ML20042C270

Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan

ML20042C270
Person / Time
Site:	Susquehanna
Issue date:	03/26/1982
From:	CITIZENS AGAINST NUCLEAR DANGERS
To:
Shared Package
ML20042C271	List: ML20042C270 ML20042C278
References
NUDOCS 8203310153
Download: ML20042C270 (2)

Text

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IN THE IGTTER OF 3l'

.PENUSYLVANIA POWER & LIGHT CO. BERWICK ATOMIC POWER PLANT AND SUSQUEHANNA UNITS 1 & 2 ALLEGHENT ELECTRIC COOPERATIVE INC. DOCKET NOS. 50-387 & 50-388 CITIZENS AGAINST NUCLEAR DANGERS PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW FOR THE EMERGENCLEVACUATION PLANS-Due to the inadequate, inconclusive and apparently fraudulemt onergency drills conducted at the Berwick atomic power plant on or about March 18, 1982 (which constitutes important new relevant information in this case) the Citizens Against nuclean DanEers (CAND) cubmit the following' findings of fact and conclusions of law on Contentions 6 and 20,(Emer6ency Evacuation- Plans). -

,The Applicants summary disposition af fidavits, plus their pre-hnarin6 and public hearin5 testimony affidavits presented to the Atomic Safety and Licensin8 Board (ASLB) during 1981 attest to the fact that ,'

.cxtensive emor6ency evacuation plans would be completely tested, thereby '(in their estimation) not necessitatin6 actual presentment of certain direct testimony, ner the need for allowance of cross-examination on certain important aspects of the Emergency Plan, etc., at the public hen rin5s held in October,1981.

The ASLB partially--and wron617--spproved these summary disposition motions over the valid and timely objections of CAND. We concluded then, intuitively, as every party should now know factually, that the l Applicants deceived the ASLB concerning their intentions on compliance i

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with governmental emergency evacuation drill requirements.

There was the explicit understandin8, both on and off the record, th3t a comprehensive test of the Emer6ency Plan would be conducted encompassin6 the ten mile radius of the Berwick atomic power plant site.

18,1982, The so-called emer6ency drill that the PP&L actually held on March '

involved carticination by oniv four of the twenty-seven community This non-compliance with the governments within this ten mile radius.

full test requirements of the Emer6ency Plan certainly impeaches the credibility of the Applicants affidavits previously submitted on Contentions 6 and 20.

The Citizens A6ainst Nuclear Dan 6ers conclude that the Applicants, the Pennsylvania Emer6ency Mana6ement A6ency (PEMA), and the Federal Emer6ency Mana80 ment Agency (FEMA) are in violation of federal and' state laws in this[ matter, and that the ASLB, therefore, should not issue an.

operating license for the Berwick reactors until the appropriate safety laws are complied with.

Incidentially, CAND will definitely appeal all aspects of the Emer6ency Plan test drill insdequacios associated with Contentions- 6 & 20 including pertinent ASLB decisions.

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