ML20099M015

Anthony/Friends of the Earth Motion in Opposition to Util Motion for Exemption from 10CFR50.47 Provisions for Emergency & Evacuation Planning for Graterford Prisoners & Staff.Schedule of Discovery & Hearings Should Be Set Up

ML20099M015
Person / Time
Site:	Limerick
Issue date:	03/15/1985
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
CON-#185-168 OL, NUDOCS 8503210198
Download: ML20099M015 (2)

Text

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'4 R]: PHILA. ELEC. CO. Limerick Nuclear Gen.Sta. DOCKET # 50-352, 353 #b U M TEC March 15,1985 ANTHONY /FOR MOTION IN OPPOSITION TO9Eco'S MOTION FOR EXEMPTION FROM 10 CFR PROVISIONS FOR EKERGENCY AND EVACUATION PLANNING FOR GRATERFORD PRISONERS AND STAFF.

'85 W118 P4:12 Intervenor Anthony / FOS registers our opposition to granting an exemption to PEco from the requiremenkhl,gh[p.47 and 42 U.S.C 2231 for planning for a radiological emergency at LiDE5k in relation to the prisoners and staff of the Penna. maximum security prison at Graterford,dich is within the EPZ. We move the Bo a rd to deny this exemption and to set up a schedule of discovery and hearings to throughly explore'ecargency platis for Graterford and to relate these to the emergency plans for the other entities in the EPZ and adjacent to it.

1. The population concentration at the prison, an estimated average of 2,400, along with the potential threat to the community from accidental release of pris-oners advictimizing of local residents makes A complete, workable, safe plan for Graterford one of the key links in protecting the public in the event of a radio-logical emergency at the Limerick plant.

2. There is such a close interrelation between safe emergency planning for the communities in,and adjacent to the EPZ ,and Graterford that no operating lie-ense should be granted until both plans are approved and demonstrated as workable.

Presently there is no assurance that any plan can be made workable. The Proposed Findings submitted by Ms. Z.G.Ferkirs on 3/6/85 state- (p.2.) ..the Co=monwealth does not choose to certify at this time that the plans are adequate and c pable a of being implemented".

3. Furthermore, the NRC Staff's Proposed Findings, 3/7/85, place a condition l on the current plans,that the testimony of FD'A witness,T.Urbanik,be implemented for traffic control points beyond the EPZ so that ev acuation traffic can " continue to move". (NRC Findings Para. 6,16,37),Urbanik specifies " south and east of EFZ."

Graterford evacuation would have to move south and east away from the plant. Safe l planning for Graterford cannot be assured without the addition of these controls.

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4. #e adopt and endorse all the points in Graterford Inmates' Motion in Opposition to Applicant's Motion for Exemption,eubmitted by their counsel Angus i R. Love. We include the Inmates' Motion in its entirety by reference here. We I also endorse Major John Case, Field Director of the Pennsylvania Prison Society, as a qualified expert.

5. We add the points that follow as essential considerations.which must be explored in discovery and a pre-hearing process,and resolved throdgh testimony and findings in hearings before any operating license can be issued.

6. The timing of a Graterford evacu ation is crucial. Would ' P3'A authorize 8503210198 850315

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'v it at an early stags of a Limerick emargency in order to avoid conflict with evacuation traffic from EPZ7 How many and what kind of prisoners would be assign-ed for e srly evacuation ?

7. The im, pact of a partial,early evacua tion would tie up staff a d n have the potential to cause a panic among prisoners.

S. A postponement of Graterford evacuation to an advanced stage of a Limerick emergency would pose aggravsted problems such as the problematic chan ge of staff shifts with guards having to make plans for their families and homes ra ther than reporting for work.

9 In addition the level of tension in the prison would rise rap' idly with the first radio and TV news of a Limerick emergency and with the pressure on the staff to organize for- a possible evacuation.

10. Any rele a se of prisoners from' locked cells under such tension could create panic conditions,even with additional personnel. The potential for injuries and deaths would be high,both inmates and guards.

11. Perhaps even more inevitable could be the potential for panic an d riat if radiation should be carried by the wind in the direction of the prison and meesures undertaken to measure the levels in the prison and to protect and treat the steff on a pricrity basis.

12. A decision not to evacuate prisoners and to rely on sheltering in the build-ings could pose perhaps1he greatest threat to the safety of prisoners and stsff since the potential for riot sud possibly a mass jail break would be high. Such an eventuality would bring great d nger a to the community.

13. In conclusion we state that the interrelation between emergency plans for Graterford the whole EPZ*ias so compler that neither can be successful without full consider-ation of the mutual impacts. The implications for the public must be completely studied a n d resolved in a complete hearing process. The hazards involved in planning for Graterford must be considered through testimony and public partici-pation. The public must understand the risks,and consent to the safest plan that can be devised.

14. We repeat our motion that the Board deny PEco's motion for an exemption in relation to Graterford prison and its inm ates and staff, and that the Board give the required weight to these emergency plans by setting up a full discovery and hearing procedure. We further move that the Board postpone any decision on emergency plans for the whole EPZ until the hearing process on Gr9t erford emer-gency planning has been ocmpleted and the two aspects have been coordinated into a workable whole.

cc:NRC LB Judges, Staff Counsel, Docketing Serv.Respectfull s d, PR0o , PEMA , FEMA , A . Love , others on Serv. List. Bor 186 Moylan,Pa. 19065

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