ML20126G922
| ML20126G922 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/11/1985 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML20126G911 | List: |
| References | |
| OL, NUDOCS 8506180186 | |
| Download: ML20126G922 (3) | |
Text
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AIR and WATER W
Pollution Patrol BROAD AXE, PA.
June 11, 1985 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 BEFORE THE ATOMIC SAFETY AND LICENSING APPLEAL BOARdCUETED etsc In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-3~@
(Limerick Generating Station and 50-3# JW 17 A11 :06 Units 1 and 2)
CFFtz,e: g, BRIEF OF AWPP/ ROMANO IN OPPOSITION TO THE MAY 2[,0C g
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i BOARD'S ORDER IMPLEMENTING ITS GRANT OF APPLICANT'S &g$3CH TION FOR EXEMPTION FROM REQUIREMENT OF 10CFR 50.47 (a)
AND (b) FOR A PERIOD OF TIME CONTENTIONS OF GRATERFORD INMATES ARE CONSIDERED BY THE BOARD--AUTHORIZATION FOR DIRECTOR OF NUCLEAR REACTOR REGULATION TO ISSUE FULL POWER LICENSE.
On May 29, 1985, intervenor AWPP/ Romano appealed the Licensing Board's ciay 24, 1985 Order " implementing its [May 9, 1985] grant of A.plicant's motion for exemption".
I Statments made in AWPP's May 29, 1985 statement are as included by reference.
In its ORDER of May 24, 1985 the Board specifically stated "The Board's grant of an exemption was based solely on the provisions of 10CFR 50.47 (c) (1) :',
50.47 (c) (1) states "Fa11ure to meet the [various] standards set forth in paragraph 50.47(b) of this section may result in the Comm-1ssion declining to issue an Operating License.
According to 50.47(b) the offsite emergency response plans for nuclear power reactors re-quire the licensee response to be unambiguously defined, and have ade-quate staffing to provide offsite support and response activities which have been fully specified.
As it relates to the ambiguity and total lack of specificity of offsite support activities the Applicant has neither demonstrated that deficiencies, such as in sheltering, are not significant, nor that the public and the Graterford inmates have even been made aware that under a General Emergency accident, or in night-time subfreezing blizzard-blocked reads, conditions could pre-kh 0
- 9 AIR and WATER Pollution Patrol 4
BROAD AXE, PA.
(2) i AWPP Brief in opposition to 5/24/85 Order of the Board continued:
l vent evacuation.
Under such conditions people could die in their l
cellars and prisoners could die in their cells.
The prisoner's es-cape effort could be blamed on fear caused by unavability of eva-I cuation Information giving vent to the fundemental natural instinct i
i of self-preservation.
In the case of dangercus crininals there coulc i
t be tragic consequences.
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5 0.47 (b) ( 2) of 10CFR, calls for unambigious specifications and l
l definition of response by personnel to emergency c:-ordination.
The l
Applicant was recently fined S75,000 for repeated indications of care-less and erronecus response to emergency conditions after repeated r.ctice.
t At 50. 47 (b) ( 5) the called-for procedures to notify the public I
j has been deleted, in particular the so-called sheltering Option to eva-(
i j
cuation which a survey by AWPP(Romano) indicates Pottstown area indi-i t
viduals do not know of it in spite of the fact they could die because i
of Applicant negligence.
{
Further, 50.4 7 (b) (7) calls for establishment of co-ordinated dis-l semination of information to the public re emergency.
The degree to I
which the information relating to the sheltering option has not been j
disseminated to the public, or the Graterford inmates, is evident in l
the fact that Paul Bartle, Chairman of the Montgemory County Board of Cor.missioners when asked if sheltering would improve his feeling re his stated lack of confidence in the workability of evacuation plans, i
I said at Tr.18,616 that he, in effect, did not know what sheltering i
was.
Further, Miss Ecilly, Cheif of the Pennsylvania Bureau of Radic-tion Protection, in testimony before Judge Hoyte stated sheltering at I
most, would protect for only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
When Mr. Bartle's Erergency Cc-f r
ordinator, Mr. Lindly Bigelcw, was asked by re, in the r,re wnce of Mr.
)
Dartle's representattw Mr. Penninctcn, what do people d-after twc i
hours, he said "they have a problem".
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As it related to 50. 4 7 (b) (8) adequate facilities and equiprent l
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AIR and WATER Pollution Patrol BROAD AXE, PA.
(3)
AWPP Brief in opposition to 5/24/85 Order of the Board continued:
to test, obtain, store, and distribute uncontaminated food and water have not been provided or maintained.
In fact, the degree of confus-ion that proves the unreadiness of the evacuation plan became evident when Mr. Bartle stated it was not the responsibility cf Montgomery Co-unty but that of the State of Pennsylvania.
However, Mr. John Patten, Director of Pennsylvania Emergency Management Agency disputed Mr. Bar-tle's statement by saying the uncontaminated food and water supply and distribution was the responsibility of " elected township officials and the County".
Such corrcspondence is known to Mr. Bartle and Mr. Patten.
As per letter of May 24, 1985, NRC IE Information Notice 85-41:
Scheduling of pre licensing emergency preparedness exercises as pub-lished in May 8, 1985 Federal Register (50 FR19323) AWPP/ Romano re-quests that " sheltering" receive the drills and information relative to stopping action of Gamma rays and inhaled radioactive particles for dif forent type houses in the EPZ area surrounding Limerick where people may be required to be sheltered for reasons given above.
Respectfully submitted, AIR & WATER POLLUTION PATROL i
4*c i
Fran R.
Romano, Chairman 61 Forest Ave.
i Ambler, Pa. 19002 l
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