ML071780418

2007/06/25-Comment (9) Submitted by Exelon Generation Company LLC, Darin M. Benyak, on Ucs'S PRM-73-13 Regarding to Amend 10 CFR Part 73, Physical Protection of Plants and Materials

ML071780418
Person / Time
Site:	Dresden, Peach Bottom, Byron, Braidwood, Limerick, Quad Cities, Zion, LaSalle
Issue date:	06/25/2007
From:	Benyak D Exelon Generation Co, Exelon Nuclear
To:	Annette Vietti-Cook NRC/SECY/RAS
SECY RAS
References
72FR17440 00009, PRM-73-13
Download: ML071780418 (1)

Text

Exelon Ceneratlon 4 300 W~nfieldRotad Nuclear Warrenvillc. 11. 60555 DOCKETED June 27,2007 (1 :I 8pm)

OFFICE OF SECRETARY June 25,2007 RULEMAKINGS AND ADJUDICATIONS STAFF Ms. Annette L. Vietti-Cook Secretary Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

PRM-73-13, Comments on the Petition for Rulemaking Submitted by the Union of Concerned Scientists (72 Fed. Reg. 17440)

Reference:

Letter from Douglas J. Walters (Nuclear Energy Institute) to NRC, "PRM-73-13, Comments on the Petition for Rulemaking Submitted by the Union of Concerned Scientists (72 Fed. Reg. 17440)," dated June 22, 2007 Exelon Generation Company, LLC (Exelon) is providing comments on the petition for rulemaking on 10 CFR Part 50, submitted by the Union of Concerned Scientists. Exeion endorses the comments provided by the Nuclear Energy Institute (NEI) in the referenced letter regarding the petitioner's two requests.

As described in the referenced letter, Exelon concurs with the petitioner's request to amend 10 CFR 73 to require, when information becomes known that would prevent an individual from gaining unescorted access to the protected area of a nuclear power plant, that measures be implemented to preclude the individual from entering the protected area. The Commission shcald issue a notice of proposed rulemaking to appropriately modify the NRC regulations.

Exelon does not agree with the petitioner's second request that would require an armed security officer to escort a visitor. Trained individuals have served as visitor escorts for many years at Exelon without incident. With the additional emphasis on security in the last few years, only persons with a work-related need for entry are typically allowed as visitors. The escorts for these visitors are trained and badged individuals that are selected, as appropriate, for the purpose of the visit. The petitioner has not demonstrated a benefit commensurate with the cost of increasing the size of the security force to provide armed security officers as escorts, nor has the petitioner cited instances demonstrating the inadequacy of existing processes. The petitioner's second request for rulemaking should be denied.

Sincerely, I

Darin M. Benyak Director, Licensing