ML20087C132
| 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 DOCKETitG & SERVICE August 3,1995 BRAliCH DOCKET NUMBERas 'sa Secretary of the Commission PROPOSED RULEJn U.S. Nuclear Regulatory Commission bEO Washington, DC 20555 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 by NEI to ensure the stab lity and cenainty of the Part 52 licensing process.
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52 60FR17924 PDR
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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, qf
[J.F. Quirk g
I cc:
D.M. Crutchfield (NRC) 1 S.M. Franks (DOE)
R. L. Simard (NEI)
C.B. Brinkman (ABB/CE)
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