ML20154N340

Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operation

ML20154N340
Person / Time
Site:	Seabrook
Issue date:	05/21/1988
From:	Marlone Davis Sierra Club
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR16435, RULE-PR-50 53FR16435-00017, 53FR16435-17, NUDOCS 8806020268
Download: ML20154N340 (1)

Text

_. ._ _ _ _ _ _

I;7 DOCKET NUMBER PROPOSED RULE PR .50

%? * '

(55 FR l(ogssf

'88 MY 26_fM59t Cub Cumber /and Chapter 213 Westmoreland Court Of R3 ., : .s,i s.

Georgetown, KY 40324 00CEElm4 . %' 00 502-863-4267 BRAMH 21 May 1988 Samuel J. Chilk, Secretary of the Commission US Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch RE: CFR part 50, Emergency Planning and Preparedness Requirements for Nuclear Power Plant Fuel Loading and Initial Low-Power Operation The Cumberland Chapter of the Sierra Club is opposed to the proposed amendment to the emergency planning requirements for nuclear power plant fuel loading and low power operation. Our reasons include the following:

The current proposed change appears to be an attempt to address the situation at the Seabrook plant, where accident warning sirens are absent. The Seabrook licensing issue should be dealt with in the context of the Seabrook adjudication not as a rmle change that will affect all new plants.

It is completely illogical not to have the same emergency planning requirements for fuel loading and low-power operation as for full-power operation. Running a reactor that does not meet full-power requirements at low power contaminates it with radioactivity before it is known whether it will ever be able to operate as planned. The nation will have more than enough plants to decommission without decontaminating plants that have run only at low power f or a few months.

Accidents can happen at low power as well as at high power. The start-up of any operation is a vulnerable time.

Moreover, sabotage is always a possibility. If the population needs to be able to be notified when a plant is operating at high pover--and they certainly do--they need also to be able to be notified when it is operating at low power.

h y .[ht e '

8806020265 880521 Mary Davis Nuclear Issues Chair

{DR53h16435 PDR n . ,.v a, . , ,,,,1, . . . ,, , ,,1 n e,,a.r, ,, r u,, , ,,, ,11,, , < n , ra.< r e ovarr,,rc ovninir,, ,,,,,1,,.n,1, r,,, u 0 ~lC

__