NRC-88-0251, Comment Opposing Proposed Rule 10CFR50 & 52 Re Financial Qualifications.Licensee Should Have Adequate Resources to Protect Health & Safety of Public

Comment Opposing Proposed Rule 10CFR50 & 52 Re Financial Qualifications.Licensee Should Have Adequate Resources to Protect Health & Safety of Public

ML20195E733
Person / Time
Site:	Fermi
Issue date:	10/27/1988
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-88-0251, CON-NRC-88-251, FRN-53FR32913, RULE-PR-50, RULE-PR-52 53FR32913-00020, 53FR32913-20, NUDOCS 8811100294
Download: ML20195E733 (2)

Text

_- __ _____ __ __

8. Ralph $ylvd --

iener v<e prevoert DOQO)V ,,_ , m . n ,, _ , s spg 0 o san = - '88 h'0V -2 P4 :08 yH ..

dcht. 27.,.1988 PE-88-0251

%e Secretary of the Ccanission U. S. tuclear Regulatory Carmtission Washington, D. C. 20555 Attention: Docketing and Service Branch

Reference:

Fermi 2 tE Docket tb. 50-341

? E License No. NPF-43 ,

Subject:

tbtice of Receipt of Petition for Rulemaking on Financial Onlifications (PR Doc. 88-19542)

Se receipt of a petition for rulemaking was noticed in the August 29, 1938 Federal Register. S e petition requested that the t K amend its regulations to reinstate financial qualifications as a consideration in the operating licensing hearings for electric utilities. Granting of this petition is unnecessary for protection of the health and safety of the public and potentially could be abused.

Each license applicant is required to meet the rules and regulatims enacted to protect the health and safety of the ptblic. We plant is

_ licensed based on a Final Safety Analysis Report and IE review of the

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plant doctnented in Safety Evaluation Reports. As long as the utility has the financial mpahility to treet the regulations enacted to protect the health and safety of the public, it should be licensed.

Review of financial qualification is unnecessaty and the financial state of the licensee may vary depending on its size and its type (investor-owned utility, cooperative, holding concany, runicipality, etc.)

A potential side effect of granting this petition could be the questioning of financial qualifications for operating plants. License changes allow the opportunity for hearings. Discussion of financial qualifications could prolong such hearings unnecessarily and expend considerable resources - both NIC and licensee.

Detroit Edison feels the irportant issue is that licensees have adequate resources to protect the health and safety of the public. If es11100294 De10N PDR P R 53%3p9g3 5

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i USNRC October 27, 1988 NRC-88-9251 '

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the applicant can denonstrate that the public health and safety will be adequately protectM during license hearings, there is no reason for a detailed exanination of financial qualifications.

Sincerely, cca Mr. A. B. Davis

• Mr. R. C. Knop Mr. W. G. Ibgers ,

Mr. J. R. Stang '

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