ML20150F873

Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning

ML20150F873
Person / Time
Site:	Seabrook
Issue date:	03/01/1987
From:	Pratt C, Pratt J AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
FRN-52FR6980, RULE-PR-50 52FR6980-00129, 52FR6980-129, NUDOCS 8807190100
Download: ML20150F873 (2)

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s RR 3. Box 44 .r,..

p Brentwood, N.H. 03833 March 1, 1987 Nuclear Regulatory Commission Washington, D.C. 20555

Dear Commissioners,

We wish to record our dismay at the Commission's recent decision to post the proposed rule change to allow licensing of nuclear plants on the basis of Emert'ency Response Plans submitted by the applicants in cases where state authorities have decided to submit no plans.

State authorities best know the conditions in their own state. They are appropriately given the task of developing plans. If they believe no adequate plan can be developed, it is their responsibility to refrain from submitting plans.

If state authorities do submit plans, it is the responsibility of the Atomic Safety and Licensing Board to judge the adequacy of those plans. We ourselves have followed closely the development of New Hampshire plans for the past several years. One af us served on a local committee' charged with evaluating the plans for the town of Exeter when we lived in that town, and we have both been active on this issue since our move to Brentwood. It is evident to us that the plans submitted by the State of New Hampshire for local communities are woefully inadequate. We have expressed our concerns to local authorities, to the New Hampshire Civil Defense Agency, to the Federal Emergency Management Agency on numerous occasions. The State Civil Defense Agency seems to us to be operating as an arm of the utility. It is our vi9w that the State of New Hampshire, rather than submitting plans with the assertion that "with reasonable assurance, they provide for the safety of citizens of New Hampshire -

living within the emergency planning zones for Seabrook j 8tation as well as for the transient population...." should have  !

followed the course taken by the State of Massachusetts.

Since they did not, we must count on the Atomic Safety and Licensing Board to look with an honest eye at those plans and the objections that have been raised to them.

There is, then, absolutely no conflict between the roles of the states and the licensing board. It is perfectly appropriat9, if safety is the primary consideration, that both local officials and the Nuclear Regulatory Commission ba satisfied of the adequacy of emergency response plans before a license can be granted, just as the Senate and House of Representatives, 1 as well as the President, must agree before a proposed bill l becomes law. -

Allowing a utility to submit plans for a state would i be folly. If the state does not participate in the development 8807190100 870223 52 6980 PDR. hNd I

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of the plans, the plans can not be effectively implemented in an emergency. Yes, it is likely that some or most -

officials would fill their assigned roles in case of an actual incident. But the planta are good for thirty to forty years, and the p)ans must be also. Constant and serious training and (L*illing are required. Many important roles in our local plans are assigned to volunteers or near volunteers -- the town Civil Defense Director, the '

Selectmen, volunteer firepersons, and others. A plan adopted without the cooperation of and against the will of state and local officials will at best be regarded with cynicism and drilled without faith. Clearly, to approve a plan under such conditions is to compromise safety.

No plantshould be constructed until Emergency Response Plans have been developed and approved. In the case of Seabrook Station, plant owners went on record long ago stating their full awareness that they were building the plant at their own risk, with no guarantee that Emergency Response Plans would be approved or the plant licensed. The argument of the NRC staff that the rule change is necessary to avoid economic hardship to the applicant is therefore totally without merit.

We trust that you will not give final approval to l this proposed change.

Sincerely, Oh 2. re h g fa [

Charles and Joan Pratt copies to: Governor John Sununu  !

Governor tiichael Dukakis 1 New Hampshire Senators and Representatives 1 P

!!a}lectmen, rector, New TownHampshire Civil Defense Agency of Brentwood Civil Defense Director, Town of Brentwood 1

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