ML20080A633
| ML20080A633 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/31/1984 |
| From: | Zitzer P LIMERICK ECOLOGY ACTION, INC. |
| To: | Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20080A636 | List: |
| References | |
| NUDOCS 8402060173 | |
| Download: ML20080A633 (3) | |
Text
limerick ecology actionw BOX 761 POTTSTOWN, PA.19464 (215) 326-9122 January 31, 1984
-2 Pi2:24 6
h Lawrence Brenner, Chair Administrative Judge
' ^
U.S.
Nuclear Regulatory Commission Washington, DC 20555 L
h Dr. Richard F.
Cole Administrative Judge U.S.
Nuclear Regulatory Commission Washington, DC 20555 Dr. Peter A. Morris g
Administrative Judge g
U.S.
Nuclear Regulatory Commission Washington, DC 20555 g/
O Re:
Limerick Generating Station, Units 1 and 2
'7.,
Philadelphia Electric Company
- O Docket Nos. 50-352, 50-353 CC OU Gentlemen:
Enclosed please find off-site emergency planning contentions for Limerick Ecology Action and other coordinated intervenors, in c
response to the Board's Orders of May 16, 1983, Nov. 22, 1983, 6 Jan. 20, o 1984.
LEA, as lead intervenor for off-site emergency planning, received g
contentions from Robert Anthony (F0E), Marvin Lewis, and Joseph White, g
which have been incorporated into LEA's filing, g
.L I
LEA also notes for the Board's consideration that LEA c
was put in the position of filing many off-site emergency planning o
l contentions that allege a lack of in formation realizing that the Board
]
would prefer not to have such contentions before it.
u 6
l Due to the fact that draft Radiological Emergency Response Plans O
(RERP's) for Limerick are still under development, LEA does not wish to prejudice itself by failing to allege informational deficiencies L
that currently exist in the plans.
We have done so, recognizing once O
again that such contentions may be denied without prejudice to a later
.O filing, until such a time when additional information will hopefully be 6
made available.
Where our concerns apply to deficiencies or unmet needs o that apply to all of the draft RERP's, we have provided sample critiques g of each type of plan, as well as specific examples to demonstrate our concerns, without necessarily listing all 3 Risk County, 42 Municipality, g 15 School District, 10 health care facility, and 2 Support County draft RERP's.
G402060173 840131 PDR ADOCK 05000352 O
)
j
< LEA has been operating under a good-faith assumption that it has been receiving all available information on a timely basis, pertainirg to Philadelphia Electric's consultants involvement in the development of drsft local and county RERP's, according to the Board's Order of June 14, 1982.
Ilowever, a recent meeting with the Applicant's Counsel to discuss the filing of these contentions resulted in the realization that in several instances this has not been the case.
A request for information regarding the schedule for the development of implementing procedures for local and county draft RERP's was made on January 26, 1984.
Neither Mr. Conner nor Roberta Kenkus could provide any information; although we received copies of 40 municipal RERP imple-conting procedures via express mail on January 28, 1984 - 3 days before these contentions were due to be received in Washington.
A conversation with the Union Township Emergency Management Director, Mary Catherine Lowery, revealed that this information had been sent by Philadelphia Electric's consultants (ECI) to her in early November, along with a copy of Union Township Draft 4, RERP.
(, November 10, 1983 letter attached).
These draft municipal implementing procedures still fail to provide sufficient information to satisfy LEA's concerns as specified in the following contentions. The impicmenting procedures were reviewed over the weekend to determine if receipt of this information would necessi-tate any significant changes in the enclosed filing. This unexpected additional information to review before the filing deadline made it nocessary for LEA to hand deliver the contentions to Washington on Jcn. 31 to insure a timely filing.
LEA's areas of concern were discussed with other interested governmental participants in this proceeding. The City of Philadelphia is expected to file contentions on the' Ingestion Exposure EPZ. PEMA is expected to raise concerns relating to the need for an updated evacu-stion time estimate study and the need for additional dosimetry materials.
We have attempted to coordinate our concerns with these participants as requested by the Board's Orders.
l l
i Respectfully submitted, Phyl
.s Zitzer, President Limerick Ecology Action J
/
l h-l ENERGY CONSULTANTS RIVERS!DE OFFICE CENTER 3 i 2!01 N. FRONT ST HARR!SBURG / FA 17110 PH Dl7)23E-0031 CORPORATE OFFICE: 1:1 SEVErmi STREE' P;TT3EUR 3H ' PA 12:22-34U / PH (412:434 L230 November 10, 1983 Ms. Mary Catherine Lowery Box 33, R. D. #1 Douglassville, PA 19518
Dear Ms. Lowery:
I am forwarding herewith for your review three (3) copies of Draft 4 of the Union Township Radiological Emergency Response Plan for incidents at the Limerick Generating Station.
As you know, Draf t 3 was informally submitted to the Pennsylvania Emergency Management Agency (PEMA) for review and comment at the state level.
In coordination with the Berks County Emergency Management Agency, the applicable comments have been incorporated in Draft 4 As we discussed during our telephone conversation of November 3,1983, it is this document which will be forwarded to the Regional Assistance Committee (RAC) for review at the federal level. Once again, this is being accomplished with the understanding that your plan is in draft form, is subject to revision, and in no way reflects official policy.of Union Township.
Thank you for your continued cooperation.
If you have any questions or concerns, please feel free to contact me.
Sincerely) j
/
6 Planning Specialist RLD/gmg cc:
Berks County EMA
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