ML20128P099

Forwards Newspaper Clipping Demonstrating Degree of Relevant Info Bearing on Adequacy of Evacuation Planning & Support Planning Excluded from Record in Fact Finding Hearing. Served on 850531

ML20128P099
Person / Time
Site:	Limerick
Issue date:	01/28/1985
From:	Dardis M AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
CON-#285-234 OL, NUDOCS 8506030459
Download: ML20128P099 (3)

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-. SSVED llAY 311985 R.D. 2, Box 46 Newtown, Pa. 18940 January 28, 1985 -

Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.cMLQ7 5 Administrative Judger Helen P. Hoyt,

-- UShRC Dr. Richard F. Cole, and ~

Dr. Jerry Harbour Re: I,imerick Nuclear Generating

'85 MY 31 P1 :31 Station, Docket Nos. 50-352; 50-353 dt.

CFF F :' ,R.

Dear Admini[ Mfd g y dges:

The attached newspaper clipping from the Bucks County Courier-Times, January 27, 1985, illustrates the degree to which relevant information bearing on the adequacy of evacuation planning and support planning for the counties around Limerick has been excluded from the record in the fact-rinding hearing before you.

In my attendance at sessions of this hearing, I discovered that the recalcitrance of the applicant, Philadelphia Electric Company, and the operation of your own rules, resulted in omission of a great part of the facts concerning whether the plans are adeouate and workable. Virtually the only testimony admitted has been whether there'are plans, no matter how foolish, incompetent, and ill-conceived they may be.

I do not believe that a Federal panel, selected for its achievements in law and science, would wish to be denied access to solid facts in the real-world matter which you are considering. I therefore respectfully give you the following background of the attached clipping.

1. At a Bucks County Commtssioners' Meeting early last July, prior to the evacuation drill, I called the Commissioners' attention to the listing of a mass care center at the old Delhaas Eigh School, as it appeared in the Support Plan, Draft 4, October, 1983. To my certain knowledge, Delhaas was no longer a part of the Bristol Township Schools; its abandonment had, in fact, been the subject of considerable front-page public protest.

2 Throughout this hearing, reference was made by witnesses to the " updating" and " revision" of evacuation and support plans. The document entered into your official exhibits, I believe, as E-4, purported to be a Final Plan for Bucks as a support county. Although it is dated October, 1984, it still lists Delhaas High School (complete with a Fire Depart-ment monitoring / decontamination assignment) as a mass care center.

3. In that same month, October,1984, I examined the former Delhaas High School myself. One wing contained offices, eq'aipped with normal office furniture and files; another wing was piled almost to the ceiling with stored foodstuffs in cartons; the third wing was filled with plaster, rubble,-ladders, and construction materials. It was entirely unsuitable as a mass care center, except possibly for rats.

4. The Bristol Township School District superintendent's office informed me that Delhaas is no longer their property. (They also tell me that another school listed as a mass care center has been rented to a 3 )

private organization and is also, presumably, not available.) T 8506030459 850128 PDR 6>

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1 The significance of the Delhaas High School " goof", extreme and ridi-culous as the example is, lies in much more than its own specifics. ?lhat really matters is that, if so simple and obvious a defect in the plans does not appear in the record (as far as I am aware, it does not), then many.more flaws.of concept and implementation must also have failed to come to the notice of this Board.

The clipping is only the visual tip of the proverbial iceberg. Another issue that did not surface is the conflict between support plan assumptions of early dismissal and the emergency retention procedures of various Bucks school districts. Not to mention actual available space at mass care cen-ters, as compared with the plan's schedule for the number of evacuees to be dispatched from the reception centers; little verification of estbmates seems to have taken place. And, of course, the discrepancy between FEMA's methodology and PEA's directives on decontamination at mass care centers, a matter which may appear, obliquely in the testimony.by now.

Although I have not always categorically opposed nuclear power, I now hesitate to entrust health, safety, and the economy of my neighbors and myself to the competence of people who cannot discover in well over a year's time that they have listed for emergency use a non-existent institution. And who testify under oath before a Federal agency that their plans are updated, revised, and, yes, even Final!

In short, more of the information needed in your fact-finding process may lie outside the record than in it. I call this one item to your attention now, hoping that, by demonstrating what has not been said, it may help you in deliberating over what has been said.

Respectfully yours, i o AlptU. . Of6 kl Margaret M. Dardis (See Appendix 4-C-1 of Bucks County. . .Suppor plan... LGS, Draft 4, Oct. 1983 for listing of Delhaas High School as Mass Care Center 14, accepting 475 persons. 'See also the same entry on the same-numbered page of the October, 1984 unnumbered ("Pinal") draf t of the same essential document.

Also see Appendix 5-E-1 of both documents where the Bristol 3rd Dist. Fire Company is shown as being assigned to Delhaas High School.

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- pluss or permit.s for the renova- %A It.:R.l g g n p u ig; viewed an application from tion of the former Delhaas Iligh o.,g. g them."

. School building on Route 413. ista g"

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One of the problems the Bureau of Employment Security experi-

.; ne state Bureau of Employw meet Security willjoin three other h,Agiaredes 31.w aganst Answaa enced at its former Tullytown of-businesses in the old school build- (IB 2221966ermB564N fice was a lack of parking. While 11g turned office complex - a the Delhaas building has ample move the township's building in- .

parking, police believe a light and spector said will be illegal. --- access road are needed.

According to John P. Boyle, di- in8ee8 m l Another. township employee, rector of the township department No permits for Delhaas renovation were issued, officials say who preferred to remain anony-ot heenses and inspections, he has mous, said he was not surprised nevrr reviewed an application for indignant over the development road were submitted to Ahe town- by the turn of events. "They think a permit for occupancy of the that came to his attention late in ship.however Boyle said. they're in the sticks up here and butiding. Derefore, Boyle said, the week. Gawel told Jones he Boyle recalled the owner said can do anything they want." l "They will be in there illegally." should close the building if he con- he was waiting to go through the Delhaas closed in 1980 because The building was purchased for siden ed it unsafe for occupancy.

$1.35 million in November by Nor- "It's up to you," Gawel said.

state Department of Transporta- of declinmg student enrollment. f

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j ., mm Weiss, head of Weiss Devel- Jones admitted the " place is a

.. opment Corp., of Kingston, Pa., shambles," but added, "They're

,, who told school officials he working like crazy. I suppose pitaned to renovate the grounds they'll have it operational Mon-and building at an approximate $6 day."

mi!! ion cost. Weiss could not be The fire marshal said the own-retched by telephone Saturday. er is supposed to submit design Township Fire Marshal Wil- plans foi such renovations to the

lism Jones said be inspected the towrfQiip. The owner also is obli-building on Friday and found the gated to obtain plumbing, electri-ptrtially revamped interior un- cal and occupancy permits.

dergoing construction. Jones also None of the businesses leasing salat the sprinkler system was not space at Delhaas were aware they connected to the water supply. had to have such permits, Jones ,

Jones said, however, he did not said. The state also was unaware ixtend to close the offices because o. the responribility, said a bureau of the problem. spokesman.

.- Although the fire marshal said On another matter, the owner he did not intend to take punitive promised to install a road around Ection against the owners, town- the back and side of the building, thip Manager Stanley Gawel was leading to Route 413 and facing Rockview Drive. No plans for the

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