ML20104A914

Motion Contending That Applicant & Staff Never Considered Making Public Plans or Tested Plans to Insure Against Health Effects in Case of Accident at Facility Under Conditions Which Would Prevent Evacuation,Per 850115 Hearing

ML20104A914
Person / Time
Site:	Limerick
Issue date:	01/27/1985
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20104A890	List: ML20104A888 ML20104A914
References
OL, NUDOCS 8502010574
Download: ML20104A914 (3)

Text

.. .

AIR and WATER

=

• Pollution Patrol January 27, 1985 -

n ._

J' BROAD AXE, PA.

U.S. Nuclear Regulatory Commission '83 ,

Washington, D.C. 20555 K,Y 37 g e ,_

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD . wt

^d . T:,

In The Matter Of Docket Nos. 50-352 Olh[. " "

PHILADELPHIA ELECTRIC COMPANY and 50-353 O(_

(Limerick Generating Station Units 1 and 2)

AS IT RELATES TO SHELTERING, AIR AND WATER POLLUTION PATROL (RO-MANO) CONTENDS THAT APPLICANT AND STAFF NEITHER CONCENTIOUSLY CONCERNED THEMSELVES, NOR MADE PUBLIC PLANS FOR, NOR TESTED THE ADEQUACY OF SUCH PLANS, OR OTHERWISE INSURED AGAINST HEALTH EFF-ECTS FROM MASSIVE IONIZING RADIATION RELEASES AS GASES OR PARTIC ULATE ENTITIES, IN CASE OF A SERIOUS ACCIDENT AT LIMERICK UNDER CONDITIONS WHICH WOULD PREVENT EVACUATION.

Meeting the requirements of Section 2,714 (a) (1) (i), the cause for late filing involves the life-and-death importance of the real poss-ibility of " sheltering" brought forth on January 15th 1985 before the' Atomic Safety and Licensing Board in Philadelphia, Pa.

At that hearing Philadelphia Electric's attorney was, in*effect, forced by Paul Bartle, Chairman of the Board of Montgomery County Com-

! missioners to admit that under conditions that make evacuation imposs-ible, " sheltering" will be the means,to protect the people in the Lim-erick EPZ in case of a severe accident.

Such a case ties described in subfreezing blizz-by Mr. Bartle as an accident in 3A.M. darknessi

~

ard-blocked reads ( as per transcript of Testimony on afternoon of f

i Jan. 15, 19 8 5) . (Also see enclosed letter) .

! The ASLB, as then chaired by Judge Lawrence Brenner has, in its I Order of September 14, 1984, referred to the Limerick Test of Evacua-tion Capability (LTEC) contention filed by Air and Water Pollution Patrol on August 8, 1984, as " Draconian". On January 15, 1985 P.E.'s attorney Rader, brought out that it could be a real possibility.

Since Air and Water Pollution Patrol's (AWPP) instant contention has not really been litigated re its suitability as an option to evac-uation, and since the sheltering issue is life-threatening, the ASLB 8502010574 850127 PDR ADOCK 05000352 O pop

AIR and WATER F Pollution Patrol BROAD AXE, PA.

(2)

Air and Water Pollution Patrol Contention re " Sheltering" continued:

can not in good concience rule it untimely.

It must be litigated, also, because AWPP has no other means avail-cble for protecting me with my property 10 miles from Limerick, and its members, and the public, in view of the fact that while evacuation is being handled by LEA, with FEMA and others judging its adequacy, the same criteria as to plans, publicity, testing, monitoring, etc.

has not been adequately considered or performed for " sheltering"...

cven though it is more critical. For this reason the ASLB must per-l l nit litigation of this previously inadequately considered, extremely cerious aspect of life or death in a nuclear accident with people un-cble to leave their homes.

Further, AWPP will contribute to the record in that it will show that adequate plans and studies were not made re sheltering in the l cverage home as would most likely be the case in a sudden runaway acc-i ident under those worst conditions heretofore mentioned. AWPP will l

contribute by calling expert witnesses on barrier requirements again-et massive and intensive gamma radiation as a measure of the degree l to which gamma radiation may or may not be stopped by different ty-l pes of house construction in the EPZ of the Limerick reactor. AWPP will contribute by bringing in expert witnesses on air transfer with-in average residences as it realtes to the evaluation of the amount of particulate matter that can inflitrate the airspaces that cannot block out air in to the average house. AWPP will contribute by bringing in expert witnesses to testify on the environment of houses that are too airtight for breathing by large numbers of people for ex-tended times. These times may not be just a few days as is errone-l cusly considered for nuclear accidents, since sheltering may be required l for a week or more. In fact there is no assurance that the time dur-ing which no contact can be permitted with the outside atmosphere can go into months or longer in severe accidents. Such times have not been l

I

J AIR and WATER Pollution Patrol BROAD AXE, PA.

(3)

Air and Water Pollution Patrol Contention re " Sheltering" continued:'

considered even with evacuation of the population.

The Nuclear Regulatory Commission, as a result of the Three Mile Island Accident, has made a workable evacuation plan a condition of licensing nuclear reactors. That sensible requirement was born of an accident that had it gone 30 minutes more could have brought death and disaster to half the State of Pennsylvania. The need to litigate the recent admitted possibility that the opposite to evacuation, name- '

referred ly," sheltering" might be forced upon unsuspecting thousands, to by Mr. Bartle, merits the same requirement of planing, familiari-zation by the public, monitoring, testing drills and all-inclusive home communication systems, before sheltering can be used as an option.

AWPP (Romano) contends that neither the Applicant not the Staff adequately paralleled the conditions required of evacuation with shel-tering. Neither the Applicant nor Staff, therefore, did all that is work-necessary to demonstrate that sheltering could be considered a able option to evacuation. Neither did Applicant nor Staff formally assure that sheltering would not indeed be a term, which in this in-stance, may hide the possibility of meaning a death trap.

Respectfully submitted, i

' Air and Water Pollut' n Patrol Frank R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 enclosure l

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