ML20087D540

Comment Opposing Proposed Rule 10CFR52 Re Standard Design Certification for ABWR & Sys 80+ Designs

ML20087D540
Person / Time
Site:	Cook, 05200002
Issue date:	08/01/1995
From:	Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR17902, RULE-PR-52 60FR17902-00013, 60FR17902-13, NUDOCS 9508110025
Download: ML20087D540 (2)

Text

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indene M dulan 8 PowerCompeer P.O. Box 16631 Columbus OH 43216 00CKETED /TPJ /3 USHRC mar DNDEANA AINNf0AN

'95 AUG -9 Pl2:25 0FF# Or' ECRETARY DOCKEin ,5E9VICE August 1, 1995 AEP:NRC:0508A0 Docket Nos.: 50-315 50-316 DOCKET NUMBER as PROPOSED RULE rn N Secretary of the Commission U. S. Nuclear Regulatory Commission

([gpg)7yg Washington, D. C. 20555 ATTN: Docketing and Service Branch Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 COMMENTS ON PROPOSED RULEMAKING:

10 CFR 52 STANDARD DESIGN CERTIFICATION FOR U.S. ADVANCED BOILING WATER REACTOR AND SYSTEM 80+ DESIGNS This letter provides comments on the proposed 10 CFR 52 rulemaking regarding design certification for the Advanced Boiling Water Reactor and the System 80+ designs. The proposed rulemaking was 1995, published in the Federal Register on April 7, (ref 60 FR 17902 and 60 FR 17924, respectively).

The NRC is to be commended for incorporating several innovative concepts in 10 CFR 52, which lays the foundation and regulatory framework for future plant licensing. The process has worked well to date, in providing early resolution of key safety issues and standardization of the safety significant design features. It'is vital, however, that the implementing vehicles, such as these proposed rules, carry out in practice the principles inherent to the 10 CFR 52 process.

The Nuclear Energy Institute (NEI) has compiled industry comments identifying a number of proposed NRC staff positions that, contrary to the fundamental principles of 10 CFR 52, introduce licensing uncertainties and impose unnecessary burdens on future licensees.

The NEI comments are expected to be submitted to the NRC by August 3, 1995. We participated in the development of these comments and endorse them.

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'U. S. Nuclear Regulatory Commission AEP:NRC:0508AO_ }i Page 2.

k l- We appreciate the' opportunity to comment on the- proposed e I

rulemaking. Questions regarding these comments should be addressed to Mr. Steven Brewer at (614) 223-2020. -l i

1 Sincerely,  ;

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E. E. Fitzpatrick Vice President l

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~1 cc: A. A. Blind G. Charnoff '!

H. J. Miller  !

f NFFE Section Chief NRC Resident Inspector - Bridgman a J. R. Padgett {

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