ML20196E678

Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations.Lists Reasons for Support

ML20196E678
Person / Time
Site:	Seabrook
Issue date:	06/22/1988
From:	Daley W AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR16435, RULE-PR-50 53FR16435-00957, 53FR16435-957, NUDOCS 8807010670
Download: ML20196E678 (2)

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DOCKET Hut.lBER PROPOSED RULE b 87 June 22, 1988 g g; N /0 VS l USN"C l Secretary of the Commission United States Nuclear Regulatory Commission 's AN 23 P1 :55 Washington, DC 20555 i

Attention: Docketing and Service Branch '

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i' BRtNLM Gentlemen:

The Nuclear Regulatory Commission in 53 Fed. Reg. 16435, proposed an amendment to 10 CFR 50.47(d) to clarify and codify what offnite emer-gency preparedness requirements of the Commission are applicable to low power operation. I think the actions of the Commission are appro-priate and therefore support the Commission's proposed rulemaking.

My reasons for reaching this conclusion both as an engineer and as a lawyer include:

o The NRC Staff has thoroughly evaluated the risks associated with low power operation.

o The specific issue of low-power license issuance and attendant risks had been subject to litigation in the past prior to promulgation of the current rule.

o The design of a power plant is predicated on full power operation.

Therefore in most cases there is significant safety margins in the plant design when operating at low-power. This also equates to a greater time being available to take emergency action at low power operation then that for full power (i.e. , at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />).

o The plant is in reality only critical for short time periods and therefore the fission prcduct inventory is significantly less than that for full-power operation.

o The explicit language of the current rule does not require any review by the NRC or FEMA concerning offsite emergency preparedness.

The requirements, as it was shown in the Seabrook proceeding, arise out of responses to comments contained in the Statements of Consid-eration rule.

provided in the Federal Register Notice enacting the current "

Therefore it is appropriate that the Commission in the first instance explicitly codify what offsite emergency preparedness re-quirements, if any, are pertinent to low power operation.

o The interpretive rulemaking is required again by the NRC to deal with' the intentional misune of Commission regulations to obfuscate and delay the licensing and impact process and to maximize the cost of the facility to rate payers.

8807010670 880622 53 16435 PDR D S-/ c

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United States Nuclear Rsgulatory Commission Page 2 Attention: Docketing and Service Branch The rule proposed by the Commission should be evaluated on the basis of the knowledge and information has regarding low power operation and the associated risks. I would encourage the NRC not to allow nuclear power opponents or self-serving public officials to derail the NRC in its efforts to clarify and eliminate any ambiguities that may exist in the current rule.

As a final note, during the summer months, I and my family have for the last few years spent our summers on the beaches of Salisbury, MA which is well within the 10-mile EPZ for Seabrook Station. Therefore, your proposed rulemaking is more than just a passing concern to me.

Sincerely, William J. Daley, Jr., Esq.

71 Martin Avenue North Andover, MA 01845 O s -/ o

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