ML20101T610

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Comment Supporting Proposed Rule 10CFR50 Re Receipt of Byproduct & SNM
ML20101T610
Person / Time
Site: Beaver Valley
Issue date: 07/10/1992
From: Sieber J
DUQUESNE LIGHT CO.
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-57FR15034, RULE-PR-50 57FR15034-00028, 57FR15034-28, NUDOCS 9207210245
Download: ML20101T610 (2)


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bil C57FE /So3y kg Be ver Valley Power Station Stuppmoport. PA 15077 0004 i ULPIII.D (412) 393-52$5 UbHNC 1

29y10,1992

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Vice President Nucieer Group

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Secretary, U.S. Nuclear Regulatory Commis)s onum:i

!"i Washington, DC 20555 Attention:

Docketing and Service Branch

Subject:

Proposed

Rule,

" Receipt of Dyproduct and Special Nuclear Material" 57FR15034 Gentlemen:

Duquesne Light Company (DLC) would like to submit these comments for consideration in response to the Nuclear Regulatory Commission's (NRC) proposal to amend 10 CFR Part 50, " Receipt of Byproduct and Special Nuclear Material,"

as published in the Federal Recrister on April 24, 1992 (57FR15034).

The NRC is proposing to amend its regulations governing the conditions of licenses for production and utilization facilities to allow a reactor licensee to receive back byproauct and special nuclear material that is produced by operating the reactor after that waste has been sent offsite to be reduced in volume by compaction or incineration.

Beaver Valley Power Station (BVPS), like most reactor licensees, utilize offsite vendors for volume reduction services.

At present, the vendors treat the waste (e.g., incineration or compaction) and ship the volume reduced waste directly to the low-level radioactive waste (LLRW) disposal facilities.

Effective January 1, 1993, or anytime thereafter, the industry may be denied access to the existing LLRW disposal facilitiec.

In this case, we would be required by law to take back the volume-reduced portion of the waste.

However, we would not be permicted to receive back the waste under the conditions of the BVPS operating licenses.

The proposed minor amendment would allow operating reactor licensees to continue with already significant efforts to reduce

LLRW, maximize the use of existing storage facilities, ard minimize the need to develop new facilities with no adverse effect on the public health and safety.

Amending Section 50.54 would provide the requisite authorization, eliminate the need to expend the significant NRC and licensee resources required' to review multiple Part 50 license amendment applications and Part 30 license requests, and avoid duplication of effort associated with reviewing such requests on a case-by-case basis.

?207210245 920710 PDR PR 50 57FR15034 PDR

Proposed Rulo, " Receipt of Byproduct and Special Nuclear Material" 57FR15034 Page 2 The Edison Electric Institute Utility Nuclear Waste and Transportation Program (EEI/UWASTE) has prepared comments which strongly endorse the proposed rule.

As a member of EEI/UWASTE, DLC concurs with their comments on the proposed change to 10 CFR 50.54.

We appreciate the opportunity to submit comments on the proposed rule and urge the NRC to promptly adopt the proposed rule as published.

Sincerely,

' t,.

s D.

Sieber o

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