ML19207B826
| ML19207B826 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/12/1979 |
| From: | Roisman A National Resources Defense Council |
| To: | Salomon S NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 7909050333 | |
| Download: ML19207B826 (2) | |
Text
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Natural Resources Defense Council,Inc.
917 15TH STREET, N.W.
WASHINGTON, D.C. 2 coo 5 202 737-5000 Westem 0$ce Neur York 0@ce 2345 YALz sTRzzT
- zAST 42ND STRzZT PALO ALTO, CALIF. 943o6 June 12, 1979
= vonx. 3 Y tai 7 455 337-8080
- 949-ugg Steven N. Salomon Sta9e Program Officer Nuclear Regulatory Commission Washington, D.C.
20555
Dear Dr. Salomon:
This letter is in response to the receipt of NUREG-0553 (Draft), dated March 30, 1979.
I have not had an opportunity to read the entire report in depth, but one factor which immediately struck me was the question of the funding of the proposed upgrading of emergency preparedness which you recommend.
It seems to me that, rather than the limited assessment of these additional costs on the utilities operating the plant, the entire assessment of the additional costs should be imposed on the utilities operating the plants.
Unless this is done, there will be a failure to properly internalize an external cost associated with the operation of a nuclear facility.
If I understand the thrust of your report, it is that an important ingredient for the Nuclear Regulation Commission to be able to conclude that the operation of a nuclear plant provides a reasonable assurance of adequate protection of the public health and safety is the existence of adequate emergency preparedness.
Certainly that conclusion is one with which we are in complete agreement.
If that is so, then the cost for the NRC to be able to make that finding is the cost of providing such emergency oreparedness.
Pursuant to Title 31, U.S.C.,
S 483a,
the NRC is required to recoup the cost of processing and approving applications for licenses for nuclear plants.
It would therefore appear that, so long as the NRC is itself funding the upgraded emergency preparedness as a part of being able to make a reasonable assurance finding, it would be permissible, if such a finding is made, to impose the full cost of such emergency preparedness on the utility.
Even if there is some question about existing au hority to impose the costs on the utility, I would think it would be desirable for the NRC to affirmatively recommend that all such costs be imposed upon the utility.
It should not o a o m.s U,84)*e'i()
4:s gQiIb
Steven N. Salomon, Ph.D.
June 12, 1979 Page Two be the case that the financial difficulties of a local community would inhibit the implementation of the necessary emergency preparedness plan or the continued viability of such a plan once implemented.
There is a related question which you -address directly in your paper, and that is the question of whether plants which now do not have adequate emergency preparedness plans should be allowed to continue to operate (p. I-2).
As you may know, this has been the subject of comments filed by the Natural Resources Defense Council and Citizens for a Better Environment upon which essentially no action has been taken by the Staff.
(In the Matter of Appendix E --
Emergency Plans For Production and Utilization Facilities:
Natural Resources Defense Council and Citizens for a Better Environment Comments on Proposed Amendment to Appendix E to 10 CFR Part 50.)
For your convenience, I am enclosing a copy of those comments and requesting that you attempt to encourage the powers that be within the Staff to provide an answer to the comments, particularly an answer in line with the findings of your report --
i.e.,
that without adequate emergency preparedness a nuclear plant should not be allowed to operate.
Sincerely,
~
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enclosure
~m f few t
Anthony /.' Roisman a e o c.. -
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