ML18093B172
| ML18093B172 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek, 05000000 |
| Issue date: | 09/16/1988 |
| From: | Preston B Public Service Enterprise Group |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLR-N88150, NUDOCS 8809270037 | |
| Download: ML18093B172 (2) | |
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Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge. New Jersey 08038 Nuclear Department Document Control Desk SEP l 6 198f$
NLR-N88150 U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen; PROPOSED CHANGES TO 10 CFR 71 PACKAGING AND TRANSPORTATION OF RADIOACTIVE MATERIAL SALEM.AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272, 50-311, AND 50-354 Public Service Electric and Gas Company has reviewed the subject.
proposed rulemaking as published in the Federal Register dated June 8, 1988.
The following comments are forwarded for your consideration.
The need to conform to IAEA standards is not justified based on the arguments presented.
~AEA standards are utilized by international interests to address situations which do not necessarily exist in the U.S. (e.g. Trans-oceanic and muiti-national shipments).
Additionally, a well developed network for accident response and mitigation exists in the U. s., *unlike many European and Eastern Block countries.
The NRC stipulates that the level of protection afforded the public health and safety would be marginally increased by the rulemaking.
Further, the NRC references a 1987 draft backf it analysis in order to establish estimates of licensee costs and impact on accident analysis and consequences.
In so doing, it is not clear as to whether the potential increased probability of an accident resulting from an increased number of shipments has been considered.
The NRC also fails to address the increased financial burden placed on the licensee due to increased surveillance requirements associated with Type B shipments, and an increased number of notifications and interactions with state authorities.
8809270037 880916
~DR ADOCK 05000272 PDC The Energy People 95-2168 175M1 1 2-8...i
Document Control Desk 2
SEP 1 6 198&
Additionally, the estimated ongoing expense of $1.7M/yr only takes into account the difference in costs between a Type A and B shipment multiplied by the expected number of shipments.
The implicit assumption is that the present cost of a Type B shipment will not be influenced by the increased demand for Type B shipping casks.
In as much as only two Type B casks are known to be available on the east coast, the likelihood of this assumption proving valid is judged to be small.
Further, the one year "breather" proposed by the NRC is arbitrary and insufficient to_ allow Type B cask production at a level which would effectively address the anticipated demand.
It has been our pleasure to participate in the rulemaking process by providing the above comments.
If you have any questions, please feel free to contact us.,
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