculated average risk of boiling for the upcoming refuel outage at the DAEC is ~ 1.9E-06/ hour. with a peak risk ,
of ~ 7.6E-05/ hour, as compared to the NSAC-175 results for Grand Gulf of 1.7E-05/ hour (ave.) and 1.0E-01/ hour l (pcak). ]
)
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, NG-95-0464 February 3,1995 Page 3 Finally, we strongly disagree with the stated reason for this rule, which is to impose a " regulatory footprint on outage safety and codify improvements made by the industry." We view this approach as being very detrimental to the positive working relationship that the industry has had with the Staffin dealing with this complex subject. It would set a precedent that would stifle future voluntary efforts on the part of the industry to work with the Staff to improve safety out of fear ofincreased regulatory burden wxi enforcement exposure by retroStting such a " footprint" to those voluntary efforts. We urgently request the Commission to reconsider the need for this rulemaking.
Sincerely, CW Kekth Young' Manager, Nuclear Licensing KDY/RAB/pjv~
cc: R. Browning J. Franz L.Liu L. Root DOCU