ML20196K816
| ML20196K816 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/24/1988 |
| From: | Moughan T CITIZENS WITHIN THE TEN MILE RADIUS |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR16435, RULE-PR-50 53FR16435-01439, 53FR16435-1439, NUDOCS 8807070126 | |
| Download: ML20196K816 (3) | |
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l JtN 23 00014:89 AT8/TELSYS to.11uRYPORT617C623001 P.2 i-DOCKET NUMBER d
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Citizens Within the Ten MIIghadius e
Post Office Box 302. Amesbury MassgplupsdftsN}3 Post Office Box 301, Exeter, New Hampshire 03833
%[cI June 24, 195e Samuel J. Chilk Secretary of the Commission gE; g
or U.S. Nuclear Regulatory Commission Y
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1717 H Street, N.W.
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Washington, D.C.
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- Ys-o Attention: Docketing and Service Branch SE M
C-w Dear Secretary Chilk This is submitted as comment on the Nuclear Regulatory Commission's (NRC) proposed rulemaking regarding emergency planning and preparedness requirements for nuclear plant fuel loading and initial low-power operations as published in the i
Federal Register on May 9, 198e.
As an organization representing thousands of residents of communities neerest the Seabrook nuclear power plant, Citizens Within the Ten Mile Radius (C-10) vigorously objects to the proposed rule change.
C-10 believes the rule change is unwarranted.
It is contrary to public safety needs, and it is punitive in nature.
The NRC acknowledges in its public notice that the proposed amendment was motivated by the removal of strens in the Hassachusetts communities within the Seabrook emergency planninq
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zone (EPZ).
The Commission attempts to make a case that the rule change would correct A O m ric problom in licensthy Ivw power operation in other instances.
This is not a generic issue.
The situation with. regard to-notification systems and emergency planning for low-power
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operations is specific to Seabrook alone.
The siren system removed from the Hassachusetts Ep2 communities was determined by-Federal court to be illegal and unlawfully placed.
?urthermore, the utility is on record as stating it has alternatives to use in place of the siren system.
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0.6. 23,88 02:51 PM
- MAVROULES DC OFFICE P02 AN 23 '8814:20 ATFTD.SYS PEWBLRYP@T6174623001 B.3 2
The resolve of this issue does not belong in the rulemaking forum.
It belongs in the Seabrook adjudicatory process.
It makes little sense to weaken safety requirements for other applicants in order to resolve the problems of one utility.
The Commission aleo states that it is intending only to clarity what amergency planning requirements are needed for fuel loading ana aower pover operation.
In fact, the proposal would eliminate all offsite emergency response requirements for low-power operation.
It is ironic that in the first instance of a contested issue regarding compliance with of fsite aspects of the applicant 's onsite plan to come before the NRC, the Commission has chosen to clinincte the issue tethm then dwei with the suostance or the situation.
The Commission has chosen to use this opportunity to eliminate all offsite emergency planning requirements for low-power testing even though no new evidence has been presented to indicate that the public reection to an onsite incident would be any less chaotic than anticipated when the original rule was adopted.
In order to adopt this rule, the NRC must'believe that time is a cure for difficult M ? nations, Finally, in choosing the rulemaking process to address Seabrook's problem, the Commission states that it "prefers to subject its proposal to a broader spectrum of public comment than simply the litige
- in the Seabrook case".
To accomplish that ob]ective the cor ton initially established a thirty day pub!!c comment.pe Even with the extension to forty-five days, there was ha
.y time to broaden the spectrum of public comment.
At best, the Commission has demonstrated a minimal effort to inferm the public and to receive comment.
There is a subtle but discernible attempt in this rulemaking to coerce states and locel comrcunities into accepting inadequate safety measures by allowing reactors to operate prior to the resolve of full power safety requirements.
The Commission clearly is preparing to allow nuclear plants to begin operation without adequate or approved emergency plans and thereby place the burden on local officials to accept whatever safety provininn9 Are n+ fared, whether adequato or met.
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coercive as a generic rule change and punitive with respect to the SeabrooX issue.
I Plo
l-06.23,88 02:51 PM
- M A V RD U L E S DC OFFICE P03 JUN 23 '86 14:21 AT!/TELsys NEWBR& ORT 6174623221 P.4 3
With this newest rulemaking proposal, the public new hos added cause to question the motives of the NRC.
Is the commission prepared to change its rules every time a utility places itself in non-compliance with state and local laws or is unable to meet minimal safety criteria?
That approach will only result in a further. erosion of public confidence in the NRC, the utility, and in emergency preparedness.
As residents directly affected by this obvious retreat from existing and necessary safety requirements, we urge the Commission to reverse its course of action and reject the proposed rule change.
Sincerely, 4
THOMAS F. MOUGHAN, Coordinator l
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