ML20065N719

Comments on Petition for Rulemaking PRM-50-32B Re Electromagnetic Pulse in Nuclear Power Plants.Requests That 10CFR50 Be Amended to Require Provision for Design Features for Protection Against Attacks & Destructive Acts

ML20065N719
Person / Time
Site:	Midland
Issue date:	08/31/1982
From:	Marshall W MAPLETON INTERVENORS
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
RULE-PRM-50-32B ISSUANCE-OM, ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8210220294
Download: ML20065N719 (2)

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Wendell H. Marshall DOLetETED MAPLETON INTERVENORS USNRC Route 10 Midland, Michigan 48640 N SEP1 P2:11 DOCKET NOMBERE FICE OF SECR y August 31, 1982 "MEilNG & SE I EETITION RULE _ PRM %;3cq b BRANCH j ,

Secretary c3t m ;n.n-, ._.

United States Nuclear Regulatory Commission

] Washington, DC 20555 ragg,ng-[~h,h,6{gp g

Dear Sirs:

The Mapleton Intervenors request that NRC amend 10 CFR lart 50 as is indicated in this letter.

The Mapleton Intervenors maintain that electromagnetic pulses are generated in space by detonation at high altitudes of nuclear de-vices.

The explosion of any nuclear device in space is capable of producing an electromagnetic pulse capable of derailing, disrupting, interfering with and temporarily destroying all electronic control systems, especially in regard to nuclear power plants.

s In view of the seriousness of the electromagnetic. pulse, the Mapleton

! Intervenors request that 10 CFR Part 50 be amended as follows:

I. Section 50-13. Attacks and destructive acts by enemies of the United States, and defense activities.

I (a) An applicant for license to construct and operate a production or utilization facility, or for an amendment to such license, is not required, with the exception of (b) below, to provide for design features or other measures for the specific purpose of protection against the effects of (I) attacks and destructive acts, including sabotage directed I against the facility by an enemy of the United States, f whet'ner foreign government or person, or (II),

j Use of deployment of weapons incident to United States defense activities.

[ (b) Such applicant must, however, provide for design features to protect against the effects of electromagnetic pulse fron whatever source.

Appendix A subpart 50. This portion of the regulation should be amended to read as follows:

• py2o 294 820031 50-32B PDR

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,o b Secretary United States Nuclear Regulatory Commission August 31, 1982 Page Two "Criterian 4 - Environmental and missile design bases. Structures, systems and components important to safety shall be designed to accommodate the effects of and be compatible with the environmental conditions associated with normal cperation, maintenance, testing and postulated accidents, including loss-of-coolant accidents.

These structures, systems, and components shall be properly protected against dynamic effects of missiles, pipe whipping and discharging fluids that may result from equipment failures and from events and conditions outside the nuclear power unit including, but not limited to the electromagnetic pulses".

To support the proposed change to NRC rules and regulations is impor-tant since the Mapleton Intervenors claims that the present regula-tions provide a serious defect in nuclear power plant safety design which can be closed with proper design. Nuclear power plant harden-ing circuitry and equipment can be designed and installed at the time the plant is being built or constructed.

The petitioner to this rule change is an intervenor in the Midland Nuclear Power Plant licensing procedure, Dockets #50-329 and #50-33'O.

The Mapleton Intervenors request that the NRC pursuant to Chapter .

, 2.802 (d) of its regulations suspend those portions of the Midland licensing procedures relating to safety pending disposition of petition for rule making.

Sincerely, ,

/Wendellb .

H. Marsha 1 President Mapleton Intervenors i cc: Charles Bechhoefer, Esq. Mr. Robert W. Huston Mr. Ralph S. Decker Dr. Charles H. Carson, PhD Dr. Frederick P. Cowan U.S. Nuclear Regulatory Commi~ssion Jerry, Harbour, Esq. Resident Inspectors Office Michael I. Miller, Esq. Ms. Barbara Stamiris Ronald G. Zamarin,'Esq. Mr. Myron M. Cherry, Esq Alan S. Farnell, Esq. Mr. R. B. Borsum

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James E. Brunner, Esq. Mr. Don van Farrowe Ms. Mary Sinclair Mr. Walt Apley Stewart H. Freeman Mr. James G. Keppler Mr. Steve J. Gadler, P.E. P. McCallister, P.E.

Docketing & Service Section Frank J. Kelly Michael Wilcove, Esq. William D. Patton, Esq.

WHM/nm

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