ML20096D728

Submits Issues of Concern W/Respect to Issues 18 & 19 in Response to ASLB 840815 Order Requiring,Inter Alia,Submittal to ASLB by 840906 Re Narrowing of Admitted Issues & Contentions & Repts of Settlements.Certificate of Svc Encl

ML20096D728
Person / Time
Site:	Limerick
Issue date:	08/31/1984
From:	Simon T PHILADELPHIA, PA
To:	Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel
References
OL, NUDOCS 8409060265
Download: ML20096D728 (3)

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LAW OEPARTMENT 15th Floor. Municipal Services Building ,

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CITY OF PHILADELPHIA BARBARA W. MATHER, City Solicitor TERI R. SIMON, Assistant City Solicitor

, 07.fETf' m via (215) 686-5246 August 31, 1984

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Administrative Law Nkfb" Lawrence F. Brenner Administrative Law Judge Richard F. Cole Adminis trative Law Judge Peter A. Morris United States Nuclear Regulatory Commission Washington, D.C. 20555 RE: IN THE MATTER OF:

PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station Units 1 and 2)

DOCKET NOS. 50-352, 50-353 0/

Dear Sirs:

Bursuant to the Board's Order dated August 15,19 84 which requires, inter alia, a submittal to the Board by September 6,19 84 r01ating to tr.e narrowing and focusing of admitted issues and contentions end reports of any settlements, the City of Philadelphia r spectfully submits the following e On August 30, 19 84 representatives of Applicant and the City, cnd representatives of other interested parties met. At the meeting, Applicant handed to the City representatives 'present a copy of letter purporting to contain Applicant's position and analysis with respect to City Issues 18 and 19. This letter is being reviewed by appropriate City officials and response will be made thereto in due course.

Accordingly, as of this time, the City's Issues of Concern rcmain the same, i.e., 3 (18) . Emergency planning in the Ingestion Exposure Pathway is inadequate, and the State Plan is inadequate in the area of emergency planning because in the plan there is no adequate implementable plan for providing an alternate source of water for the City of Philadelphia which is appropriate to the locale of Philadelphia and which gives consideration to the PAG guidelines , namely, subs titution of other B409060265 040031 PDR ADOCK 05000352 PDR g , ,

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Administrative Law Judge Lawrence F. Brenner Administrative Law Judge Richard F. Cole Administrative Law Judge Peter A. -Morris e _ Augus t - 31, 19 84 Page 2.

drinking water sources , importation of -water, rationing, substitution of other beverages

-and designation of critical users. " Implementable; plan" includes consideration of ability to. implement ,

in'which.is-included resources available.

(19) . -Emergency planning in the Ingestion Exposure Pathway is inadequate, and the State Plan is inadequate in the area of emergency planning-because in the, plan there is no adequate implementable-plan or implementable alternatives and methods for decontamination of the City's water supply and water supply system. " Implementable plan" includes consideration of ability to implement-inyhich is-included resources available We will keep the _ Board apprised if any settlements

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cre reached.-

Very truly yours,-

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4 TERI R. SIMON Assistant City Solicitor TRS cc: To all parties e

k _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ . _ _ _ _ - _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _______._______.m.______._..__ ___. ___________._____________.____._________.________________._______________m

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UNITED STATES OF AMERICA.

-J - 10CIIAR REGLUIORY COtESSION A70EC SAFEIY NO LICESSING BOARD-

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i BEKRE THE ADMINISIRATIVE JUDGES lawrence Bremer, Chairman Dr. Richard F. Cole -

Dr. Peter A. Morris

-In the Matter of:

,- - PHILADELPHIA E1ECIRIC C04PAhY -  : DOCKET No. 50-352-OL 50.-353-OL r.

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.(Limerick Generating Station,  :

LUnits-1~&~2T 3

e CERTIFICAIE OF SERVICE' I fhereby. certify that a'true and correct copy of the_ foregoing

- r-letter has been served.on the following persens named en the actsched

service list by hand delivery er b Federal Express Mail, er by' causing

'the.same to be deposited in.envelepes addressed to said persons, first 1 Slass;! postage prepaid,^ and deposited with the Ur. iced States Postal

' Service at Philadelphia,. Pennsylvania. .,.

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.ssictant Ci-J feliciter i

i[ ' h 3.!ED: August 31, 1984 t -

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