ML101370622

Comment (12) of Mike Rose, on Behalf of Interjurisdictional Planning Committee, on NRC-2010-0080-0001, NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3, Guidance for Protective Action Recommendations for General Emergencies; Draft for Comment

ML101370622
Person / Time
Site:	San Onofre
Issue date:	05/12/2010
From:	Maret Rose Interjurisdictional Planning Committee
To:	Rulemaking, Directives, and Editing Branch
References
75FR10524 00012, NRC-2010-0080-0001, NUREG-0654/FEMA-REP-1, Rev 1, Suppl 3
Download: ML101370622 (3)

Text

6'Page 1 of 1 As of: May 13, 2010 Received:

May 12, 2010 PL C AV% &I4 9XV4 64 Status: Pending-Post PUBLIC ISSIObN Tracking No. 80aebfe2 Comments Due: May 24, 2010 ISubmission Type: Web Docket: NRC-2010-0080 Notice of Availability of NUREG-0654/FEMA-REP-1, Revision 1, Supplement 3, Guidance for Protective Action Recommendations for General Emergencies Comment On: NRC-2010-0080-0001 NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3, Guidance for Protective Action Recommendations for General Emergencies; Draft for Comment Document:

NRC-2010-0080-DRAFT-0014 Comment on FR Doc # 2010-04878 Submitter Information Name: Mike Rose Address: 33282 Golden Lantern Dana Point, CA, 92629 Organization:

Interjurisdictional Planning Committee Government Agency Type: Local Government Agency: City of Dana Point (7-)FT]t N)F-Fri Cl)General Comment Please see the attached IPC letter to the NRC in reference to Docket NRC 2010-0080 Attachments NRC-2010-0080-DRAFT-0014.1:

Comment on FR Doc # 2010-04878

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05/13/2010 JInterjurisdictional Planning Committee County of Orange-County of San Diego-City of San Clemente-City of San Juan Capistrano City of Dana Point°California State Parks°U. S. Marine Corps-Southern California Edison May 4, 2010 Gregory B. Jaczko, Chairman U.S. Nuclear Regulatory Commission Mail Stop O-16G4 Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff

Subject:

Comment on Proposed Rulemaking.NRC Docket ID: NRC-2010-0080

Dear Chairman Jaczko;On March 8,

2010, the U.S. Nuclear Regulatory Commission (NRC) published NUREG-0654/FEMA-REP-1, Rev. 1, Supplement 3, "Guidance for Protective Action Recommendations for General Emergencies; Draft Report for Comment." Please accept the following comments relating to this report from the San Onofre Nuclear Generating Station (SONGS) Interjurisdictional Planning Committee (IPC).1. The IPC is requesting an extension to the posted comment period to a date no earlier than June 25, 2010. The IPC requests that at least one additional public meeting be conducted in early June in a location accessible to most stakeholders.

2. We would request that the NRC coordinate with FEMA to have the appropriate FEMA Radiological Emergency Preparedness program representatives present at the public meeting(s).

Due to actual or perceived cross cutting issues effecting Offsite Responding Organizations (ORO) and licensee pre-emergency coordination and emergency protective action decision making, it is imperative that FEMA be engaged in this process with the stakeholders.

3. The IPC has long been a supporter and proponent of active ORO-Licensee relationships as we believe this is the best way to protect the public's health and safety during a radiological emergency.

However, we also believe that our Federal partners must continue to work together to support these relationships by providing logical and reasonable guidance supporting the clearly defined oversight roles of FEMA and the NRC over the OROs and Licensees respectively.

Many of the proposed requirements in this supplement require the licensee to establish plans that clearly fall into the offsite emergency response arena, and may result.in unintended consequences during an actual emergency.

Further, offsite jurisdictions are not subject to NRC regulations and guidance and will not be required to implement changes being imposed upon licensees.

I would encourage the NRC to address these concerns and others in additional public meetings with offsite stakeholders and FEMA representation present to share their interpretation of these proposed changes and the potential results.Sincerely, Mike Rose Director of Disaster Preparedness, City of Dana Point Chairman, SONGS IPC The SONGS Interjurisdictional Planning Committee (IPC) is made up of representatives from the Offsite Responding Organizations in the Emergency Planning Zone of the San Onofre Nuclear Generating Station. These agencies include the Counties of Orange, and San Diego, the Cities of San Clemente, Dana Point, and San Juan Capistrano, the Marine Corps Base Camp Pendleton, and the California State Parks.c: Commissioner Kristine L. Svinicki Commissioner George Apostolakis Commissioner William D. Magwood, IV Commissioner William C. Ostendorff James R. Kish, Director Technological Hazards Division, FEMA