ML20092B572

Comment Supporting Pr 52 60FR17902 Re Standard Design Certification for Us Advanced BWR Design

ML20092B572
Person / Time
Site:	05200001
Issue date:	08/31/1995
From:	Roberts J ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR17902, RULE-PR-52 60FR17902-00020, 60FR17902-20, NUDOCS 9509120073
Download: ML20092B572 (2)

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BRA-ici DOCKET NUMBER BD August 31,1995 PROPOSED RULE ra sa Secretary, U.S. Nuclear Regoiatory Comm. .

ission

((doFe.W\oh Washington, D.C. 20555 Attention: Docketing and Service Branch

SUBJECT:

Proposed Rule " Standard Design Certification for the U.S. Advanced Boiling Water Reactor Design (60 Federal Register 17903, April 71995)

CNRO-95/00019 Gentlemen:

Entergy Operations, Inc. (EOI) is pleased to comment upon the above-cited Federal Register notice. We strongly support the innovative concepts incorporated into 10 CFR Part 52 in addition to the sound, fundamental principles inherent to the Pan 52 process.

However, there are positions advocated within the rule that appear contrary to the pnnciples and would introduce licensing uncertainties and unnecessary burdens on future licensees. Specifically, we believe the proposed rule Does not provide sufricient finality for resolved issues and permitted changes, Will, with the new " applicable regulations," create the potential for destabilizing backfits, Lacks a provision to ensure that the NRC will have a stable and predictable process for making its fmdings that the ITAAC (inspections, tests, analyses and acceptance criteria) have been met, is burdensome and more restrictive thnn needed by requiring the consideration of severe accident and probabilistic analy.ses in section 50.59 safety evaluations (in order to preserve severe accident insights),

Does not allow the design certification applicant to make 50.59-like changes after design certification, and 9509120073 950831 PDR PR 52 60FR17902 PDR pc

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s Proposed Rule" Standard Design Certification for the U.S. Advanced Boiling Water Reactor Design (60 FederalRegister 17903, April 71995)

August 31,1995 CNRO-95/00019 Page 2 of 2 Does not incorporate the substantive provisions in the design co, ,rol documents introduction into the design certification rules.

EOI views the proposed rule as an excellent step towards a predictable and stable licensing process for future plants and encourages the NRC to move fonvard in this area.

We appreciates the opportunity to provide comments on the subject notice.

Sincerely,

{fs D/RLT/baa cc: Mr. H. W. Keiser Mr. William H. Rasin (NEI)

Mr. J. C. Roberts