ML20195G287
| ML20195G287 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/06/1988 |
| From: | Brown H CONNECTICUT, STATE OF |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR16435, RULE-PR-50 53FR16435-00473, 53FR16435-473, NUDOCS 8806270288 | |
| Download: ML20195G287 (1) | |
Text
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DOCKET NUMBER nn PROPOSED RULE rn g
@ff21 STATE OF CONNECTICUT (63fMy}
OmCE 0:* POLICY AND AIANAGEhfENT
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2; COMPREHENSIVE PLANNING DIVISION L
June 6, 1988
'88 JUN -8 P4 :23 Secretary of the Commission
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a Attn: Docketing and Service Branch.
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- M G U.S. Nuclear Regulatory Commtssion BRM4" Washington, DC 20555 Review by Connecticut state agencies of proposed rules and regulations published in the Federal Register is coordinated by this office.
The following are the comments that we received from the Energy Division of the Office of Policy and Management. The comments are in opposition to the proposed rule on "Emergency Planning and Preparedness Requirements for Nuclear Power Plant Fuel Loading and Initial Low-Power Operations (Federal Register dated May 9, 1988).
The comments are as follows:
It is our opinion that this proposed rule change is not good public policy for several reasons.
First, it is not consistent with the NRC's general position that the safety analyses of 1982 are still valid.
If i
those analyses are still valid, it does not logically follow that the l
public need not be promptly notified in the event of an incident during fuel load and low power operations.
Second, the NRC apparently feels there is some risk involved with low-power testing since the Commission still is requiring that all of the other emergency response mechanisms that were established in 1982 be in place today.
Third, the public near the plant have the right to be notified promptly in the event of an accidenh It is our contention that it would not take much in the way of resources to implement an emergency notification system.
The utility could utilize some mobile units with loud speakers attached, as are available in election campaigns, to tell the public there has been an accident.
It also would not be too difficult to have a list of radio and TV stations available at the plant or the emergency operations facility, with phone numbers, and people to make the calls, in the event of a crisis.
We see no basis for supporting this rule change. Many nuclear plants l
including Millstone 3, have received licenses under the 1982 rules, j
These utilities, and the state and local officials working with them, t
have been able to meet all the requirements of emergency planning under the 1982 rules. The same rules should apply today.
1 i
Thank you for this opportunity to comment on these proposed rules.
l Sincerely,
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PDR PR 50 53FR16435 PDR Horace H. Brown Under Secretary HHB/js attachment j
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