ML19310A228

Submits Opposition to NRC Clarification of Emergency Planning Requirements.Locating Emergency Operations Facility within Emergency Planning Zone Adds to Number of People to Be Evacuated & Creates Weakness Inside Zone

ML19310A228
Person / Time
Site:	Browns Ferry
Issue date:	05/29/1980
From:	Godwin A ALABAMA, STATE OF
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8006060322
Download: ML19310A228 (2)

Text

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.N State of Alabama x

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De0artment of Public Health i

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Montgomery, Alabama niso m a t. u v E as, u. o.

May 29, 1980

$? A TE M E AL,TH Qjr FiCER Mr. H. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D.C.

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Dear Mr. Denton:

In a r.cing with several U.S. Nuclear Regulatory Comission representatives on May 20, 1980, at Browns Ferry Nuclear Plant, we were provided a copy of a memorandum to all Power Reactor Licensees dated April 25, 1980, from Darrell G. Eisenhut.

In this memorandum Mr. Eisenhut " clarifies" some of the require-ments for emergency planning. One item of particular concern is the near site EOF.

You should be aware of the significant state and local governments' opposition to this concept. My opposition is as follows:

1. A facility of this type should not be located within an area that evacuation planning is necessary. To locate the facility within the plume EPZ only:

A. Adds to the number to be removed from the area; thereby, putting further strain on resources.

B. Creates a weakness in the security of the evacuation zone. The admission of individuals who normally do not work or reside within the zone is a problem.

2.

There are no comunication systems which would have to be in place out-side the EPZ. You admit this, since an alternate facility is also required.

3.

The provision for limited press coverage at this facility invites the multipoint information confusion as existed at TMI.

4.

The cost is unnecessary. As pointed out in 2 above, comunication systems are available even beyond the plume EPZ.

If the facility is co-located with an EOC beyond the plume EPZ, an alternate is no longer needed. Further, state and local government staff resources will not be further stretched by having to man an EOF and an EOC.

I recognize your criteria does not require such, but I believe we will be forced by the event to provide such manpower.

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5.

A strong belief, perhaps erroneous, that many U.S. Nuclear Regulatory Comission staff are assuming all plants and incidents will follow the

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Nt. H. Dinten, Directer Prg3 2 May 29, 1980 TMI pattern. I think some recognition of the differences between some metropolitan areas and largely rural areas should be considered.

I ask that prior to adopting the EOF as is presently given, serious consideration be given to the above. Further, you may wish to have a similar facility for directing recovery operations. Such a facility is logical for use after the threat of evacua-tion has ended.

In this case, it should be called the recovery operations facility (RDF).

1 My last question is whether or not anyone has considered what the effects would be on the emergency response if, af ter establishing the decision making for both the utility and government at the EOF, it became necessary to abandon the EOF. We have.

Sincerely, e

'L Aubrey V. Godwin, Director Division of Radiological Health 4

AVG:ka cc:

Mr. D. Moeller,

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Advisory Committee on Reactor Safeguards Mr. Sam Slone, III I

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