PLA-4193, Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety

Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety

ML20072S517
Person / Time
Site:	Susquehanna
Issue date:	08/31/1994
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR30308, RULE-PRM-9-2 59FR30308-00024, 59FR30308-24, PLA-4193, NUDOCS 9409140112
Download: ML20072S517 (2)

Text

. . . -

p N

PPat. Pennsylvania Power &. Light Compg._gy, ;ap,

. _ _ - - - .. - . _ - L ,., o .

c ,

Two North Ninth Street e Allentown, PA 18101 1179

• 610/774-515% !-

94 SEP -7 P 3 $_5 ,

Robert G. Byram Senior Vice President-Nuclear $

x 610/774 5019 ( 51F R 303@) yh ,

AUG 311994 Mr. John C. Hoyle, Acting Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTN: Docketing and Service Branch SUSQUEllANNA STEAM ELECTRIC STATION COMMENTS TO "O1110 CITIZENS FOR RESPONSIBLE ENERGY: PETITION FOR i RULEMAKING (PMR-9-2) Docket Nos. 50-387 '

FILE R41-2/A17-11 and 50-388

( PLA-4193 i

Dear Mr. Hoyle:

l l

Pennsylvania Power and Light Company (PP&L) endorses the comments submitted by the Nuclear Energy Institute (NEI) for the Federal Register notice concerning the Petition for Rulemaking ,

(PMR-9-2) submitted by the Ohio Citizens for Responsible Energy (.OCRE) requesting that NRC l revise its regulations (10CFR9) to provide public access to information that is held by licensees but not submitted to the NRC (59FR30308). PP&L along with NEI urges NRC to deny OCRE's l l '

petition in its entirety.

l PP&L's comments, which are similar to those being submitted by NEl, are as follows: l 1

• PP&L believes that NRC's responsibility is to perform an oversight function to ensure the safe operation of nuclear power plants to protect the public h. 'th and safety. NRC therefore to a large degree represents the public interest.' OCRE l provides no evidence that the suggested changes to 10CFR9 are necessary to ensure that the NRC responsibly represents the public or that additional public oversight of i the NRC and their licensees, through massive document requests, is necessary to further public health and safety.

l l

I 9409140112 940831

, PDR PRM PDR l

'~

- -- - -- " ~ SHD

i l

l FILES R41-2/A17-11 PLA-4193 Mr. John C. Iloyle a PP&L believes that NRC does not have the statutory authority to mandate public 1 disclosure of licensee-held documents. The three Acts (The Freedom of I Information Act, The Privacy Act and The Govenunent in the Sunshine Act) which allow for public disclosure of information prevent NRC from granting OCRE's petition.

• Existing statutory and regulatory mechanisms reflect a sound public policy for determination of the most appropriate balance between the public's "right to know" and the rights of private entities (NRC licensees) to conduct their business.

• NRC has recognized that in some areas it is not necessary for licensees to provide the NRC with specific data, but rather that this data be maintained at the licensee's facility. This position remains appropriate and should be maintained.

• The proposed petition would create a significant administrative and cost burden to licensees to implement without a substantive corresponding benefit to the public.

PP&L appreciates the opportunity to comment on the OCRE petition (PMR-9-2).'

l Very truly yours, s 0 R. ,

l cc: NRC Document Control Desk (original) l NRC Region 1 Mr. D. J.Mannai, NRC Resident inspector - SSES l

Mr.C. Poslusny, Jr., NRC Sr. Project Manager t

l l

! l