ML20040G196

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Comments on Proposed Rule 10CFR50 Re Revised Emergency Plans.Requests 30-day Notice of Intention to Approve Revised Emergency Plans
ML20040G196
Person / Time
Site: Pilgrim
Issue date: 02/03/1982
From: Shotwell J
MASSACHUSETTS, COMMONWEALTH OF
To: Palladino N
NRC COMMISSION (OCM)
References
FRN-46FR61132, RULE-PR-50 46FR61132-55, NUDOCS 8202110407
Download: ML20040G196 (2)


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Nunzio Palladino, Chairman s

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Nuclear Regulatory Commission

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20555 g,g aso RE:

Revised Emergency ' Plans for GM'OSED RULE 1

f Pilgrim Unit I

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Dear Commissioner Palladino:

On behalf of Francis X. Bellotti, Attorney General of the Commonwealth of Massachusetts, I request that you provide thirty days' notice of your intention to approve the revised emergency plans for the Pilgrim I power plant located in Plymouth, Massachusetts.

Those revised plans are currently under review by your staff, having been submitted by Boston Edison Company in accordance with the Commission's new regulations on emergency plenr.ing, 10 C.F.R.

SS50.47 and 50.54 and 10 C.F.R. Part 50, Appendix E.

This office is interested in ensuring the safe operation of any nuclear power plant sited in this state.

For that reason, we participated actively in the construction' permit proceeding for the now abandoned Pilgrim II plant, which was proposed for siting adjacent to the existing Pilgrim unit.

At the time the Pilgrim II project was cancelled, this office was preparing to participate in a hearing before the Pilgrim II y

Atomic Safety and Licensing Board on the issue of emergency planning and other TMI-related safety questions.

Indeed, the i

i Attorney General had already submitted detailed contentions challenging the size of the emergency planning zones established by the applicants and the NRC staff and the sufficiency of the proferred evidence that the public would be adequately protected in the event of a severe accident at the Pilgrim site.

sl While Boston Edison has now abandoned its. plans to build O

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Pilgrim II, we remain concerned about the feasibility of I

protective action in the event of an accidental release from g',

Pilgrim I and about the adequacy of the emergency plans being pf),,al Acknowledged by card..k.7.

.n 8202110407 820203 h 46 R61132 PDR

r-o Nunzio Palladino, Chairman February 3, 1982 page 2 developed for use in connection with that existing unit.

It is our understanding that the NRC Staff is now reviewing revised plans for Pilgrim I.

In our view, approval of those revised plans will constitute.an amendment to the Pilgrim I operating license.

There can be no doubt but that approval of such plans involves a significant hazards consideration, since the plans are being reviewed for their ability to assure adequate protection in the event of a spectrum of accidents, including Class 9 accidents.

See NUREG-0396/ EPA 520/1-78-0167 " Planning Basis for the Development of State and Local Government Radiological Em,ergency Response Plans in Support of Light Water Nuclear Power Plants" (December, 1978), at 4-5, which report received the formal endorsement of both the Commission and the Enviror. mental Protection Agency (see 44 Fed. Reg. 61123, October 28, 1979).

Accordingly, on behalf of Attorney General Bellotti I hereby request that I receive, pursuant to S189 (a) of the Atomic Energy Act of 1954, 42 U.S.C.

S2239 (a), thirty days' notice of the Commission's intent to approve the revised emergency plans for Pilgrim I.

This office will thereby be able to review the plans as approved and request a hearing for the purpose of contesting their adequacy should that be necessary, ry truly yours, Ann Shotwell ssistant Attorney General Environmental Protection Division (617) 727-2265 JAS/mkj cc:

Commissioners Ahearne, Bradford, Gilinsky and Roberts Harold R.

Denton, Director of Nuclear Reactor Regulation Executive Legal Director, Nuclear Regulatory Commission Thomas Dignan, Esq.

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