ML20125B729
| ML20125B729 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/07/1985 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#285-354 OL, NUDOCS 8506110519 | |
| Download: ML20125B729 (1) | |
Text
hW U.S.SUCLEAR REGULATORY CCMI/ISSIOU... ATOMIC SAFETY A:D LICEN2ING APPEAL LOAR3 RE: PHILA EII.C.CO. Limarick Gen.Ste. Units 1 & 2.
LOCEET No. :
50-352,353 CL_
' 3 's URDER IEPLE-EENTING ITS GRAUT 0F EX$.ITION FR06. 100FR 50 47 (/2/85 L
ANTECNY/F0E BRIEF IN SUFFORT OF OUR APPEAL OF 6
FROM a.) (b) AND AUTHORIZING LICENSE.
June 7,19_8.5 We are in receipt of the Boerd's Order of 6/3/85 setting the briefing sched-ule for the above appeals.
We are cocplying with this curt iled timing although p
it imposes hardships on us not to be subject to the statutory allowance of 30 days.
DX Kr*,rn hence our brief will be limited for the mogart to material c1 ready 'shbRtted.
- e believe,however,that the Board will. find,the weight required to convince the Ecard to reverse LB's decision granting the exemption from 10 CF 50l#ffda y g and its authorization of the issuance of a full power license.
kk'/85, o
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- 1. We incorporate here all of our brief submitted to the NCH on L3'e Partial Init,ial Decision on Offsite Emergency Planning for Limerick. '
This brief shows that the Limerick EPZ was set up without the participation of FEMA,requiredunder 44 CFR 350 7 (b)
PEco's evacuation time study estimates and the use of evacuation routes were thrown into question by the testimony of the NRC witness,and new planswillhavetobedrawnuptoincludeValleyForgePark/
Eing of Prussia and Marsh CreekPark/Exton areas in the EPZ,and the bounda ies of r
the EPZ will have to be reconsidered,and revised evacuation plans for the whole EPZ retudied ' and submitted to the review and hearing process. Since the evacu-ation plans for thE Graterford prisoners is dependent on the configuration of the EPZ and the plans for the whole EPZ, these plans will havd to be re-worked in relation to revised evacuation plans for the total EPZ.
We believe that his means and valid plans for evacuation of the EPZ no longer are in band the process for EPZ 3
and Gtaterford evacuation will have to be reconstituted.
Hence a plan for. Grater-ford will be in abeyance and an exemption cannot be granted nor a thorization u
to issue a license granted, as we trust the Board will find.
- 2. Furthermore we incorporate here our motion of 3/15/85 in opposition to PBCo's motion for an exemption for Graterford and we stress especially the danger to the EPZ community and the greater community from a panic at the prison and tv Q the escape of dangerous prisoners at a time of high tension during an evacuation of the EPZ.
The " table Top" exercise for Gr terfoxd did not satisfy 44 CFR 350.2 (j) 3 a
og in respect to the number of personnel trained and involved, i.e. " emergency persone h
nel are engaged in sufficient numbers to verify the capability to respond..."
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5
- 4. Since there is no record of FEMA participation in the Graterfoni pre-hearing l omQ process or the protective Order of3/20/85, LB and FEMA did not comply with the requirements of 44 CFR 350 3 (d) " Cooperative effort with State and local,etc.,
and 44 CFR 351.20 (a) through (1) " establish policy and provide le der hip,"etc.
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PEco,FFb,esEEMA,,A. Love,0thersStaffCounsel,Docketinbt.
Respect ly submitte AB Jud ASL3 cc on Serv.L 1
mox le6 an,Fa.'1 65 gf)
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