ML20100D198
| ML20100D198 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/27/1985 |
| From: | Anthony R FRIENDS OF THE EARTH |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#285-329 OL, NUDOCS 8504020333 | |
| Download: ML20100D198 (3) | |
Text
,DOCKirtW G t- %fLvi er ATOMIC SAFE;TY AND LICENSING DOARD U.S. NUCLEAR REGULATORY COMMISSION....
PHILA.ELEC. CO.
him2 rick Huclcar 0:n. Sta.
DOCKET / 50- 352, 353 R]s ADDITIONAL STATEMENT IN OPPOSITION TO PECO's MOTION T 10CFR 50.47 onFJERGENCY PLANNING. BY R.L. ANTHOMY/
FROM REQUIR N NTS OF March 27, 1995 On3/15/85 Anthony /F0EfiledamotioninoppositiontoPEco'smotionof
~
2/7/85toexempttheGraterfordPrisoninmatesandstafffromtherequirements 3
NR /
of 10 CFR 50.47 for evacuation and emergency planning for the Limerick Slant.
4.
.,. ".9 We are restating herewith our motion in opposition to granting thisceremption p", 4 with the providbg of additional arguments as follows
- 1. Untti The Graterford Prison Inmates are allowed conplete acces's to'She the total evacuation and emergency plarre prepared for them by PEMA,and have been ve them accepted and considered in free to file contentions on these plans and ha be no assurance that the total plc "- 4"
~-
inevidentia y hearings, there can r
EPZ can be successfully implemented.
- 2. The NRC Staff presented a number of reserv tions about PEco's motion in a
...it would be inappropri-itsResponsedated3/18/85,concludingwith(p.12.),"
ate at this time for the Licensing Board to consider the Applicant s motion for 3/18 exemption..."
to the Staff's (NRC Re p.)
s
- 3. We give due weight,and believe ASLB should also, ssigned" lead responsibility " by Presidential Order, (p.8.)thatFgAhasbeenaits findings on FEMA findings, and FE!?A has not review and (p.9.) NRC, base.
evalu ted the Graterford plans.
- 4. It seems inconceivable that ASLH would consider circumventing the Presi-n dential Order by cutting FEMA out of the review process by grnnting TEco's motion.
- 5. The exemption would dineredit the whole process to protect the public via workable emergency plens since the plant could operate up to full powerd without the Graterford plan,upon which the success of EPZ evacuction depen s internacting prison traffio.
uce of the routing of ev cuation traffic east and ocuth and north, g a
bece
- 6. Up to now it appegra that FEMA has not teken part in any of ASLD's pre-hearings. FEMA was not. listed in the Harrisburg conferences of 2/27/85 o 3/22/85 FEMA is not included in ASLB's Protective Order of 3/20/85 Ahis raises a serious question about FEMA's participation and the ability of NRC to make a of the Graterford plan and the whole EPZ plan.
decision on the workability Unless FEMA is included the Grnterford plan cannot be valid,nor the public protected y
- 7. We agree with the Staff that NUHEG-0396 takes into account core malt accidents and'still requires " offsite plans for protective censures out to nbout 10 miles " (NRC Resp. p 10).
We agrea with the Staff that PECo has no bnsis for probability arguing that emergency planning for the Inmates is not needed due to low (p.10,ll,12). #e agree that it would be inappropriate "for the Licensing Board to consider the use of the exemption authority under 10 CFR 50.12." (p. 9 )
8504020333 850327 l
SO I')
a
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D oish to call ths Bo rd's attention to the Commonzealth'u rebutt:1 8.
a of PEco's claim thht prison evacuation planning is not an " absolute zwquirement ".
(Commonwealth Hosponse to Applic nt'a Motion, 3/15/05(PEMA Resp.) p. 7.)
We a
adree with PEMA that #aterford, 16 Uhc 1550,1566, cited by PECo, contrary to l
PECo's position, " expressly conditioned issua ce of the operating license on da-n velopment of prison evacuation plans."
(PEMA Hesp. p.8.)
- 9. We agree with PEMA that formulation of workable plans for Graterford and a carrying through of a caplete heaning process on Inmate contentions will not result in "significant delay"to the operation of the Limerick plant (PEMA Hesp.
- p. 3.) And we adree that " exigent circumstances " do not exist in this ease.(p.2) 10.
We endorse PEMA's position that it " does not believe exigent circum-stances are present in this case and thus does not support Applicant's Motion for an exemption.." ( p.8.)
11.
- e call the Board's attention to an application to the Delaware River Basin Commission by PECo dated 3/15/85, forw rded to the members of tho'Deerd on a
3/19/85byMarkJ.Wetterhahn.
We believe this application for supplemental cool-ing water for the Limerick plant proves that the controling factor in the rise of power output is not an emergency plan for the Graterford Inmates but the avail-ability of cooling water (See letter, E.G.Dauer.to Susan Weisman, DRBC 3/15/85,
- p. 1.)
PEco's application to DRBC includes anaffidavitbyVincentS.Boyer,3/15/85 ThisaffidaitinvalidatesV.S.Boyer'saffidaitof3/14/85submittedtothe v
v Board by M.J.Wetterhahn 3/19/05 as an attachment to " Applicant's Motion for Ex-emption.." (re.Graterford).
In the 3/15 affidavit Mr.Doyer says, "the Plant will be ready to proceed to power levels greater than allowed under our existing license by the end of darch,1985 (para. 2.) and (para.3.) " In order to proceed with the u it 1 af ter the issuance of a full power license power ascension program for n
by the NHC,it is necessary to have in place a supplemental cooling water supply".
It is apparent f g g g r} 3/15/85 affida it that the restriction v
12 '.
the la k of cooling water.
on operating the reactor is not a Graterford plan but c
a
- 13. The application to ""'c for cooling water from the Schuylkill River is a PEco move which prompts the question:why was the einborate and costly plan to water from Pt.Ple sant ever undertaken by PECo and approved by DHBC 7 We pump a
are certain that DRBC will not back down from its protective restriction on the use of Schuylkill water for supplemental cooling, even temporarily.
The process involved with the applic tion will take weeks and probably months. In that time a
there will be ample opportunity to arrive at emergency plans for Graterford. Hence no exemption should be granted by ASLD.
- 14. PEco's proposal to substitute monitoring of dissolved oxygen levels in placeofthe59/temperatureconstraintinthegchuylkillniver(3/15/85PEco g
application to HBC) i g ig gmgng ljy g gggd gill bring controversy and almont certa b e" N. The proceau could be protracted. This will hold up power ascension.
A further restriction on Schuylkill water could come from the current rain shortade.
oth,ers on ae fv.Lis t.PECo,PEMA, FEMA, Hespectfully submitted, ce Dockettna Serv.
Ce s NRC "t, a aor le6 A. Lovd g
b ISn iMb )
E _._ _ _. _
7
l Box 186 M:yl:n,Pa. 19065 M. Suran C icran, S:crot:ry Arr4cHmcm ;
Delt: Ora Riv;r Basin C rmicsicn March 28, 1985
'B:x 7360 W:st Trentcn,N.J. 08628
Dear Ms.Weisman,
As an intervenor in the NRC lic~ensing procedings for Philadelphia Electric plant, we have been representing citizen he lth and a
Company's Limerick Uuclearsafety interests under the name of Robert L. Anthony / Friend We recently were provided with a copy of PECo's application,
Delaware Valley.
the standards for the dated 3/15/85, seeking Da3C's authorization to changeprovide cooling water by release Schuylkill River and toWe wish to inform DrWC of our vital interest in this application reservoir.
and to request that we be admitted as parties and included in written presenta-tions and afforded the opportunity to testify before the Commission.
We ask that DRBC provide us time to make a thorough study of the impacts of the authorizations requested by PECo ahd to submit our evidence against any change in the present regulations governing the Schuylkill River before any final consideration by the Commission.
ummarize our opposition to PEco's application under the At the moment we s following headings:
- 1. DRBC set its standa ds for the Schuylkill af ter careful study and r
these should not be changed,even temporarily,without a new environmental impact study.
- 2. A temporary permit could certainly lead to a longer term one,since and continuing there is uncertninty over the status of the Pt. Pleasant diversion litigation.
- 3. The City of Bhila. has offered to sell water to PEco.
The possibility of accelerating this connection could provide a temporary,and a permanent, solu-tion of the supplemental water supply.
If D:tBC decided that using its water reserves for Limerick cooling 4
was a proper use of area water,it only arrived at this conclusion on the basis of combining water from the Delaware with the Schuylkill.
Providing water from the Schuylkill alone, the Commission wisely never authorized and this decision should not be modified in any way.
PEco has not demonstrated that it has explored alterna,tives,such as 5
water from the City of Phila.
( See PEco Attachment 2.)
- 6. Other users will be enda gered as PEco intimates in Attach. 2 (1) in n
stating that consumptive use will make the Schuylkill "largely unavailable for such (PEco) withdrawals during the period June to October.1985."
DRSC made the water unavailable to protect water resources on a sound basis.
s cha ge to modify DER Secretary R. A.Lukaa's position quotedin
- 7. Nothing hn n
Attach. 2 (3), " Green Lane is not large enough to meet the combined needs of PSW Co. and Limerick."
0 Me suring disadvad oxygen levolu is not a substitute for the 59 tempera-8.
ture constraint. liigher temperatures impact the biological life of the river.
a
- 9. A dissolved oxygen restraint should be added to the Schuylkill standards, 0
not substituted for the 59 limitation.
- 10. The current rainfnll shortage could progress into a drought. This reinfor-ces the need to conserve water resources and not to modify the present restrictions.
- 11. We oppose PEco's application as it would degrade the Schuylkill and im-peril essential water reserves.
Cc: NRC-ASLB Judges, Staff, Docketing -
Respectfully submitted, PEco,PEMA, FEMA, Angus Love,uthers on Limerick Serv.
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