ML20085H833

Comment Supporting Proposed Rule 10CFR50 Re NRC Proposed Amend to Policy Statement Concerning Cooperation W/States at Commercial Nuclear Power Plants

ML20085H833
Person / Time
Site:	Vermont Yankee
Issue date:	10/23/1991
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-56FR41968, RULE-PR-50 56FR41968-00004, 56FR41968-4, BVY-91-106, NUDOCS 9110290032
Download: ML20085H833 (2)

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< u o, m m v o,em m October 23, 1991 U.S. Nuclear Regulatory Commission Secretary of the Commission Washington, DC 20555 Attention: Docketing and Service Branch

Subject:

Comments on NRC Propose _d Amendment to Policy Statement Concerning Cooperation with States at Commercial Nuclear Power Plants Vermont Yankee Nuclear Power Corporation appreciates the opportunity to comment on the subject polley statement. Vermont Yankee is the owner and

- operator of a nuclear power plant located in the southern part of the State-of Vermont and our Emergency Planning Zone (EPZ) extends into two adjacent -

states New Hampshire and Massachusetts..

. Vermont Yankee endorses the concept of the current- policy of NRC.

communication and cooperation with State governments on issues relating to the regulation of commercial nuclear power -plants. We are, however, concerned with the direction the Commission is contemplating-with ihn implementation of the Proposed Polley Change. -

Vermont Yankee encouragos the process of open communications with members of adjacent States. . iowever .we- firmly believe that the host State deserves special consideratlon and, for this purpose we have: established- a Memorandum of Understanding (MOU) with the State of Vermont for the purpose of _ providing a mechanism to facilitate ongoing communications of both routine as well as off normal situations. The state of Vermont also has a formal agreement with the NRC relating to state participation in inspection activities at the ' Vermont Yankee plant. Consistent w th the MOU, we nave established.a

. position .of State ~ Liaison Engineer within Vermont Yankee whose role -is to communicate daily and to meet weekly with the State of Vermont representatives.

Extending the courtesies presently afforded to -host states to additional representatives of adjacent states.will certainly increase the t,urden on the NRC and potentially diminish the effectiveness of NRC inspections as wall as place an additional burden on plart staff and facilities.

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, VERMONT YANKEC NUCLC AR POWER CORPOR ATION U.S. Nuclear Regulatory Commission October 23, 1991 Pago 2 This proposed chango will, undoubtodly increase the timo and effort of NRC aorsonnel to train and interact with Stato inapoctors and resuh in unjusti' lod additional cost billod to licenseos, in addition, it ic not difficult to foresco competition developing between host and nolghboring stato inspectors which could degrado the relationship betwoon one of the states and the NRC '

or the Utility, in conclusion, wo urgo the Commission to reconsider its proposed policy change and, continuo to recognizo the priorities of the holt stato and encourage the ad acont states to communicate with host state representativos on mattors portain'ng to the operation of host stafo nuclear power plants.

Very truly yours, Vermont Yankoo Nuclear Power Corporation

& # n'hm Q Warron P. Mu,rphy Senior Vice President, rpcions at cc: USNRC Region 1 Administrator USNRC Resident inspector VYNPS USNRC ProJoct Manager VYNPS USNRC Document Connol Desk

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