ML20087M632
| ML20087M632 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/23/1984 |
| From: | Ferkin Z PENNSYLVANIA, COMMONWEALTH OF |
| To: | |
| References | |
| NUDOCS 8403300122 | |
| Download: ML20087M632 (7) | |
Text
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12'b3 UNITED STATES OF AMERICA 0th
~
NUCLEAR REGULATORY COMMISSION M tlAR29 pi:oy BEFORE THE ATOMIC SAFETY AND LICENSING BOARD bfahf $5 '
9 EU Ncy In the Matter of
)
)
PHILADELPHIA ELECTRIC COMPANY
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Unit 1 and 2)
)
Response of the Commonwealth of Pennsylvania to Limerick Ecology Action's " Supplemental Information on LEA Off-site Emergency Planning Contentions" In accordance with the Licensing ~ Board's oral directive at the prehearing conference held March 5-8, 1984, the Commonwealth of Pennsylvania hereby responds to additional information filed by intervenor Limerick Ecology Action
.( LEA) with regard to several of LEA's off-site emergency planni'ng contentions.'
Parties were directed to serve the Board with their responses to LEA's supplemental filing at the prehearing conference held March 20, 1984. Tr. 7987 Because LEA did not serve its filing on the Commonwealth either by express mail or hand delivery, counsel was unable to provide the state's response at that time.
At the March 20, 1984 prehearing conference, the Board orally granted the Commonwealth leave to. file its response by Monday, March 26, 1984.
8403300122 840323 PDR ADOCK 05000352 Q
PDR 40^5
g N LEA-13 (VIII-33):
LEA's additional filing provides a list of day care centers, pre-school programs, and day and overnight camps located within each Risk County.
The staff of the Pennsylvania Emergency Management Agency (PEMA) is reviewing this list to determine whether these facilities are identified and accounted for in the municipal plans.
Without further information than LEA has provided to date, the Commonwealth cannot determine whether, with regard to day care and pre-school programs, such facilities are the type of private school that must be included in school district plans.
See Annex E at E-31.
Day and overnight camps are considered private enterprises and thus are responsible for developing their own plans.
To the extent any of the identified facilities have'or are in the process of developing their' own emergency plans, the municipal emergency management coordinator should be provided with a copy of such plans for. review to. ensure consonance with the municipal, and ultimately the county plan.
PEMA also has provided this list to' the applicant's consultant for use in preparation of.the-evacuation time estimate study.
LEA-20 (VIII-41):
LEA states that as of March 12, 1984, Charlestown and South Coventry townships located in Chester County have not designated Municipal Emergenc y Operations
~
Centers (EOC).
These EOCs must be designated and identified in the respective municipal plans prior to the full-scale exercise scheduled for. July 1984.
Further applicant's j
statement in its response to LEA's supplemental filing (at
3 s
p.4) that municipalities may share a combined EOC with an adfacent municipality is correct only in the circumstance where the municipalities involved develop a common emergency response plan which describes actions that will be taken in the combined EOC and provides for a single, combined EOC staff.
1
_ LEA-28 (VIII-53):
LEA correctly characterizes the information provided by PEMA with regard to the response capabilities of the Pennsylvania National Guard.
LEA also
~
accurately states that the Commonwealth supports that 1
portion of LEA-28 that questions the availability of
,non-state provisions for towing, gasoline supplies and snow removal.
It should be noted with regard to applicant's response to LEA's filing (at p. 5) that the Pennsylvania I
National Guard neither has resources for snow removal nor has responsibility for the activity under the state plan.
See Annex E at E-24.
'07 LEA-17 (VIII-37)t LEA here lists numerous asserted defi iencies in two township plans as " examples" of the basis'for its allegation that the municipal plans are not adequate.
PEMA's preliminary review of the listed items indicates that LEA has identified many aspects of the plans that are significant when considered in their totality and must be resolved before these plans can be implemented.
Nevertheless, in its present form LEA-17 does not constitute a litigable contention'.
N LEA-3 (VIII-23) cnd LEA-4 (VIII-24):
LEA identifies a
portions of the two support county (Bucks and Lehigh) plans that it believes are crucial to implementation of the Risk County plan for Montgomery County.
LEA does not identify any. " gaps" in the support county plans ; rather, LEA ' simply points out portions of those plans that interrelate with planning for Montgomery County.
Because LEA presents no basis for its implicit assertion that Bucks and Lehigh Counties will not eventually adopt their plans, LEA-3 and LEA-4 do not present litigable issues.
The Commonwealth would note, however, that the counties must adopt their plans before PEMA will submit them to the Federal Emergency
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Management Agency (FEMA) for approval.
Respectfully submitted, __
-~
s Zori G. Ferkin w~
Assistant Counsel Commonwealth of Pennsylvania Governor's Energy Council P. O. Box 8010 1625 North Front Street Harrisburg, Pa.
17105 Date:
March 23, 1984 cc:
Attached Service List O
UNITED STATES OF AMERICA UC[ff[ED-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD MR 29 p3;gy hg"hf[C;.
In' the Matter of
)
)
BR*7
= V /!i",
PHILADELPHIA ELECTRIC COMPANY
)
Docket Nos. 50-352
)
50-353
)
(Limerick Generating Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Response of the Commonwealth of Pennsylvania to Limerick Ecology Action's Supplemental Information on LEA Off-site Emergency Planning Contentions" in the-above-captioned proceeding have been served on~ the following by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Commonwealth of Pennsylvania's internal mail system, this 23rd day of March 1984:
Lawrence Brenner (2)
Docketing and Service Section Administrative Judge Office of the Secretary Atomic Safety and Licensing U. S.
Nuclear Regulatory Board Commission U. S. Nuclear Reg ulator y Washington, D.C. 20555 Commission Washington, D.C.
20555 f
Richard F. Cole Mark J. Wetterhahn, Esq.
Administrative Judge Conner and Wetterhahn Atomic Safety and Licensing 1747 Pennsylvania Avenue, N.W.
Board Washington, D.C.
20006 U. S.
Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555:
Board Panel U. S.
Nuclear Regulatory Commission Washington, D.C.
20555' t
Peter A. Morris Ann P.
Hodgdon, Esq.
Administrative Judge
~
Benj amin H. Vogler, Esq.
l A60mic Safety and Licensing Counsel for NRC Staff
- 7. S.
Nuclear Regulat~ory Office of the Executive Legal i
Commission Director r
Washington, D.C.
20555 U. S.. Nuclear Regulatory Commission l
Washington, D.C.
20555 e
~
Atomic Ssfoty and Licensing Philadelphia Electric Company Appeal Panel ATTN:
Edward G. Bauer, Jr.
U. S.
Nuclear Regulatory Vice President &
Commission General Counsel Washington, D.C.
20555 2301 Market Street Philadelphia, Pa.
19101 Frank R. Romano
- David Wersan, Esq.
61 Forest Avenue Assistant Consumer Advocate Ambler, Pa.
19002 Office of Consumer Advocate 1425 Strawberry Square Harrisburg, Pa.
17120 Robert L. Anthony Steven P. Hershey, Esq.
Friends of the Earth of Community Legal Services, Inc.
the Delaware Valley Law Center West P. O. Box 186 5219 Chestnut Street 103 Vernon Lane Philadelphia, Pa.
19139 Moylan, Pa.
19065 Marvin I. Lewis Angus Love, Esq.
6504 Bradford Terrace 101 East Main Street Philadelphia, Pa.
19107 Norristo wn, Pa.
19104 Joseph H. White, III Phyllis Zitzer 15 Ardmore Avenue Limerick Ecology Action Ardmore, Pa.
19003 P.O. Box 761 Pottstown, Pa.
19464 Charles W. Elliott, Esq.
Sugarman, Denworth & Hellegers Brose and Postwistilo 16th Floor Center Plaza 1101 Building 101 North Broad Street 11th & Northampton Sts.
Philadelphia, Pa.
19107 Easton, Pa.
18042 Jacqueline I.
Ruttenberg
- Director, Pennsylvania Keystone Alliance Emergency Management Agency 3700 Chestnut Street B-151, Transportation and Philadelphia, Pa.
19104 Safety Building Harrisburg, Pa.
17120 i
i H
e n
'o
' Thomas Gerusky, Director Martha W. Bush, Esq.
Bureau of Radiation Kathryn S.
Lewis, Esq.
Protection City of Philadelphia Depart. ment of Environmental Municipal Services Bldg.
Resources 15th and JFK Blvd.
Sth Floor, Fulton Bank Bldg.
Philadelphia, Pa.
19107 Third and. Locust Streets Harrisburg, Pa.
17120 Spence W. Perry, Esq.
Associate General Counsel Federal Emergency Management Jay M. Gutierrez, Esq.
Agency U. S. Nuclear Regulatory 500 C Street, S.W.,
Rm. 840 Commission Washington, D.C.
20472 Region I' 631 Park Avenue Gregory Minor King of Prussia, Pa.
19406 MHB Technical Associates 1723 Hamilton Avenue San Jose, CA 95125 Timothy R. S. Campbell Director Department of Emergency Services 14 East Biddle Street West Chester, Pa.
19380 f
0 S..
U ori G. Ferkin Assistant Counsel Governor's Energy Council Date: Qg fcg.L7 e