ML20127G216
| ML20127G216 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/16/1985 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-073, CON-#285-73 OL, NUDOCS 8505210007 | |
| Download: ML20127G216 (1) | |
Text
< OD U.S. NUCLEAR HIGUIA TORY C0hMISSION.. AT0;iIC UAFETY AHL LICEN3ING BoaaD FHILA,,ELEC. CO. Limorick Cen. Sta. Unito 1& 2 DOCKE2 No. 50-352,353%
May 16, 1985 STATiAENT OF ALTHONY/F0a IN OFFOSITI0d TO GdANTIdG APPLICAN T'S '.10 TION FOR E.GiFTION PdOM 100Fd 50.47 (a) & (b) RE: EhCUATIOJ PLAM FOR IUMATSS.
The objections which Anthony /F0E submitted to the 3 card on 3/15/85 are still valid and unanswered; we reassert these.
We dis.6ree with,the Board's e
E,,
order of 5/9/S5 in most:
aspects,and aspecially the conclusion Wait)' " the inmates' health and s fety are, in the opinion of the expert agency in the a
emergencies, adequately protected in the event of a rabNgiAi!237 area of emergency at Limerick."
- e ae impressed with the deficiencies set forth irr th h h osed BRANCH Revised Contentions, 5/13/85, and we agree that these are serious and could result in the miscarriage of evacuption plans acd the release of dqngerous criminals into the community,at a time of extrece tension.
'Je also call the Board's attention to the memor.indum of R.7 Krima FDiA, 4/9/85,to E.L. Jordan N'IC (p.2)
" the overall radiological emergency olans and preparedness are not adequate to provide reasonable assurance that the appropriate measures can be taken to protect the hepith and safety of the public in the vicinity of the Limerick Cenerating Station in the event of a radiologic l emergency."
a It is obvious that evacu tion of the inmates will coincide with the evac-a uation of the rest of the residents of the EPZ and if FEMA has not approved the overall plans,there are deficiencies which will invalidate any assurance that Graterford plans will protect the inmates,or tha residents of the EPZ.
Further~ ore, the Bo.rd placed a condition on its decirion,L3P-85-14 h.74) in connection with our contention LEA 24/F0E 1. in resnonse to FDiA's restriction, the Director,0ffice of Nuclear Reactor Regulation, shall receive verification of plans to implecent a leval of traffic control in the King of Prussia area.."
It is,therefore, not true ' hat " any final impedimant to t'.e issuanca of a full power license has been removed". (ALAE 5/9/95, p.8 )
Im addition there are many impediments to the safe operation of the Limerick plant as documented in Anthony / FOE's petitions to E.R.Denton, Jir.NRR,12/?3/85, 2/25/85,5/9/85,and our letter of 4/27/85 to H.L. Thompson,NES.
PECO doas not
,N have permission from DRBC for cooling watar to allow operation of tha reactor and it violated the low power license in its application to DRBC.
In the
@g oparation of the plant a hikh level of Licensee ibents continuam,45 from 1/1/85 to 4/2/85.Mtm than 1/3 of thase wen caused by personnel error and another 1/3 3D J W
by design and equipment deficiencies. These' events" prove FECo's operation unsafe at any power level. Consequently a nuclear emergency could happen at any moment.
m Je submit that the Board's reference to" restart of construction of Unit 2"
$a.
is grstuitous, irrelevant nnd prejudicial.(p.9) Apper. ring to sponsor Unit 2 Q
is not an appropriate function for the 3oard in its judicial role, es, ALAS,0thers on Serv. List Raspectfully submitted, Box 1 6 co'ilA,Fg3,P Coudsel, Docketing
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