Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations.Changes Would Significantly Weaken Level of Public ProtectionML20150B080 |
Person / Time |
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Site: |
Seabrook ![NextEra Energy icon.png](/w/images/9/9b/NextEra_Energy_icon.png) |
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Issue date: |
06/23/1988 |
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From: |
Richardson D EMPLOYEE'S LEGAL PROJECT |
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To: |
NRC |
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References |
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FRN-53FR16435, RULE-PR-50 53FR16435-01575, 53FR16435-1575, NUDOCS 8807110259 |
Download: ML20150B080 (10) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed ML20248L4071998-06-0505 June 1998 Comment on 980506 North Atlantic Energy Svc Corp License Exemption Request for Changes to TS to Permit 24 Month Refueling Cycle at Seabrook.Requested Exemption Involves No Significant Hazards Considerations ML20248J6751998-06-0101 June 1998 Comment Opposing Proposed GL Re Guidance on Storage, Preservation & Safekeeping of Quality Assurance Records in Electronic Media ML20248J5101998-05-29029 May 1998 Comment Supporting NRC Proposed GL, Augmented Insp of Pressurized-Water Reactor Class 1 High Pressure Safety Injection Piping ML20248C5861998-05-22022 May 1998 Comment Opposing Several Requests for License Changes That Appeared in Fr on 980422,pp 19972-74 ML20217N3091998-04-0202 April 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds: Amended Requirements 10CFR50.55a,Requirements for ISI & IST of NPP Components ML20217H2981998-03-27027 March 1998 Comment Opposing Proposed GL, Laboratory Testing of Nuclear Grade Activated Charcoal, Issued for Comment on 970225. Requests That NRC Consider Impact & Feasibility for Industry to Implement Requirements of GL ML20216C1461998-03-0505 March 1998 Comment Opposing Proposed GL, Yr 2000 Readiness of Computer Sys at Npps ML20203L6071998-02-27027 February 1998 Comments Re Draft Reg Guide DG-5008 (Proposed Rev to Reg Guide 5.62) Reporting of Safeguards Events ML20204A7571997-11-24024 November 1997 Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20211H4231997-09-30030 September 1997 Comment Supporting Draft NUREG-1602 & DG-1061 & Encourage NRC to Carefully Consider Comments as Well as Encl Comments ML20141G9691997-07-0303 July 1997 Comment Opposing NUREG-1606 Re Proposed Regulatory Guidance Related to Implementation of 10CFR50.59.Licensee Supports Approach Proposed by Nuclear Energy Inst ML20148N0561997-06-19019 June 1997 Comment on Proposed Supplement to NRC Bulletin 96-001, Control Rod Insertion Problems. North Atlantic Endorses Concerns & Considerations Presented on Topic by NEI, Westinghouse & Wog,Specifically Control Rod Testing ML20077M7431994-12-27027 December 1994 Comment Supporting Proposed Rule 10CFR50 Re Shutdown & Lower Power Operations for Nuclear Reactors ML20078N0281994-11-30030 November 1994 Comment Supporting NRC Initiative to Issue GL to Reconsider Positions Re Certain Security Measures to Protect Against Internal Threats at Npp.Supports Comments Presented by NEI ML20071H0761994-06-29029 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Which Requested That NRC Change Frequency That License Conducts Independent Reviews of Emergency Preparedness Program from Annually to Biannually ML20057F7181993-09-13013 September 1993 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Exercise Requirements ML20045F7841993-06-18018 June 1993 Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Opposes Rule ML20245K4201989-08-0707 August 1989 Comments on Draft Reg Guide,Task DG 1003, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Funding Schedules Should Continue to Be Developed by Utils. Recommends That App B 3.1 Be Revised to Read as Stated ML20248B6201989-08-0202 August 1989 Comments on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. NRC Should Permit Use of Potential Tax Refund as Source of Decommissioning Funds ML20246H8851989-07-0606 July 1989 Comment Opposing Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T3581989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs for Nuclear Power Plants.Util Endorses Comments Filed by NUMARC & Nuclear Util Backfitting & Reform Group.Rule Fails to Provide Basis for Determining Effective Maint Program ML20196D0091988-11-0303 November 1988 Forwards Constituent Rj Perry Comments Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20205Q1501988-10-28028 October 1988 Comment on Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear Plant License Renewal. Safety Sys Functional Insps & Configuration Mgt Programs Support Renewal Basis as Opposed to Relicensing Process ML20151L9621988-07-26026 July 1988 Comment Opposing Proposed Rules 10CFR170 & 171 Re Revs of Fee Schedules.Requests That Commissioners Reexamine NRC Current Budgetary Processes in Order to Provide Greater Assurance of Reasonable Correlation Between Svcs & Costs ML20151H3561988-07-22022 July 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20150E8641988-07-11011 July 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20150E8681988-07-0606 July 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20150C4781988-07-0101 July 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20150C0131988-06-28028 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196K2431988-06-25025 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196L2631988-06-24024 June 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196K8161988-06-24024 June 1988 Comment Opposing Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F2101988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F2131988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F3111988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F2671988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196G2591988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F0911988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F2951988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F1641988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F0961988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations ML20196F2591988-06-23023 June 1988 Comment Supporting Proposed Rule 10CFR50 Re Emergency Planning & Preparedness Requirements for Nuclear Power Plant Fuel Loading & Initial Low Power Operations 1999-09-02
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THE PACKING BOX TEL No.617308dddl Jun 23.88 11:22 No.001 P.02
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'D' OPOSED RULE -- -
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PR(f3 FR /W3Q UNITED FFATES OF AMERICA 1
% M/k g NUCLEAR REGULATCET COGGSSION Proposed Rule: 10 CFR Part 50 ) oEGca ofSmt /gg k W'g Energency Pleaning and Preparedness
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l Dr.4YIt'8 LEGAL PROJECT CODNENT8 Introduction The 0.8. Nuclear Regulatory constission has issued s propeeed rule
- to establish more clearly what energency plaaming and preparedness requineents
. are needed for fuel leading and lowr power operatten of soclear power plaats?"
N proteced rule weald amedd 10 CFR %.47. N practical effset of the pre.
posed ru5e would be to replace the cesaltaent made by tne Cosmaission, in the preamble te its rule M.47 (d) issued July 13, 1962, to review certain aspects of the applicaat'< 'Isite plans cited in Sectien 2.47(b)(3),(5),(6),(8),(9),
(12), tand (15), limitaties of the CeamissLes's review to ealy those aspects of the applicant's emerlency plemming and preparedness which would support as easite emergency reopease, cited in the proposed rule as M.47(d)(1) ,
l OteethoS9'Af td)TW .. .
It is the censidered posities of the Employee's Legal Project that the pro-peeed rule weald significantly weaksa the level of protecties of the public health and safety provided under the Ceamissioe's current eastgency plamains review peliay; that the level of. protection provided urAer current Commission policy serves 19 unet a valid need to ensure ,the public saf.ety, bo);h as 4
.8*seric iseos and specifically with' ragard tm 4e4 brook Station; and that the Coeudasies's proposed rule is inappropriate under these cipecastaa:es, M
g71g259880623 50 53FR16435 PDR -
THE PACKING BOX TEL No.6173884441 Jun 23,88 11:22 No.001 P.03
I. Tha Procesed knie Would Stanificantly Weaken the Current Invei_ of fretecties of the public4aelth and Safeity.
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The rule as issued in 1MO did met differestiete be.tvoes low power sed fall I power licencias, se naarde eenrsency pisanias and propendness. Ignea th cesadselen issued its gevised rule in 1M2, altheosh the consissies ruled that prier to issuing a low power license it would be rehired to review eely tha applicaat's easiH plane, it said in the rule preeable that it would at that time review the aspects of the applicast's plans cited to 50,47(b), this stated coenitanat la effect established an esorgency plamaing/preparodotes review prec-tice for les power licensing which has beam followed free that time satil the preeest, imeludies evaluation of the following aspects of offsite plasmies
,, which relate directly te ,the proteetles of the public health and safetyr
- arrangensats for identifying sad stilising assistance researces '(50.47(b)(3)).
astificatles ei respenee erskg:atiens sad peroesnel ,(50,47(4)(5)).
. early notification and imetraction of the peblic (50.47 @)(5)).
- eeumusications emees roepenee organisations, pereeeeel and the public' (50.47 ())(6)). ;
- in-use monitoring of actual er potential offsite ceneequences (50.47(b)(9)).
- previstes of emergency feetilties and equipment (50.47(b)(8)).
- arrangesents for medical care for-contamiaated injured pereess(50.47(b)(13)).
radielegical energency treir.iag for assistias perseenal (50.47(b)(15)).
The aspects of et.feteacpastsency plameias which an included in the Ceumis-stea's entreat. review policy are precteely these which provide, at a minimum, a mechaatse td enable the identificat es of, and developeemt withis a reasen-able time of a reopease te, potential threets to, the public health sad esfety.
Na must assume that this das inteaded by .the Commission to address a specifically
JHE PACKING BOX TEL No.6173884441 Jun 23.88 11:22 No.001 P.04 9
actu t construction gustity. la these circumethaces it is not yet established i .
that the level of pnteetles afforded by the eestalassat is as high as may b
' assumed by the Coentastem.
The aheve factere usy sentrikte negatively to the third exted by the Coenis-S siest that enough time wed1d be available te mitigate accident coesequences. 0 Operator errors, equipasst esfacts, and unevallable er less capahls safety sye.
tear esa work, sigly or cellectinly, to rekee the ties available to mitigate the ceasequences of as accident.
, la ' light of the aben, circumstances, ELF don 81deitf'th5 Mt#di Mik to tha pt1.14 from low power operation of Seabrook to be significantly greater them thesCesmission a,'asames as a generie conditten. Any relaxaties etths surrent policy would therefers be inappropriate, i A.
N Ceamieston's preeeeed kule Is Iseeerspriate.
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y .
In the Federal Register metico gf t) propeoed rule, the Commissies ststes 1
that tha basis for the 19,62 rule change, which established the current rule and the eCennission's stated policy of reviewing this specified aspects of offsite plasmias,
"...was the Consissies's estermination that the degree of emergemey planaiag and preparedescs necessary te provies adequate pr6tecties of the public health ** and safety is sigstficantly less them that' required for full power oper-I ation...." Furthermore, the Oeemission states that "...the Commissies reevaluated
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JHE PACXING BOX TEL No.6173884441 Jun 23,88 11:22 No.001 P.05 3
delianted level of risk judged to be present in low power operaties, Under the proposed rule, however, review by the Cosmaissies of these offeite F
plakaiag aspects would be ustricted solely to their previskne for assistance by offsite esencies in the event of an easite emergency, with no review as to the capability or availability of the subject agencies, perseamel, procedores, er equipment to perform say of the functions cited in the current rule which any hacena necessary to pntact the baalth and safety of the public effsite.
N sete esceptione are the notification of response organisations by the 11 consee, and the availability monitoring methode and systems, both of whicha@
weakened by the propeeed ru1,e.
The limitaties of nyiew contained in the proposal would effectively remove any assurance that civil authorities in the area surrounding the plant would have available to them the manpower, communicstionsffacilities and pre-i l
t.
cedures, traiains, or medical er emergency facilicio er equipeast in piece l to respeed to as incidest having actual or potaatial offsite cessequences, if g one should occur, N Cesmissies maintains that enough time would be available l
to orgaalse and carry eut such a reopense in the absence of these provisions, citing a worst case time period of can hours avellable for precautionary actions to be taken, Decent experience would indicate that this conclusion is not accurate. A fin at the Johnees Chemicals varabeuse in Seabrook, ER,,
ocestring in early spring 1934, nquin4:the evacuation of fewer than ene l
l hundred people from a notShboring trailer park, Despite the esa11dise.4f hthe l'
evacuation effort required, sad the f act that only sea local jurisdicties was inwired, the incident devaleped into a cesfused leadership situaties whieb eegendered a series of destradictory instructions to the reatdeuts. N ene-unties process teek ese to two hours to complete. ELP f f Ws it tacredible that
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the Ceemission states that the safety;of a potentially many tiens larger pop-ulaties can be massaably assund without, at thei least, wrifying the previs-ion of adequate aschanisms and equipsont for N censuaicaties and eeerdisaties of the local public safety authorities.
The proposal would furtberare rescind any requirement that an emergency notificaties system be in place prior to low power licensing. As with the other aspects of offsite plaaming, N Ceemdssion la 1962 committed itself to aview.
ing h satabitshmast of such a system, h Ceessissients justification for rescinding this Nguireatst is of insOfficient merit.
It has not been establishedp not even argued by the Ceumissies, that the risk to tbs pubite which voeld necessitate the previsisu of a notification system has abated sinec 1M2. In f act, the oppeaita is true. W Csemissies states is its original tule that a major f acter in this requiremskt, if not the only facter, is the prettation of panic among the public if as incident were to I occur during low power operaties. Since that time, publicity about W
. Chernobyl accident has increased the concera of N semeral public for their potential danger in the event of any incident. This was brought to E1.p!s I
attentiemby the tesetion to sa incident at Seabrook in February 1987 is which
. a centainment airlock valve malfunctioned, and amether shortly af terward in which steam was released free safety valves at the plant. These events them-selves furNr increased public fears abwt the reliability of the Seabroek f acility. Beth events caused a great deal of cesfusion and concern among the public: Seabroek police received somerous calls aheat the ascend event. It was known at the time that the plant was met operatias. If an incident were to occur while the plant was known to be operating, even at les power, with no provision for immediate mass broadcasting of reliable informatten - which only
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JHE, PACKING BOX' TEL No.6173884d41 Jun 23.88 11:22 No.001 P.07 a esatralised system each se the seabnek sires and prepared massages system :
.1 eesid he espected to pewide . the result would inevitably be shoes.
. v
.__ De Level of Protection Provided Under current -
_ _ _s_ sion Polier Serves to that a Talid Reed.~ '
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Is its metice of the propeeed rule the Cownissies acknowledges that is low power operaties inexpertoaced operater* ~'ay 20ce more mistakes, and that there is a seseter pe ential for sadiscovet.'d defects to manifest themselves. As regards BeahM, the Crea'.ssion's admewl%dgsucht is retafereed by recent 20 A ties reports. As umgee. ELP wistee to site the following:
- light est of f!f teen licensee Event Reports oespiled in the latent,$sabrook
$ ALP own des to operator errorf W fin to defective cometraction er coupe *.
nests, musindiested that the rate of operator errors and luk of stteatten to detail in operaties were subjects of eencert. Fine of thd fifteen 1 W e precipitated Engineered safety Feetsne eetuattees.
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Of particular concers te ILP is the proposed modificati,em of the current N
- ) 50.47(b)(9) requirement for poetisieme for monitorias offsite comoegoences from "in mee" to 'available." his modificaties has the potential to casos delay I in the identification of an eetual o'r potential hasard to the public stenaies I
frwe a redfelegical osargency. Seabroek opersying perseasel have, during as 4
l .' Desenal great on Feb. 11, 1987, and a f a&1ure of the centrol room ventilation inelatten equipment in oprius IM7, and assia in sa emersaaey preparedness drill on Dec. 1.5, 1987, failed repeatedly to identify conditions requiring beightensd awaressestefootegylegv&powerfpeeferunace,,and to take appr=priate eetiene.
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I ,THE PACKING BOX TEL No.6173884441 Jun 23,88 11:22 No.001 P.08 w ,- .
6
It siwald be noted that the Dec. 15,1984 esercise was specifically designed to demonstrate that thsee falleros of awareases had been corrected, yet the eser-
- stee centre 11ers had to prompt staties perdessel to take acties la order to
- t istfill their p omario, Seabrook has yet te demonstrate that its peteennel ,
can be depended 'en to prouptly recognise when ass-rootias measures to tasure the publid safety need te he takaa. ,la. Itsht of hkis cireamstance, ELF attently recounnada that the current requirement that asaltering progrene and systems he "in use" set he modified as propeeed. ,
- - Through IM7 a series of ficiencies and malfweetiene of the Centrol Bail-dias Air Bandling lystes eere identified, which prevented the system fres fulfilling ice safety fsnetiens. These were feeed when the system failed in use. A nejer redesign is pionned af ter low power testing.
- Nough 1987 a series of deficiencias and malfunctions were identihted in the Beergemey Feedvetor eystem and shrtup feedweter pway. N eo were feoed when the equipeest fai? perform adequately in testing. My were addressed by system modificatis A relaxaties of seceptsace criteria., 'EFW is a safety system; the SOFF serves as a backup EFW peop. .
- N Primary Ceepenamt Cooling Water heat enchagers were manufentured to a '
~
'eenfisoraties whicEau'edtM oroetes of its-tebing 'te the extent that 2/3c4f ,
' ~ ' --
- It'of the tubes in een, and a like amount in the other', had to be repaired.
af ter het fumettesal testins. b faulty eenfisvrettes esamet be cerroeted des te speca , limitations; thus tube erestem will centinos. This is a safety system. ,
Seabroek has hoes trylag staco 1985 te gorrect deterioratias seats la a group of valves, identified due to in-service entfonettene. It has met yet been esteh-liehod whethat the latest repair techatque will withstand service. These are seed LisafeEy systems.
,THE, PACKING BOX TEL No.6173884441 Jun 23.88 11:22 No.001 P.09 7
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1a as och as the sited tastenoes, fless with eWrs, demonstrate Nt opr,et1,as ,
perseemel errors and sodioceverId defects are met spoeulative het rather actual econe 3s, & Ceemissien should assign taeressed weight tis these fasters in deteralaing W risks of low power operation,
'N Cecisaise cites in oppeetties to the abess achaowledsenesta three facters which it statas reduce & risks of kov power operaties. ,
The first etted is the fact Nt fission product inesatory is miniasi. This is rebutted by W Oslen of Concera*4 Scientists in commaats or, the 1962 rule chasse.
The seceed fatter cited is the f act tk e safety systems are met required to provide N'ir'fv11 capacity at low power. rtrwould again cite the 1982 008 causesta as robottal. In particular E1.P wisces te oeement en the tuplicit assumy.
ties that these systems would he evallable as moeded, part of the propes4d testias would involve the dafsat of certain systems in order to ageess &
perforusses of others. Bowever, incidents such as bos cited in ELP's discus-
, sien of wadioeevered defects densmetrats ht there is' a oeseiderable degree of unreliability la the availability of Maat safety systems.
' As sa spangle, ELP si,tes s 'oerijs of failurse is operaties of ea r:Ma of the service water, primary component cooling, and resietal heat reaeval kystems, ,
T*6ehr these systems serve W foncties of coelius a member of eafety eesposeats is operaties, and alae of removal af' decay heat from b roseter eere.I
- i It 14 aseemed by E12 that they will be required to be operdble to support law i
power teettag, and sabeequest plant coeldova. As cited ahevo, in W past year both PCCW heat exshangers han required repair as well as a group of pit valves.
A154,cemiE RR eystem has f ailed dee(te ereeked welde, and both RR pomys how
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.JHE, PACKING BOX TEL No.6173884441 Jun 23,88 11:22 No.001 P.10 8 l
.-' j repind repair as has a PCOW check valw, Because of the interniated' fumetiens of thsee systems, and the tinies with
. which those failuna have occurfed, sees instsacas how dowleted where the ,
has been deprived of the availabilicy of both treine of the Pccr er tem systems
,' siwsitaaseusly. In coping with these ocevrrences, the plas't' has had to oesplete repairs te one trala of a system befete any availability could be restered, and '
in ses easette est4bitbh a highly sedsul and emeralmated coalisuratten involving various components of tise tesias of the 700W, Raa, and centstammet seeling systems is ordar to provide a sisteue available m fsacties.
What is of particular sencera te ILP is that 8sabzwek Ladicated to NRC staff that it would perfefs similar actions in t'ha future as it felt wars desirdle
. te its perpeces, imelodies dering operatien when there are no great ameoste of
' decay heat prosest. Thid voeld preseably include low power operation. This '
r indicates to ELP that the plant anticipates terthar problems with the availability of safety systems, and is attempting to swid cessittius'itos!f to providing '
evallability of all repired safety systems spea which approval of its operaties had haea predicated, lac staff hs.s met yet decided whether this positica is acceptable. la RLP's judgensat each actives cM1d Ledrasse risks to the public associated,with the plast's .,
operaties, ELF wesid aloe mots, aEdgered.O #eabreek contatsnaat latogrity, that it has handled allegattees conceraits impwper wantreeties and oeecute orcking in
[
the containment beilding; and that unreselnd items identif'ied by 20 in iswati '
gaties of eescrete goalitys11gutione %ect thru safety stuctures have met yet A.
i been closed est. la toatimesy beF m tbe new aampektre lieuse Ceemdttee se science, Techselegy and Easygy, Jr, Richard Wilson'steted that tbs probabilistic risk usesensat fort scabW had been hamed on the centaimmaat osatsu, met its k .
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THE PACKING S0X TEL No.6173834441 Jun 23,88 11:22 No.001 P.11
.. I 10 and sees no reason to doubt the safety rationale stated by the Coassistion in promulgating its 1962 wie."
In fonulattag the 1962 rule, the Commission does not arlos that rf.dk to the public free low power operation is absent. Rather, the Commission's astablished policy of review of the specified aspects of offsite planning wesid appear to recognise the presence of a definite, albeit possibly reduced, risk to the public. Nor does the Commission argue now that the risk to tha public from low power operation has lessened. Indeed, ELP contends, as :is.deseribed.-
abeve*, that the risk to the public from low power pperation at Seabeook is greater than acknowledged by the Commission.
The Coussission, in its notice of proposed rulemaking, fails to provide any justification based upon abated risk to the public for relaxing its current emergency preparedness review policy for low power licensing, In the absence I
of such justification, iELP..ishab<< concluded that. the attrib 4tes of the offsite energsacy plans which the Commisaies coussittad itself to reviewing in the presable of its 1962 rule must still be reviewed for adequacy prior to the '
of a *.. .* - '
issuance of a low power license for Seabrook er any other nuclear power plant tu order to maintain the prueent level of protection of the public health and safety which the current rule and rwiew policy prwide.
DATED:
g jg Respectf ally esbetitted, h .Dousias E. Richh (rdson &
. Researcher Employee's 143al Projoct P.O. Bot 633 Amesbury, Ma. 01913
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