ML20080M745
| ML20080M745 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/14/1984 |
| From: | Bush M PHILADELPHIA, PA |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8402210277 | |
| Download: ML20080M745 (20) | |
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DOCKETED UNITED STATES OF AMERICA USNac NG1 EAR REGUIA'IORY COMISSION arnIC SAFerY AND LICENSDE BOARD FEB 17 /1i0:28 BEEDRE AMINISTRATIVE JUDGES 4
Lawrence Brenner, Chairman Dr. Richard F. Cole s
Dr. Peter A. Morris In the Matter of Docket Nos. 50-352-OL PHIIADELPHIA ELECTRIC CMPANY 50-353-OL (Limerick Generating Station, Units 1 and 2)
CITY OF PHIIADELPHIA'S ISSUES OF COtCIEN WI'1H THE DRAPI ENVIBOtMENIAL IMPACT STATmENT, SUPPLMENT NO.1 I.
INTRODUCTION AND BASES l
A.
The National Envitu== ital Policy Act Mandaters Full Disclosure Of The Envirornental Consequences Of A Requested Federal Action And i
Themafter A Decision As To Whether The Federal Action Must Yield To f
'1he National Goal Of Environmental Protection.
The Congressional purpose in enacting the National Envisuwaital Policy Act ("NEPA" cr "the Act",, Fub.L.91-190, S2, Jan.1,1970, 83 Stat. 852, 42 U.S.C.A. 54321, was stated, inter alia, to be,
[tlo declare a national policy widch will encourage productive and enjoyable harrony between man and his environment; to prmote efforts which will prevent or eliminate damage to the environment and biosphere and stinulate the health and welfare of man;....
Id.
The ensuing declaration of policy in the Act makes it clear that Congress intended that federal officials actively effectuate this goal of protecting and preserving the enviiniment:
8402210277 840214 gDRADOCK 05000352 g 03 4
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all cupnts of the natural environment, i
particularly the profound influences of....new and expanding technological advances and rectonizing further the critical importance of restoring and maintaining environmntal quality to the overall welfare and developnent of man, declares that it is the continuing policy of the Federal Government, in cooperation with State and local goverments, and other wuc+.rned public and private organizations, to use all practicable reans and measures, including financial and technical assistance, in a manner calculated to afoster and promote the general welfare, t_o create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, econcanic, and other recuirments of y _.o and future generations of Americans.
b).. In order to carry out the policy set
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forth in this chapter, it is the continuing sbassibility of the Federal Goverment to use all practicable means, consistent with other essential considerations of national policy, to inprove and coordinate Federal plans, functions, ymt_., and resources to the end that the nation may-(1) fn1M11 the responsibilities of each generation as trustee of the environment for st W Lng p m etions; (2) assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings; (3) attain the widest range of beneficial uses of the envirornental withcut degradation, risk to health or safety, or other undesicable and unintended consequencer,;
(4) preserve inportant historic, cultural, and natural aspects of our national heritage, and maintain, wherever possible, an environment which supports diversity and variety of individual choice; (5) achieve a balance between population and resource use which will permit high standards of living and a wide sharing of life's amenities; and (6) enhance the quality of renewable resources and approach the maxinum attainable recycling of depletable resources.
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', 9, ff 43U.h.C.A'.54331.. (hknphasisadded.) Accordingly, those who act on behalf of
- l the Federal % t have been given a clear direction "to use all practicable d
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neans, consistent lwith other esspntial considerations of national policy, to 4
inprove... Federal... functions....to the end..." of protecting the environment.
-The Act did not and c?ould not say substantively how federal officials
-in carrying out their functions should in each instance follow tMir direction.
'Ihe appropriate course nust obviously be left.to the discretion of the s
% ciate federal official. Masever, the overriding Congressional intent is l
-clear: projects which require federal action may be required to yield to the i
-national goal of protecting and preserving the environment. Arlington Coalition on Transportation v. Volpe, 458 F.2d 1323,1327 (4th Cir.1972), cert. denied, 409 U.S. 1000, (1972).- (Federal highway construction halted ~pending issuance of
-EIS; otherwise "reconsidez'ation would be a hollow gesture.")
Congress explicitly providediin the Act that all federal agencies nust issue an EIS before taking actions:
... include in every rem-miation or report on pr - als for... major Federal actions significantly affecting the quality of the human envirotunent, a detailed statenent by the responsible official on-(i) the envirorsnental inpact of the proposed action,
.(ii) any adverse environmental effects which cannot be avoided should the proposal
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be inplemented, (iii) alternatives to the pwersed
- action, (iv) the relationship between local l
short-term uses of man's e.nvironmental and the Inaintenance and enhancernent of long-term-productivity, and J
(v) any irreversible and irretrievable h
ccanitznents of resources which would be L.
involved in the proposed action shculd it be inplenented.
42 U.S.C.A. S4332 (C).
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Ccusistent with this requirement, the Council on Environmental Quality
'has stated in NEPA's enforcenent regulations that: "NEPA procedures nust insure that environmental information is available to public officials and citizens before decisions are mado and before actions are taken." 40 C.F.R. 51500.1(b)
The courts have stated that the federal agency, Congress, and the public nust have sufficient information through an EIS to independently evaluate the environmental consequences, Coltabia Basin Land Frei.ection Ass'n v. Schlesinger, 643 F.2d 585, 592 (C.A. Wash.1981), c.nd that such a statement nust provide "a record upon which a decisionmaker could make as informed decision." Sierra Club
- v. Frochike. 345 F.Supp. 440, 444 (W.D. Wis.1972), aff'd 486 F.2d 946 (7th Cir. 1973).
"The %=7 of the content of the EIS is determined by a rule of reason...."
Colu.tia Basin, rupra at 592. It nust contain "[a] reasonably thorough' discussion of the significant aspects of the probable environmental
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u.nuit:quences. " Trout Unlimited v. Morton, 509 F.2d 1276,1283 (9th Cir.1974).
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The analysis unst be "sufficiently detailed to aid in the substantive decision whether to proceed with the project in light of the invironmental consequences."
Save Lake Washington v. Frank, 641 F.2d 1330,1334 (9th Cir.1981). The Supreme Court has established that the governing standard as regards NEPA is whether the federal agencies involved have fulfilled the NEPA mandate to take "a 'hard look'
, _ at the environmental consequences." Kleppe v. Sierra Club, 427 U.S. 390,-410, n.21 (1976).
The above legislative history and judicial construction flatly
- contradicts the notion advanced by sane that NEPA is a mere disclosure requirement. To the contrary, Congress clearly envisioned that application of
^the Act might well result in a-federal decision to substantively alter a l
proposed project in order to minimize environmental harm. This was made clear 4-
most'recently in Weinberger v. Catholic Action of Hawaii, 454 U.S. 139, 143 (1981), where.the Court noted the " twin airs" of NEPA were "to infom" and "to inject environmental considerations into the federal agency's decisionmaking process." Similarly, in agreeing that develognent of a breeder reactor nust be evaluated under NEPA, Circuit Judge J. Skelly Wright observed:
l These precedural requirernents are not dispensable technicalities, but are crucial if the statecent is to serve its dual functions of informing Ccngress, the President, other concerned agencies and the public of the envitu-dulti affects of agency actions [fcutetel, and of ensuring meaningful consideration of environmental factors at all stages of agency decisionmaking.
[f000otel Scientists' Institute for Public Information v. ABC, 481 F.2d 1079, 1091 (D.C.
Cir. 1973).
Moreover, in upholding the Nuclear Mgulatory Cm mission's
. jurisdiction to review the siting o# a transmission line associated with a nuclear facility, the First Circuit in Public Service Cmoany of Hew Haneshire
- v. N.R.C., 582 F.2d 77, 85-6 (1st Cir.1978), cert, denied, 439 U.S.1046 (1979), concluded that the rendates of NEPA were just at h90fLiuit as those of the Atm ic Energy Act:
...[U]nder the dictates of NEPA, it [the tGC] was obliged to minimize adverse enviiua=ntal inpact flowing therefrm.
[footnotel We quote Judge Wright frcm the Calvert Cliffs opinion,
"[c]learly, it is pointless to ' consider' environmental costs without also seriously considering action to avoid them." 146 U.S. App.D.C. at 52, 449 F.2d at 1128. The Cm mission has statutory authority to condition licenses. 42 U.S.C. SS2131, 2133 (a), 2233.
~Cf. 5 U.S.C. 5551(9);' North Anna Env. Coalition v. NFC, 174 U.S. App. D.C. 428, 431, 533 F.2d 655, 658 (1976). In this instance, the Camission used one of its statutory powers in the furtherance of IEPA, whose mandate the Cmmission nust follow.
The Camission is under a dual obligation: to pursue the objectives of the Atmic Energy Act and those of tha National Environmental Policy Act.
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"'1he two statutes and the regulations pronulgated under each nust be viewed in para [ sic] materia."
Citizens for Safe Power v, NIC, 173 U.S. App.D.C.
317, 325, 524 F.2d 1291, 1299 (1975).
In stumary, it is clear that the requirments of NEPA nust be strictly observed in this proceeding. An envi.mtal analysis nust be produced here which is factually couplete, thoroughly reasoned and pr=4W on the understanding that the federal action here may have to be Inodified if on balance the consequences fcund are unacceptably harmful to the public and the envirorunent.
B.- -Given The Unique Siting Here And The Absence Of A
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.,.. If Generic Standard or Other Final Policy For Assessing The Envirorunental or Public Health l:, 27 "Inpact Of Severe Accidents At Nuclear Cendating Facilities, The Board Must Carefully Review the l.
Severe Accident Consequences In '1his Case And i
Decide Whether Any Alternative or Mitigative Actions Are Needed Here.
t On June 13, 1980, the Nuclear Regulatory Connission issued its
" Statement of Interim Policy on Nuclear Power Plant Accident Considerations Under the National Envina m utal Policy Act of 1969," 45 Fed. Beg. 40101, et
_seg.. arxi expressed therein its intent to henceforth review more closely the possible consequences of severe accidents:
'Ihe March 29, 1979 accident at Unit 2 of the Three Mile Island nuclear plant has emphasized the need for changes in NBC policies regarding the considerations to be given to serious accidents t
frczn an environmental as well as well as a safety point of view.
Id.
In its. licensing decisions prior to that date, no explicit consideration
-was.given to the environmental impacts of severe accidents beyond a design I
basis. As stated by Ccanissioner Asselstine, "it was thought that such 6
u accidents were so unlikely to be virtually incredible."
F. 48 Fed. Reg. 16022 i
- (April 13,1983). We now know differently.
In its Statment of Interim Policy the Comission also expressed its
" intent...that the staff take steps to identify additional cases that might warrant early consideration of either additional features or other actions which I
would prevent or mitigate the consequences of serious accidents." '1he Ccenission uent on to ' state that "[iln carrying out this directive, the staff should consider relevant site features, including population density associated with accident ris)rinwwison to such features at resently cpe&dng plants." Id. at 40103.
G On April 13, 1983 the Ccmuission issued a Proposed Policy Statment 1
that purported to sumarize "the changes in rules, policies, and regulatory practices that constitute the NIC approach for severe accident rulemaking.".48
. Fed. Reg. 16014. In this very recent proposal, recognizing the limitations on the prior approach, the Ccanission stated the new policy would " replace _
unfocused, long term generic rulmaking." For plants under cons + M on there 7
would now be "regdlatory decisions based on generic evaluations and decisions...." 45 Fed. Reg. 16014. For new plants, if any, there will be a standardized design requir ment.
t In its discussion of " Treatment of Severe Accidents in Ongoing Licensing Proceedings" the Comission noted that it had considered whether to require any more current regulations to mitigate consequences of severe accidents.
Id. at 16018. The Ccumission stated that extensive on-going efforts "have not yet pr M v'ad significant new insights into consequence mitigation
. features sufficient to support further regulatory changes, nor have they yet shown a clear need to add such features."
_Id,.
The Comission further proposed that in spite of their 1980 Statement of Interim Policy on NEPA, "the capability 7
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of current designs or procedures (or alternatives thereto) to contal or mitigate severe accidents should not be addressed in case-related safety hearings." M. Finally, the Ccmnission expressed its view that by mid-1984 it
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would conplete its review to detemine if adaitional rules were needed for plants under construction. M.
Under NEPA adequate and full disclosure nust be made of environnental consequences. Until the results are developed and reviewed for this unique Limerick site and its surrounding enviuammit, the Ccmnission cannot reasonably and rationally decide whether alternatives, mitigation actions, or protective-actions are required.
Furthermore, under the Cm mission traditional regulatory approach Z~
persuant to the Atcmic Energy Act alternative design features may be ordered if needed to ameliorate harm to the public. For example, according to previous NBC regulations, "there will be scue water cooled nuclear power plants for which the General Design Criteria are not sufficient and for which additional criteria nust be identified and satisfied in the interest of public safety. In particular,'it is expected that additional or different criteria will be needed to take into account unusual sites and environmental conditions...." Part 50.
App. A.
See also, LEA's Peply To Applicant And Staff Fesponse To Severe Accident Risk Assessment Contentions. Independent of NEPA, it is clear that the Atomic Energy Act requires a review of alternatives, if needed. Tht.; if the NEPA analysis points to unacceptable adverse health impacts, the Cmmission nust consider appropriate alternatives, mitigation actions and protective actions.
C.
The NEPA Fevies For The Limerick Generating Station Does Not Provide Full Disclosure Of Environmental Consequences Of A Severe Accident Or An Adequate Basis For A Reasoned Licensing Decision.
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10n May 6, 1980, the NBC staff requested that PECO make a severe 5
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, accident risk assessment for Limerick which would include "the evaluation of
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. high population densities and p1.tfy-4 power levels en severe accident sequences." Draft Envirtomental Statment related to the operation of Limerick Generatiner Station, Units 1 and 2,- NURIKH974, Supp. No.1 at 1-1.
(Hereinafter
" DES".)
As a result of its review cf.PE00's SARA submission, the NBC Staff concluded, as follows:
I Based on the foregoing considerations of
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enviu _ Aal inpac':s of accidents, which have not' t
been found to be significant, the staff has concluded that there are no special or unique E
cire m stances about the Limerick site and environs that would warrant consideration-of alternatives for Limerick Units 1 and 2.
DES at 5-61.
For' the reasons deem 41=d below, this conclusion cannot be L
~. by the Cenutission at this time because it was founded upon insufficient factual
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And methodological bases.
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An understanding of ~ the Limerick site and its proximity to 4'
j-Philadelphia is essential here. Limerick is located on the-Schuylkill River, a.
L major source of drinking water for the City of. Philadelphia. 'Ihe plant is
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owthtely:21 miles (SER at 2-1) frun the northeastern edge of the City of Philadelphia. The 1980. pr=1ation of the City prw was 1.7 million people (1980 Census) and 4 the metropolitan area, over 4.7 million (SMSA value,1980,
. Census). The entire City and both of its drinking water sources, the Schuylkill
'and Dclaware Rivers, are' located within the ingestion pathway energency planniry zone. l'Ihe predminant wind directions are toward Philadelphia: there is a more than one'in four. chance the wind would be' blowing toward Philadelphia (ESE-16%
Land SE-ll%,' DES at 5-20)..
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o The proximity of Limrick to the high density population Philadelphia metropolitan area and its water supoly not only justifies, but mandates a precise and reasoned analysis of the potential consequences of severe accidents at the facility so that the consequences resulting frm severe accidents can be accurately weighed and factored into the decisionmaking process, including a consideration of alternatives. The developnent of probability of conmquence data separate frcxn probability of release data is essential here. A severe accident is now assmed to be credible. Certainly the consequences of such an accident mst be examined separately frcan the probability of its occurrence.
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The nethodology used in the present DES, igpgly averages the probability of occurrence with the probabilities of consequences. Together with some questionable input assunptions, this methodology reduces and obscures the consequences of an accident, particularly as to the citizens of the City of Philadelphia. The DES also does not, an it shculd, isolate and examine the health effect of a severe accident on the high density populatwn of the Ph41
- 1phia metropolitan area. Those results are lunped together with consequences for all popdation densities in a circle around the. plant. These and other inportant deficiencies in methodological approaches and input assunptions are detailed below.
In sunmary, it is clear that the DES does not contain the necessary information for adequate disclosure, for reasanca decisionmaking or for developing policies to reduce the radiological effects of an accident. The current DES does not emply with NEPA or the requirements of 10 C.F.R.
SS50.20 (b), 51.21, 51.23 (c) and 51.26. Furthernere, such an analysis is needed in this present case in order that the Ccmnission can determine whether it is fulfilling its mandate under the Atcznic Energy Act to protect the public frm tae real hazards associated with the use of nuclear energy. A more detailed 10
analysis nust be undertaken. Based on that analysis, an informed decision can be made as to the need for any al.ternatives, mitigation strategies, and/or protective actions.
II. THE CITY OF PHIIADELPHIA'S ISSUES OF PUBI.lC CONCERN CITY-13 Consequences to the citizens of Philadelphia in to: Ins of dose-distance relationships are not presented in the DES analysis, nor, in fact are such mnepces for any area. 'Ibe absence of this explicit data makes it inpossible for this Camission to accurately ascertain the likelihood of the public receiving doses in excess of Protective Action Guide (" FAG") levels, or in excess of sme other unacceptable level of societal risk, at, for exanple the 21 miles which is the distance a plute would have to travel to reach the City of Philadelphia. Caputer analysis by the City has developed preliminary specific
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dose-distance consequence data for the high density Philadelphia area.* These firdings raise serious questions about the adequacy of the DES.
1 For purposes of this presentation source terms frcan the DES case II-T/NW were used. This sequence is 1/100,000. The ingestion pathway assunptions as to no prot -tive action as developed in NUREG-^396, were also used for these purposes. This analysis is not in all respects one that would be presented, for exanple, in test.Lnony. It is a limited analysis made under constraint of the filing acaaline for the sole purpose of presenting scme dose-distance data and some high dersity population data to the Board to denonstrate the seriousness of the City's contentions.
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Unde these values, should there be a severe accident at Limerick with the wind moving toward the SE Sector, the chance of citizens of Philadelphia receiving a whole-body dose of 5 rem at the City boundary 21 miles down wind frcxn Limerick is 70%; the chance of a 30 ran dose is 40%.
(At the eastern boundary of the City on the Delaware River, scxne 30 miles frcxn the plant, the public has a 55%
chance of receiving a 5 ran dose and 15% chance of 30 rems). In 50% of such severe accident releases, given wind direction toward Philadelphia, the total exposure within the SE Sector in the 20-30 mile range could reach 10.5 million p&scaa-rems. This ocuM result in as many as 8,400 latent induced cancers including 4,200 latent cancer fatalities.
A further analysis is also necessary to delineate the results of a severe accident that might directly contaminate the water sources of the City, the Schuylkill and Delaware Rivers, creating health consequences of an unacceptak s level.
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The Cmmission announced in its Statement of Interim Policy that both the probability of occurrence of release and the probability of occurrence of eniiu4 mental consequences are now to be considered. 45 Fed. Peg. at 40103.
Iogic tells us that if they are to be meaningful these probabilities cannot be presented as a cabined value as has been done in the present DES.
If these probabilities are to be reperately understood and evaluated, they nust be presented seperately. 'Ihe Ccmnission has also stated that these "new treatments... will take into account sig:tificant site-and plant-specific features...."
Id_. at 40103. Again,' strict adherence to this requirement is essential here in order that the significanca of the high density population around the site can be fairly exanuned in isolation in light of the new credibility of severe accidents.
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u The Staff's failure to provide such an adequate analysis violates the Ctanission's rules.. This samary analysis also deprives federal officials of the ability to make a reasoned decision,~and deprives the Congress and the public of real knowledge of the environmental inpact of severe accidents.
. Without this base data, no' reasoned decision as to the need for alternatives or
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'other mitigating action can be made, nor can there be a judgment as to whether c
the public safety requirenents of the Atomic Energy Act are met.
CITY-14 The DES does not accurately reflect either the median or upper estinates of the radiological effects which could result frcan an accident at Limerick W=== several key input assunptions associated with human activity after a severe accident are not realistic.
(a). The base case average evacuation time of 2.5 i
uph is hamad on an 1980 study which is now inaccurate. See also Statanent of Issues of the Canotwealth of Pennsylvarda with Respect
.to Offsite Dnergency Planning, January 30, 1984.
(b) Not included in the base case is the known phencuenon that as evacuees approach the City outskirts,.their apaads would reduce, backups would occur and consequences due to trapped evacuees would increase.-
(c)
It.is unrealistically assumed.that people beyond ten miles would after an accident engage in " normal" activity, i.e., average shielding, and then when appropriate would
. rapidly relocate to safer areas. This assunption nust be more carefully examined in light of the " shadow" ptr.rs rawi, the high population density and any other factors that 3
might be more appropriate in terms of reasonable human response patterns in this situation.
(d) The CRAC model asstunes an unrealistic radial evacuation path away frcan the plant. The actual evacuation paths will vary with road
. patterns.
'i (e) The DES does not separately portray the health consequences of an accident under a
. bad weather scenario. Many weather 13
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scenarios, including theoretically bad weather conditions, are averaged together.
(f) W e evacuation scenarios used in the DES for seiamim11y-initiated accidents present an unrealistic portrayal of health effects W e they unreasonably assume " normal behavior" beyond the EPZ. To the contrary, an earthquake would result in the kind of i
disorganized behavior, such as unnecessary evacuation, that would surely increase adverse health consequences.
C M -15 Se DES does not adequately analyze the Contamination that could occur to nearby 14?id pathq:;, and the City's water supplies sourced
..therefran, as a results of precipitation after a release. A reasoned decision as to enviuamaital inpacts c.4uict be made without a site specific analysis of such a scenario'.
'" he DES addresses at great length releases to groundwater (DES at 5-34 et _seg.), but gives only a cursory and conclusory discussion of
- contantination of open water. (DES at 5-33). mis issue is of crucial concern here as the two major water bodies at and near the facility are the City's only water supplies. The City also has open reservoirs within its boundaries which couki be ' contaminated through precipitation. For an issue of such great inportance, insufficient consideration has been given here. The mandate of NE:PA I
to take a'hard look at environmental consequences has been ignored.
C m -16 DES understates the range of reasonable enviuamaital impacts in terms of latent-cancer fatalities per person-rem because the input values used
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in the health effects model do not include state of knowledge study results.
Se Ccmnission has explicitly required that "[h]ealth and safety risks...shall be discussed in a manner that fairly reflects the current state of kncwledge...." 45 Fed. Reg. at 40103. m is direction has not been followed.
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e It is obvious that environmental inpacts cannot be meaningfully identified and examined by ignoring current data.
CITY-17 The input assunptions used in the cost benefit analysis for the direct benefits and ecorrnic costs overstate the benefits and understate the econcnic costs. This is true for a nunber of reasons. Icong other possible short ccmings, it is erroneously assumed that Limerick power will replace power g
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pr M M frcm PECO's current facilities. In fact, nuch displacement will be of PJM prMM power at' a-lessor cost saving in many instances than PECO prMM power. PECO is a large purchaser on the PJM because the running costs of PECO's
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units in relatively higher F A detailed analysis will also have to be made to determine whether power produced by Limerick, especially Unit No. 2, is replacing mal base load power, whose capital investment is already made. A PECO-specific, as well as PJM-specific, cmputerized analysis would have to be made to determine whether the production of electricity, especially for Unit No.
2, is a benefit to other PJM-members' custcmers or to PECO's cust[mers.
9 III. PIOCEDUPAL MATTERS Pursuant to the Loard's Order of October 28, 1983 (slip op at 9) and a subsequent schedule adopted by the Board at the hearing of January 11 and 12, MLeorardum And Order Confirming Rules Made At Hearing, January 20, 1984 (slip op. at 1-2), the City of Philadelphia tareby subnits its severe accident risk
-assessment filing. This presentation was made after informal discovery responses were verbally received from the NBC Staff and is a refinement of the City's issues previously distributed and discussed by the Board and parties at r
the Prtearing Conference of October 17 and 18, 1983.
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This blocument is tinelys filed under the Board's orders and the principles
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of Duke Power Cmpany (Catadba) Nuclear Station Units 1 and 2, AIAB-687,16 NIC l
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460, 469 (1982).
'j TheinstantfilingisresponsivejtotheStaff'sDESwhichwasissued It was wholly reable, and was so ordered by the
..cn Decentx.r 16, 1983.
Board, that this filing bc nude in the time frame.
IV. CNCIUSION ~
For all' 'the foreping reasons, the conclusion of the DES as to the -
i acceptability of the siting of Idmerick, the asses,anent of the consequences to man and his envirornent of the plant's operation, and the benefits of the plant are based upon an insufficient analysis and nust be rejected.
WitPout the needed revisions di'sNssed above, the Ccmnission and the public will be unable to make reascned decisions as to enviua xutal inpacts and any appropriate alternatives, mitigation actions, or protective actions required for the particular circumstances of Limeric'k's operation.
Respectfully submitted, l
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MARIEA W. BCSH Deputy City Soliciter TYLER E. WIEN Divisional Deputy City Solicitor BARBARA W. !&THER City Solicitor Dated: February 14, 1984 A.
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N UNITED 54ATES OF AMERICA h
NUCLEAR REGULATORY COMMISSION t
ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES s
Lawrence Brenner, Chairman Dr. Richard F. Cole
- o Dr. Peter A. Morris P'
In tb.: Matter of Docket Nos. 50-352-OL 50-353-OL PHILADELPHIN ELECTRIC COMPANY (Limerick Ge'neratir[g Station, Units 1 and 2)u' 4
CERTIFICATE OF SERVICE
~ I hereby certify that the Severe Accident Environmental Impact Iss*?.es of the City of Philadelphia in the above-captioned proceeding have been served on the following per' dons named on the. attached service list by Federal Express or by causing the same to be deposited in envelopes addressed to said persons, first class, postage', prepaid, and deposited with the United States Postal Service at Philadelphia, Pennsylvania 19107.
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Respectfully submitted, t
00 0
MARTHA W. BUSH Deputy City Solicitor s
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Dated: February 14, 1984 (By telephone, ori, February 13, 1984, Administrative Judge Lawrence Brenner granted the Cik bf Philadelphia a one-day extension.)
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s Adm. Law Judge Lawrence Brenner Robert L. Anthony Atomic Safety & Licensing Board 103 Vernon Lane U.S. Nuclear Regulatory Commission Moyland, Pennsylvania 19065 W chington, D.C.
20555 Adm. Law Judge Richard F. Cole Phyllis Zitact Atomic Safety & Licensing Board Limerick Ecology Action U.S. Nuclear Regulatory Commission P.O. Box 761 W2chington, D.C.
20555 Pottstown, Pa.
19464 Adm. Law Judge Peter A. Morris Zori G. Ferkin Attmic Safety & Licensing Board Assistent Counsel U.S. Nuclear Regulatory Commission Governor's Energy Council Wachington, D.C.
20555 1625 North Front Street P.O. Box 8010 Harrisburg, Pa. 17125 Docketing & Service Section Frank R. Romano Office' of the Secretary
-61 Forest Avenue U.S. Nuclear Regulatory Commission Ambler, Pennsylvania 19002 Withington, D.C.
20555
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Benjamin H. Vogler
. Gregory Minor O.E.L.D.
MHB Technical Associates U.S. Nuclear Regulatory Commission 1723 Hamilton Avenue Wighington, D.C.
20555 San Jose, CA 95125
' Mark Wetterhahn, Esq.
Eugene J. Bradley Trsy B. Conner, Jr., Esq.
Philadelphia Electric Company Nils N. Nicholas, Esq.
Associate General Counsel
' Conner and Wetterhahn 2301 Market Street 1747 Pennsylvania Avenue, N.W.
Philadelphia, Pa.
19101 Washington, D.C.
20006
/
i Edward G..Bauer, Jr.
Marvin I. Lewis
.Vice-President & General Counsel 6504 Bradford Terrace Philadelphia Electric Company Philadelphia, Pa.
19149 2301 harket Street Philadelphia, Pa.
19101 Mr.' Vincent Boyer Frederic M. Wentz
-S:nior Vice President County Solicitor Nuclear Operations County of Montgomery Philadelphia Electric Company Courthouse
. 2301. Market' Street Norristown, Pa.
19404 Philadelphia, Pa.
19101-Mr. J.T. Robb, N2-1. 72 Angus Love, Esquire Philadelphia' Electric Company 101 East Main Street
-2301 Market.Straet.4 m- -
Norristown, Pa.
19401 Philadelphia;'Pa. ~19101
.H:n. Lawrence Coughlin Joseph H. White, III H:use of Representatives 8 North Warner Avenue
- Congress of the United States Bryn Mawr, Pa.
19010 Wachington, D.C.
20515 Fr:nk Hippart,' Director, Steven P. Hershey, Esq.
P:nnsylvania Emergency Community Legal Services, Inc.
M::nagement Agency, B-151-5219 Chestnut Street Transportation & Safety Building Philadelphia, Pa.
19139
-Harrisburg, Pa.
17120 Roger B. Reynold, Jr., Esq.
Robert L. Sugarman, Esq.
324' Swede Street Sugarman & Denworth
.Nstristown, Pa.
19401 Suite 510, North American Bailding 121 S. Broad Street Philadelphia, Pa.
19107 p
.o e
y g
w pw-er--een,
n-Ch5rles W. Ellict, Esq.
1101 Building Ecston, Pa.
18042 Jacqueline I. Ruttenberg K;ystone Alliance 3700 Chestnut Street Philadelphia, Pa.
19104 SpInce W. Perry, Esquire
.Artociate General Counsel Fzderal Emergency Management Agency Roos.840
'500 C St., S.W.
r Washington, D.C.
20472 EU.S.N.R.C. Region I 631' Park Avenue King of. Prussia, Pa.
19406 Thomas Gerusky, Director Bureau of Radiation Protection Dept. - of Environmental Resources 5th Floor, Fulton Bank Bldg.,
- Third & Locust Streets Htrrisburg, Pa.
17120 Atemic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Commission JWashington, D.C.
20555
..