ML20102A394

Limited Appearance Statement on 841213 Before ASLB, Admonishing NRC for Lack of Sound Principles in Assuring Adequate Evacuation Plan.Served on 850207

ML20102A394
Person / Time
Site:	Limerick
Issue date:	12/13/1984
From:	Greenwood, Morris, Turnell AFFILIATION NOT ASSIGNED
To:	Cole, Harbour, Hoyt Atomic Safety and Licensing Board Panel
References
CON-#185-442 OL, TRAN-841213, NUDOCS 8502080340
Download: ML20102A394 (2)

Text

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...-n n c.... n h q Ij M 3 TO THE ATOMIC SAFETY AND LICENSING BOARD NUCLEAR REGULATORY COMMISSION (s ' -

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Judge Hoyt, Judge Cole, and Judge Harbour:

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sufficient to finish it."

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>N g 'l If you look up the word " adequate" in Webster's Unabridged Dictionary, you will find this Bible passage. There is a tendency, in this day of cheaply. used superlatives, to demote " adequate",

but the dictionary does not support it, but instead supplies " fully sufficient" as a definition ~and " competent", " suitable", " full",

" satisfactory" and " ample" as synonyms.

Unfortunately, the great issues--a citizen's rights not to be evacuated and not to have his property sacrificed to Mammon--have not-been addressed. No one ever said it better than did Richard M. Ketchum, of "Blair and Ketchum's Country Journal" in July, 1979:

"Why should intelligent people tolerate an energy system that re- '

quires an evacuation plan?"

.Since millions of peopig like it or not, are caught up in the nuclear system, no legal proceeding- that even pretends to justice can, in evaluating evacuation plans, ignore the most serious and thorough attention to the controlling word: " adequate". No " pass-fail", " barely enough", "on balance", or " number-counting" concept will sufilce. Every aspect of-time.and place must be thoroughly and honestly considered, whether the mileage be 1, or 10, or 50, or the time 1 day, or 30, or 10,000, as in the case of a serious particulate dispersal. If "probabilistic risk" is a fair standard against failure of a nuclear plant, it is a fair standard against success of an. evacuation plan. And such a plan is a dread cost.

You are in a posi. tion of grave responsibility - and shining

. opportunity. No rules require you to compound error. No rules pro-hibit you from introiucing ' statesmanship to a presently sordid area of the law.

Tragically, for thirty years, American proponents of nuclear power, in their headlong drive. to realize upon economics they presumed superior - now dramatically disproven by experience - have been faith-less to a basic. principle upon which all engineering integrity rests.

They have disposed of unresolved problemsEwith a. steamroller. Driving on, they have equipped that steamroller with wheels and operated it

' at. high speed, on a twisting, narrow gauge legal track. And there, in the word.s of an -Oklahoma journalist of years ago, they have vio--

. lated all. the principles of good railroadin.g by placing the " empties" at - the head : of their train of thought.

p"um 88: 2 Ds63

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In your determination of the existence or absence of an ade-quate evacuation plan, no sound principles require you to join these nuclear activators in this cataclysmic " force fit." .No sound prin-ciples' require.you to accept as your standard of the orbit of danger

'an unproven last minute truncation of an already artifio' ally limited ten mile. circle. .No sound principles require you to bludgeon the people of the Schuylkill and Delaware Valleys with this final con-

.temptuous blow.

.In determining adequacy, you have available an age-en'uring d

. guide, in eleven words, which are commended to your memory, from.a

. great scientist. Among his many achievements was expertise in the detection and control of poisons. When he died in 1878, France accorded him the first public funeral ever bestowed by it on a man of

' science. Claude Bernard said: "True science teaches us to dg, andnin ignorance to refrain." _

History will regard as unimportant whether you win one for a governmental administration. History will regard as supremely im-portant.whether you win one for Claude Bernard - and for all who love truth. . >

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