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',${. 4pd Mr. Thomas G. McCreless Nuclear Regulatory Cotraission Advisory Comittee on Reactor Safegeards Washington, D.C.
20$55 Re:
January 29, 1977 ECCS n;ceting Exxon Nuclear Company, Inc. - Jersey Central Power
& Light Co.
Oyster Creek Nuclear Generating Station
Dear Mr. McCreless:
Please be advised thct I represent Sands Point Harbor, Inc.,
Philip Mai. tone, Wilson T. Crisman and Ruth L. Crisman, who all own property bordering on Oyster Creek in the immediate vicinity of the Oyster Creek Huclear Generating Station, which is owned and operated by Jersey Central Power & Light Co.
Because of their very close proncity to the station, they have c paramount concern that adequate reactor safeguards be imposed at this facility.
My clients'have asked me to submit this written statemant proposing mandatory monetary penalties to i
the Ar'visory Committee on Reactor Safeguards for the Committee's consiceration in determining what recommendations it shall make l
concerning public health and safety.
Hone of my clients is a nuclear scientist nor will they attempt to impersonate one during this proceeding.
The suggestion of mandatory monctcry penalties is intended tG supplement and give added meaning to-the ultimate recommendations made by the Com-mittee concerning the Emergency Core Cooling Systems proposed by Exxon Nuclear Company, Inc.
My clients only wish to assist the Committee to accomplish its mission of protecting the health and e fety of the public.
l My clients have extensively researened the performance record l
of Jersey Cent sl in its operation of the-Oyster Creek Nuclear l
Generating Station.
As a result of their investigation my I
clients have become involved in several administrative proceedings I
in an effort to have meaningful conditions imposed upon Jersey' Central's operating license.
With regard to the station operation l
my clients have a petition pending before the NRC to intervene in proceedings pending before that agency.- In addition,-my clieqts CRS 0:?fice Copy - Remin gIy.G 9203270228 910807 f Q f h } $ b f f @ Q:f ( } @ h Q Q M f Q @ @ t @/
"0 brnynx P. Russo January 21, 1977 m onstr u uw Page 2 3
have already intervened before the EPA concerning Jersey Central's pollution discharge permit.
My clients are presenting issues which do not now concern this Com,nittee and I shall not outline them here.
My clients became involved in those two proceedings because of their concern for the safe operation of the nuclear station in a manner that will not be detrimental to public health, safety and property.
One fact that is very clear in administrative proceedings is that the present. mood of the country to find alternate power sources is causing agencies to sacrifice public health and safety.
In so doing the power companies become the regulators, not the administrative agencies.
The power con.panies are dictating what restrictions should be impost.d, and those conditions they will abide by and those that they will not.
It is time the pendulum swung back in favor of ad-ministrative agencies.
The most frustrating aspect. of the conditions and regulations im-oosed by administrative agencies is that they are seemingly violated ay a power company with little or no consequences.
The public records room ir. repletc with instances where Jersey Central has violated g
conditions imposed on its operating license.
But, in the interest of supplying power, conditions are compromised to the general detri-ment of the public health and safety.
Jersey Central, while being a regulated public utility is nonetheless a profit making organization.
My clients urge the Committee to recommend reasoncble guidelines for a mandatory monetary enforcement procedure.
Such penalties would provide administrative agencies with procedures permitting the enforcement of the conditions thcy impose.
Such penalties would have to be absorbed out of the profits of the company as the Public Utilities Commissioners would net raise Jersey Central's rates to permit the collection of such penalties frow its constimerc.
This incentive system would act to control the arrogant disregard of the regulatory process 1.ow in existence.
My clients intend to seek the imposition of monetary penalties in every adcinistrative forum in uhich they appear, in an effort to make Jorsey Central and other power companies realize that they have a duty to protect the public health and safety.
I we'.:ld respectfully request that the Committee recommend the im-position of monetary penalties for a violation of any limiting con-ditions for operation which are imposed on the Emergency Core Cool-ing Systems.
Such a penalty system will act to put the responsibility for public safety where it belongs,with the company.
In behalf of my clients I thank the Committee for this opportunity to be heard on this matter.
g Ver[trulyJoys.
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SPR:nt EVEN P. RUSEO cc:
Mr. Philip Maimonc Nfs h 0 t al H Et""& Light Co.
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