ML20195F853

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

ML20195F853
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/06/1988
From:	Lewis M AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR16435, RULE-PR-50 53FR16435-00454, 53FR16435-454, NUDOCS 8806270163
Download: ML20195F853 (2)

Text

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wi.c L. Lewis ria r v i n

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ecretary of the CommAssion -* '

Attention: Docketing and Service Branch ,

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U. 6. N. R. C.

Washingtons O.U. 20bbb Uear Secretary; Please accept this letter as my comments upon 10 CFR 60.4*/

(d), Proposed Hule on Emergency Planning.

Ancient marancrs had a saying,"'the ship belongs to the captain, the liteboats belong to the crew."

i paraphrase,"the reactor belongs to the utility; the emergency evacuation belongs to the residents."

Ihis proposed rule eliminates the most affected governmental units.from participntion in an emergency plan. By ruling that cooperation of local and State governments is unnecessar,y in an emergency plan for a nuclear power plant, the Commission is ruling that local and State participation it, unnecessary in any phase of emergency planning. What the NRC is doing is what teder alists have ralled to accomplish in 800 years: eliminate States Rights. Stetes have a right to paiticipate or not par t'ic ipa te in the private business trancp.ising within their respective boundartes, btates also have a i ight to censuie certain businesses eithin their respective boundaries.

An easy exaniple of a States Hight to censure or promote a 9 particular busi:.ess is prostitution. Most States outlaw

. prostitution for pay, but Colorado and Nevada legalize and regulate that business.

A similar case can be made for private electrical utilities.

9tates have a right to censure thru lack of participation, or promote thru p3rticipation. Ad.ni n i s t ra t i ve agencies have never had a right in peacetime to eliminate States Rights. An action like this should not be an action of an administrative agency, but an action of Congress.

Improper Assumptions the assumpblon in the supplementary inrormation accompanying the Proposed Rule assumes that low power operation is less dangerous and sarer than tull power operation. An assumption is an educated guess. lhe Chernobyl reactor was operating at very low power when it experienced its very powerful accident. the assumption ot' less danger at low power is merely that, an assurnp t i o n .

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, the assumption at less danger at low power bears further

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Investigation. It a reactor has been run tor a long time with an experienced crew, the reactor might operate at a particular power level with little danger.The same might be said if all the systems ~had become familiar thru usage, A new reactor does not have a crew which is accustomed to it.

A new reactor otten has deficient parts for many, many reasons and needs operating experience at all power levels to overcome dangers.

Uperating at different power levels is not the only problem in'the start up ot a new nuclear plant. Other unrelated and related problem abound. Une such problem which affects all power levels tollows:

the thernobyl teactor had a tire in its fuel pool. New reactors have empty fuel pools, and cannot experience a spent fuel tire in the fuel pool or car they?

Iransshipments of spent tuel are common today to preserve tull core ottload capability at reactor sites where the fuel pool is near capacity. Io avoid any problems with the tuel pool, this petitioner requests that this rule include a ban on r, pent tuel shipments into tuel pools of reactors tacing startup.

ihere are many unchallenged assumptions in the Supplementary information. there are just too many reasons to tear that low power operation is too dangerous to proceed without State and local Governmental cooperation.

Finally, there is the experience of Shoreham. ~lhe arrogance of the Commission in granting a license and the lack of concern of the utt11ty in increasing danger and cost by low power-l operation of the Shoreham plant shows what the problem is. the problem lies in the Commission, which is so enamored of nuclear power that Shoreham was licensed despite the financial condition of the parent utility and the resulting costs and radioactive

!, exposures.

4 For bod, Cointry and motherhood, please eliminate this proposod rule trom consideration.

Hespectfully bmitted, 4, v -

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MarM b6.tf 1. Lewis 7801 Hoosevelt Blvd.#6B Phila., PA 19162 (81b)684 16'/4 6-6-88.

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