ML20197G856

Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations.Suggests Several Reasons for Keeping Present Rule Overlooked

ML20197G856
Person / Time
Site:	Seabrook, 05000000, Shoreham
Issue date:	06/02/1988
From:	Jeffery Grant AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR16435, RULE-PR-50 53FR16435-00321, 53FR16435-321, NUDOCS 8806150354
Download: ML20197G856 (1)

Text

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Jane B. Grant h

M N,U;;C Rt.. 2 , RFD 2, Box 154 i

~N- l Conco rd , New Hamushire 03301 3M/h8h June 2, 1988 l

'85 J:: -6 LL :n ,

Secretary, Tuclear Regulatory Commission I Washington, D.C. 20555 ,, 1 V"0 u C 4. ', i. ,

i Re: Emergency Planning and PreparednesE Requirements  ;

for Nuclear Power plant fuel loading and initial i low-power operations. Comment:

Basing your proposed rule primarily on the relatively low risk to the public of low-power testing overlooks several in-portent reasons for keeping the present rule.

Foremost is the fact that the plant will become radio-active, as is the case with Shoreham, Once this becomes a realit:,

the olcnt can never be converted to another use. In the case of S abrook, with the enrgency planning process in such disarray, it is hs.r0 for me to conceive that the owners would propose low-cower testing, thus cancelling the option for conversion which richt well be their only course.

Unrcsolved financial and safety questions also add to my objections to low-power testing at Seabrook. Should the plant never ; o on line, how could a company in bankruptcy pay for de-com=issioning?

Although the proposed lowering of standards for emergency preparedness is stated as applying to all plan,ts, it is . obvious

. . . ry ; . . , s that the situation at Seabrook prompted this proposal. Any lower-

v. , . w m. . << -

ing of standards points indubitably to utility,and agency press-ure to speed up the licensing process, a very poor reason for l chan ginc the rule. 1 see this as another example of the Commission favoring promotion over regulation. My cohment thus,,is.a strong m

crotest agninst the proposed rule change. ' } d fn -

8806150354 000602 M 'O P' " ' 5 PDR R 50 53FR16435 PDR

,J.ane B. Grant /