ML20062A183
| ML20062A183 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle  |
| Issue date: | 10/15/1990 |
| From: | Mcgee S OGLETHORPE POWER CORP. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR29043, FRN-56FR64943, RULE-PR-2, RULE-PR-50, RULE-PR-54 55FR29043-00034, 55FR29043-34, AD04-2-027, AD4-2, AD4-2-27, NUDOCS 9010190181 | |
| Download: ML20062A183 (3) | |
Text
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M Oglethorpe Power Corporation Wp 1
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(404)496 7600 3
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Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission i
Washington, DC 20555 Dear Mr. Chilks.
Subject:
Proposed Rule - 10 CFR Parts 2, 50, and 54 Nuclear Power Plant License' Renewal 55 Federal Register 25043.(July 17, 1990)
Request for comments i
These comments are being submitted on behalf of Oglethorpo Power Corporation (an Electric Membership Generation & Transmission l
Corporation) ("Oglethorpe Power"), an electric membership corporation organized and existing under the laws of the State of Georgia.
Oglethorpe Power provides wholesale electric service to 39 elect.ric distribution cooperatives (the." members"-) with a service' a
territory consisting of 71 percent of.the land area of the State of Georgia.
Oglethorpe Power's members distribute electric energy to over two million people.
Oglethorpe Power is a I
co-owner with Georgia Power Company, the Municipal Electric Authority of Georgia and the City of Dalton of two nuclear power plants in Georgia, Plant Alvin W. Vogtle and Plant Edwin I.
- Hatch, i
GENERAL t
Oglethorpe Power Corporation supports the NRC's development of l
technical requirements and standards and procedures for renewal-i of existing nuclear operating licenses.
Furthermore, Oglethorpe Power genera 1ly endorses the Nuclear Management and Resources Council, Inc. ("NUMARC") position with regard.to the technical and procedural rules which the NRC is proposing for license-
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renewal.
Oglethorpe Power agrees with the NRC that the primary focus of the license renewal process should be on the health and safety of 9010190181 901015 l
[$5F 29043 PDR; An Electric Membership Cooperative 3
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'l Mr.. Samuel J. Chilk Page 2 October 15, 1990 i
the public within the framework of the Current Licensing Basis (CLB).
The CLB provides the ongoing assurance that the health and safety of the public is fully protected.
Oglethorpe Power also very strongly supports the NRC's principle that each plant's CLB must be maintained during the renewal period.
This approach 3
is acceptable in that it recognizes the evolving set of conditions that may change as technology advances and more operating experience is gained.
However, Oglethorpe Power is opposed to any CLB definition that would appear to freeze CLB requirements during the renewal process; thus potentially causing unwarranted plant shutdowns.
Based on the preceding fundamental support of NRC's principles regarding license renewal, Oglethorpe Power is submitting the i
following summary comments related specifically to antitrust 1ssues of the proposed rule, j
i f
NRC RULEMAKING ANTITRUST ISSUES Oglethorpe Power believes that the NRC's statement that license f
renewals will never constitute modifications resulting in a new or substantially different facility is overly broad.
There may l
be competitive advantages for a utility to renew an existing f
plant license, as opposed to incurring expenses in constructing a i
i new facility, that could be important to examine in the context
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of an antitrust review.
The NRC's proposed rules would foreclose interested parties from having an opportunity to present evidence that the renewal plant constitutes a new or substantially i
different facility.
j The proposed rule allows for the possibility of an antitrust review by the Attorney General where there are " changes in licensee activities."
Oglethorpe Power believes that the NRC will need a proper administrative record in each. case upon which to determine whether changes in licensee activities have occurred warranting an antitrust review.
Therefore, the NRC should I
require applicants to submit evidence as part of their renewal application, and allow interested parties also to submit auch evidence, as to whether there have been any such changes in licensee activities.
I CONCLUSION Oglethorpe Power Corporation appreciates this opportunity to
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comment on NRC's Proposed Rule - 10 CFR Parts 2, 50, and 54.
Oglethorpe Power and its members support the NRC and industry I
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Mr. Samuel J. Chilk Page 3 October 15, 1990 cooperative efforts which will ensure that license renewal is a viable option for existing nuclear power plants.
Oglethorpe Power welcomes any opportunity to discuss our comments and share our commitment to nuclear power with the NRC.
Sincerely,-
JL.
Steven R. McGee Program Director Regulatory & Project Services i
SRManc f
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