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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 ML20140J0731997-06-0505 June 1997 Affirmation Authorizing Jj Hagan to Sign & File W/Nrc, Response to GL 92-08 RAI for Facility 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 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 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 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 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 ML20043D4781990-05-19019 May 1990 Comments on Notice Re Grand Gulf Document Collection ML20006C5721990-01-15015 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. ML20006A5481990-01-0808 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 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 ML20235T4141989-02-24024 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 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 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 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 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 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 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 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 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 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 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 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 ML20043D4781990-05-19019 May 1990 Comments on Notice Re Grand Gulf Document Collection ML20006C5721990-01-15015 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. ML20006A5481990-01-0808 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 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 ML20235T4141989-02-24024 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 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 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 1997-06-19
[Table view] |
Text
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PO. Box 756 gr/j ft * *** j (f ,, n U Port Gbson, MS 39150
.. Tel 601437-6470 lN.O ? 'l l (j % l 2[j W.K.Hughey l Nocear Safety & RwNat7f
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March 7,1997 UStiRC 1
I l
U.S. Nuclear Regulatory Commission I Mail 5, top P1-137 l Washington, D.C. 20555-0001 Attention: Document Control Desk i
1
Subject:
Proposed Generic Communication; Generic Letter 96-XX, Effectiveness
! of Ultrasonic Testing Systems in Inservice Inspection Programs Arkansas Nuclear One - Units 1 and 2 River Bend Station Docket Nos. 50-313 and 50-368 Docket No. 50-458 I License Nos. DPR-51 and NPF-6 License No. NPF-47 Grand Gulf Nuclear Station Waterford 3 Steam Electric Station Docket No. 50-416 Docket No. 50 382 i j License No. NPF-29 License No. NPF-38 l GNRO: 97/00018 I
j Gentlemen:
l l The NRC issued the subject draft generic letter (DGL) for comment on 12/31/96.
We are disturbed by the inherent implications of this DGL and the justification l
given for the issuance of it. This letter provides Entergy Operations' comments on this preposed communication, in general, we believe that the DGL has not adequately justified the request for licensee actions cited in the DGL. In addition to Entergy Operations' comments, the Nuclear Energy Institute (NEI) provided comments on the DGL to you in a letter dated 2/21/97. We participated on the task force that developed those comments and fully endorse the NEl comments.
NEl commented on a variety of issues regarding the proposed issuance of the DGL. Entergy Operations wishes to elaborate on a couple of the points we find to l
be especially important. These include the current levels of safety, evaluation of current inservice Inspection (ISI) programs, implementation of Appendix Vill,
'O Performance Demonstration Initiative versus Appendix Vill and the upcoming 10-year updates at the Entergy Operations' sites. Each is discussed in more detail below.
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9703130319 970307 OI PDR ADOCK 05000313 P"
eaaap!usmpt!i l
4-l '.
GNRO-97/00018
[ Page 2 of 6 I l
Current Levels of Safety
! The NRC recognizes that no safety concern exists that would warrant immediate l backfitting of Appendix Vill. This is based on defense-in-depth measures, Code margins in component design and leakage monitoring systems. Further; industry l experience indicates that these defense-in-depth measures provide an acceptable margin of safety to prevent catastrophic failure, it is evident that our current ISI programs provide an acceptable level of safety since no safety concern exists in the past, viable arguments have been made with statistical proof the the new j techniques allow for the better detection of flaws and more accurate sizing of those l flaws once detected; however, these improved techniques only provide added assurance of safety to an already safe situation.
Given this information, the requested action to evaluate our current ISl programs and the implied requirement to implement performance-based ultrasonic (UT) examination methods are inappropriate without furtherjustification. A backfit evaluation is the appropriate mechanism to impose new requirements although it seems unlikely that such an evaluation would be successful since no safety l concem exists and associated costs are high.
l i
l The evaluation of current ISI programs and the implementation of Appendix Vlli l are discussed in more detail below in the next two sections.
l Evaluation of Current inservice inspection (ISI) Programs l The DGL would request each addressee to perform an evaluation to determine whether its current ISI program ensures that flaws in the reactor vessel and safety-related piping are reliably detected and sized.
By this request, the NRC is essentially requesting licensees to justify the current requirements of 10CFR50.55a which endorse the Section XI ASME Code. These requirements have been mandated by the NRC; the licensee should not be required to perform an evaluation to justify their implementation. This is the NRC's l
responsibility under the rulemaking and backfit processes. The use of various codes and standards has long been accepted by the nuclear industry and the NRC as an efficient and effective way to preserve resources while maintaining an acceptable level of tafety' and the DGL presents no evidence that questions the effectiveness of the ASME Code to maintain safety.
4 The request for information is inappropriate given the justification presented in the DGL. An evaluation of the effectiveness of the ASME Code would likely result in 4
1 s ' Entergy Operations challenged this position as it related to the mandatory 10-year update
! provision by proposing a Cost Beneficial Licensing Action that would have eliminated the i
10-year update except for changes that provided a substantial safety benefit. Recently, the NRC denied the request but we are aware that the NRC is considering the use of the backfit rule in adopting later editions of the ASME Code.
. _ _ _ _ _ _ . _._ _ _ _. _ _ ._ _ _ _ _ __ _ __._ _ _ _ __ _~ _ _ _ _ _ _
GNRO-97/00018 Page 3 of 8 many manhours to prepare the response with no increased safety benefit. This request should be limited to fact-finding and not det?rmination of compliance.
l Additionally, this request appears to merely be an introduction for the main issue -
to gain a commitment from a licensee to implement performance-based methods for UT examination.
, implementation of Appendix Vill l We are aware that the NRC has been working for some time on a revision to l 10CFR50.55a which would require the implementation of performance-based l methods for UT examination. We understand that these requirements are being l evaluated under the provisions of 10CFR50.109. This is the appropriate path for implementing new requirements to ensure that the safety benefit is commensurate l with the cost to implement the new requirements.
However, the DGL implies that these requirements should be implemented in i advance of rulemaking to improve the methods in performing UT examinations.
l There is no evidence that implementation of Appendix Vill-type examinations are l necessary from a safety perspective. Since the DGL shows neither safety benefit j nor reasonable cost considerations to implement these requirements, this implication is inappropriate. Any suggestion that a licensee should implement or j justify not implementing performance-based UT methods to comply with 10CFR50.55a should be removed from the DGL. The NRC's desire to mandate performance-based UT examination methods should be evaluated against the criteria of the backfit rule.
l
! Performance Demonstration Initiative vs. Appendix Vill in the DGL, the NRC staff found that Performance Demonstration initiative (PDI) has established and is in the process of executing a well-planned and effective program to test UT technicians on selected portions of Appendix Vill. Accordingly, the NRC staff found that UT procedures qualified under the PDI program using performance demonstration methods provided an acceptable level of quality and safety.
However, PDI does not address several requirements of Appendix Villa, nor does it comply with Appendix Vill as written. PDI was formed to develop a program to perform UT examinations in accordance with Appendix Vlli but found that it could not implement Appendix Vill as writtan. Since 1994, PDI has taken over 20
. specific exceptions to Appendix Vlil and several code cases and code charps i have been processed to correct the Appendix Vill problems documented in the PDI j program. Since many Appendix Vill requirements are unreasonable and virtually
- Such as supplements 10 and 11 or the referenced Appendix ill required by Vill-3110(c) of Appendix Vlli, i
4
+ .
tr GNRO-97/00018 Page 4 of 6 Impossible to implement, PDI has become a program in the spirit of Appendix Vill.
PDI results provide inputs into the ASME Code to bring about changes to Appendix Vill; however, revision of Appendix Vill is probably several years behind the latest PDI information. Therefore, a usable Appendix Vill does not exist at this time.
While the NRC recognizes that PDI is an acceptable substitute for Appendix Vill, no approval or guidance is given for implementation of performance-based UT methods in advance of the rulemaking. Entergy Operations supports the voluntary implementation of Appendix-Vill-type methods for certain applications and believes !
that guidance would be useful to ensure consistent implementation of these i methods. This guidance could include, as examples, reconciliation with various !
regulatory guide commitments for certain types of examinations and the appropriate use oflWA-2240 of Section XI of the ASME Code.
Upcoming 10-year Updates at Entergy Operations' Sites By a letter dated December 12,1996, the NRC approved our request to use the 1992 Edition of ASME Section XI for our upcoming intervals. In the approval, the ,
NRC deferred review of our proposal to exclude Appendix Vill of the 1992 Edition l
of ASME Section XI and to instead follow the requirements in Appendix 1 of the ;
1989 Code Edition which were already incorporated into 10CFR50.55a. In a letter dated January 9,1997, the NRC noted that the subject DGL had been issued for comment. Further, the NRC stated that Entergy Operations would be expected to !
respond to the generic communication when it is issued in final and to revise our ;
ISI programs accordingly. !
As a rule', generic letters do not contain requirements that must be implemented by licensees. If the DGL is issued, Entergy Operations intends to evaluate our
)i options, considering cost and safety benefit. ' Depending on our evaluation, our l actions could range from proposing altematives to determining that no action is necessary, ,
i We appreciate the opportunity to comment on proposed communications and hope that you view these comments as helpful in supporting the issuance of appropriate regulatory communication. If you have any questions concoming our comments, please contact Sheri Mahoney at 601-437-6552.
Yours truly, 1
WKH/SBM cc: (See Next Page) l 3
NRC Inspection Manual Chapters 0720 and 0730 l
i .',
t I
l GNRO-97/00018 Page 5 of 6 cc: Ms. S. C. Black (NRC/NRR) l Mr. K. Cozens (NEI)
! Mr. R. B. McGehee l l Mr. N. S. Reynolds l Mr. H. L. Thomas l Mr. J. W. Yelverton l GGNS Resident inspector i
! Mr. L. J. Callan (w/2) l Regional Admin lstrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation l
U.S. Nuclear Regulatory Commission Mail Stop 13H3 ;
Washington, D.C. 20555 I L
Chief, Rules Review and Directives Branch U. S. Nuclear Regulatory Commission
) Mail Stop T-6D-69 l Washington, D.C. 20555 l
l