ML20128G941
| ML20128G941 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/03/1985 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-717 OL, NUDOCS 8507090364 | |
| Download: ML20128G941 (1) | |
Text
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U.S. NUCLEAR RIGULATORY COMMISSION.
ATOMIC SAFETY AND LICENSING BOARD S
RE: PHILA. ELEC. CO.
Licorick Gan. Sta. Unita 1 & 2.
Docket #
50- 352,353 L July 3, 1985 R.L. ANTHONY /F0E RESPONSE TO APPLICANT'S RENEWED MOTION FOR Ri EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50.47 (a) and (b) RE. CONTENTIONS OF GRATERFORD PRISONEERS.
Anthony /F0E renew our sitipq to the motion of PECo for an exemption from s
5 the requirements of 10 CFR a'nd T bj as related to the contentionsc of. the Grater-ford Prisoners "during the period necessary for litigation" and we further oppose PECo's motion to operate Limerick"at power levels greater than Sn... prior to the completion of litigation of the contentions.." (above).
(PECoReneEedIbt[o'nd.1.)
l SUPPORT FOR OUR RESPONSE In support of our opposition to PECqts motion we cite our 3/15/85 Eo'tichippondtion, j
cnd include by refer 6nce in their entirety here, 3/27/85 Additional statement in Opposit.,6/2/95 Appeal to AB of LB 5/24 order,and l
f/7/85 Brief in Support of our Appeal (AB).
l We also include here by ref'erence our 6/29/85 inswer Opposing Request for Expedited Review of ALAB-809 and Relief.
In relation to PECo's claim that the Graterford emergency plans have no deficiencies and that previous deficiencies have been resolved (PECo Renew, p.6,7,8 ) we es11 the Board's attention to our 6/25/85 Notice of Appeal to the Director, FEMA,in which we prove that FEMA has no I
basis for certifying the emergency plans for Greaterford or the whole EPZ. We petitioned the Director to revoke the certification of these plans. We showed that FEMA failed to fulfill the requirements of 44 CFR 350 7 (b), 44 CFR 350.10 and 350.22.
l FEMA also fai ed to fulfill the regulations under 10 CFR 50,Appendir E Sec. IV F 1, and 44 CFR 350 9 as well as 44 CFR 350 3 (d) and 350.2 (j).
We are convinced that we will prevail in this appeal and that the Director will re-l voke the FEMA certification.
We further include here by reference our 7/2/85 Brief in support of our Appeal from ASLB 6/4 Memorandum and Ordler on effluent releases at Ligerick. We to chowed PEco's management of radiological activities has been subject NRC category III violation and assessmant of a fine, and PECo is in violation of 10 CFR 20.106 (b),
cod 20.106 (c) (1,2,3,4 ).
PEco's radiolotical effluent management also violates N
Mok 10 CFR 50 36 (c)(1) and (B)(ii)(A) as well as 50 36a (a)(2).
On the basis of gga. these violations we expect thd Board will find that the public health and safety l 80 is threatened from routine releases of radioactivity dt Limerick as well as releasee
! Uu lg from nuclear emergencies and that no full power license should be authorized.
In umma y we assert that PECo has not met the requirements of 10 CFR 50.47 r
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$4 for an exemption as we have shown above,and the reactor at Limerick cannot be or cafely operated.
PECo,furthermore, has not met the necessary factors under 10 CFR an o 40.0 50.12 (a) since an exemption and license authorization is not in the public inter-est and PECo's claimed costs are not a compelling reason. The public would be better off to have Unit 1 permanently shut down,thus eliminating most fuel and personnelcosts,andkeepingLimerickUnit1outoftherateg}e.
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