ML12200A414

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Comment (229) of Kimberly L. Prosser on Behalf of Brevard County Emergency Management, on PRM-50-104 Regarding Emergency Planning Zone
ML12200A414
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 07/16/2012
From: Prosser K L
Brevard County, FL, Emergency Management
To: Bladey C K
Division of Administrative Services, NRC/SECY/RAS
SECY RAS
References
NRC-2012-0046, 77FR25375 00229, PRM 50-104
Download: ML12200A414 (3)


Text

Page 1 of 1 As of: July 16, 2012 Received:

July 16, 2012 AA9 PUBLIC SUBMISSIONengost PUBL C S BMIS IONTracking No. 81-09c0 14 Comments Due: July 16, 20 Submission Type: Web Docket: NRC-2012-0046 Petition for Rulemaking Submitted by Nuclear Information and Resource Service and Multiple Co-Petitioners

-Expansion of Emergency Planning Zone Comment On: NRC-2012-0046-0003 Emergency Planning Zone; Notice of Receipt and Request for Comment Document:

NRC-2012-0046-DRAFT-0175 Comment on FR Doc # 2012-10314 12 Submitter Information Name: Kimberly Prosser Address: Brevard County Office of Emergency Management Rockledge, FL, 32955 Submitter's Representative:

Debbie Coles Organization:

Brevard County Office of Emergency Management Government Agency Type: Local Government Agency: Brevard County Board of County Commissioners/

Local Government General Comment See attached letter.Attachments BCOEM comment to Docket ID NRC-2012-0046 https://www.fdms.gov/fdms-web-agency/component/contentstreamer?objectId=09000064...

07/16/2012 BOARD OF COUNTY COMMISSIONERS F S C FLORIDA'S SPACE COAST -'OFFICE OF EMERGENCY MANAGEMENT (321) 637-6670 1746 Cedar Street Fax: (321) 633-1738 Rockledge, Florida 32955 www.embrevard.comC July 16, 2012 Ms. Cindy Bladey Chief, Rules Announcement and Directives Branch Division of Administrative Services Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Docket ID NRC-2012-0046

-Petition for Rulemaking 50-104

Dear Ms. Bladey,

Brevard County Office of Emergency Management appreciates the opportunity to provide comments on the above referenced petition as noticed in the Federal Register on April 30, 2012, The petition was filed with NRC by Mr. Michael Mariotte and was dated February 15, 2012. The petition was filed on behalf of the Nuclear Information and Resource Service (NIRS) and 37 co-petitioners.

In summary, the petitioner requests the NRC amend its regulations to expand the Emergency Planning Zones (EPZs) for nuclear power plants in the United States.Brevard County is part of the St. Lucie Nuclear Power Plant Taskforce and is a host to evacuees should the situation arise.This Office supports the opinions on this petition by the Nuclear Energy Institute and the State of Florida. Further, this Office recommends that the NRC deny the petition because the petitioner failed to provide adequate justification to support a modification to the current rule.Brevard County takes the "All-Hazards" approach to emergency management and follows the principles of the National Response Framework, National Incident Management System (NIMS), and Incident Command System (ICS). The "All Hazards" approach allows for ease of scalability, thereby allowing response activities to quickly expand or contract based upon the circumstances.

The development and implementation of the NIMS/ICS under the National Response Framework has enhanced response capabilities and provides for prompt and effective protective measures for all populations that may be affected.In conclusion, recent Department of Homeland Security policies and initiatives have provided a solid basis for implementing the ad hoc expansion of Protective Actions for Nuclear Power Plant Emergencies as described in the planning basis, NUREG-0396.

Based upon implemented changes from the Post 9-11 and Post Katrina initiatives, the Radiological Emergency Preparedness community in Florida exceeds the necessary resources and protocols to expand Protective Actions beyond the current EPZs in order to reduce public health risks from radiation exposure.

Therefore, the consideration of expanding the EPZ is in my professional opinion not required.Sincerely, (L Brevard County Office of Emergency Management PRINTED ON RECYCLED PAPER Rullemaking Comments From: Sent: To:

Subject:

Attachments:

Gallagher, Carol Monday, July 16, 2012 4:24 PM Rulemaking Comments Comment on PRM-50-104 NRC-2012-0046-DRAFT-0175.pdf Van, Attached for docketing is a comment from Kimberly L. Prosser, Brevard County, on the above noted PRM that I received via the regulations.gov website on July 16, 2012.Thanks, Carol