Name: Martin L Vyenielo

Organization: Commonwealth of PA

Subject: 180c Review Comment

Please let it be noted: The Commonwealth of PA is a transit state for all shipments of Spent Nuclear Fuel from any of the Nuclear Power Plants in the North East and as such we would like to participate in any pilot program for the 180(c) that may occur. In addition, these comments are from the Commonwealth of PA and may differ than those of the Northeast Council of State Government's High Level Radioactive Waste Transportation Task Force.

Overall the FR notice is agreed to and the following addresses the specific questions raised at the end of the notice:

1.a No, it should be $500,000 based on previous costs of public need/risk assessments.
1.b No, should be based on route mileage, population and both perceived and actual risk.
1.c Yes, annually, $50,000.

2.a Yes and No, it is appropriate for most states west, in the Northeast all shipments must pass through PA and this amount should be raised accordingly to at least $150,000
2.b Yew, however, since this is a very long campaign, the amount may need to be raised as those areas trained replace staff (as much as 33% turnover every two years for volunteers (which 90% of the local responders in PA are volunteers.))
2.c Formula needed for variable amount based on # of shipments within state for each year.
2.d No

3.a No
3.b Yes
3.c 0.10 times the amount allocated to the State where the route occurs.
3.d Yes

4.a At the minimum, 5-6 years would be better, once routes are decided.
4.b Yes
4.c Yes

5.a No, these fees are for security and escort.
5.b They should not.
5.c Yes

6.a It should not.
6.b Funds should be separated, technical assistance should not.
6.c Should not impact SNF shipment allocations, but will impact need for technical assistance due to different routing and transport methods.


Thanks for the opportunity to respond.

Martin L Vyenielo