ML20079R438
| ML20079R438 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/30/1984 |
| From: | Ferkin Z PENNSYLVANIA, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8402020229 | |
| Download: ML20079R438 (4) | |
Text
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J CCL F.ETE:
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
'84 FEB -1 All :12 l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L l. C~ h t.
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0;;: Gj.i & SEf V,^
In the. Matter of
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PHILADELPHIA ELECTRIC COMPANY
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Docket Nos. 50-352 (Limerick Generating Station,
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50-353 Unit 1 and 2)
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Statement of Issues of the Commonwealth of Pennsylvania with Respect to Offsite Emergency Planning a
In accordance with the Atomic Safety and Licensing j
t Board's orders issued Novemoer 22, 1983 and January 20, 1984, the Commonwealth of-Pennsylvania hereby files notice of issues on which it wishes to participate with respect to offsite emergency planning.1 In light of its important overall role in coordinating and administering emergency planning matters, the Commonwealth intends to participate in upcoming hearings on offsite emergency planning matters to the extent consistent with the provisions of 10 C.F.R. 52.715(c).
The
-1 10 C.F.R.S 2.715(c) authorizes the Board to require an interested state participant "to indicate with reasonable specificity, in advance of the hearing, the subject matters on which he desires to participate."
R402020229 840130 PDR ADOCK 05000352 O
Y 5
I Commonwealth also lists here specific offsite emergency planning issues it believes must be resolved in this j
proceeding:2 3
I.
No operating license for the Limerick Generating Station, Units 1 and 2, should be authorized until arrangements are in place for procurement, and distribution to all offsite emergency workers identified in the state, county and municipal emergency plans as requiring dosimetry, of adequate numbers of self-reading (0-20R and 0-200R) and e
permanent record (thermoluminescent) dosimeters.
t 50.47(b)(10), (11); NUREG-0654, Rev.
1, " Criteria for
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Preparation and Evaluation of Radiological Emergency i
Response Plans and Preparedness in Support of Nuclear Power t
Plants" (November 1980), Criterion K.3; FEMA-REP-2,
" Guidance on Offsite Emergency Radiation Measurement i
Systems, Phase 1 - Airborne Release" (September 1980).
evalaation II.
The applicant must prepare an updated l
time estimate study for the Limerick station plume exposure pathway emergency planning zone (plume EPZ).
The evacuation
~
i time study the applicant has submitted to the Nuclear is outdated and based on Regulatory Commission for approval i
As intended by the Board, representatives of the LimeFick Ecology Commonwealth have met with the applicant, Action, and the City of Philadelphia prior to today's filing t
to discuss and coordinate offsite emergency planning issues.
L i
m Deficiencies in the study include, inaccurate in fo rm ation.
u but are not necessarily limited to, reliance on out-of-date
.f 5
and inconsistent census data (see pp. 1-6; 2-8; see also pp.
2-11-2-13 and 3-4-3-7); use of incorrect evacuation routes (see pp. 3-9-3-12; 3-14-3-17); use of a concept of " maximum evacuation time" that does not accurately reflect the size M
of the plume EPZ, (see p. 3-18)', and failure to account for the notification system to be installed by the applicant.
10C.F.R.)50.47(a)(1), (2), (b)(10); 10 C.F.R. Part 50, Appendix E, Section IV; NUREG-0654, Rev.
1,
" Criteria for (November Preparedness in Support of Nuclear Power Plants,"
1980), Criterion J.8 and Appendix 4.
Respectfully submitted,
a
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& Q.
W Zori G. Ferkin Assistant Counsel Commonwealth of Pennsylvania Governor's Energy Council P.O. Box 8010 1625 North Front Street Harrisburg, Pa.
17105 Date:
January 30, 1984 I
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UNITED STATES OF AMERICA c a r.E q :
NUCLEAR REGULATORY COMMISSION 7U7 e
BEFORE THE ATOMIC SAFETY AND LICENSING B_QARDTEB -1 All :12
=
og In the Matter of
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Philadelphia Electric Company
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Docket Nos.YC508352& sERvm
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M (Limerick Generating Station,
)
50-35pCH u
Units 1 and 2)
)
E CERTIFICATE OF SERVICE
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I hereby certify that copies of " Statement of Issues of the Commonwealth of Pennsylvania with Regard to Offsite Emergency Planning" in the above-captioned proceeding have y
been served on the following by United States Postal Service
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Express Mail this 30th day of January, 1984.
Copies have been served this day on the remainder of the service list in the above-captioned matter by deposit in the United States mail, first class, or through deposit in the Commonwealth of
- j Pennsylvania's internal mail system
c Lawrence Brenner (2)
Troy B.
Conner, Esq.
g Administrative Judge Conner and Wetterhahn
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Atomic Safety and Licensing 1747 Pennsylvania Avenue, N.W.
Board Washington, D.C.
20006
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U.S. Nuclear Regulatory Commission Benjamin H. Vogler, Esq.
5 Washington, D.C.
20555 Counsel for NRC Staff Office of the Executive Legal Director
~ Richard F. Cole U.
S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.
20555 Atomic Safety ana Licensing Peter A. Morris l
Board U.S.
Nuclear Regulatory Administrative Judge Atomic Safety and Licensing Board Commission Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Respectfully submitted, N
Zori G. Ferkin Assistant Counsel Governor's Energy Council Date:
January 30, 1984 y
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