ML20196D499

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

ML20196D499
Person / Time
Site:	Seabrook
Issue date:	06/13/1988
From:	Brock M HAMPTON, NH, SHAINES & MCEACHERN
To:	Parler W NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
FRN-53FR16435, RULE-PR-50 53FR16435-00776, 53FR16435-776, NUDOCS 8807010393
Download: ML20196D499 (1)

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_PO Box 360,25 Maplewood Avenue Portsmouth. New Hampshire 03801 June 13, 1988 M JN 17 A10 34 0FFM ,

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00Crdis;c.6 ERAN William C. Parler, General Counsel Office of General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 Re: EMERGENCY PLANNING AND PREPAREDNESS REQUIREMENTS FOR NUCLEAR POWER PLANT FUEL LOADING AND INITIAL LOW-POWER OPERATIONS (PROPOSED RULE)

SECY-88-109

Dear Mr. Parler:

The Town of Hampton comments upon, and objects to, the proposed rule change on the following grounds:

1. The proposed rule is arbitrary, capricious and otherwise violates provisions of the Administrative Procedure Act since the rule would subject the public to unreasonable risk of harm by permitting low power operation, without means to notify the public in the event of emergency.

2. The proposed rule represents an improper use of the Commission's rulemaking authority to promote the licensing of a single nuclear plant. The proposed rule therefore is an unlawful use of the generic rulemaking process.

3. The proposed rule is further evidence of pervasive bias and prejudice by the Commission as it attempts to circumvent the regulatory framework established by the Atomic Energy Act and by the Commission's own regulations.

l The Town of Hampton respectfully asks that the proposed rule be rejected.

Very truly yours, TOWN OF HAMPTON By Its Attorneys 88070103"?3 800613 S INES & McEAC , P.A.

53 f16435 PDR ,

N Matthew T. Brock MTB/jlr P.O. Box 360,25 N1aplemnod Avenue Portamouth, New Hampsh.re 03s01 Telephone 603/436 3110. FAX: 603/416 2993 Robert A. Shaines Paul NicEachern, John H NicEachern, Duncan A.

NicEachern, Gregory Robbins. Dan W.Thornhill. Branch Sanders, Ahce K Page. Ntatthem T. Brock Daniel C. Hoene, Pamela D Eldredge.

Wilham H Gamble, R. Timothy Phoenis. Fred J. Madngan tretiredt of counsel J Robert O'Bnen bC-ID