ML20134A815
| ML20134A815 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/05/1985 |
| From: | Conner T, Rader R CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#485-096, CON-#485-96 ALAB-819, OL, NUDOCS 8511110028 | |
| Download: ML20134A815 (20) | |
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UNITED STATES OF AMERICA E.: ,mm0 h)-
NUCLEAR REGULA'IORY COMISSION 3 dt.j g,j'( y Before the Ccmnission " )} p In the Matter of )
)
Philadelphia Electric Capany ) Docket Nos. 50-352
) 50-353 (Limerick Cenerating Station, )
Units 1 and 2) )
LICD4SEE'S PETITION FOR REVIBi OF AIAB-819 Sunnuy of the Decision Below Licensee Philadelphia Electric Cmpany (" Licensee") petitions the Ccmnission to exercise its authority under 10 C.F.R. 52.786 to review an important issue of law and Camission policy arising fran ALAB-819, wherein the Atanic Safety and Licensing Appeal Board (" Appeal Board")
has, without any direction fran the Ccmnission and in the absence of any damnstrated necessity, interpreted 10 C.F.R. 550.47(b) (12) to create a wholly new requirment for backup mxlical support.1 1/ Philadelphia Electric Cmpany (Limerick Generating Station, Units 1 and 2) , ALAB-819, 22 NFC (October 22, 1985). In AIAB-819, the Appeal Board decided aTI Tssues (except one) arising fran the Atanic Safety and Licensing Board's (" Licensing Board") Second Partial Initial Decision in favor of the Licensee (then Applicant) .
See Limerick, supra, LDP-84-31, 20 NPC 446 (1984). 'Ihe sole exception was the adequacy of backup medical support for onsite plant workers who might be contaminated and injured in an accident.
Despite its finding of error, the Appeal Doard in ALAB-819 did not suspend operation of the Limerick Generating Station (" Limerick")
because "the deficiency in PECo's mergency plan identifial here is not so significant as to warrant license suspension." AIAB-819 at 50.
0511110028 851105 POR ADOCK 05000352 e- o o PDH 3 )
e The crux of the issue which Licensee requests the Comission to consider is whether additional requirements may be inposed under 10 C.F.R. Part 50 ani Appendix E regarding the proximity of the backup hospital to a nuclear plant, i.e., the travel tine frm the plant to the l hospital in the event of an emergency. Specifically, in this instance the Ccumission should decide whether the Appeal Board exW its l
l authority in ruling that the Hospital of the University of Pennsylvania l
(" HUP"), located in Philadelphia about a 45-minute drive from Limerick, "is too distant to serve as an adequate backup hospital" for the treat-ment of contaminated injured onsite workers.2_/
'Ibe Appeal Board's novel interpretation requires that arrangenents
( be made to obtain a second backup hospital for the treatment of contam-l I
inated injured workers at Limerick, which should be located "beyond the area subject to potential evacuation, but . . . otherwise . . . as close as possible to Limerick."- Nothing in the Federal Dnergency Kanagement Agency's or the Ccmission's regulations, policy statenents and prece-l dents en the adequacy of supporting medical facilities suggests that the proximity of HUP to Limerick is inadequate. Moreover, in numerous t
licensing actions, the Ccmission has uniformly approved arrangements with backup hospitals at the same or greater distance and with greater travel times fr m the plant.
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2/ AIAB-819 at 44.
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3/ Id. at 49.
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O Legal Error Assigned In ruling as a mat ter of law that a backup hospital located 45 minutes driving time frcm a nuclear facility is inadequate, the Appeal Board usurped the Cmmission's rulemaking powers to set generic emergen-cy planning standards. It must be enphasized that the & peal Board made no finding, factual or legal, which would distinguish nedical needs or arrangements for Linerick onsite workers frcm those at any other nuclear facility.O Decause to reason for making a special case out of Limerick was dcnonstrated or even attspted, the Appeal Board's ruling necessari-ly has generic application to every plant in the country, including many facilities licensed by the Ccmmission with a backup bcspital more distant or less accessible than HUP is to Limerick, i.e., 45 minutes driving time.
If the NBC Staff had inposed the same requirement under 10 C.F.R. 550.47(b) (12), its interpretation clearly would have required a omplete backfitting analysis to shcw, inter alia, "that there is a substantial increase in the overall protection of the public health and safety or the ccrmon defense and security to be derived frcm the backfit and that the direct and indirect costs of implementation for that facility are justifiM in view of this increased protection."E Although 4/ The Appeal acud apparently reached a different conclusion for Limerick because Licensee had not " explore (d) the entire range of reasonable options" regarding other hospitals. ALAB-819 at 49 n.47. 'Ihus , the basis for its decision was the possible availability of other options rather than any requirement inherent in the rule.
5/ 10 C.F.R. 550.109(a) (3) . See 50 Fed. Peg. 38097, 38112 (Septanber 20, 1985).
4-inapplicable g g to its adjudicatory boards,5I the new backfitting rule nonetheless crticulates the Cmmission's serious concern that new, unwarranted regaimnents are being ratcheted upon existing standards in a nev:r-ending " quest for a risk-free plant, an unobtainable cbjective c_ recognized by Congress in establishing the standard of no undue risk in the Atcmic Energy Act." Thus, the Appeal Board exceeded its authority and violated the presumption, expressed by the Ccmission, "that the current body of NRC safety regulations provides adequate protection."U The Appeal Beard cited no textual or other objective basis for its conclusion that HUP car.not provide adequate backup nedical suprt for Lirerick onsite workers.9I It correctly observed that the Camission's 1/ The propcsed rule sculd have included acticns by the Licensirey ard Appeal Boards. See 49 Fed. Reg. 47034, 47040 (Novmber 30, 1984)
(additional views of Ccmissioner Asselstine). The Ca mission adopted a definition of "backfitting" in the final rule, homer, which was limited to a new staff interpretation of the rules. See 10 C.F.R. S50.109(a). The discussion in the Statments of Consideration published with the adopted rule on this provision did not ccmnent upon the change excluding adjudicatory board decisions.
50 Fed. Reg. at 38102. The Licensee agrees with the Connission that "it is of little consequence how a back. fit is inposed." d.
at 38101, 7/ 50 Fed. Reg. at 38103. As further stated in tre backfitting rulaaking, "the Cmmission would not ortlinarily expe. that safety inprovments would be required as backfits which result in an insignificant or small benefit to public health and safety or the cmmon defense and security, regardless of the inplmentation costs." Id,. at 38102.
8/ 50 Fed. Reg. at 38101.
9/ The bacic purpose of the backup hospital is to provide patient evaluation and long-term care in cases of severe radiation exposure. Such evaluation and treatment is norrally beyond the (Fcotnote Ccatinued)
emergency planning regulations simply require that "[a}rrangements are made for medical services for contaminated injured individuals,"EI which the planning guidance defines as " local and backup hospital and nuidical. services - having the capability for evaluation cf radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals." E Accordingly, no requirement that a backup hospital be closer than 45 minutes driving time is contained in the Cczanission's regulations or planning guidance. Except for its newly created requirement of closer proximity, the Appeal Board found no inadequacy in the' capability of HUP toperformitsdesignatedbackuprole.NI (Footnote Ccntinued) innadiate capacity of the local hospital. See, . eg, Limerick, supra, LBP-84-31, 20 NRC 446, 531-32 (1984); Ccmmonwealth Edison Capany (Byron Nuclear Power Station, Units 1 and 2), IRP-84-2,19 NRC 36, 266 (1984) .
-10/ 10 C.F.R. 550.47(b) (12) . Further detail is provided in 10 C.F.R. Part 50, Appendix E, Sections IV.E.6 and 7, which require that
"[aldequate provisions shall be made . . . for . . . [alrrangements for transportation of containated . injured individuals fra the site to specifically identified treatment facilities.outside the site boundary" and for " treatment of individuals injured in support of licensed activities on the site at treatment facilities outside the site boundary."
M/ Criteria for Preparation and Evaluation of Radiological Bnergency Response Plans and Preparedness in Support of Nuclear Power Plants, NURErs-0654, Criterion L.1 (Rev.1, November 1980) -("NUREG-0654") .
M/ '1hus, the Board found no' deficiency in the existence of agreenents with the primary and why hospitals for receipt of contaminated injured onsite workers, nor any inadequacy with arrangenents at the
- primary hospital- designated in the Licensee's energency plan, the Pottstown Memorial Medical Center ("Pottstown Menorial"), located about two miles from Limerick.
There are no unique medical support needs for Limerick which justify making it a special case apart frca every other licensed plant in the United States.EI Several licensees in the South use the Oak Ridge National Laboratory Hospital for their backup facility. In the case of Turkey Point, this hospital is approximately 800 miles away.b Conversely, the Ccmnission has approved many plans with primary hospital facilities which are within the EPZ. The hospitals approved for the Pilgrim plant present an almost identical situation to those for Limerick. Pilgrim's primary hospital is two miles from the site and the backup facility is 35 miles away.
t In short, there is no regulatory basis for requiring more than one backup hospital or_ for requiring that the hospital be closer than a 45-minute drive from the facility.
'Ihe Appeal Board correctly stated that the ccmmission's standard is
" prudent" planning,E but overlooked the Ccmnission's statement in San
-13/ 'Ihe staff expert testified that the Ccmmission has routinely licensed plants on the basis of a primary hospital near the plant and a backup hospital at a greater distance from the plant (Sears, Tr. 9929). In reported cases, the Diablo Canyon plant relies upon backup Mimi support at St. Francis Menorial Hospital in San Francisco, about 200 miles frce the facility. See Pacific Gas and Electric Capany (Diablo Canyon Nuclear Plant, Units 1 and 2),
LBP-81-21, 14 NBC 107, 134 (1981). 'Ihe backup hospital for Byron is the Northwestern Memorial Hospital, which is located in Chicago, likewise 50 miles away from the plant. Byron, supra, LBP-84-2, 19 NBC 36, 266 (1984) .
14] Attachment A contains a conparative listing of the approximate distances frca representative reactor sites to their primary and backup hospital facilities.
15/ See Southern California Edison Ccupany (San Onofre Nuclear Generating Station, Units 2 and 3), CLI-83-10, 17 NBC 528, 533 (Footnote Continued) 4
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s-Onofre that it was aware of "the general practice for licensees or offsite authorities to make _special arrangenents for emergency treatment of contaminated injured onsite personnel and emergency workers."E
- ht <+wa.tvation at least inplicitly approved the adequacy of existing arrangements for operating plants, which are no different than for ,
TAmarick. If the Ccmmission wishes to change onsite planning require-ments, it would obviously do so in the context of its current rulanaking i
on renand frm GwWD v. NRC, supra, inaensch as the Comnission has held that medical arrangements already in place for onsite workers and +
emergency workers provide " core services" - for the general public as ,
well.EI l The Appeal Board's judgment that HUP is "too distant" to function
. as a backup is rooted in a major unfounded prenise. It seriously erred i
l in its implicit asstaption that other hospitals more distant frm j Limerick but closer than HUP would be unavailable or incapable of providing emergency madical care for contaminated injured individuals.
j ht assunption flies in the face of the Comnission's holding in San Onofre that prudent planning for madical services "does not require dedication of resources to handle every possible accident that can be 4
f l (Footnote Continued) e (1983), rev'd on other grounds, GUMD v. NBC, 753 F.2d 1144 (D.C.
Cir. 1985) .
. 16/ Id. at 535.
I 17/ Id.
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imagined," but can be satisfied by " core planning with sufficient planning flexibility to develop a reasonable ad hoc response . . . ." E l Moreover, the uncontradicted testimony frm both the Licensee's medical expert and the staff's planning expert, both uniquely qualified by training and experience, was that the probability of a total hospital evacuation in the event of any radiological emergency, as distinct frm the general population, is "vanishingly small."EI Even the Licensing 18/ Id. at 533. There are a nurrber of hospitals in the area of the Erick plant, including Phoenixville, Reading and Norristown, which are approximately eight to ten miles frm the site (Linnemann, Tr. 9906, 9911; Bayer, Tr. 9911) . Licensee's medical expert testified that no hospital would decline to accept a patient because the patient was radioactively contaminated. Even assuming high level contamination and a severe injury requiring im-Hate surgery, "it would be almost virtually an inpossible situation" that contamination would preclude acceptance of the patient and, therefore, there is no possibility "that contamination is going to interfere with life-saving measures" (Linnamnn, Tr. 9922), the sole justification for the Appeal Board's requirenent of a second backap hospital..
-19/ Limerick, supra, LBP-84-31, 20 NRC 446, 534 (1984). The staff's witness was John R. Sears, a Senior Reactor Engineer with the Dnergency Preparedness Branch, Division of Dnergency Preparedness and Engineering Response, Office of Inspection and Enforcement.
Since 1976, Mr. Sears has served as the reviewer responsible for energency planning for operating reactors in the United States.
See ff. Tr. 9776, Professional Qualifications of John R. Sears at
- 2. Licensee's principal witness on medical services was Dr. Roger E. Linnanann, who specializes in the areas of radiobiology, radiology and nuclear medicine. See ff. Tr. 9772, Professional Qualifications, Roger E. Linnenann, M.D. Several licensing boards have relied upon Dr. Linnerann's testimony on this subject in other s uceedings such as San Onofre and Byron.
In Diablo Canyon, the Ccunission expressly authorized licensing boards to consider the probability of postulated events in determining whether energency planning measures are prudent and adequate. In holding that a board need not consider the conterporaneous occurrence of an earthquake and a radiological release fra a nuclear plant, the Ccmnission held "that earthquakes (Footnote Continued)
_9_
D Board dissent, upon which the Appeal Board relied, agreed with the majority that " probabilities nust be kept in mind" such that plans need not account for contingencies "too remote" in reality.2_0/
Beyond the " core services" required by Section 50.47(b) (12) and NUREG-0654 (i.e., designation of a primary and backup hospital), the Ccanission has stated that prudent planning even for the general public only requires identification of " local or regional medical service facilities considered capable of providing support for contaminated injured individuals."El Indeed, the Comission's recent policy state-nent on M imi services prohibits a board frcan inquiring into the specific capabilities of hospitals which suppleent " core services."El (Footnote Continued) of sufficient size to disrupt emergency response at Diablo Canyon would be so infrequent that their specific consideration is not warranted." Pacific Gas and Electric Con 1pany (Diablo Canyon Nuclear Power Plant, Units 1 and 2) , CLI-84-12, 20 NBC 249, 252 (1984) (enphasis aMad) . As the Ccanission further noted,
" emergency plans do have considerable flexibility to handle" even unforeseen events. Id. at 253.
20/ Limerick, supra, ~BP-84-31, 20 NFC 446, 530 (1984) .
. 2_1_/ San Onofre, supra, CLI-83-10,17 NRC 528, 535 (1983) .
M/ See Statment of Policy cn Dnergency Planning Standard 10 CFR 50.47 (b) (12) , 50 Fed. Reg. 20892 (May 21, 1985)..
In its policy statement, the Ccmnission, in effect, reinstated the holding by the Licensing Board in San Onofre which rejected an argtrient that a hearing should be afforded cn the capabilities of hospitals listed in the offsite plans. See San Onofre, supra, IEP-83-47, 18 NRC 228, 232-33 (1983). 'Ihus, the Appeal Board inproperly rejected the uncontradicted M imi testimony that all of the hospitals in the area of Limerick have been certified by the Joint Ccanittee on Hospital Accreditation to have adequate plans for handling contaminated injured patients. Limerick, supra, LBP-84-31, 20 NRC 446, 534 (1984).
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'e In sum, the Appeal Board departed fran the plain text of the regulations _ and haaari its holding upon a subjective belief that more planning was r==dar1 It had no authority, however, to substitute its i judgment as to what constitutes " prudent" planning for that of the ,
4 Ccaunission in 'its regulations and planning guidance. 'Ihe Appeal Board's intuitive belief that'a 45-minute driving time renders a backup hospital j inadarmte cannot, therefore, be justified.El Exercising Discretion to Review
'i
'Ihe Ocmunission should exercise its discretion to review this i
inportant issue of Cmmission policy' and its regulation on medical support preparedness in order to ensure that all nuclear plant appli-cants and licensees are subject to a uniform, nondiscriminatory standard
)! regarding the availability of a backup hospital for contaminated injured 1 onsite workers. 'Ihere is no sound reason why any single plant should be i
1 i
i 2_3/
3 By contrast, the regulations and planning guidance are quite :
,' explicit whenever they require that certain emergency responses i
- nust be capable of being performed within a given time. See, n ,
i 10 C.F.R. Part 50, Appendix E, Section IV.D.3 (notification of governmental agencies within 15 minutes after declaring an
! emergency; initial notification of public within the EPZ in 15 l minutes); NUREG-0654, Criterion B, Table B-1 (onsite augmentation capability 'within 30 and 60 minutes), Criterion J.5 (onsite i
personnel accountability within 30' minutes), Criterion J.12 (monitoring evacuees at relocation centers in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />), Appendix 3 ,
(notification within 45 minutes of EPZ population not receiving initial notification); ' Functional Criteria for Dnergency Response i
Facilities, NUREG-0696 (February 1981) at 9 (location of 'nchnical Support Center within two minutes walking time fran control room i
and full operational readiness in 30 minutes), at 18 (location of a Bnergency Operations Facility within 10 to 20 miles fran plant) .
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- subjected to mw and different requirements which exceed . existing regulations and planning guidance.
Respectfully subnitted, CONNER & WETITERHAHN, P.C.
o B. Conner, Jr.
W) N* h Robert M. Bader Counsel for Licensee Noveter 5, 1985 r
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l APPENDIX A l List Of Representative Or rating Nuclear Power Plants And Primary And Backup Hospitals For Treaggent Of Contaminated Injured Onsite Workers-i Name And Distance From Name And Distance From l Name And Location Plant to Location Plant To 1
Location Of Primary Primary Hospital Of Backup Backup Hospital of Plant Hospital (Miles) Hospital (Miles) l Arkansas Nuclear St. Mary's 5 University of 66 One, Units 1 Hospital Arkansas for and 2, Pope Russellville, Medical Sciences County, Arkansas Arkansas Little Rock, Arkansas Oak Ridge 525 REACTS Facility Oak Ridge, Tennessee Brunswick Dosher Memorial 3 New Hanover 20 l
Steam Electric Hospital Memorial Plant, Units 1 Southport, Hospital and 2, Brunswick, North Wilmington, North Carolina Carolina North Carolina
-1/ The distances in Appendix A, sometimes approximate, were obtained as follows: Licensees' designated location of primary and backup hospitals were taken from information in their emergency plans and the Commission's Environmental Statements and Safety Evaluation Reports.
Where the hospitals were located within 100 ciles of the site in cities in excess of 1,000 residents, the distances were taken from Demographic Statistics Pertaining to Nuclear Power Reactor Sites, Table 15 (October 1979) (NUREG-0348). In instances beyond 100 miles and in smaller towns, straight line map measurements on a standard atlas were used. No attempt was made to determine the relative location of the particular hospital within the city. In some instances, distances to the identified towns were tak n from (NUREG-0580), Regulatory l Licensing Status Summary Report (January 1984). Whera more specific information is
! available, the data are marked by a footnote.
o-. o-2 --
Name And Distance From Name And Distance.From Name And Location Plant to Location Plant To Location Of Primary . Primary Hospital Of Backup Backup Hospital-of Plant Hospital (Miles) Hospital (Miles)
Byron Nuclear Rockford 16 Northwestern 85 Power Station, Memorial Memorial-
. Units 1 and 2, Hospital and Hospital Ogle County, Swedish American Chicago, Illinois Hospital Illinois
.Rockford, Illinois callaway- Callaway 10 Northwestern 350 Plant, Units 1 Community Memorial' and 2, Calloway Hospital Hospital County, Missouri- Fulton, Missouri Chicago, Illinois Catawba Nuclear Piedmont Medical 9 Oak Ridge 200 Power Station, Center REACTS Facility Units 1.and.2, Rock Hill, Oak Ridge,
. York County,. -South Carolina Tennessee South Carolina Cooper Nuclear Nemaha County 10 Falls City 25 Station, Nemaha Hospital Community County, Nebraska Auburn, Nebrasha Hospital Falls City, Nebraska Diablo Canyon French ~ Hospital 10 St. Francis. 200 Nuclear Power San Luis Obispo, Memorial Plant, Units 1 California Hospital and 2, San.Luis San Francisco, Obispo County, California California
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3-Name And Distance From Name And Distance From Name And Location Plant to Location Plant To Location Of Primary Primary llospital Of Backup . Backup.Hospitall of Plant Hospital (Miles) Hospital (Miles)
Joseph M. Farley Southeast 16 University of 190 Nuclear Plant, Alabama Medical Alabama at Units 1 and 2, Center Birmingham Houston County, Dothan, Alabama Medical Center Alabama Birmingham, Alabama Oak Ridge 340 REACTS Facility Oak Ridge, Tennessee Fort St. Vrain North Colorado 16 St. Luke's 35 Nuclear Medical Center Hospital Generating .Greely, Colorado Denver, Station, Weld Colorado County, Colorado Haddam Neck Middlesex 9 Lawrence & 22 Plant, Middlesex Memorial Memorial County, Hospital Hospital Connecticut Middletown, New London, Connecticut Connecticut Kawaunee Nuclear Two Rivers 22 University of 135 Power Plant, Community Wisconsin Kawaunee County, -Hospital Hospital &
Wisconsin Two Rivers, Clinics-Wisconsin Madison, Wiscsnsin Monticello Nuclear Big Lake 5 2/ North Memorial 35 Generating Plant, Hospital Medical Center Unit 1, Wright Monticello, Robbinsdale, County, Minnesota Minnesota Minnesota 2/ As stated in plan.
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Name And Distance From Name And Distance From Name And Location Plant to Location Plant To Location Of Primary ' Primary Hospital Of Backup Backup Hospital of Plant Hospital (Miles) Hospital (Miles)
Oconee Nuclear Oconee Memorial 8 Oak Ridge 120 Station, Units 1, Hospital REACTS Facility 2 and 3, Oconee Seneca, Oak Ridge, County, South South Carolina Tennessee Carolina l Perry Nuclear Lake County 7 Northwestern ; 350 Power Plant, Memorial Memorial Units 1-and 2, Hospital, Hospital Lake County, Painesville, Chicago, Ohio Ohio Illinois, Hospital of the' 340 University of Pennsylvania Philadelphia, Pennsylvania l
l Pilgrim Nuclear Jordan Hospital 2 Shriners Burns 38 Power Station, Plymouth, Institute
! Plymouth, Massachusetts Boston,
! Massachusetts Massachusetts Point Beach Two Rivers 8 University of 120 Nuclear Plant, Hospital Wisconsin Units 1 and 2, Two Rivers, Hospital &
Manitowoc County, Wisconsin Clinics Wisconsin Madison,'
l Wisconsin l Quad-Cities Moline Public 20 Northwestern 140 l Nuclear Power Hospital Memorial Station, Units Moline, Hospital, 1 and, Rock o Illinois Chicago,
- Island County, Illinois
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5-Name And Distance From. Name And -Distance From.
Name And Location Plant to Location Plant To Location Of, Primary . Primary Hospital Of Backup Backup Hospital of Plant Hospital (Miles) Hospital (Miles)
St. Lucie Nuclear Lawnwood Medical 8 Oak Ridge 700 Power Plant, Center REACTS Facility Unit Nos.11 and Ft. Pierce, Oak Ridge, 2, Hutchinson Florida Tennessee Island,' Florida Sequoyah Nuclear Earlanger 18 Oak Ridge 71 Plant, Units.1 Medical Center REACTS Facility ,
and 2, Hamilton Chattanooga, Oak Ridge, County, Tennessee Tennessee Tennessee 1
Virgil C. Summer Richland Memorial 26 Oak' Ridge. 215 ,
Nuclear Station, Hospital REACTS Facility ;
j Unit 1, Columbia, Oak Ridge, i Fairfield South' Tennessee 1 County, Carolina South Carolina r
28 2/
Susquehanna !
Berwick. Hospital 5 Geisinger -
Steam Electric Berwick, Mcdical Center Station,. Units Pennsylvania Danville, l 1 and 2, Pennsylvania Luzerne County, Pennsylvania Hospital of 100 University of Pennsylvania Philadelphia, Pennsylvania Turkey Point Baptist Hospital 25 Oak Ridge 800 l Nuclear of_ Miami REACTS Facility i Generating Miami, Florida Oak Ridge, j Plant, Units 3 Tennessee i and 4, Dade ,
County, Florida .
3/ Measured on Appendix E, Pennsylvania Disaster Operations Plan, PEMA, 1981. .
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.. ,l 6-Name And Distance From- Name And' . Distance From*
Name And Location Plant to Location- Plant To Location Of Primary, Primary Hospital Of. Backup. Backup Hospit'a lj of Plant Hospital (Miles) Hospital . (Miles) -
Wolf Creek' Ransom Memorial 40$I University of. 83L Nuclear Hospital Kansas Medical +
Generating Ottawa, Kansas Center'
_ Station, Unit Kansas City,.
No. 1, Coffey Kansas County, Kansas
. Zion Station, . Victory Memorial 7 Northwestern 40 Units 1 and 2, . Hospital Memorial Lake County, Waukegan, Hospital-Illinois Illinois . Chicago, Illinois 4,/- As stated in plan. ~
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6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-! - In the Matter of )
)
! Philadelphia Electric Company ) Docket Nos. 50-352 l ) 50-353
- ~(Limerick Generating Station, )
-Units 1 and 2) )
i
-CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Petition z
for Review of ALAB-819," dated November 5, 1985 in the i captioned matter have been served upon the following by deposit in the United States mail this 5th day of November, 1985:
i
- _ Samuel J. Chilk, Secretary Lando W. Zech, Jr.,
Office of the Secretary Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory
. Commission Commission
- Washington, D.C. 20555 Washington, D.C. 20555 Nunzio J. Palladino, Christine N. Kohl, Chairman
[' Chairman Atomic Safety and Licensing U.S.. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory s - Washington, D.C. 20555 Commission Washington, D.C. 20555 Thomas M. Roberts, Commissioner Dr. Reg'inald L. Gotchy 3 U.S. Nuclear Rugulatory Atomic Safety-and Licensing-Commission Appeal Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission James K. Asselstine,- Washington,.D.C. 20555 Commissioner
- U.S. Nuclear Regulatory Gary J. Edles
- Commission . Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Frederick M. Bernthal, Commission
. Commissioner. Washington,ED.C. 20555 U.S. Nuclear. Regulatory Commission.
Washington,.D.C. 20555 v ,-
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Helen F.'Hoyt, Esq. ' Atomic Safety and Licensing Chairperson- Appeal Panel Atomic Safety.and U.S. Nuclear Regulatory
/ Licensing Board U.S. Commission
. Nuclear Regulatory Washington, D.C. 20555 Commission
-Washington, D.C. 20555 Docketing and Service Section Office of.the Secretary Dr. Richard F. Cole U.S. Nuclear Regulatory
~-Atomic. Safety and Commission.
Licensing Board __ _
Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Ann P. Hodgdon, Esq.
Washington, D.C.
20555 counsel for NRC Staff Office of the_ Executive Dr. Jerry Harbour Legal Director Atomic Safety and U.S. Nuclear Regulatory
-Licensing Board Commission U.S. Nuclear Regulatory _ Washington, D.C. 20555
' Commission:
Washington, D.C. 20555 Angus Love, Esq. 107 East Main Street Norristown, PA 19401 Atomic Safety and Licensing
- Board Panel Robert J. Sugarman, Esq.
U.S. Nuclear Regulatory Sugarman, Denworth &-
Commission . Hellegers Washington, D.C. 20555 16th Floor, Center Plaza 101 North. Broad Street Philadelphia Electric Company Philadelphia, PA 19107 ATTN: Edward.G. Bauer, Jr.
'Vice President & Director,. Pennsylvania General-Counsel Emergency Management Agency 2301 Market Street Basement, Transportation Philadelphia, PA 19101 and Safety Building Harrisburg, PA 17120 Mr. Frank R. Romano 61 Forest Avenue Kathryn S. Lewis, Esq. City of Ambler, Pennsylvania 19002. Philadelphia. Municipal Services Bldg. 15th and JFK Mr. Robert L. Anthony Blvd. Philadelphia, PA 19107 Friends of the Earth of the Delaware Valley 106 Vernon Lane, Box 186 Moylan, Pennsylvania _ 19065 l
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Charles W. Elliott, Esq. Spence W. Perry, Esq.
325 13. 10th Street Associate General Counsel Easton, PA 18042 Federal Emergency Management Agency Phyllis Zitzer,-Esq. 500 C Street, S.W., Rm. 840
. Limerick Ecology Action Washington, DC 20472 .
P.O. Box 761 4
762 Queen-Street Thomas Gerusky, Director L Pottstown, 1NA 19464- Bureau of Radiation 4
Protection Zori G. Ferkin, Esq. Department of Environmental Assistant Counsel. Resources Commonwealth of Pennsylvania' 5th Floor,'Fulton Bank Bldg.
Governor's Energy Council Third and Locust Streets 1625 N. Front. Street Harrisburg, PA 17120 2
Harrisburg, PA1 17102 i James Wiggins Jay M. Gutierrez, Esq. U.S. Senior Resident Inspector Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 631 Park Avenue P. O.-Box 47 King of Prussia, PA' 19406 Sanatoga, PA 19464
. Timothy R.S. Campbell Mr. Ralph Hippert
- Director .
Pennsylvania Emergency Department of Emergency Management Agency l Services B151 - Transportation i 14 East Biddle Street Safety Building West Chester,' PA 19380 Harrisburg, PA 17120
. Theodore G. Otto, Esq.
Department of Corrections
! Office of' Chief Counsel P.O. Box 598 Lisburn Road Camp Hill, PA 17011 i
i i
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! LRobert M. Rader A
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