ML20195F276

Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations

ML20195F276
Person / Time
Site:	Seabrook, 05000000, Shoreham
Issue date:	06/13/1988
From:	Lash T ILLINOIS, STATE OF
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR16435, RULE-PR-50 53FR16435-00702, 53FR16435-702, NUDOCS 8806270007
Download: ML20195F276 (2)

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a STATE OF ILLINOIS  %

DEPARTMENT OF NUCLEAR QFETY 1035 OUTER PARK DRIVE h0hf1"*'nib"b '

SPRINGFIELD 62704 (217) 785 9900 TERRY R. LASH June 13, 1988 o@tCTOR The Secretary of the Coaxnission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

i Attention: Docketing and Service Branch Re: Proposed Rule, "Emergency Planning and Preparedness Requirements ,

for Nuclear Power Plant Fuel Loading and Initial Low-Power Operations," 10 CFR Part 50, 53 Federal Register 16435-16438  !

(May 9, 1988) 1 The Illinois Department of Nuclear Safety (IDNS) hereby submits its i

comments on the above-mentioned proposed rule concerning emergehey planning and preparedness requirements for nuclear power plant fuel l loading and initial low-power operations. Illinois currently has 13 operational reactors on 7 sites within its borders. IDNS is the lead agency in Illinois for preparing emergency plans for and coordinating emergency responses to accidents at these nuclear power plants.

The proposed rule appears to be an attempt to preclude future occurrences of Shoreham/Seabrook-type situations where there are fundamental disputes over emergency planning after completion of plants.

Participation of local and state governments in emergency planning must be thatsettled long before fuel loading, but this rule change will not cause to happen. The problems at Shoreham and Seabrook were not caused by inadequacy of planning standards, but by failure of the Federal government to get commitments of state and local governments' participation before issuing the construction permits.

The proposed rule is valid in a narrow sense. With the low degree of risk posed to offsite persoas by operating at less than 5% of rated power, it appears that the proposed requirements are easily sufficient to assure protection in the unlikely event of an accident. However, with a Shoreham/Seabrook-type situation such a rule might only cause further animosity.

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1 The problem of local and state government participation must be dealt j with as a whole and as early as possible in the process. A piece-mec1 approach will on'y serve to aggravate the situation. IDNS therefort believes that this proposed rule should not be adopted. Rather, NRC should ',

propose a rule that will as3ure full involvement cnd concurrence af. state i and local governments on emergency planning before a construction permit is issued.

Si erely,

' l err R. Lash '

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