ML20147G413

Comment Opposing Proposed Suppl 1 to Rev 1 to NUREG-0654, FEMA-REP-1.Document Should Be Immediately Withdrawn Pending Outcome of Numerous Court Challenges to Rule Change

ML20147G413
Person / Time
Site:	Seabrook
Issue date:	02/24/1988
From:	Lord W AMESBURY, MA
To:	Meyer D NRC
References
FRN-52FR45866, RTR-NUREG-0654, RTR-NUREG-654 52FR45866-00005, 52FR45866-5, NUDOCS 8803080222
Download: ML20147G413 (4)

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\ , , s0 am"53 meS DU y Board of Selectmen Town Hall, Amesbury, MA 01913 Tel. 388-0290 February 24, 1988 Membw  % /12'?

Mr. David Meyer Chief, Program Procedures Branch Mail Stop - 4000 MNBB Washington, DC 20555 Town of Amesbury comment on NUREG-0654 TEMA-REP-1, Rev. 1, Supp. 1.

The Town of Amesbury's initial response to the concept of the proposed document was one of the appearance of an inherent redundancy in offering public comment on a document intended to usurp the authority and intentions of local and State public entities.

Notwithstanding the aforemer.tioned notion, the Town stands firm in its opposition to the document and intends to continue its fight in the Courts to overturn the recent rule change which precipitated the drafting of this document.

The proposed criteria is nothing more than a self-serving publication that adds to the public perception that the NRC will let nothing stand in its way to prevent the licensing of a nuclear power plant.

Interim use of the document defies logic - how is the NRC to honestly assess the nerits of a utility plan when guided by a document that may face dramatic revision? Would the NRC take it upon itself to go back, and demand utility plan changes to a submittal the NRC may have already deemed adequate? The experience gained by the Town of Amesbury in current NRC proceedings suggests but one answer - NO!

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W... Amesbury Board of Selectmen Town Hall, Amesbury, MA 01913 Tel. 388-0290

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The Town of Amesbury also feels interim use of the document, prior to public comment and final adoption, violates the accepted principles of procedure, including provisions of the Administrative Procedure Act. There is no national emergency or national security issue at hand that would allow such interim use.

The Town is currently an active party to the on-going Seabrook Station licensing proceeding. The Town is one of the non-participating governments this document, and the related rule change, were developed to circumvent. Since November 18, 1985, when the Town adopted its policy of non-participation, Amesbury and its agents have been labeled by the Applicants as "uncooperative", "obstructionists", "emotionally driven radicals" and most recently our actions have been likened to those of criminals and terrorists (to which Applicants were harshly reprimanded by the AGLAB).

Amesbury wa; the first government in the Commonwealth of Massachusetts to take a stand of non-participation. That decision must be viewed

!n the historical perspective from which it evolved. As early as November of 1980, the Town of Amesbury had developed its first draft of an emergency plan for Seabrook related incidents. Subsequently, six additional drafts were prepared with the cooperation of Town officials. The decision to halt planning was by no means a hasty one.

Thousands of nours were invested analizing, updating and improving the proposed plans. Only when it was determined that the "best possible plan", developed and implemented with the full cooperation

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Board of Selectmen A esbury '

' Town Hall, Amesbury. MA 01913 Tel. 388-0290 (3) of local and State government, fell woefully short of the standards

, of safety our citizens deserved, did the Town entertain the polic, ,

of non-participation. That policy was voted by Town Meeting and .

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immediately adopted by the Board of Selectmen.

• - The document assumes (at D.1.a) that in an actual radiological emergency local officials would "exer'cise their best ef forts. to .

protect the health and safety of the public". In contrast, the Town feels it is making its best effort to protect the public by l \.

fighting the im ysition of unworkable plans on the citizenry. ,

Furthermore, the Town intends to continue its active presence in the licensing hearings to prove once and for all that emergency planning for Seabrook is not in the realm of the possible.

In conclusion, the document should be immed'iately withdrawn pending ,

outcome of the numerous court challenges to the rule change. Only after a court decrees that State and municipal. rights can be cast aside for the economic benefit of a handful of investors should the concept of utility plan evaluation be reconsidered.

For the own of Amesbury, M, lM*/ .

William S. Iffr"d Amesbury Board of Selectmen e

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, brd of Selectrnen Town Hall Amesbury, M A 0191.)

Mr. David Meyer Chief, Program Procedures Branch Mail Stop - 4000 MGB , '

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