ML100350392
| ML100350392 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/21/2010 |
| From: | Blumenthal R State of CT, Office of the Attorney General |
| To: | Leeds E Office of Nuclear Reactor Regulation |
| References | |
| FOIA/PA-2011-0115 | |
| Download: ML100350392 (3) | |
Text
State of Connecticut RICHARD BLUMENTHAL ATTORNEY GENERAL U._
Har~yý1 January 0
Mr. Eric Leeds Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555-.00.0.
Re: Reduction in Staff at Millstone Nuclear Power Station
Dear Director Leeds:
I write to urge the Nuclear Regulatory Commission ("NRC") to exercise its regulatory authority ;to.,carefully overs.ee.Dominion Nuclear Connecticut's plan to significantly reduce its workforce atý Millstone Nuclear Power station in Waterford,. Connecticut and to require the companyeto maintain full staffing.e.
n roompersonne.
As chief legalofficer of the State of Connecticut, rplis jo seek fUll protection for Connecticut's citizensunder state and fedeal aw.' Primanry respoisibijlity for regulating the nuclear power indust'ry lies with ihe NRTC. In particular, Section 161(b)-of the Atomic Energy Act ("AEA") empowers the Nuclear Regulatory Commission to "establish rule[s], regulation[s], or order[s]" to "protect health or to minimize danger to life or property."
42 U.S.C. § 2201(b), (i). The AEA prohibits the NRC from issuing a license to operate a nuclear power plant if it would be "inimical to the common defense and security or to the health and safety of the public." 42 U.S.C. § 2133(d).
Published news reports indicate that Dominion currently has 1,285 employees at Millstone and will offer voluntary buyouts to as many as 550, with the intention to reduce its overall workforce by 200 workers. The company's deeply troubling plan would reduce its workforce by almost 18% at one stroke. The security and safety of Connecticut's citizens should be the first priority of Dominion and the NRC. Any plan that could potentially reduce safety, security or emergency personnel.or staff of the control room or other vital facilities is flatly unacceptable. Many thousands of Connecticut's citizens livewithin the 1o0 mile emergency evacuation;,zoneý around. Millstone and essentiallyallý.of Conýecticut lies"within the 5Oimiie ingestion pathway zone around the facility. Any release of radioactive materia-l fro6m Millstone (would:immediately.impact residents, of the state-and thevital natural resourcpe, sof Long Island
.:Soundi KMillstOne has: been, o
many years and has.recenily hd its operating license extended for another.20 years.-
The law is clear. NRC has the authority to require more than the minimum of protection to the public. In fact, one court has said that the NRC's authority to protect the public
... cannot be read simply to permit the Commission to provide adequate protection; another section of the Act "requires" the Commission to do that much.
We therefore must view section 161 as a grant of authority to the Commission to provide a measure of safety above and beyond what is "adequate." The exercise of this authority is entirely discretionary. If the Commission wishes to do so. it, may order power plants already satisfying the standard of adequate protection to take additional safety precautions. I Public safety is the first, last, and a permanent consideration in any decision on the issuance of a construction permit or a license to operate a nuclear facility. Power Reactor Development Corp. v. International Union of Electrical Radio and Machine Workers, 367 U.S. 396, 402 (1961). High population density in Connecticut and the unique location of Millstone on Long Island Sound clearly require that the NRC exercise its discretionary power to require Dominion to maintain a full complement of emergency response, security and control, room personnel.
Thank you for your attention to this matter.
Sincerely RICHARD BLUMENTHAL
' Union of Concerned Scientists v. NRC, 824 F.2d 108, 110 (D.C. Cir. 1987).
0 Attorney General 55 Elm Street Hartford, Connecticut 06106 RU>
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- MAILED FROM ZIPCCODE 61 06 Mr.
Eric Leeds Director Office of Nuclear Reactor Regulation U.S.Nuclear Regulatory Commission Washington, DC 20555-0001