ML19257C316
| ML19257C316 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 11/20/1979 |
| From: | Mathews E WISCONSIN PUBLIC SERVICE CORP. |
| To: | Ryan R NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| RTR-NUREG-0553, RTR-NUREG-553 NUDOCS 8001280328 | |
| Download: ML19257C316 (3) | |
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WISCONSIN P U B LIC S E RVIC E CO RPO R ATIO N P.O. Box 1200, Green Bay, Wisconsin 54305 Nove::ber 20, 1979 Mr. R. G. Ryan, Director Office of State Programs U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Ryan:
Decket 50-305 Operating License DPR-43 NUREG-0553, Bevond Defense In-Depth The subject report has been reviewed by our Corporate Nuclear Licensing Staff.
As a result of this review the following comments are submitted:
I.
Exhibit li, Examole 12 Errors The su= mary of utility assistance provided to Wisconsin state and local govern:mnts for radiological emergency response plans and preparedness is not correct. As a minimum, WPSC and WEPCo. have provided assistance to state and local governmental agencies in the development of general emergency plans and detailed i=plementing procedures.
Additionally, training in the handling of radioactively contaminated personnel is provided to local hospital personnel on an annual basis.
I have attached for your information a more detailec summary of assistance that WPSC has provided.
II.
Proposed Funding Method Emergency planning is necessary for any potential threat to the health of the general public; this applies to threats from natural disasters, transportation or industrial accidents involving lethal or volatile chemicals, or accidents at nuclear power plants. Over the years many people have been lost to natural disasters or transportation accidents (seventeen fatalities occurred in two 1977 train de-railments involving tankcars; evacuation of tens of thousands of people resulted most recently in Torento from a train de-railment) while no member of the general public has been physicall harmed as a result of a nuclear power plant accident.
Since many emergency procedures developed for radiological emergency responses are directly applicable to other situations, it is inappropriate 1819 143 p[nfua lC 3aV
' Mr. R. C. Ryan Novecher 20, 1979 Page 2 to expect the nuclear industry, the lowest-risk threat, to completely fund state and local governments amergency planning efforts. Such planning falls within the public domain and is one of the basic responsibilities of government; therefore, emergency planning should be funded through normal methods of meeting governmental fiscal responsibilities from the tax base.
The assu=ption made on page I-12 that the utilities would recoup the
$1 million - plus fee by passing this cost to their customers does not take into account the dif ficulty and delays commonly experienced by utilities when requesting public utility commission approval for rate increases and the very real possibility that the approved rate increase rould be less than requested and would not fully recover the fee and interest costs.
Finally, it should be pointed out that, since the committee involved with the preparation of this report consisted entirely of state and local government agency personnel, the recommended funding method is obviously political. Af ter all, no public official would fail to support a proposal that removes some of the burden from tax revenues.
In su= mary, we believe that the funding recommendation made in NUREG-0553 is poorly justified and is not consistent with normal methods of financing activities that are the responsibility of state and local government.
Very truly yours, x
E. R. Mathews, Vice President Power Supply & Engineering suf Enc.
1819 144
Attachment Su= mary of Emergency Planning Assistance Provided to Wisconsin State and Local Governments.
1.
WPSC personnel assisted in developing the initial state radiological emergency response plan and later revisions.
2.
WPSC did the initial relocation survey and formulated the traffic plan and the plan for contacting the residents in the Kewaunee Plant LPZ.
3.
WPSC helped train the local Civil Defense personnel in LPZ evacuation pracedures and have participated in joint drills since 1973.
4.
WPSC provided training to local Civil Defense personnel on the handling of transportation accidents involving radioactive material.
5.
WPSC and WEPCo. jointly constructed an emergency facility at the Two Rivers hospital for handling radioactively contaminated personnel.
6.
WEPCo. conducts annual refresher training in the handling of radioactively contaminated personnel for the hospital staff.
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