ML20155E893

Comment on Proposed Rule 10CFR50.54(w)(5)(i) Re Amending Implementation Schedule for Stabilization & Decontamination Priority & Trusteeship Provisions of Property Insurance Regulations.Nrc Initiated Exemptions Expected Before 881004

ML20155E893
Person / Time
Site:	Peach Bottom, Limerick, 05000000
Issue date:	10/03/1988
From:	Gilmore R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR36338, RULE-PR-50 53FR36338-00003, 53FR36338-3, AC26-2-11, NUDOCS 8810130045
Download: ML20155E893 (2)

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'Hu?USED ROLE L g 3 PHILADELPHIA ELECTRIC COM ANY NI 2301 MARKET STREET P.O. BOX 8699 '88 (ET -4 P4 :21 PHILADELPHIA PA 19101 (zi el es t.4 eco hpe0CFi's v.:

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RICH A RD G. Gil.MORE October 3, 1988 Docket Nos. 50-277 50-278 50-352 Mr. Samuel J. Chilk, Secretary U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch Re: Notice of Proposed Rule 10 CFR E50.54(wi(E)(1)

Dear Mr. Chilk:

On September 19, 1988, the NRC published a proposed rule in the Federal Reaister (53 Fed. Reg. 36338) that would amend the implementation schedule for the stabilization and decontamination priority and trusteeship provisions of its property insurance regulations. (10 CFR S50.54(w)(5)(i). The effective date of those provisions would be changed from Octobet 4, 1988 to April 4, 1990. This action responds to concerns about the present rule, adopted on August 5, 1987 (52 Fed. Reg. 28963), that have been expressed to the NRC by power reactor licensees, industry groups, and nuclear property insurers and which are recited in the NRC's Notice of Rulemaking. As the NRC is aware, insurance policies fully satisfying the decontamination priority payment and independent trustee requirements are not available and trust arrangements cannot be established by October 4, 1988.

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Mr. Samuel J. Chilk, Secretary October 3, 1988 Since the comment petiod for this proposed rule will not expire until after the October 4, 1988 deadline, the proposed rulemaking does not provide licensees with timely relief from the deadline. It is Philadelphia Electric Company's under-standing that NRC will issue exemptions from the October 4, 1988 deadline on its own initiative in each docket and is discouraging the filing of individual exemption requests. The purpose of this letter is to set forth our understanding of actions that are intended by the NRC and our reliance on the assurance that we will be relieved from the October 4, 1988 deadline. While no further action is anticipated at this time, we will contact the NRC Staff to determine the appropriateness of submitting a utility specific exemption application if our understanding of the NRC's intentions in this matter proves erroneous.

Very ruty purs,

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m Ricrard G. Gilmore

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cc: W. T. Russell, Regional Administrator T. J. Kenn;', Senior Resident Inspector T. P. Johnson, Resident Inspector