ML20128H114
| ML20128H114 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/03/1985 |
| From: | Anthony R ANTHONY, R.L. |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#385-715 OL, NUDOCS 8507090412 | |
| Download: ML20128H114 (1) | |
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N U.S. NUCLEAR REULATORY COMMISSION.. BEFORE THE COMMISSION RE.PHILA ELEC.CO.
Litcrick Gon.Stn. Units 1 & 2.
DOCKET # 50-352.353 July 3,1985 R.L. ANTHONY /F0E RESPO'iSE IN OPPOSITION TO PECO's NOTION FOR AN EXEMPTION FROM THE REQUIREMENTS OF 10 CFR Part 50 APPENDIX E, SECT.IV.F.1, EXERCISE WITHIH 1 YEAR Anthony /FCE received PECo's motion for an exemption from the requirements of 10 CFR Part 50, Appendix E,IV.F.1 for a full,nar_ticipation exercise wititin one year befor-the issuance of a full power license. Ne are opposed to tpj g nting of this exemption.by the Commission for the substantial reasons setaforth below.we petition the Commission to deny this exemption.
- 65 Graterford has never been included in a full scale exercise,J4 -8 P1 :09 ei ne recorded in cur 6/29/85 Answer Opposing Review of ALAB -809,and Relief (para,2.;),ynd our 6/7/85 C
Brief in Support of Appeal from LB's 5/24/85 Order which we ihNohhNere in its entirety. We showed above and in our 7/3/85 Response to PEco's Renewed Motion for an Exemption,which we also incorporate in its entirety,that there are a number of deficiencies and violations in the emergency plans for Graterford and the whole Limerick EPZ.
As evidence we include here by reference our 6/25/85 Notice of Appeal to the Director,FD'A, in which we specify violations or deficiencies under 44 CFR 350 7 (b), 350.2 (j),350 3 (d),350 9, 350.10 and 350.12 as well as 10 CFR Appendir E sec. IV F 1. On the basis of the above submissions we believe the Commission cill find that the emergency plans for Graterford and the entire EPZ are not ade-quate or able to be implemented and it is essential that these be revised and aug-upcoming tented as a result of the hearing by L3 on the Craterford contentions,and' appeals, 3
including ours, related to emergency planning and the inability of PEco to operate Unit i safely.
A new full participation exercise must be conducted after all de-ficiencies have been corrected and before a full power licence is issued.
We call the Commission's attention to our 6/6/85 Brief in Support of our Ap-peal from ASLB Third PID and our 6/2/05 Appeal from ASLB's Order of 5/24/85 both of which we include in their entirety by reference to further reinforce the de-n ficiencies in emergency planning.
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We further cite and include by reference our filing on the inadguscies of n.
@.n the Graterford plans and PECo's inability to opernte Linearick safely 4our3/15/85 Eotion in Opposition, 3/27/85 Additional statement in Opposition, and 7/2/85 Brief in Support of our Appeal of 6/7/85 fromASLB Order 6/4/85 7
Furthermore,in summary we state our opposition to the above exemption on h
the basis that PEco is abusing privilege in applying to the Commission rather than LB in this motion and PEco has not met the requirements under 10 CFR 50.12 as set forth in our Respense 7/3 85 we repest our petition to the Commission to deny
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FEco's motion for an exemption from the require = ente of 10 CFR 50 App.E,sec.IV.F.1.
' hA,Yh,'f.I$ove,Ne'
'hn b D fs b Resp-etfully submi y i
Box 186,Moylan 190C g, $&
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