ML20058E064
| ML20058E064 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 11/10/1993 |
| From: | Denise Edwards YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR48080, RULE-PR-MISC 58FR48080-00004, 58FR48080-4, NUDOCS 9312060148 | |
| Download: ML20058E064 (2) | |
Text
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YANKEE ATOMICELECTRIC COMPANY
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580 Main Street, Bolton, Massachusetts 01740-1398 "f37 93 m 15 P2:55
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(NM November 10, 1993 FYC 93-025 SPS93-109 i
I Secreta ry U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Docketing Service Branch I
Subject:
Proposed Policy Statement on Staff Meetings Open to the Public (58FR48080)
Dear Sir:
Yankee Atomic Electric Company appreciates the opportunity to comment on the proposed policy statement on public meetings.
Yankee is the owner of the i
Yankee Nuclear Power Station in Rowe, Massachusetts and provides engineering and licensing services to other nuclear power plants in the northeast, including Vermont Yankee, Maine Yankee, and Seabrook.
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i We believe that the NRC has done well in their commitment to provide the f
public with the fullest practical access to its activities.
The current Commission has emphasized, repeatedly, the importance of ensuring public
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involvement as the staff exercises its regulatory and safety responsibilities.
We agree with and support public openness in regulation and believe that l
current guidance provides the necessary balance for the NRC staff to function and still continue to meet its openness goals.
r The proposed revised policy represents, in our view, an unnecessary and.
inappropriate addition of another administrative burden to the workload of j
every technical member of the staff.
While allegedly being focused at t
" planned formal encountt.rs." the policy. we believe, will create yet another i
barrier in the minds of the staff when an attempt is made by licensees to meet with an individual staff member relative to technical or procedural information. The added policy appears as, potentially, a major impediment;to.
l the exchange-of information that is so vital to the proper. conduct of the j
regulatory process.
This proposed policy could well constitute a barrier that will prevent meetings from being held on a short notice to resolve issues of immediate concern and will further serve to delay interaction that is.
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appropriate.
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9312060148 931110 i
PDR PR
-i MISC 5BFR48080 PDR r
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.I Secretary November 10, 1993 U.S. Nuclear Regulatory Commission Page 2 It has been our experience that the rather rigorous process for production of public announcements has resulted in notification of some meetings being published either exactly on the day of the meeting or so close to the date that participation in the meeting would have been impossible.
Two recent examples are 58FR57636, " Meeting with BWR Owners Group on IGSCC Inspector Training and Qualification Requirements." which occurred on October 26 and was announced that date also and 58FR54531, " Discussion of 1
Upcoming Regulations and Revisions" which took place on October 25 and was announced in the October 22 issue which we received on October 26.
The point is that this occurs f airly frequently and such information merely clogs an already full Federal Register system. More notices (the result of this l
policy) will not necessarily provide better public involvement.
Finally, this proposal represents another non-safety overhead activity which will siphon resources away from focus on safety and regulatory responsibilities.
It will merely serve to increase agency costs at the expense of licensees under the 100% user fee policy at a net loss in regulatory effectiveness and with no public benefit.
We urge that the proposal be abandoned.
Sincerely, S
Donald W. Edwards Director Industry Affairs DWE/dhm f
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