ML20196D769
| ML20196D769 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/20/1988 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | NRC |
| References | |
| FRN-53FR16435, RULE-PR-50 53FR16435-00862, 53FR16435-862, NUDOCS 8807010455 | |
| Download: ML20196D769 (2) | |
Text
DOCKET NUMBER nn M0 POSED RUL 3 ffIb'I35_
Chlil A
USNFC June 20, 1988 16 JWl 22 P1 :32 COMMENTS OF OHIO CITIZENS FOR RESPONSIBLE ENERGY, INC. ('OCRE')
ON PROPOSED RULE TO 10 CFR 50,
'EMERGEMQW: P.LANNING AND PREPAREONf"5 REQUIREMENTS FOR NUCLEAR POWER FSRmfiKyELai(#, DING AND INITIAL LOW POWER OPERATION $'.
53 FEO. REG. 1 e@35t+ (M A 9,
1988)
The Commission is proposing o revision to emergency pionning requirements for all nuclear power plants because of a
situation unique to the Seabrook station:
communities within portions of the EPZ ore removing the emergency notirication sirens.
OCRE opposes this revision.
The NRC hos provisions for o situation in which one facility faces circumstances making complionce with the regulations difficult or inappropriote: the exemption procedures of 10 CFR 50.12 and the procedures for seeking woiver of a rule under 10 CFR 2.758.
These oie the procedures which should be used at
- Seabrook, Chonging the rules for 011 licensees for the sote of one is not the oppropriate response to the Seabrook situation.
The Commission *S chorocterization of this mother os o
' generic sorety issue' opplicable to oil pending and future opplications for fuel looding and low power operations rings hollow.
There are very few facilities left which are focing initial fuel load and low power operations.
No new orders for nuclear power plants are pending.
The Commission is simply changing the rules in the middle of the gome to accomodote Seabrook.
Clearly, the Commission *s action is motivoted >/ the utilities' investmene in Seabrook.
Consideration of costs to licensees in either setting or enforcing stondords for odequate protection of the public is prohibited.
Union of Concerned Scientists v.
NRC. 824 F.2d 108 (D.C. Cir. 1987).
What makes the instone
,'roposal even more galling is that the NRC told the courts thot the financial investment in seabrook would not influence its cr.ns i dera t ion o r emergency pionning issues at the operating license stage.
Seacoast Anti-Pollution League of New Hoopshire v.
NRC, 690 F.2d 1825, 1930, 1933 (0.C. Cir. 1982).
% u
.venu.ey; m i,,r l
The Commission eloins to have re-examined its 198FCF0LeDrenonge. -
e to determine whether there is any sofety basis for"#db6bihuihg
to require public notification before low p o w e r l i c e Ns'i6 g, ' "T h e '
j Commission states that 'the analyses done at that time a r e.
[
still opplicable.'
However, on the basis or these
- onolyses, the Commission in 1982 retained public notification as o
l requirement fcr low power. licensing.
There is no evidence that low power operation hos become much sofer than in 1982.
Thus g ir the 1982 onalyses remain applicoble, then the 1982 rule should stond unchanged.
Obviously the Commission is hosing its' ' C oCtions on purely political Considerations.
The risks of low power operation ore not insigniricone, Indee'd, o p e r o Eo' s 'W6v'e 'l e s's os the Commission notes, or low power plant r
8807010455 000620 PDR PH N
l 50 53FR16435 PDR
o GXperience and there is o greotfr potential for undiscovered defects.
Furthermore, for o lorge reoctor s u t. h as
- Seabrook, extended operation ot ICW power Would result in o
buildup or rassion product anventory equivalent to that or o
smaller reactor.
E.g.,
Seobrook's roted copocity is 1150 MWe net. This econslates to o thermo1 power or opproximote'.y 3450 MWt.
Five percent power is equtvolent to 172.5 MWt.
A recetor or this size would be required to meet the emergency plonning requirements, includir.g that for public notification.
Because of the controversy surrounding the Seabrook plant and the hotly contested emergency planning issues in the licensing proceeding, it is likely that Seabrook would operote at low power for on extended period or time before receiving authori20 tion for rull power, if indeed this ever comes to poss.
It is oiso userul to exonine What olteri.otives to strens are ovoilable for public notification if on occident were to occur at low power.
Telephone lines would likely be Jommed.
Shortly orter the Jonuary 31, 1996 torthquoke in Northeast Ohio the telephone lines were overlooded for at least 30-40 minutes.
Arter events like this there is considerable ponic os people call police deportments trying to find out what hoppened and call family members to make sure they are unhormed.
Mobile sirens mounted on trucks or helicopters Would take time to mobilize and may not even be available in severe Weather conditions.
While TV and radio stations Would be able to broadcast information, not everyone hos o TV or radio on all the time.
These alternatives are o poor substitute for the sirens.
Without the prompt r.otification provided by the sirens, the public Will either remain uninformed until it may be too lote to take protective actions, or people Will ponic and spontoneously evocuote, cousing choos.
The Commission should retain its current requirements for public notification.
The problems unique to Seabrook should be litigoted in the ongoing cose-specific forum.
One opplicant*S problems should not prompt the NRC to change its rules for all licensees.
Respectrully submitted, ff s
Susan L.
Hiott CCRE Representative 8275 Munson Rood Mentor. OH 44060 (216) 235-3158 osso