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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212L0841999-10-0101 October 1999 Exemption from 10CFR50,App R,Section III.G.2 to Ensure That Adequate Fire Protection Features Provided for Redundant Cables or Equipment Located in Same Fire Area Outside of Primary Containment ML20141D7351997-06-19019 June 1997 Comment Supporting Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Reactor Operating W/Framatome Cogema Fuels Mark-B Fuel Requested to Be Excluded from Final Bulletin Suppl DD-97-15, Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request1997-06-18018 June 1997 Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request 0CAN049709, Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants1997-04-21021 April 1997 Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants ML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20128M3411996-09-30030 September 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20099M4921995-12-18018 December 1995 Comment on Draft Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses 0CAN119504, Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI1995-11-13013 November 1995 Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI 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 ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule 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 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 ML20058D8581993-11-26026 November 1993 Comment on Proposed Rule 10CFR72 Re Notification of Events at Isfsi.Believes General Licenses Should Not Be Required to Use New 10CFR72.75 ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 0CAN059206, Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety1992-05-28028 May 1992 Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety 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 ML20006C5721990-01-15015 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. ML19353B2001989-12-0404 December 1989 Comment Supporting Opinions Expressed by NUMARC on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Supports Philosophy of Proper Maint as Important Part of Safe & Reliable Nuclear Power Plant Operation ML20247N1311989-07-0707 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Existing Regulations,Codes & Stds Including Industry Procurement Improvement Activities Are Adequate ML20235T4141989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20206M6171988-11-17017 November 1988 Comment Supporting Proposed Rule 10CFR26 Re NRC Rulemaking on Fitness for Duty Programs.Endorses NUMARC 881118 Comments on Subj Proposed Rule & Suggests Incorporation of NUMARC Suggested Changes 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 0CAN088804, Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress1988-08-0404 August 1988 Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress ML20149E8581988-02-0404 February 1988 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Licensee Response to Notice of Violation & Proposed Imposition of Civil Penalty by ML20236A0441987-10-13013 October 1987 Comment Opposing Proposed Rule 10CFR50 Re Rev to Backfitting Process for Power Reactors.Proposed Rule Devoid of Objective Guidance or Criteria for Distinguishing Between Cases Where cost-benefit Analysis Permissible & Where Not ML20215D6741987-06-12012 June 1987 Suppl 4 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.Ucs Reply to Responses from NRC & B&W Owners Group.* Certificate of Svc Encl ML20214Q6151987-06-0101 June 1987 Order Imposing Civil Monetary Penalty in Amount of $50,000 for Violation Noted in Insp on 860106-31.Evaluations & Conclusions Encl ML20210C4191987-04-0606 April 1987 Principal Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Petition Should Be Denied ML20205F2911987-03-23023 March 1987 Suppl 3 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Requests That Listed Names Be Added to List in Paragraph 1 of 870210 Petition ML20210C2691987-03-0606 March 1987 Initial Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Request for Immediate Suspension Should Be Summarily Denied.W/Certificate of Svc ML20211F5091987-02-20020 February 1987 Suppl 2 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Lists Names to Be Added to 870210 Petition & Corrects Address for Save Our State from Radwaste ML20210N4861987-02-10010 February 1987 Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W Co.* OLs & CPs for Facilities Should Be Suspended Until Listed NRC Actions Taken ML20203A1491986-03-10010 March 1986 Affidavit of Jh Taylor Demonstrating That Encls May Be Withheld Per 10CFR2.790 & Listing B&W Procedures for Withholding ML20137L5911985-09-10010 September 1985 Response Opposing Jf Doherty 850611 Petition for Show Cause Order Requesting NRC to Institute Consolidated Proceeding Per 10CFR2.202.Certificate of Svc Encl ML20126A3531985-06-11011 June 1985 Petition/Request for Order to Show Cause Why Plants Should Not Be Shut Down Until CRD Mechanisms Inspected ML19343B1761980-11-13013 November 1980 Affidavit Supporting Proprietary Treatment for CEN-139(A)-P, Statistical Combination of Uncertainties.. ML20126M2581980-03-14014 March 1980 Affidavit for Withholding Proprietary Info Re Low Pressure Turbine Rotor (Ref 10CFR2.790).Nonproprietary Version Attached ML19326C6621978-09-28028 September 1978 Forwards Executed Amend 7 to Idemnity Agreement B-65, Including New Article Viii ML19326C6511978-08-0707 August 1978 Executed Amend 6 to Indemnity Agreement B-65,changing License Numbers ML19326C6531975-03-27027 March 1975 Executed Amend 3 to Indemnity Agreement B-65,increasing Liability Premiums ML19317H1351974-05-0303 May 1974 Acknowledgement of Svc of Amend 45 to Application for OL ML19326B8481973-08-10010 August 1973 Acknowledges Svc of Amend 40 to OL Application on 730810 1999-10-01
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20141D7351997-06-19019 June 1997 Comment Supporting Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Reactor Operating W/Framatome Cogema Fuels Mark-B Fuel Requested to Be Excluded from Final Bulletin Suppl 0CAN049709, Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants1997-04-21021 April 1997 Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants ML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20128M3411996-09-30030 September 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20099M4921995-12-18018 December 1995 Comment on Draft Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses 0CAN119504, Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI1995-11-13013 November 1995 Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI 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 ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule 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 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 ML20058D8581993-11-26026 November 1993 Comment on Proposed Rule 10CFR72 Re Notification of Events at Isfsi.Believes General Licenses Should Not Be Required to Use New 10CFR72.75 ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 0CAN059206, Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety1992-05-28028 May 1992 Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety 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 ML20006C5721990-01-15015 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. ML19353B2001989-12-0404 December 1989 Comment Supporting Opinions Expressed by NUMARC on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Supports Philosophy of Proper Maint as Important Part of Safe & Reliable Nuclear Power Plant Operation ML20247N1311989-07-0707 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Existing Regulations,Codes & Stds Including Industry Procurement Improvement Activities Are Adequate ML20235T4141989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20206M6171988-11-17017 November 1988 Comment Supporting Proposed Rule 10CFR26 Re NRC Rulemaking on Fitness for Duty Programs.Endorses NUMARC 881118 Comments on Subj Proposed Rule & Suggests Incorporation of NUMARC Suggested Changes 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 0CAN088804, Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress1988-08-0404 August 1988 Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress ML20236A0441987-10-13013 October 1987 Comment Opposing Proposed Rule 10CFR50 Re Rev to Backfitting Process for Power Reactors.Proposed Rule Devoid of Objective Guidance or Criteria for Distinguishing Between Cases Where cost-benefit Analysis Permissible & Where Not 1997-06-19
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cc-ENTERGY masn 232 Au::scue. AR /2801 Tcl 501853-5000 December 18,1995 _.
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Chief, Rules Review and Directives Branch $ s U. S. Nuclear Regulatory Commission U'.
" j Mail Stop T-6D-69 O Washington, DC 20555-000'. !
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Subject:
Arkansas Nucl:ar One - Units 1 and 2 I_
Docket Nos. 50-313 and 50-368 License Nos. LPR-51 and NPF-6 Comments on Draft Supplement I to Generic Letter 83-11,
" Licensee Qualification for Performing Safety Analyses" Gentlemen:
The purpose of this letter ir, to provide Entergy Operations' comments for Arkansas Nuclear One to the draft Supplement I to Generic Lette. 83-11. In addition to comments on the proposed supplement, the Staff requested comments on three questions. The following are comments on the requested questions.
(1) To what extent can an organization other than the NRC (a third party) review a new methodology or a significant change to an existing methodology?
Since many of the NRC reviews of methodologies are currently assigned to subcontractors, it would seem that third party reviews would not be significantly different.
There would be concerns with the " independence" of the review but such reviews / audits are currently practiced in other industries, such as the financial sector; therefore, it would appear to be a reasonable approach. An alternative might be the development of a set of NRC-approved standards and criteria that the third party reviewer would be required to maintain in which licensees could hold the third party reviewer accountable.
(a) What capabilities should be required of a third-party reviewer?
These third party reviewers would obviously have to possess the appropriate technical and licensing capabilities to provide a defensible review. The NRC should establish a certification process for third party reviewers. This would ensure an adequate supply of j qualified reviewers. This could include current /former NRC contractors in the area of interest, documented expertise in the required field, and documented experience in 9601040027 951218 PDR ADOCK 05000313 l H PDR O 040003
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U.S.NRC Dec:mber 18,1995 0CAN129502 Page 2 performing analyses of the type being reviewed, etc. It would seem that such capabilities / requirements would already be compiled for current NRC contractors.
(b) What is the safety significance of not having the NRC perform the review?
With appropriate controls placed upon the quality of reviews, comparison to other vendor methodologies and the exercising of sound engineering judgment, the safety significance would be minimal.
(c) What documentation should be submitted to the NRC by the third-party reviewer and/or by the licensee?
A report summarizing the methodology and applications that were reviewed, a synopsis of ,
the review process and depth, and comparisons to standardized problems or other industry I results that would support reviewers' judgments regarding the subject. Additionally, the i reviewer would prepare a licensing assessment including comparisons to existing l regulatory requirements and issue a safety evaluation report. In short, the report should l include the information necessary for the NRC to audit the controls over the application of j the methodology. This report should include a clear delineation of the applicability of the i methodology and could possibly be required to have a pre-defined format and content.
(d) What type of acceptance (e.g., a safety evaluation report) should be issued?
A cover letter reflecting receipt of the licensee / contractor review report and the applicability / limitations of the methodology should be issued. The letter could state that ,
application of the methodology is permissible within the constraints outlined in the l submitted report and that future NRC audits / inspections would verify compliance with the report.
(e) How would approved references (e.g., Core Operating Limits Report (COLR) parameters in technical specification reporting requirements) be handled?
Referencing the submittal reports and NRC approval letters that described the methodology and application would be a method of handling approved references.
(f) What information, if any, should be available for NRC audit?
The same information that would currently be available for topical report reviews -- all of it.
(2) What other viable approaches can be used for accepting new or revised methods?
Standard benchmark cases might provide a means of determining the validity of methods.
With the extensive benchmark data from the NRC's own development of RELAPS and other methods, such benchmark cases could be readily compiled.
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U. S. NRC December 18,1995 0CAN129502 Page 3 (a) Should a regulatory guide be developed?
A regulatory guide would be valuable in order to ensure consistency in documentation content and format and for ease in NRC audit / inspection.
(b) Can a set of criteria, as proposed in the generic letter supplement for previously approved generic methods, also be developed for new methods?
This could be done on a case by case basis.
(3) To what technical disciplines should this process apply? Commentors should clearly differentiate any comments submitted in response to these questions from comments on the generic letter supplement.
The above responses are from the perspective of reactor physics, accident, and transier.t analysis.
The following are general comments on the proposed Attachment 1 of the draft Supplement I to Generic Letter 83-11. With the increasing frequency with which utilities switch fuel vendors, the applicability of a particular method to either a specific fuel design or to a core which contains a mixture of fuel types will be important. Use of a vendor's hot channel analysis code with an EPRI or different vendor's transient codes may not necessarily yield conservative results and, in fact, may not be consistent with the " reload analysis package" that has been approved by the NRC. In-house application procedures should have the proper controls to preclude such a misapplication but should also be permitted to include the flexibility to perform comparison tests between the different methodologies, possibly with vendor assistance, to show that a conservative assessment can be made. This, in effect, would be a deviation from " approved" methodologies but one that is supported by analysis and acceptable under 10CFR50.59.
Compliance with the generic letter would be easier if an NRC inspection procedure was developed concurrently so licensees would know the requirements, and specifically, what questions and documentation requests might be needed to support audits. The effort to provide both the generic letter and the inspection procedure at the same time would probably make the documents more consistent. Also, the NRC should consider providing licensees the flexibility to conduct its own asse:sment of a third party reviewer similar to what is currently allowed in NRC Inspection Module 40501, " Licensee Self-Assessments Related to Team Inspections".
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U. S. NRC Decemb r 18,1995 0CAN129502 Page 4 1
1 Should you have any questions, please contact me. I Very truly yours,
. Dwight C. ims l Director, Nuclear Safety DCM/nbm cc: Mr. Leonard J. Callan Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 Mr. George Kalman NRR Project Manager Region IV/ANO-1 & 2 U. S. Nuclear Regulatory Commission l NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission l Document Control Desk l Mail Station Pl-137 I Washington, DC 20555 Mr. Jim Eaton Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, DC 20006-3708 l