ML20035D039
| ML20035D039 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/05/1993 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR6730, RULE-PR-30, RULE-PR-40, RULE-PR-50, RULE-PR-70, RULE-PR-72 58FR6730-00028, 58FR6730-28, NSD930346, NUDOCS 9304120066 | |
| Download: ML20035D039 (2) | |
Text
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s 01/05 93 16:03 HPPD-flUCLEAR SUPPORT 002 00CKET NUMBER L
PROPOSED RULEh 3d.*/83ofOd-72.
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GENERAL OFFICE
" ML P o. Box 4W. COLUMBUS. NEBRASKA 68602-04H Nebraska Public Power District "Ts"Me'llin" y
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NSD930346 x
April 5, 1993 The Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch l
Subject:
Comments on NRC Proposed Rule Affecting LLRW On-Site Storage Cooper Nuclear Station NRC Docket No. 50 298/DPR 46
Reference:
Federa' Register, Volume 58, No. 20, 6730 - 6740, dated Tuesday, February 2, 1993, " Procedures and Criteria for On-Site Storage of Low-Level Radioactive Waste" l
Centlemen:
On February 2, 1993, the Nuclear Regulatory Commission (NRC) published in the Federal Register a proposed rule establishing restrictions regarding on-site l
storage of low-level radioactive waste (LLRW) af ter January 1,1996. The Federal l
Register requested that commer.ts on the referenced proposed rule be forwarded to the Commission by April 5,.993.
The Nebraska Publ.i.: Power District (District),
which operates the Cooper Nuclear Station (CNS), aas e:hosen to comment on the proposed rule.
Contained in this letter are th; District's comments for NRC consideration in the fin 1 rulemaking:
1)
As a licensee, we would agree with the NRC that permanent disposal of LLRW is certainly preferable to the interim on-site sturage of LLRW at reactor sites. However, LLRW generated at reactor sites can be safely stored on temporary basis under NRC requirements and guidance related to the a
interim storage of LLRW.
Because interin on-site storage requires licensees to protect public health and safety, it cannot be concluded that permanent disposal of LLRW significantly enhances the public health and safety as compared to the on-site storage of LLRW.
Nevertheless, ALARA considerations favor permanent disposal over interim storage.
2)
The proposed rule states that for LLRW storage beyond January 1,
- 1996, "the licensee shall document that it has exhausted other reasonable waste I
management options," to dispose of its LLRW. This statement is ambiguous and needs to be clarified in order to more specifically describe what is required of a licenser to demonstrate that it has " exhausted other reasonable waste management options."
3)
The NRC, through this rulemaking, is
? tempting to place the burden upon licensees to ensure new permanent disposal sites are developed. The LLRW Amendments Act of 1985 places this butdan upon the states, not licensees.
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04/05/93 16:04 ilPPD-tOCLEAP SUPPORT 003 U.S. Nuclear Regulatory Commission Page 2 of 2 April 5, 1993 This attempt to shif t responsibility is not statutorily supportable and is an impossible burden on licensees.
The District appreciates the opportunity to comment on the proposed rule and would welcome the opportunity to discuss our comments.
If you i ve any questions, please contact me.
Sinc ely, N
G R. Horn Nuc uar Power Group Manager GRH/ mis /dnm cc:
U.S. Nuclear Regulatory Commission Region IV Arlington, TX NRC Resident Inspector Cooper Nuclear Station