ML20113C669
| ML20113C669 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/24/1996 |
| From: | Dennis Morey ALABAMA POWER CO. |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-61FR15427, FRN-62FR47588, RULE-PR-50 61FR15427-00035, 61FR15427-35, AF41-1-086, AF41-1-86, AF41-1-87, NUDOCS 9607020050 | |
| Download: ML20113C669 (3) | |
Text
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Southern Nuclear Operatng Company Post Ottee Box 1295 Birmingham, Alabama 35201 Telephone (205) 868 5131
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00CF Docket Nos.
50 348 a.,
m 50-364 Mr. John C. Hoyle, Secretary DOCKET NtMBER o n
U. S. Nuclear Regulatory Commission PROPOSED RULE rH %
ATTN: Docketing and Service Branch
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Washington, D. C. 20555 Comments on Advanced Notice of Proposed Rulemaking
" Financial Asserance Requirements for Deconunissioning Nuclear Power Reactors" (61 Federal Register 15427 dated April 8.1996)
Dear Sir:
Southem Nuclear Operating Company has reviewed the Advanced Notice of Proposed Rulemaking (ANPR) " Financial Assurance Requirements for Decommissioning Nuclear Power Reactors," published in the Federal Register on April 8,1996. In accordance with request for comments, Southem Nuclear Operating Company (Southem Nuclear) endorses comments of the Nuclear Energy Institute (NEI). NEl's comments accurately convey Southern Nuclear's position on the referenced ANPR. In addition, Southem Nuclear offers the following comments for your consideration.
We agree with NEl that as long as licensees recover all or part of their costs under the authority of state or federal regulations, the current regulatory framework is adequate to assure that funds will be available to safely decommission the nation's nuclear power plants. Any rule proposed by NRC to assure funding in the event of a totally deregulated industry should avoid prescriptive measures, such as a requirement that financial surety be provided or that collection of decommissioning funds be accelerated. Southern Nuclear strongly suggests that the NRC consider the uncertainty associated with the restructuring of the electric utility industry and allow licensees flexibility in demonstrating assurance of adequate decommissioning funds.
Moreover, the NRC should recognize that its current regulatory authority is sufficient to assure that a licensee's expenditures for operations and maintenance are sufficient to provide adequate assurance of public health and safety.
As reflected in the NEI comments, the NRC should require the same degree of assurance that adequate funds will be available for the safe decommissioning of all U.S. nuclear plants,-
regardless of the type of entity that owns the plant. For example, federal licensees should be sulject to the same decommissioning requirements as investor-owned nuclear utilities. Such a rest;lt is not only necessary to assure adequate decommissioning funding, it is consistent with the transition to equitable competition.
9607020050 960624 PDR PR so 50 61FR15427 PDR
Page Two U.S. Nuclear Regulatory Commission Finally, we urge the NRC to carefully consider the effect of any rule it might propose on the economic ' iability of the nuclear industry. Unnecessary prescriptive measures, which may be based o* ansconceptions regarding the rate or extent of deregulation, could increase operating and maintenance costs for some licensees and be ccenter-productive to the NRC's goal of ensuring that adequate decommissioning funds are available when needed. For this reason, the NRC should monitor the process of deregulation closely and impose additional financial assurance requirements only as market conditionsjustify them.
Should you have any questions, please advise.
Respectfully submitted, h9 NktMV Dave Morey DNM/JDB REES File: G.02.10 I
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Page Three U. S. Nuclear Regulatory Commission
-cc:
Southern Nuclear Oneratine Comnany R. D. Hill, Plant Manager U. S. Nuclear Reculatory Commission. Washincton. DC B. L. Siegel, Licensing Project Manager, NRR U. S. Nuclear Reculatory Commission. Region II S. D. Ebneter, Regional Administrator T. M. Ross, Senior Resident Inspector i
l l
REES File: G.02.10