ML20039C214
| ML20039C214 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/21/1981 |
| From: | Anthony R FRIENDS OF THE EARTH |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8112290065 | |
| Download: ML20039C214 (5) | |
Text
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UNITED STATES MUCLEAR REGULATORY COMMISSION f,
l,' l JEFORE..THE ATOMIC SAFETY AND LICENSING BOAPS h
att of PHILADELPHIA ELECTRIC COMPANY GN Limerick Gen.*ating Station, Units i and 2 DOCKET Nos.
50-352
}
S DEC28 Rg&
qs gaf HES ONS OF FRIENDS OF THE EARTH IN THE DELAWARE hh15iT;,VC 6 ROBERT L. ANTHONY AND OTHER NAMED INDIVIDUAIS TO THE NR 9
4 AND APPLICANT'S ANSWERS TO THE PETITION OF COORDINATED IN m.vr3 ORS Mll CONTENTION I-53 Fuel Cladding,
PEco is reminded that more detail on this subject is included in a published paper "The Zirconium Connection", The Ecologist Vol.9,Nos 4/5, Aug.1979, referenced in the contention. The generation of hydrogen by zirconium clad rods in emergency cooling posed a grave hazard during the TMI acci. dent.
Until some way is found to make certain that this hazard will not be a possibility in the operation of Limerick,the reactor should not be licensed for zirconium clad fuel rods.
CONTENTION I-54 G.E.0ceratine Record.
The operating record of G.E. reactors is one of the key facters.in safety analysis for future operation'of G.E. reactors at Limerick.
In the TF.I #2 accident General Public Utilities now claims that if they had been supplied with the almost identical history of valve misfunction and cooling water failure in op-
'og crating Eabcodk and Wilcox reactors the accident would not have happened.
x-J G.P.U. has entered a $4 billion damage suit against MIC on this account.
em 88 The parallel with Limerick is obvious. PEco,its ratepayers,the area S
residents,and NHC have a basic interest in knowing in detail the record m
of G.E. reactor failures in order to take precautions and make corrections mfo against any similar or related equipment or operating failures at Limerick.
CONTENTION V-1. Historic Monuments.
The plume and its dimensions are new DW f
matter not considered at the construction sta'Se.
ERCP notes only whether j l the site itself is visible from Hopewell Village and Valley Forge Park.
Although the plume itself may not carry the major part of the radioactive vent releases, the plume is a signal that invisible radioactivity is being
-r-carried in the sa=o direction by the same winds.
The record of-wing dist ' s ribution (FSAE Table 2 3 2.-26) shows more than 25 % frequency of pre-valling WIN and Ibl winds together in the direction of Valley Forge' and King of Prussia. From a factual point of view,without any psychological reference,the plume will show the wind direction and the path in the air of vent releases from the Limerick plant. The visible aspect of the plume will and the parallel invisible Limerick emissions have i= pacts on Valley Forge Park and Hopewell Village and French Creek State Park that have not been cvaluated and constitute new matter.
In relation to the clearance by the Advisory Council on HEstoric Preservation, 36CFR 800.4 puts the responsibility for co=pliance on the requesting federal agency, i.e. AEC (NRC).
AEC was at fault in accepting an inadequate and erroneous evaluation from ACEP,especially one that-did not correspond with any classification under the regulations,"no National Register properties that would be affected" by Limerick.
There is no such classification under 36 CFR 800.3. It specifies " changes" caused by an
" undertaking", i.e. Limerick.
It is apparent that Limerick will bring changes in air, water,and weather conditions as well as the possibility of accident-al hi' h level radioactive releases.
Since these changes were nc considered s
in ERCP they cust come in as new =atteri; lacking in ERCL,too, - P Further infornation is being scught from ACHP files and those of the Penna. State Historic Preservation Officer as to the Limerick plant's effect on National Register properties, Valley Forge Park,Hopewell Village, French Creek Park and the Schuylkill Canal. Frick's Lock,only a few hun-dred feet from the plant constitutes an archeological site which nas dis-missed without evaluation in the ERCP and EROL.
It =ust now be given adequate consideration as new infor ation.
COUTENTION V-2 Schuylkill River.
The staff was correct in noting our error in quoting Table 5 3-9 Ea0L as.175 milligra:s or mercury instead of.175
~
micrograms.
The original conclusion,however, is unaltered after this cor-rection,since the mercury criterion in Table 5 3-5 is.05 nicrosra=s,=aking
=
b is the mixed' blowdown concentration at.175 micrograms of mercury come to 3 5 times the criterion.
As noted in the contention, Mr.Kenneth E.Shull,V.P. for Research/
Environmental Affairs, Suburban Water Co. was supplied a copy of EROL by
.PECo only on Nov.12,1981.
This company supplies a population of 831,000; Keystone Water (Norristown District) serves 72,200.
Suburban Water has its own radioactivity monotoring facilities.
The reviews from these two water companies of the effect of Limerick on water quality is essential new infuzmation.
We reserve the right to submit these reviews when they are available.
The prospects for damaging effects on water quality':inthe &chuylkill s
i from accidents at the plant were raised with Bectel Power Co.by Mr. Norman R.Chupp, Area Manager,U.S. Dept.of Interior, Fish and Wildlife Serv.,Earric-a burg. See copy of Sept.10,1981 letter (EXHIBIT 1.).
W6 are expecting to
)
call upon the Dept. of Int. -for testimony from their experts to provide
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new information not provided in EROL on the long term threats to Schuylkill River qualitypat the appropriate time. 'We reserve the right to add this information to this contention.
i CONTENTION V-3..Firelines and Railroad.
Reasonabily forseeable im-pacts from the hazards noted in this contention are not covered adequately in the FES cr ESAR.
Hence the petitioner asserts these as deficiencies which must be included in the assessment.
i CONTENTIONJ;7II-2.
Constitutional Issues.
T1.e 5th,9th,and 14th l_
Amendments to the U.S. Constitution provide due pr ocessversus threats to citizens' health, property,and well being and NEPA specifies further guarantees..'There are litigable issues under 40 CFR 1500,et. seq. as' set forth in this contention.
The regulations have not been carried out by PECo or adequately enforced by AEC (NRC) in the construction stage or in the Applicantts current submissions.
Parallel issues are presently awaiting a decision by the U.S. Supreme Courtlin No. 80-1137
( Oct. Term 1980)
Caspar W.Weinberger,sec.or Def.,
-s-et A1._ v. Cauclic Action of Hawaii /Feace Education Project,et A1. Cprt iorari has been granted and briefs filed. The intervenor reserves the right to add the Supreme Court decision to this contention when it is handed down.
CONTENTION VIII -11, Valley Forge Evacuation.
There is no chal-lenge here to the NRC Regulation to " provide protective actions for the plume exposure pathway EPZ which shall consist of an area about 10 miles in radius".
This includes Valley Forge Park,where the highways that cross and the visitors' center are 10 to 11 miles from the plant site and the northern park extent is 10 miles. The park,therefore, falls within the NHC guideline of "about 10 mile radius". FSAR Fig.2.2-3 In addition Valley Forge as a state park was included in the 10 mile study area (ERCP Sect.2.1 3 3 ). It is even more significant now since its status was changed to National Historic Monument and Park in 1977. As the park has been included in the 10 mile area, correctly, it must be provided for,in emergency planning for Limerick.
Emergency planning is keyed to traffic movements and population in Eing of Prussia because evacuation would have to be carried out through King of Prussia and the turnpike and expressway interchanges. Movement of traffic north from Valley Forge would be blocked in an emergency by traffic from Phoenixville and the area toward the plant.
Another basic factor to note,FSAR Table 2.1-9,is that for the 10-20 mile radius the ESE sector (Valley Forge, King of Prussin 3crr'istown)' is the l
most populous one and the SE sector (Valley Forge, King of Prussia, Lower Herion,etc.) is the third densest. These two sectors included 241,500 residents in 1980; projected to 247,000 $n 1983,FSAR Table 2.1-10.
Correspondingly,FSAR Table 2 3 2-26, shows the prevailing wind directions from Limerick VRET and HW into these sectors at 255 to 28% frequeny.
The probability for radioactivity being carcied by the wind into the Valley Forge and Eing of Prussia sectors,therefore, is one in four.
This adds emphasis to the importance of evacuation plahs for Valley Forge
7
. U Park 'and gives a clue to the prospects for spontaneous flight and congos-tion in the Valley Forge and Eing of Prussia area resulting from a nuclear smergericy at Limerick.
I certify that I am depositing in the U.S. Mail, firs. class,prepaidi today, copies of this response-to the following:
1.
Judge Lawrence Brenner Dr.Hichard F. Cole Dr. Peter A. Morris Frank R.Honano Ato:ic Safety and Licensing Brd. Panel Docketing and Serv. Sect. lac Edw. G.Eauer,Jr.
Troy 3.Connor, Jr.
Charles Br:^,e Taylor Marvin I. Lewis Atomic Saf.And Lic. Appeal Panel Enviro. Coalition on Unclear Pow.
Thos.Gerusky,Dir. Bur. Rad. Prot.
Dir. Energ. Hgnt. Agency John Shniper Judith A.Dorsey, LEA Donald S.Eronstein James M. Heill Waltsr W. Cohen, Cons. Advo.
Robt U.Adler Randall Brubaker Jos. H. White,III Alan J. Hogee, Keystone All.
Robt.J. Sugar:an, Del-Aware Dr.W:. A.Lochstet
'h d [ k. b h
P.O. Eor 186,Mcylan,Pa.190'65 Dec. 21,1981 Solstice
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UNITED STATES e.
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DEPARTMENT OF THE INTERIOR ~
'h FISH AND WILDLIFE SERVICE s
HARRISBURG AREA OFFICE
' ~ ' ~
100 Chestnut Street, Room 310 Harrisburg, Pennsylvania 17101 ER-81/1617 September 10, 1981 Mr. R.H. Elias, Project Engineer Bechtel Power Corporation P.O. Box 3965 San Francisco, California 94119
Dear Mr. Elias:
We have reviewed the Environmental Report-Operating License Stasa for the Limerick Generating Station, Units 1 and 2, Chester and Montgomery Counties, Pennsylvania, as requested in Mr. Schlueter's letter of July 31, 1981, to Mr. Blanchard, Office of Environmental Project Review, Department of.the Interior.
This letter provides technical assistance only and does not necessarily constitute the views of the Department of the Interior on,the operating license.
In general, the environmental report adequately describes project impacts on existing fish and wildlife resources except for the following:
(1) Chapter 7 discusses in detail the potential impacts to humans from a nuclear accident at the plant.
Very little is mentioned about the potential long-tem effects of such an accident on fish and wildlife resources.
What would be the initial and lo~ng-term impacts to aquatic resources in the Schuylkill River system and to the human use-of such resources in the event of radioactive contamination from a nuclear accident? How long could radioactive materials remain in-the river system and I
adjacent land areas and adversely affect the biota?
What bioaccumulation of radioactive materials occurs through the food web and how would it affect fish and wildlife?
l PAGE 1 of letter from NORMAN R. CHUPP, Area Mgr.
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