ML20126M611
| ML20126M611 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/25/1985 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | |
| References | |
| CON-#385-037, CON-#385-37 NUDOCS 8508010427 | |
| Download: ML20126M611 (1) | |
Text
@.@ IMf@8Mn M@s@DTORY @0MMISSIEN... ATOMIC SAFETY AND LICENSING BOARD E: PHILA CLEC. CO.
Limerick Gen. Stc. Units 1 c d 2 DOCKET # 50-352,353 Eb n
July 25,1985 R.L.ASTHONY/F0E PROPOSED FINDINGS AFD CONCLUSIONS ON EMERGENCY PLANNING C0hTEhTIONS FOR GRATERFORD PRISON INMATES CONCLUSIO_N As an intervenor in the Limerick licensing process with contentions on emergency planning, R.L. Anthony /F0E assert our direct involvement with the emergency plans for Craterfora inmates, andzwe' find as the outcoce of the hearings before tha t
Board on the contentions admitted,and because of the fa ilure of the Board to adittit other inmates' contentions vital to their safety, and the safety of.all the other ocespaiIits of the EPZ that the emergency plans for Graterford care not adequate nor able to be im-plegented. These plans are in violation of NRC regulations and FEMA as sgn low.
U 30 R2:18 Graterford emergency evacuation plans are intimately interrelated with emergency
, plans for the whole EPZ and these pla 8 are not adequate and not able toCb n
starting from the bound ries of the EPZ which were not set up with FEMA b@erimplemented, a
uTita k as:
required,as shows in our submissions cited below.
884NCH In addition to the flaws in off site emergency planning are the flaws in PECo olant, personnel,and operating procedures at' the plant itself which make the safe operation of Unit 1 impossible at this tima s shown below.
a Consequently we find that the Graterford inmates prevail in their contentions and that the energency plans in their present form are inadequate and not able to be imple-mented,a d hence NRC and FEMA requ irements have not been satisfied and the Board cannot n
authorize the issuance of a full power license.
EVIDENCE AS THE BASES FOR FINDINGS We cite our submissions below as overwhelming evidence for our conclusions and include all of the documants cited in their entirety by reference.
9ubmissions related to emergency plans for Graterford and for the whole EPZ :
i 3/15/85 Motion in opposition to PECo's motion for exemption for Graterford plans ASLB 2/27/85 Addition l statement vs.
a ASLB 5/16/85 Statement in opposition to granting ASLB 6/2/85 Appeal f rom ASL3 order implementing exemption and authorizing issuance AIAB 6/6/85 Brief in support of our appeal from ASLB third partial initial decision AIAB 6/7/85 Brief in support of our appeal f rom LB's granting of exemption & authorizing lic.
A1AB 6/25/85 Notice of appeal to Director, FEMA,to revoke certification of offsite plans FEMA gm:
N 7/3/85 Response to PECo's renewed motion for an exemption for Graterford plans ASLB NO 00g 7/3/85 Opposition to PECO's motion for exemption f rom requirement of exercise,1 yr. NRC 7
Submissions related to inability of PECo to operate Unit I without endangerinkublic safety:
5.c 3
12/23/84 Petition to Dir. Off. of insp. and enforcement to issue show cause order NRC
?/25/85 To H.R. Denton to issue show cause order to revoke low power license NRR Og 4/5/85 Appeal to the Commission f rom refusal of Dir. NRR M NRC cno.ra 4/27/95 Appeal to H.L. Thompson Div.of Lic., to refuse test operation of turbine NRR 4/30/85 Petition to reopen the record G. Limerick effluent releases AELB 5/9/85 Petition to H.R.Denton to reconsider show cause order on new i-formation N22 7/2/85 Brief in support of our appeal ontimerick ef fluent releases AIA3 cc: NRC-ALA3, Staf f Cou rsel,Docketi rg Despectf 11y submitted, PECo, FEMA,PEMA, A. LOVE,others on Serv List.
Ar MDNd S
Box 186 Moyl an, Pa. 19065 l-( Ch
(
x
.