ML19207B748
| ML19207B748 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/14/1979 |
| From: | Antoinette Lewis GENERAL SERVICES ADMINISTRATION |
| To: | Ryan R NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 7909050196 | |
| Download: ML19207B748 (2) | |
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Mms 2::cn Agency Wasrmgtcr. CC Z~-:5 MAY 1 4 7979 Mr. Robert G. Ryan, Director Office of State Programs U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Ryan:
Thank you for asking James Thomas to co'mment on your draft report " Cost and Funding of State and Local Government Radiological Emergency Response Plans and Preparedness in Support of Commercial Nuclear Power Stations."
Although the draft report is quite detailed, it is silent on several points which might well be discussed.
- First, the report recommends increased licensing fees as a method of funding State and local planning.
This change would require legislation which may take some time.
Consequentl this report should also discuss the feasibility of using, y, at least on an interim basis, funds derived from existing fees for construction permits and operating licenses.
Second, the report should consider the possible effect of the recommendation that all State and local government plans must have NRC concurrence before NRC grants an operating license.
Such a requirement would enable any State or local government to defer or prevent the operation of a power plant.
With the current level of public opposition to nuclear power, a public utility would be extremely re-luctant to undertake construction of a nuclear power plant when faced with the possibility that just one local govern-ment could prevent the operation of that facility.
In addition, if such a prerequisite were imposed, would it be retroactive to a power plant now in operation?
If a local or State government failed to develop an acceptable plan, would NRC be prepared to withdraw its operating permit even if the power plant (s) was needed to prevent power shortages?
Third, the entire report appears to be based on the assumption that there are no reasonable alternatives to 100 percent Federal funding of State and local radiological emergency response planning.
If the report does, in fact, make such an assumption, we have scme trouble with it.
State and local governments still have primary responsibility for the safety of the people.
Mcwever, the feasibility of using "LQC9000 I (/
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money from public utilities to fund local planning, without being funneled through the Federal Government, should be discussed in this paper.
The calculations used to arrive at estimated costs of de-veloping the required plans appear to overlook several factors which could substantially reduce these costs.
For example, the draft report recommends training for two sets of State survey teams (page II-61) to pemnit relief of these teams every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
However, no mention is made o.' Federal monitoring teams which would certainly be on the sceae within a few hours.
Likewise, the cafculations of total costs for State and local governments (pages II-70 & 71) gives no consideration to the fact that s.everal states already have plans with NRC concurrence.
In addition, many of the 65 power plants which will be coming on line in the future will not require a full scale planning effort since they wi'll be located on the same site with existing plants.
In summary, the material presented in this report provides con,siderable background data useful in future decision-making.
However, as we have observed above, you may wish to review and refine some of the ideas and cost estimates contained in this report.
Sincerely, h',0 LL Ma Arnold C.
Lewis-Acting Chief Resources Management Division
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