ML19290C606
| ML19290C606 | |
| Person / Time | |
|---|---|
| Site: | McGuire, 07002623  |
| Issue date: | 12/31/1979 |
| From: | Porter W DUKE POWER CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML19290C607 | List: |
| References | |
| FRN-44FR34466, RULE-PR-73 NUDOCS 8001220160 | |
| Download: ML19290C606 (2) | |
Text
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Duau Pownn GOMPANY LEGAL DEPARTMENT P. O. Box M 33189 GTTART OTTE, N. G. 20242 ason aua> S 'T44FR W MG)(
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"::::'::^"".L7?J" December 31, 1979 IW f
t Secretary of the Commission 4
3 U. S. Nuclear Regulatory Commission DCCM A
ust64 Washington, D. C.
20555 7 1980
- C Attention:
Docketing and Service Branch SU g.g ;5 6
ctthe 0@.gg6c3 Re:
McGuire Nuclear Station Odd 2h~ c g
Amendment to SNML-1773 D
Docket Nos. 50-369 & 70-2623 W
Dear Mr. Secretary:
The following comments are intended to express our continuing concern over those regulations pertaining to the transportation of irradiated reactor fuel in transit which are primarily set forth in 10 CFR 73.37.
I realize that the comment period has expired concerning these regulations; however, since the expiration date, we have experienced difficulties stemming from the regulations.
In light of this fact, coupled with the fact that the final regulations have yet to be published, we would hope you would receive our comments and consider them in your deliberations.
To facilitate natters, our basic comments are set forth in our letter of August 30, 1979 to Mr. William J.
Dircks, Director, Office of Nuclear Material Safety and Safeguards, U. S. Nuclear Regulatory Commission.
A copy of that letter is attached.
In addition to the attached comments, we would like to raise three additional points:
(1) There are three categories of embargoed areas.
We believe that this firm embargoing of an area creates problems for the transportation of spent fuel.
There should be flexibility permitted beyond that set forth in the interim regulations which would allow the utilization of the embargoed areas set forth in Cate-gories B and C if additional protection is provided.
(2) We question the wisdom of having a Category C inasmuch as the populations are far removed from the Sandia 1927 New York F/85 059
... - excero.. A 80 012 20 \\f O
Secretary of the Commission December 31, 1979 Page 2 City scenario.
Further, a great portion of major roadways traverse the cities listed therein, thereby limiting the use of such modern roadways which, interestingly enough, were built to facilitate safer and more expaditious trans-portation activities.
(3) We take issue wita the three mile barrier that is created around Category B and C cities and steadfastly maintain that provisions for additional protection and/or planned continuous movement are sufficient particularly for short haul distances.
Three miles is an arbitrary barrier which further precludes the use of major roadways.
Avoidance *of congested and densely populated areas within city limits should suffice.
Very truly your William L. Porter WLP/fhb Attachment 1785 060 _
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