L-2006-255, Comment (8) Submitted by Florida Pwr. and Light Company, Martin Gettler, on Supplemental Proposed Rule PR-2, 50, 51 and 52, Regarding Licenses Certifications, and Approvals for Nuclear Power Plants

Comment (8) Submitted by Florida Pwr. and Light Company, Martin Gettler, on Supplemental Proposed Rule PR-2, 50, 51 and 52, Regarding Licenses Certifications, and Approvals for Nuclear Power Plants

ML063240354
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	11/14/2006
From:	Gettler M Florida Power & Light Co
To:	NRC/SECY/RAS
Ngbea E S
References
71FR61329 00008, L-2006-255, PR-2, PR-50, PR-51, PR-52, RIN 3150-AG24
Download: ML063240354 (1)

Text

Florida Power &Light Company, 700 Universe Boulevard,.P.0. Box 14000, Juno Beach, FL 33408-0420 PR 2, 50, 51 and 52 FP3L (71 FR61329)

DOCKETED NOV 1 4 2006 USNRC L-2006-255 Secretary, U.S. Nuclear Regulatory Commission November 17, 2006 (4:00pm)

Attn: Rulemakings Mail Stop 016-Cl and Adjudications Staff OFFICE OF SECRETARY i SRULEMAKINGS Washington, DC 20555-0001 AND ADJUDICATIONS STAFF Re: Florida Power & Light Company, FPL Energy Seabrook, LLC, and FPL Energy Duane Arnold, LLC, Comments on NRC Supplemental Proposed Rule, "Licenses Certifications, and Approvals for Nuclear Power Plants" (71 FR 61330; March 13, 2006) RIN 3150-AG24 Florida Power & Light Company, the owner and operator of the St. Lucie Nuclear Plant, Units 1 and 2 and Turkey Point Nuclear Plant, Units 3 and 4; FPL Energy Seabrook, LLC, the owner of a controlling interest in and operator of Seabrook Station; and FPL Energy Duane Arnold, LLC, the owner of a controlling interest in and operator of Duane Arnold Energy Center (collectively FPL), submit these comments on the above-referenced rulemaking concerning proposed changes to Nuclear Regulatory Commission (NRC) requirements applicable to limited work authorizations (LWA).

FPL supports the proposed changes to narrow the scope of activities requiring permission from the NRC in the form of a LWA. The proposed changes will allow greater flexibility for site preparation activities to be performned prior to construction. NRC approval of pre-construction activities should focus solely on matters pertaining to safety. In particular, FPL agrees with the changes to 10 CFR 50.10(b) as described in the proposed rule at 71 FR 61336-61337, which would exclude from the definition of "construction" activities requiring NRC prior approval, activities such as site clearing, initial site grading, erosion control measures, site exploration, test boring, erection of temporary buildings and erection of permanent structures which are not required to be described in the site safety analysis report, preliminary safety analysis report, or final safety analysis report.

FPL endorses the comments submitted by the Nuclear Energy Institute on behalf of the nuclear power industry.

FPL is supportive of NRC's efforts to improve its processes for licensing and approval of new nuclear plants. We appreciate the opportunity to comment on this important rulemaking.

Sincerely yours, Martin Gettler Vice President Nuclear Projects aneFPL (G deou companyG an FPL Goup company