ML20196F594

Comment Supporting Proposed Rule 10CFR62 Re Emergency Access to Low Level Radwaste Disposal Sites.Believes Proposed Criteria Well Developed & Will Be Effective in Maintaining Control of Amount of Radwaste Sent to Sites

ML20196F594
Person / Time
Site:	Peach Bottom
Issue date:	02/24/1988
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-52FR47578, RULE-PR-62 52FR47578-00019, 52FR47578-19, AC24-2-21, NUDOCS 8803040127
Download: ML20196F594 (1)

Text

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DOCKET NUMBER PROPOSED RULE PR a n '

(52 FL 4'7$9P)

PHILADELPHIA ELECTRIC COMPANY gmc;ct, 2301 MARKET STREET P.O. BOX 8699 3 FEB 29 41:40 PHILADELPHI A, PA.19101 (215) 841 45co FJCt, g; St J, tit.e -

CMEi % /.SEWICf' JOHN S. KEMPER hkdNCy CINIO R VICE PRESIDENT NUCLE AR February 24, 1988 Mr. Sanuel J. Chilk Secretary of the Ccmnission U. S. Nuclear Regulatory Ccmnission Washington D.C. 20555 Attention: Docketing and Service Branch

SUBJECT:

Proposed Rule on Emergency Access to Low-Level Radwaste Disposal Sites

Dear Mr. Chilk:

Notice of a proposed rule on anergency access to non-federal Icw-level radwaste disposal facilities appeared in the Federal Register on December 15, 1987. Philadelphla Electric Ccrmany believes that the proposed criteria for allcwing anergency access to disposal sites are well developed and will be effective in maintaining control of the amomt of radioactive waste sent to such sites. One aspect of this process, however, may prove to be a detriment to its snooth acininistration: the 10-day pubile conment period.

If a situation is truly an emergency, delaying the disposal of waste may result in an increased hazard to pubtle health and safety.

Additionally, the current climate of pubile awareness and tendency towards legal intervention could corrbine in action aimed at the cessation of the generation of waste (i.e. the shutdown of the generator). Another method to keep the pubile Infonred should be developed: perhaps a periodic pubilcation of all petitions for anergency access, and the results of each.

We are confident that the proposed criteria are strict enough to protect the pubile health and safety without delaying the process to consider public concerns for each occurrery:e.

ACC/kan/02128802 0 127 880224 62 52FR47578 PDR D5/O k,Y: N k.<'i!)bk ///6 - lh 0 ft.AR 1 BBB Acknowfedad b9 cud,7=.,,,,.,,,

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