ML20087C132

Comment Opposing Proposed Rule 10CFR52 Re Rulemaking for Std Design Certification for Sys 80+ Design

ML20087C132
Person / Time
Site:	05200001, 05200002
Issue date:	08/03/1995
From:	Quirk J GENERAL ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR17924, RULE-PR-52 60FR17924-00004, 60FR17924-4, NUDOCS 9508090059
Download: ML20087C132 (2)

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OFFICE OF EECRETARY August 3,1995 DOCKETitG & SERVICE BRAliCH Secretary of the Commission DOCKET PROPOSED RULEJn NUMBERas 'sa -

U.S. Nuclear Regulatory Commission Washington, DC 20555 bEO @

Attention: Docketing and Service Branch

Subject:

Comments on Notice of Proposed Rulemaking for Standard Design Certification for the System 80+ Design; 60 Fed. Reg.17924 (April 7,1995);

Docket No.52-002

Dear Sir:

On April 7,1995, the,NRC p iblished a notice of proposed rulemaking (NOPR) for design cenification of the Systerr. 30& under 10 CFR Part 52. The following comments are being provided on behalf of the saplicant for design certification of the Advanced Boiling Water Reactor (ABWR), GE Nuclear Energy (GE).

The NOPR for the System 80 F is substantively identical to the NOPR for design cenification of the ABWR. GE assistet the Nuclear Energy Institute (NEI) in preparing its comments on the proposed design certification rules for both the ABWR and System 80+. GE fully supports and endorses NEI's comments. Given the extensive nature of NEI's comments, GE i is hereby incorporating NEI's comments by reference rather than duplicating the analyses contained therein.

In summary, there are a nm nber of provisions in the NOPRs that are inconsistent with either the Commission's regulatio is, prior Commission decisions, the purpose of Part 52, or previous guidance by the NRC Staff. The NOPRs as drafted would greatly decrease the  ;

stability and certainty of the licensing process envisioned when the Commission promulgated  !

Part 52. Additionally, as drafled, the NOPRs would greatly add to the costs associated with implementation of Part 52, without any increase in safety. In issuing the final design certification rules, GE urges the Commission to modify the proposed rules as recommended l' by NEI to ensure the stab lity and cenainty of the Part 52 licensing process.

9508090059 950803 j PDR PR O 1 52 60FR17924 PDR Y f

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GE is not requesting an informal hearing on the NEI comments incorporated herein. These comments raise policy-related issues that can be resolved by the Commission without a hearing. However, if the Commission should decide to hold a hearing at the request of another person on a matter that is related to these comments, GE reserves the right to request ,

to participate in such hearing in order to protect its interests in the form and content of the design certification rules.

Sincerely, l qf . i

[J.F.

g Quirk l

I cc: D.M. Crutchfield (NRC) 1 S.M. Franks (DOE) l R. L. Simard (NEI)

C.B. Brinkman (ABB/CE) l l

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