ML20247H857
| ML20247H857 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/12/1989 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-54FR30049, RULE-PR-150, RULE-PR-30, RULE-PR-40, RULE-PR-50, RULE-PR-60, RULE-PR-70, RULE-PR-72 54FR30049-00009, 54FR30049-9, AD21-2-13, NUDOCS 8909200121 | |
| Download: ML20247H857 (2) | |
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6400 North Desse Highway h
EDISON Newport. Machigan 48166 (313;58E4150
'89 SEF 18 P3 :31 f.I f September It d 989-F.; w Mr. Samuel J. Chilk Se:retary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Docketing and Service Branch RE: Proposed Rule - Preserving the Free Flow of Information to the Commission 54 Federal Register 30049 (July 18, 1989)
Request for Comments
Dear Mr. Chilk:
The Detroit Edison Company (hereinafter Company) is a public utility serving over 1,800,000 customers in southeastern Michigan.
The Company is the owner and operator of Fermi 2 Nuclear Power Plant. It is also a member of the Nuclear Management and Resources Council, which has also submitted comments in this proceeding, and the Company endorses those comments as they would apply to the Fermi 2 Nuclear Power Plant.
However, the Company also holds seven licenses pursuant to 10 CFR Part 30 of the Commission's Regulations. Those licenses authorize the possession and use of sealed sources which are used in analytical and measuring instruments. These instruments are located in five fossil fuel fired power plants, and the Engineering Research Laboratory, as well as five portable instruments that are transported to various locations for use.
Because of the nature of those sources and the cc,ntrols upon them, there is a slight probability of contractor or subcontractor employees engaging in actions which would amount to protected activities under Section 210 of the Energy Reorganization Act. Yet, the number of contracts that are issued yearly for activities where the license material is located is in the 10's of thousands. The burden imposed in issuing and administrating these contracts would impose an enormous burden on the Company, with little or no benefit in maintaining communications with the Nuclear Regulatory Commission. It also should be understood that ualike contractors who perform work at a Nuclear Power Plant, those contractors do not have normal inter-
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actions with the Nuclear Regulatory Commission, increasing the difficulty l
in negotiating the necessary contractual arrangements to assure com-pliance with proposed 10 CFR 30.7.
O S/0 8909200121 e 1o9 q PDR PR 30 54FR3OO49 PDR
1 Samuel J. Chilk September 12, 1989 Page 2 Therefore, the Company would request the Commission not adopt the proposed 10 CFR 30.7, but if the Commission feels it must adopt such a provision, it should be focused much more narrowly on contractors who are involved in the procurement, maintenance or disposal of licensed material or activities, to reduce the burden on the licensee.
Very truly yours.
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