BVY-91-106, Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT

Comments on NRC Proposed Amend to Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants. Consistent W/Mou,Util Established Position of State Liaison Engineer to Communicate W/State of VT

ML20085J751
Person / Time
Site:	Vermont Yankee
Issue date:	10/23/1991
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR41968, RULE-PR-50 56FR41968, BVY-91-106, NUDOCS 9110290337
Download: ML20085J751 (2)

Text

______-____ --__ ____ _ -

VERMONT YANKEE NUCLEAR POWER CORPORATION

, ~ .

/

'Nh{. /

Ferry Road, Bret0cboro, vT 05301 7002 BVY 91-106 b -

. ENGINEERING Of FICE t' m ,.ww m , l

, nooos o mn (500 ??9 (?11 October 23, 1991 U.S. Nuclear Regulatory Commission Secretary of the Commission ,

Washington, DC 20555 l Attention: Docketing a'nd. Service- Branch - j

Subject:

Comments on NRC Proposed Amendment to Polley Statement Concerning Cooperation with States at Commercial duelear Power Plants ,

Vermont Yankee Nuclear Power Corporation appreciates the opportunity to comment on'the subject policy statement. Vermont Yankee is the owner and operator of a nucleir power plant located in the southern part of the State of ,

Vennont and our Emergency Planning Zone (EPZ) extends into two adjacent i states, New Hampshire and Massachusetts.

~ Vermont 'Yanken endorses the concept of the. current policy of NRC communication and cooperation with State governments on issues relating to the regulation of commercial nuclear power p ants. We are, however, concerned with the direction the Commission is contemplating with the-Implementation of .

the Proposed Policy Change.

Vermont Yankee encourages the process of open communications with members ~ of adjacent States, iowever, we firmly believe that the host Stato deserves special consideration and, for this purpose, we have established 'a Memorandum of Understanding (MOU) with the State of Vermont for the purpose- ,

of providing a mechanism to facilitate ongoing communications of both routine as well' as off normal situations. The state of Vermont also has a formal agreement with the NRC relating to state participation in Inspection activillos at the Vermont Yankee plant. Consistent with the MOU, we have established a position of State Liaison Engineer within Vermont Yankee whose role .is to communicate dally and to meet weekly with the State of Vermont representatives.

Extending the .courtesles presently afforded to host states to additional ,

representatives of adjacent states will certainly increase the burden on the NRC ,

and potentially diminish the effectiveness of NRC inspections as well as place an additional burden on plant staff and facilities.

L

$ \f '

T W 9 888K sia88 m6 r pb. Lh%

= -. _

a

i3 S

i VERMONT YANKEE NUCLEAR POWER COR$ ORATION U.S. Nuclear Regulatory Commission

. October 23, 1991 '

Page 2 j

This proposed change will, undoubtedly increase the time and effort of i NRC :>ersonnel to train and Interact with State inspectors and result in.

unjustiled additional cost billed to licensees. In addition, .it is not difficult to foresee competition developing between host and neighboring state ilispectors which could degrade the relationship between one of the states and the NRC or the Utility.  !

In conclusion, we urge the Commission to reconsider its proposed polley ,

change and, continue to recognize the prioritles of the host state and encourage  !

the ad, acent states to communicate w th host state representatives on matters  !

pertain ng to the operation of host state nuclear power plants.

Very truly yours, Vermont Yankee Nuclear Power Corporation

.i s, . . hp 9

, Warren P. rphy Senior Vice resident, pe ations t

cc: USNRC Region 1 Administrator

- USNRC Resident inspector - VYNPS L USNRC. Project Manager VYNPS USNRC Document Control Desk i k

k Y

f-a prM. sw ,ve" -a , -e

,ywesw,uc rw s - - rw -t- g -w-e-+w--=-v-<-v-a wr~r- wa- - = - - r