ML19312D323

Comments on Proposed Rule 10CFR.Recommends CP Be Revoked or Suspended Until Regulations Are Finalized.Terms Significant & Deficiency Require Clarification

ML19312D323
Person / Time
Site:	Waterford
Issue date:	02/13/1980
From:	Tillman T AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-44FR75167, RULE-PR-50, TASK-OS, TASK-SD-906-1 NUDOCS 8003240217
Download: ML19312D323 (3)

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Post Office Box 344 Laplace, Louisiana 70068 February 13, 1980!

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4111Y1 , ,g Secretary of the Commission U. S. Nuclear Regulatory Commission f giuS o e ry .

Washington, D. C. 20555 <;Q ,

RE: Proposed Changes in NRC Emergency Planning Regulations "4  !

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Dear Sir:

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I am writing in response to the publication of the proposed changes in the NRC's emergency planning regulations which were published in the December 19, 197$ issue of the Federal Register.

I have read the proposed regulations numerous times, and would like to-call your attention to what I consider to be several serious problems or deficiencies with the regulations.

My concerns are due to the fact that I live within five miles of the Waterford III Nuclear Plant which Louisiana Power

& Light is presently constructing at Taft, Louisiana. I have read extensively on the issue of nuclear power, including the Report of the President's Commission on Three Mile Island and the NRC's response to that report. What I have read is far from encouraging.

My comments come from a person who will be subject daily-to potential danger if the plant is opened and adequate emergency planning has not been made.

Most of the regulations speak in vague terms, and do not provide any hint of what the NRC would consider an acceptable

! emergency plan. I am particularly concerned with the proposed i

- wording of Part 50.47. I am alarmed that the applicant will have'an opportunity to prove that deficiencies in their emergency-l- plans are "not significant". If an emerge.ncy plan has any l deficiency, it is a significant deficiency. And just what do " deficiency" and "significant" mean?

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[ defined.

These terms are never 1

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Secretary of the Commission

. February 13,-1980 Page:2-I

2. LIn general, alternative B is preferable to alternative A.

'Although more strict than alternative A, I still. feel that alternative B can be greatly improved. The regulations should be- specific, and list exactly what is required by the NRC.

I;can understand the NRC's concern about the workability of the. regulations and their economic impact. It is my under-standing that these proposed changes are merely the first step in~ improving emergency plans.- The_Taft plant is-not yet licensed

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.to operste.- Surely it makes more sense to delay licensing until an adequate plan can be developed and implemented, than to license i .it with an inadequate plan and attempt to patch it'later. Can l' the~NRC justify taking such risks after the Three Mile Island

(- fiasco?. It would save'a considerable sum to draft one detailed, complete plan rather than draft an inadequate one, and have to redraft' the entire thing as soon as the regulations are amended.

If for some odd; reason drafting one good plan is more expensive, I am sure that most consumers would pay the additional cost to know that they are much better protected.-

.I.suggest that the construction permit for Waterford III be revoked or suspended until your regulations are finalized.

This seems to'be the logical decision for the reasons stated in the preceding paragraph.

i l Particular attention must be given to notificatio'n pro-L .cedures'and emergency facilities and equipment. All the planu j -in' .the - world are ' not worth a dime if they cannot be implemented. <

And the plans must be tested and fully implemented prior'to licensing.- - An erargency could occur on the first day of operation. The emergency plan must be complete, and tested.

And that should be stated in the regulations. -

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Provisions must be :made to notify local government, and

-initurn the public, at any' time,~of the necessity of immediate action. ; Emergencies do not happen only from 9 to 5. How do

.you.notifyipeople at.2 A.M. of an emergency. House'to house door-knocking will not' cut it~.-

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Secretary-of the, commission February 13, 1980~

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As bluntly stated in the.Kemeny Commission report, the NRC.has often: failed in'its duty;to protect the public. ~Many regulations _have been stretched or bent, to the advantage of q 1-the utilities. _The_NRC now has.an excellent opportunity to  !

rightLmany past' wrongs. _ByLissuing. regulations which require ithe development and . implementation of detailed, realistic,- 1 if emergency plans, the NRC can assure that the public living '

-in close proximity to a ' nuclear power. plant will be as. safe as'is possible.

I have heard'that over one million people lived within 50 miles of;the Taft plant. I cannot be certain of the f accuracy of that' Anformation, but having lived here all of my life and being familiarfwith the area, the figures'cannot; be _ far wrong. Knowing _that the NRC has erred on the side of the' industry would not be comforting to them. The obligation ,

of protecting l these people rests on the shoulders of the NRC. '

Please' do not fail. Adopt specific regulations at least as strict?as Alternative B..

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~ I' eagerly await your new regulations, and~truly hope that l they will prove tx) be adequate. l 1

very:truly yours, TONY C. TILLMAN

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