ML11307A386
| ML11307A386 | |
| Person / Time | |
|---|---|
| Site: | Limerick |
| Issue date: | 10/25/2011 |
| From: | Ted Sullivan Montgomery County, PA, Dept of Public Safety |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR53498 00035, NRC-2011-0166 | |
| Download: ML11307A386 (2) | |
Text
COUNTY OF MONTGOMERY Commissioners JAMES R. MATITHEWS CHAIRMAN JOSEPH M. HOEFFEL BRUCE L. CASTOR, Jr THOMAS M. SULLIVAN DEPARTMENT DIRECTOR October 25, 2011 Chief, Rules Announcements, and Directives Branch Mail Stop: TWB-05-BO1M US Nuclear Regulatory Commission Washington, DC 205550001 Re: Environmental Scoping Comments Limerick Nuclear Generating Station Division of License Renewal NRC-2011-0166 Montgomery County Department of Public Safety Operations Center 50 Eagleville Road Eagleville, PA 19403 (610)631-6500 FAX (610)631-6536 www.dps.montcopa.org
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Dear NRC Staff:
The Montgomery County Department of Public Safety would like to offer the following comments regarding the NRC relicensing review information presented at the Public Hearing held in Pottstown on September 22, 2011.
" The NRC should provide a full review of environmental and public safety issues pertaining to the plant.
It is understood that emergency responders providing services to the power plant understand the hazards associated with daily operations of the plant. However, in light of events in Japan and recent seismic activity in this area, the NRC should clarify the risks associated with plant operations in times of unusual activity, outage operations, and during times of natural / man-made events that may pose a risk to the plant in terms that the public will understand in an attempt to quell public concern.
We concur that the NRC require Exelon to confoirm to the Montgomery County Comprehensive Plan to not only ensure cooperation in the community, but also in the region.
Additionally it is also suggested that Exelon be included in pending roadway infrastructure improvements projects as both a stake holder and possible source of funding.
It is important to note that the 10 - mile Emergency Planning Zone (EPZ) is the second largest in population in the nation. As a result of recent development and type of development in the area of LGS, it is important to review the Evacuation Time Estimate Study (ETE) on a more timely basis and account for the transient population present in the hotels that have accompanied this development.
Additionally, funding should be supplied for either Exelon staff or County staff to act as a transient planning and outreach specialist to assist these transient population locations with emergency planning.
It should be noted that the Evacuation Time Estimate is currently being updated. Required highway and roadway infrastructure upgrades should be included as a part of and also as a result of any changes noted in the updated ETE. Special attention for improvement should be given to the local, county and state roads used for evacuation that feed the larger highways, as many of these roadways are no longer suitable for the amount of traffic that an EPZ evacuation could produce.
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" The NRC should consider requiring Exelon to enhance planning for day to day emergency situations that require a response from local emergency services. Often times, Fire and EMS access is delayed due to screening of vehicles and personnel.
This can cause delay in patient care to potentially life threatening illnesses.
A note should be added regarding the diversion of Delaware River water to the East Bank of the Perkiomen. Due to the residential build-up along the Perkiomen Creek area, additional consideration should be presented and discussed with the Army Corps of Engineers and the National Weather Service regarding potential flooding impact this may have on the area.
While recreation utilization is of importance and a major mission within this county, homeland security must be of a concern with any open access within the vicinity of LGS. However, we concur that with support of local law enforcement and a commitment from LGS to control and monitor access, trail throughput may be accomplished.
In an attempt to promote and increase community outreach, the NRC should consider requiring Exelon to reopen the LGS Information Visitor Center. As a result of the incident in Fukushima, Japan, the Montgomery County Department of Public Safety has a received a higher than normal volume of inquiries concerning nuclear power generation from the public. The LGS Information Center, although dated, could be upgraded to provide this service to the community to raise awareness and promote education of the nuclear power industry This center could also be incorporated as an educational stop on the County Trail system.
If you have any questions please feel free to contact me.
Very truly yours Thomas M. Sullivan Director of Public Safety CQ R. Graf, CO.O.
M Stokes, Assistant Director of Planning S. Mickalonis, Deputy Director for EmergencyMgt.
J. Wilson, Radiological Planning Specialist