NRC-09-0058, Comment (4) of Rodney W. Johnson on Behalf of Detroit Edison, Fermi 2, on Availability of Funds for Decommissioning Nuclear Reactors
| ML092590129 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/09/2009 |
| From: | Rachel Johnson Detroit Edison |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 74FR31317 00004, NRC-09-0058 | |
| Download: ML092590129 (3) | |
Text
Fermi 2 6400 North DLxie Hwy., Newport, MI 48166 Detroit Edison September 9, 2009 NRC-09-0058 Rulemaking, Directives and Editing Branch Office of Administration U.S. Nuclear Regulatory Commission Washington D. C. 20555-0001 0D@
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References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) Draft Regulatory Guide-1229, "Assuring the Availability of Funds for Decommissioning Nuclear Reactors", dated June 2009
Subject:
Availability of Funds for Decommissioning Nuclear Reactors Detroit Edison reviewed the changes in Draft Regulatory Guide-1229, which is the proposed Revision 2 of Regulatory Guide (RG) 1.159 on Assuring the Availability of Funds for Decommissioning Nuclear Reactors. A Detroit Edison representative participated in the August 20, 2009, NRC public meeting on the proposed RG-1229 via webcast. Participants via webcast were requested to formally submit their comments, so this letter documents our concern as a result of the August 20, 2009 public meeting.
Proposed Section 2.1.5 of RG-1229 states in part:
A licensee that is an electric utility or that has access to nonbypassable charges sufficient to provide allftinds neededfor decommissioning, is not requiredby the NRC regulationsto have a specific amount offinancial assuranceat the end of any given year, since such licensees are allowed to use external sinkingfunds exclusively as their financialassurance mechanisms. However, such a licensee must recalculate,on an annual basis, the minimum formula decommissioning cost estimate, using IOCFR5O.75(c), and should adjust the schedule offitture collections in connection with AG/OS /
A DTE Energy Company
NRC-09-0058 Page 2 every rate case before its public utility commission, such that there is reasonable assuranceof adequate decommissioningfunding.
We ask that the wording in the last sentence of the excerpt be modified. The Regulatory Guide should only recommend that the schedule for future collections for decommissioning be addressed in rate cases as needed to ensure reasonable assurance of adequate decommissioning funding.
Adjusting the schedule of future collections at every rate case could result in reduced financial assurance for decommissioning, as well as volatility. For example, if collections are adequate or slightly above adequate, and the equity market has a short term gain just before a rate case, then it will appear that collections 'are in excess and should be reduced. Then, if the market returns to its previous value, with the newly adjusted lower collections, funding will no longer be adequate.
The Regulatory Guide revision should recommend that the future collection schedule be addressed and adjusted, as needed, to provide reasonable assurance of adequate decommissioning funding at the next general rate case if the schedule of collections is determined inadequate during the annual review.
If you have any questions regarding this comment, please contact Lynne Goodman, Manager Fermi 1, at 734-586-1205.
Sincerely, Rodney W. ýhnson Manager, Nuclear Licensing cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region mI Supervisor, Electric Operators, Michigan Public Service Commission
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