ML20205N032

Comment Supporting Proposed Rule 10CFR150 Re Reassertation of NRC Authority for Approving Onsite Low Level Waste Disposal in Agreement States

ML20205N032
Person / Time
Site:	Yankee Rowe
Issue date:	10/18/1988
From:	Denise Edwards YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR31880, FRN-61FR26852, RULE-PR-150 53FR31880-00024, 53FR31880-24, AC57-1-075, AC57-1-73, AC57-1-74, AC57-1-75, FYC-88-013, FYC-88-13, GLA-88-115, NUDOCS 8811030414
Download: ML20205N032 (2)

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e e wephone (617) 872 8100 TWX T10 390-7619 YANKEE;-

ATOMIC ELECTRIC COMPANY mu FYC8dbO13 GLA 88-115 ys 1671 Worcester Road, Framingham, Massachusetts 0$601%124 Pl2 ;Q6 e

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October 18, 1988 CMii 2 c 41.

Secretary of the Commission 00c 0"re.)

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J(- _ __L U. S. Nuclear Regulatory Commission Washington, DC 20555 MFQfg L

Attention Docketing and Service Branch

Subject:

Proposed Rule Regarding Reassertion of NRC Authority for Approving Onsite Iow Level Waste Disposal in Agreement States (53FR31880)

Dear Sir Yankee Atomic Electric Company (YAEO) appreciates the opportunity to comment on the proposed rule which reasserts NRC authctity over onsite low level vaste disposal. YAEC owns and operates a nuclear pwer plant in Rowe, Massachu-setts. Our Nuclear Services Division also provid9s engineering and licensing services to other nuclear power plants in the Northeast, including Vermont Yankee, Maine Yankee and Seabrook.

The EEI Utility Nuclear daste Management Group (UNWMG) is filing a detailed response to the subject NRC proposed rule. YAEC is an acti'le member of UNWMG and, in general, endorses its comments. We would also lik' to take this opportunity to add the following observation.

We strongly endorse the reassertion of NRC authority for approving on-site low level waste disposal. The NRC's June 1988 policy statement concerning "Coop-eration with States at Commercial Nuclear Power Plants and Other Nuclear Production and Utilization Facilities (53FR21981)" specifically mentioned 4 concern that "independent" state regulatory activities 4ould misdirect a' licensee's attention in a mannet inconsistent with NRC safety requirements.

The resulting misinterpretation of NRC safety requirements could have the effect of dual regulations. We believe that this concern is valid and, ap-plies in particular, to regulation of the disposal of radioactive vastos. The issue of proper disposal of radioactive vastes is one which needs dispassion-ate, inforced technical analysis and consistency of approach. We believe that 8011030414 001010 P gyg3gggo PDR D 6t u c ,-

.. o Secretary of the Commission Page 2 October 18, 1988 the NRC is better equipped to perform this regulatory function than state and/or local officials. We, therefore, endorse this proposal.

Very tru'.y yours, Donald W. Edwards Director Industry Affairs JMG/daa J

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