ML063210217

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Comment (2) Submitted by Duke Energy, Bryan J. Dolan, on Supplemental Proposed Rules PR-2, 50, 51, and 52, Regarding Licenses, Certifications, and Approvals for Nuclear Power Plants
ML063210217
Person / Time
Site: Oconee, Mcguire, Catawba, McGuire  Duke Energy icon.png
Issue date: 11/15/2006
From: Dolan B
Duke Energy Corp
To:
NRC/SECY
Ngbea E S
References
71FR61330 00002, PR-02, PR-50, PR-51, PR-52, RIN 3150-AG24
Download: ML063210217 (4)


Text

PR 2, 50, 51 and 52 (71 FR61329)

November 15, 2006 DOCKETED USNRC November 16, 2006 (1:30pm)

OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF BRYAN J. DOLAN VP, Nuclear Plant Development Duke Energy ECO5R / 526 South Church Street Chadotte, NC 28201-1006 Mailing Address:

P.O. Box 1006-ECO5R Chariotte, NC 28201-1006 704 382 0605 704 382 445 bjdolan@duke-energy.com 0

Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff

Subject:

Duke Power Company LLC d/b/a Duke Energy Carolinas, LLC Comments on RIN 3150-AG24, Licenses, Certifications, and Approvals for Nuclear Power Plants, NRC Supplemental Proposed Rule, 71 FR 61330 (October 17, 2006)

Duke Energy Carolinas (Duke) has reviewed the subject supplemental proposed rule language, and has participated with the Nuclear Energy Institute (NEI) in the development of their comments. Duke endorses NEI's comments, and encourages careful consideration of those comments.

Duke acknowledges and appreciates the efforts of the NRC Staff to focus the regulation on the activities that have a nexus to radiological health and safety and/or common defense and security. Duke also agrees that it is appropriate to redefine those activities that require Commission approval in a way that acknowledges that the applicant assumes the risk in conducting those activities in advance of receipt of a license.

The appropriate changes to this regulation in this regard are significant to Duke's ability to deploy new generating facilities in a timely manner. Duke particularly endorses NEI's comments with respect to the definition of "construction" in a way that excludes excavation and activities not associated with safety-related or "safety-significant" structures, systems, and components. Incorporation of these comments will further enhance the regulation consistent with the Commission's appropriate focus, and consistent with the risk that properly belongs with the applicant.

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Secretary, U.S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudications Staff November 15, 2006 Page 2 Thank you for the opportunity to comment on this important rule. If you have any questions or need any additional information, please contact Peter Hastings at (980) 373-7820.

Sincerely, xc:

S. D. Bloom, NRC/HQ S. M. Coffin, NRC/HQ D. B. Matthews, NRC/HQ J. L. Starefos, NRC/HQ W. D. Travers, NRC/RII

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"Jones, Luellen B" <lbjones@duke-energy.com>

<SECY@ nrc.gov>

Thu, Nov 16, 2006 10:05 AM Duke Energy Carolinas, LLC Comments - RIN 3150-AG24 CC:

energy.com>

"Bowling, Theodore J" <TJBowling@duke-energy.com>, "Gill, Robert L Jr" <rlgill@duke-

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Duke Energy Carolinas, LLC Comments - RIN 3150-AG24 Thu, Nov 16, 2006 10:05 AM "Jones, Luellen B" <ibj ones@ duke-energy.com>

lb ones @ duke-energy.com Recipients nrc.gov TWGWPO02.HQGWDOO1 SECY (SECY) duke-energy.com rlgill CC (Robert L Jr Gill)

TJBowling CC (Theodore J Bowling)

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