ML20151G003

Comment on Proposed Rule 10CFR50 Re Cooperation W/States at Commercial Nuclear Power Plants & Other Facilities. Suggests Rev to Policy to Grant Same Rights & Responsibilities to All States within 10 Miles of Plant

ML20151G003
Person / Time
Site:	Calvert Cliffs, Peach Bottom, 05000000
Issue date:	07/19/1988
From:	Magette T MARYLAND, STATE OF
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR21981, RULE-PR-50 53FR21981-00019, NUDOCS 8807280074
Download: ML20151G003 (2)

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DOCKET NUMBER Dp -

PROPOSED RULE E L 50 (DPRh9W Maryland Department of Natural Resota.Wi:

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C Energy Administration - Power Plant Researeb Program

./ m Tawes State Office Building Annapolis, Maryland 21401 88 n 21 P2 35 (301) 974-2261 William Denald Schaefer Gowrnor

) $y t., % . Torrey C. Brown, M.D.

Sw rtary July 19, 1988 Samuel J. Chilk, Secretary Nuclear Regulatory Commission Dockriting and Service Branch Washington, D.C. 20555

Dear Mr. Chilk:

Representatives of the Maryland Department of Natural Resources and Department of the Environment have reviewed the Nuclear Regulatory Commission's Policy Statement, "Cooperation With States at Commercial Nuclear Power Plants and Other Nuclear Production or Utilization Facilities." The following comments are offered for your consideration.

The Policy Statement makes several references to notification which can or will be made to the State Liaison Officer. The State of Maryland has no problem with the existing State Liaison Of ficer program, and no objection to most routine notifications being made to the State Liaison Of ficer. However, there may be cases, the ongoing review of the shutdown of the Peach Bottom Atomic Power Station being one notable example, where the principal contact within the State of Maryland is not the State Liaison Officer. Our only concern is to ensure that the Policy Statement is not intended to preclude future instances where the Governor may desire to select a principal contact other than the State Liaison Officer for interaction with the Commission.

It is our understanding that the Commission has directed its staff that the rights and responsibilities granted to the states under the Policy Statement are extended only to host states. The State of Maryland strenuously objects to this policy.

The scope cf our review and activities (e.g., radiological monitoring and emergency planning) for the Calvert Cliffs Nuclear Power Plant, located in state, and the Peach Bottom Atomic Power Station, located out of state, are virtually identical. The location of Peach Bottom only 3 miles north of the Maryland Pennsylvania border necessitates that this be the case. Any impact f rom the operation of this plant, whether environmental, public health and safety, social or political would be no different if the plant were located a few miles south within the state's borders.

f r Dean 3m3m 8007280074 000719 hs,b PDR PR 50 53FR21981 PDR

At least one of the readons for our level of activity at Peach Bottom is the NRC's own requirement concerning radiological emergency planning for states within 10 miles of operating reactors. This requirement does not distinguish between a host state and one three miles downstream. We therefore do not believe that the NRC's Policy Statement should make such a distinction.

We suggest that the NRC's implementation of this policy be revised to grant the same rights and responsibilities to all states within 10 miles of a nuclear power plant. We do not believe this places an unreasonable burden on either the NRC or the licensee. This aspect of the policy should also be clearly stated in the Policy Statement.

Thank you for the opportunity to provide these comments.

Sincerely, 4 <

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Thomas Mage t , Administrator Nuclear Eva untions TM/rva cc Paul Perzynski, MDE

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