ML20035D043
| ML20035D043 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/26/1993 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| 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 58FR6730-00010, 58FR6730-10, NUDOCS 9304120070 | |
| Download: ML20035D043 (2) | |
Text
_ ___ _.
OOCKET NUMBER 4
Ja**a8 Mc4*a PROPOSED RULE PR so,uo,so 7os 72 (67/CR.6730).
s Porer Company P O Box 16631 Co:umous, OH 43216 M
mid DNDIANA m7 ANCNICAN 93 tro -1
/0 90 wen AEP:NRC:0508W Donald C. Cook Nuclear Plant Units 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. D,PR-58 and DPR-74 PROPOSED RULE CHANGE ON SITE STORAGE OF LOW LEVEL RADIOACTIVE WASTE The Secretary of the Commission U.S. Nuclear Regulatory Commission a
Washington, D.C.
20555 Attn:
Docketing and Service Branch March 26, 1993
Dear Mr. Secretary:
On February 2, 1993, the NRC published a proposed rule on "The Procedures and Criteria for On-Site Storage of Low Level Radioactive Waste."
For reasons given below, I urge you not to adopt the proposed rule. The rule is not likely to meet its goal of encouraging the States and compacts to move forward with the development of low level waste (LLW) disposal facilities, and it i
will not increase the protection of the health and safety of the public or the environment.
l Indiana Michigan Power Company operates the Donald C. Cook Nuclear l
Plant in Bridgman, Michigan. As a result of the slow development l
of low level radioactive waste disposal sites, we are storing our l
waste on-site.
The States and compact regions should be encouraged to fulfill their obligations regarding waste storage.
l However, the indirect incentives placed on the licensee are j
neither equitable nor effective. The Low Level Vaste Policy Act and its amendments set milestones and penalties in this indirect manner.
In the discussion of the new rule in the Federal Register Notice, to show compliance with the proposed rules, the NRC would expect each waste generator to make an annual request for access to each operating commercial LLW disposal facility. The documented annual access requests and replies to these requests would have to be retained by the waste generator for three years. If an operating disposal facility has a stated restriction to receiving wastes from a generator, an annual access request requirement on the generator would serve no purpose and would be an unnecessary administrative burden and expense.
For example, since the State
[hf 9304120070 930326 PDR PR 30 58FR6730 PDR l
Secretary of the Commission AEP:NRC:0508W of Michigan has 54 waste generators, each operating disposal site should expect 54 requests from Michigan.
Nationally, the number of requests could easily be greater than 1,000 for each disposal site. It would be a burden for an operating disposal facility to reply to each request.
These disposal facilities will be in States and compact regions that have met the law. The States that need to be encouraged to fulfill their waste storage obligations will not be affected by the proposed rule.
The status of waste generator access to an operating disposal facility will continue to be known by both the regulators and the vaste generators.
The NRC has established a policy discouraging waste storage that can be effectively implemented. Licensees are committed to ensuring that waste storage will neither compromise safe operations nor decrease the level of safety. This commitment can be met without the additional administrative burdens the proposed rule would add.
Sincerely, a
E.
Fitzpa rick Vice President eg
.