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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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DOCKETED UFWC December 14, 1998
% der j7 All :34 i
LR-N980588 ADL g Mr. John C. Hoyle i Secretary of the Commission agg g gggggg U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 oROPOSED RULE N 50 pg Attn: Rulemakings and Adjudication Staff I
Comments on Proposed Amendment to the Maintenance Rule 63 Fed. Reg. 52201 (September 30,1998)
SALEM AND HOPE CREEK GENERATING STATIONS DOCKliT NOS. 50-272,50-311 AND 50-354
Dear Mr. Hoyle:
On September 30,1998, the Nuclear Regulatory Commission (NRC) issued a proposed amendment to the Maintenance Rule,10CFR50.65, for public comment. This letter submits PSE&G's comments regarding the proposed amendment. In addition to these specific comments, PSE&G supports the comments submitted by the Nuclear Energy Institute (NEI) and the Maintenance Rule Implementation Clearinghouse (MRIC).
1 PSE&G agrees that adequate safety assessments should continue to be performed prior to removing equipment from service for maintenance. While we agree with the general principle behind this proposed rulemaking we are concerned that the proposed rule contains certain language that is open to interpretation. If broadly construed, the proposed rule could present a significant implementation burden without a commensurate increase in safety.
PSE&G's specific comments are as follows:
- 1. The proposed revision represents an expansion in scope of the risk 0 assessment requirements. Fully integrating all Technical Specification
! surveillance tests into the formal risk assessment process requires a significant level of effort without a commensurate increase in safety. This proposal may be viewed as resulting in a requirement to conduct continuous risk assessments.
9812210322 981214 PDR PR 50 63FR52201 PDR g 5 /O 1
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Mr. John C. Hoyle 2 LR-N980588 l i
I
- 2. The proposed paragraph (a)(4) could be interpreted to require detailed risk assessments prior to any maintenance on all Maintenance Rule systems, structures, and components (SSCs). This would create a substantial additional burden, which rather than adding the benefit of increased safety, l may actually serve to remove the focus from the risk significant equipment. A l more appropriate approach may be to limit the requirement to perform risk )
assessments prior to maintenance to the high risk significant SSCs. ;
- 3. The proposed wording of the revision would require that a safety assessment "shall be used to ensure that the plant is not placed in risk-significant configurations or that would degrade the performance of safety functions to an unacceptable level". This wording appears vague and open to interpretation. Our concern is that this increases the likelihood of inconsistent applications and regulation via the inspection process.
- Risk significant configuration - This terminology is not defined in the actual rule language, nor is there a common understanding of this language between the industry and NRC. This term appears to increase the focus on the PSA such that an over reliance on the PSA is encouraged. PSA should be a tool to complement the Technical Specifications and address the limitations of the Technical Specifications for dealing with conditions where multiple equipment is out of service.
- Degrade the performance of safety functions to an unacceptable level-
" Unacceptable level" is open to interpretation.
. In addition, the definition of maintenance activities is open-ended and subject to varying interpretations.
In conclusion, we support the NRC in the endeavor to ensure that adequate safety assessments are conducted prior to removing equipment from service for maintenance. However, we are of the opinion that the proposed rule, as written, would not achieve the anticipated goals. We suggest that the proposed rule be withdrawn. We also suggest that the NRC continue to work with NEl to adopt a risk-informed Maintenance Rule, which includes wording that is clearly defined and mutually understood. The required detail and rigor of the safety i
assessments within a risk-informed Maintenance Rule should be proportional to
- Mr. John C. Hoyle 3 LR-N980588 the risk-significance of the SSC. These requirements should also be clearly defined and mutually understood prior to implementation of the rule.
We appreciate the opportunity to comment on the proposed revision and request your careful consideration of the issues.
Sincerely, Original signed by Harry Keiser Public Service Electric and Gas P.O. Box 236 Hancocks Bridge, NJ 08038 I
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