ML20094R047

Response to Applicant Motion to Strike Air & Water Pollution Patrol (Awpp) Pleading & Reply to Awpp Motion Re Contention VI-I.Contention VI-I Must Be Litigated

ML20094R047
Person / Time
Site:	Limerick
Issue date:	08/10/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20094R023	List: ML20094R020 ML20094R047 ML20094R064
References
OL, NUDOCS 8408200442
Download: ML20094R047 (1)

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. AIR and WATER Pollution Patrol BROAD AXE, PA.

U.S. Nuclear Regualtory Commission Washington, D.C. 20555 Aug. 10, 1984 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter Of PHILADELPHIA ELECTRIC CIMPANY (Limerick Generating Station, Docket Nos. 50-352 Ok-and 50-353 Units 1 and 2)

In " Applicant's Motion To Strike AWPP Pleading And Reply To AWPP Motion Relating To Contention VI-I", applicant answers the July 25, 1984, intervenor Air and Water Pollution Patrol filed "AWPP (Romano) Response to NRC Staff Response Regarding Gross Alpha Contention by AWPP". Applicant further states "to the extent it purports to be a reply to Staff and Applicant's answers to "New AWPP (Romano) Contention Re Gross Alpha (June 26, 1984)," it is prohib-ited by L0 C.R.F. 82.730 (c). As a prohibited pleading, it should be stricken !" . AWPP disagrees and reminds Applicant that in the intrest of public safety (which should be A,pplicant's concern) any finding that can cause over-riding economic and/or health problems, which niether Applicant nor Staff considered, must be litigated ir-respective of when found. For the Applicant to count on preventing or rushing the hearing on significant matters is an effort to divert the intent of the Atomic Safety and Licensing Board.

Applicant further stated "there is absolutely no showing of good cause to justify the late filing" even'though AWPP did state the cause to be a recent finding of marginal Gross Alpha concentra--

tions in drinking water wells in Montgomery County.Neither Applicant nor Staff took such fact (or studied such fact) into consideration.

Further cause is the new, unresolved shortages in well water in Montgomery County. Increases in Gross Alpha, as fallout from the Limerick operation could close drinking water wells due' to Gross l Alpha levels increasing above permitted concentrations.

For these reasons and those cited in the AWPP Jul.y 25, 1984 pleading, re Gross Alpha, this Contention must be litigated, i

Respectfully submitted 8408200442 840814 T TION PATROL PDR ADDCK 05000352 O PDR Fran . Romano, Chairman