ML20199J003

Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060

ML20199J003
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	11/24/1997
From:	Mccoy C SOUTHERN NUCLEAR OPERATING CO.
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR47588, FRN-63FR50465, RULE-PR-50 62FR47588-00015, 62FR47588-15, AF41-2-017, AF41-2-15, AF41-2-17, NUDOCS 9711280014
Download: ML20199J003 (2)

Text

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g g,g g g g IOME Docket Nos. 50-321' 50-348 50-424 HL-5524

• 50-366 'r 50-3645 50-425 - LCV-1132 Mr. Rhn C. Hoyle ()()CKET N N Secretary of the Commission g gf n U.S. Nuclear Regulatory Commission

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Washington, DC 20555-0001 ATTENTION: Rulemakings and Adjudications Staff Comments on Proposed Rule

" Financial Requirements For Decommissioning Nudear Power Reactors" (62 Federal Rekister 47588 of Sectember_l0.199'A

Dear Mr. Hoyle:

Southern Nuclear Operating Company (Southern Nuclear) has reviewed the proposed rule reganung the fmancial requirements for decommist.ioning nuclear power reactors published in the Federal Register on September 10,1997 as well as draft Regulatory Guide 1060, Financial Accounting Standards Board (FASB) Standards for Decommissioning Cost Accounting. In accordance with the request for comments, Southern Nuclear is in total agreement with the NEI comments which are to be provided to the NRC.  !

In addition, Southern Nuclear believes that the same decommissioning funding security \.

rcquired ofinvestor-owned licensees should be required of public power agencies. The definition of" Electric Utility" in the proposed rule does not appear to require that such fD agencies recover all of their coniin their ratcs, only that they set peir 9 prates. In a ,

competetive market, it does not follow that the authotlty of such agencits.to set th'eir own rates ' J, will, in and ofitself, provide assurance of decommissioning funding. Such agencies should bec deemed to meet the dehnition of" Electric Utility" only to the extent that the rates they 4 o establish provide security for the payment of decommissioning costs equivalent to that.rggyired ofinvestor-owned licensees.

M unn Finally, although the intent of the dc5nition of Federal Liccasee as expressed in the Federalw.4 .r .va Register notice is appropriate, the actual definition is ambiguous in that the term " full faith r.nd ,

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U.S. Nuclear Regulatory Commission Page 2 credit backing" of the government is neither defined nor commonly used in other legislation relating to federal agencies. The intent of the definition of Federal Licensee is obviously to exclude from the definition any federal agency whose obligations do not constitute the obligations of the United States and, therefore, are not supported by the full faith and credit of the United States. Therefore, the defmition should be modified as fol'9ws: " Federal Licensee means any NRC licensee, the obligations of which are guaranteed by and supported by the full faith and credit of the United .aates Government."

Should you have any questions, please advise, i Respectfully submitted, l [. Y C. K. McCoy, CKM/JMG cc: Ssutheiahluclear operatine commnv Mr. D. N. Morey, Vice President, Plant Farley Mr. H. L. Sumner, Jr., Vice President, Plant Hatch Mr. J. B. Beasley, General Matoger - Plant Vogtle Mr. R. D. Hill, General Manager - Plant Farley Mr. P H. Wells, General Manager - Plant Hatch U i Nusitadtglatory Commission. Washington &C Mr. J. I. Zimmerman, Licensing Project Manager - Farley Mr. N. B. Le, Licensing Project Manager - Hatch >

Mr. L. L. Wheeler, Senior Project Manager - Vogtle U. S. Nucinar Renulatory CommissionJtegion 11 Mr.L. A.Reyer. Regional Administrator Mr. T. M. Ross, Senior Resident Inspector - Farley Mr. B. L. Holbrook, Senior Resident Inspector - Hatch Senior P.esident Inspector - Vogtle HL-5524 LCV-1132 1

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