ML20039C218

Responds to NRC & Applicant Comments on Contentions in Supplemental Petition of Coordinated Intervenors.Certificate of Svc Encl

ML20039C218
Person / Time
Site:	Limerick
Issue date:	12/21/1981
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	NRC COMMISSION (OCM)
References
NUDOCS 8112290070
Download: ML20039C218 (7)

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Pollution Patrol BROAD AXE; PA.

'81 DEC 28 A8:04 C'FF :!Cr EEChE DOChtilliG & SEn':'-

BRAT 4CH' UNITED STATES OF Av. ERICA... NUCLEAR RT.GULATORY COMMISSION Before the Atonic Safety and Licensing Board k/ /

In the Matter of Philadelphia Electric Co.

Linerick Generating Station Docket No. 50-35 q

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50-35 DEC2 M y 7

RESPONSE TO NRC AND APPLICANT'S CHALLENGE TO R0"ANO CONTENTIOUS, w :q Gr

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The following are Intervenor Ronano's responses to the NRC(Staff's)

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and Philadelphia Electric's(Applicant) con =ents on his contention in the

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Supplemental Petition of Co-ordir.ated Intervenors.

V-4 Staff cocnents that Petitioner Romano wrote that calculations by the Applicant of meteriological effects of plume caused by the cool-ing towers venting 35 million gallons of water as vapor per day were made.

using average tenperatures.

Staff says that is nistaken...evecot in the case of EROLSection S.L 4.2.6.1.2.

Houever, average tennerature relat-ive to cooling tower effects are referenced in LGS EROL table 2.3.2-57 and EROL 5.1-13.

The correlation of contentions required by NRC reducted description, so that average tennerature(and humidity) was referenced from pages 3-13 and 3-14 of the Environnental Statenent, LGS 1 & 2, Nov. 1973 uhich nust be valid if the Construction Pernit based on that reference is valid. We have had weather for a long tine.so that the effects as described on page 3-13 and 3-14 are valid at this tine also.

l Those references state that " Evaporative Cooling Towers have potent-l ial for creating visible plumes of water vapor (as well as invisible)under certain atmospheric conditions...".

Continuing that plunes "nay cause in-creased fogging (and clouds) or icing, which could significantiv interfere with nornal activities (flyint;, driving) in the vicinity".

These referenced effects were discussed as based on "r typical dry bulb of 54 degrees F...

l (which) "should be close to the annual ave / ace in the Linerick area."

Fur-l ther, clouds restricting visibility and capable of air turbulance in flight are referenced in LSG E".0L 1.1.4.2.3, and "Connercial Pilot" Aero Products e.esearch, 2nd EDicion, Culver City, Ca.

PP. 117-119, item 235.

Because of reduced description conconitant with correlated content-ions "uorst condition" was my nain ennhasis as to cooling touer weather 3C)3 i

effects re cloud height, visibility and icing...all of which can restrict S

I visual flight rule flying.

Such effects will nany tines change narginal visual flight rule sky conditions (in which flying is marginally permitted)

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to conditions where the cooling teuer plume has reduced visibility and l

8112290070 811221 PDR ADOCK 05000352 G

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Ronano response to Staff and Applicant cloud height below ninimuns which hen pr g under visual flight rules.

t Further, indisputable increased clouds forned by noisture released from the cooling towers results in increased potential for carbuerator ice induced engine failure with fatal possibilities, with noisture and temper-atures that will exist at least 8 nonths of the year in the vicinity of the Limerick reactor.

Bearing on this is LGS EROL 5.1.4.2.1.1, 5.1.4.2.1.2, and 5.1.4.2.2 re incorrect conparisons, and 5.1.4.2.4 re limited observations on veather nodifications fron natural draf t towers, altogether corroborating contention V-4 is valid.

Further, on the" worst condition" days or parts thereof, when the upper air is stagnant, and saturated with noisture at near freezing temperatures, while LGS EROL reference 5.1.4.2.5 erroneously clains no ground level moist-ure changes will be expected with natural draft cooling towers, that refer-ence onits upper air noisture increases that affect flying in the Linerick area. Further, any seventh grade science book vill be a reference stating the inescapable scientific fact that the distribution and dilution of the vapor from the cooling towers which the Applicant counts on, vill not take place often enough to create the hazzardous flying conditions discussed.

Instead condensation-forned clouds or fogs or snow or ice vill form, creat-ing spontaneous, unsuspected, treacherous conditions one to five thousand feet above the ground (see figure 3.10 and 3.11 of the Environmental State-nent LGS 1 & 2, Nov.1973).

Additionally it is apparant that the Applicant purchased the Linerick l

Landing field, referenced in table 2.1-22 ot GGS EROL, tuo miles from the i

reactor for the purpose of controlling flights by controling the airport.

But the Applicant cannot control ny licensed right to fly, without danger, the air above the field, nor must the Applicant be allowed to cause non-visual flight rule conditions which vill result in denying me, at any time, the priviledge of free novement throughout that air space.

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The report on upper air soundings, Table 5.1-10 of the LGS EROL is un-clear and ccafusing at best, and cannot undue the scientific fact that air can only hold a definite amount of noisture at a definite tenperature.

In place of " soundings" the Applicant must answer as to how cany days (or parts thereof) will the tenperature and noisture conditions be such that th e l

cannot be suf ficient diffusion to prevent decreased visibility and carbuer-l ator ice fornation, and lowered cloud heis, hts (below VFR rules). Many of the calculations nade by the Applicant re diffusion and plune rise nust be questioned. For example, in the equation describing a characteristic of the plume centerline ground level concentrations, it is admitted that re-sults will vary with turbulence, wind speed, surface roughness, and are applicable only to the first 500 neters(1500ft, plus), all affecting even the standard deviation, which neans there can be no real prediction of how the touer plune vill or vill not affect flight visibility and cloud condition.

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Romano response to Staff and Applicant The Applicant's reliance on purely hypothetical formuli to charact-erize weather effects of the cooling towerc, flys in the face of the almost 50% error in general weather prediction, making it very probable that more adverse occurences will occur than will not oc.n.

Further, the Applicant states that the Board, at the permit stage, con-cluded no special arrangements need be cade in plant design due to nearby airport flights. The Applicant is mistaken.

Special arraingements were made, in particular, to accomodate instrument flight procedures, with in-sufficient attention to meterological effects on less experienced VFR pilots (see H-57 of LGS ES Nov. 1973).

There are too many fatal aircraft accidents involving small planes and VFR pilots as fly mainly in the Limerick area.

I seek to litigate this con-tention in conjunction with the present on-going program by general aviation and the Federal Aviation Authority, to insure all possibilities of acciden,ts and freedom of movement through the air space in the Limerick reactor area are avoided.

V-5.

Petitioner's 7asponse to Applicant's comments on V-5 contention:

Re routine, abnormal, and accident releases of health-endanger-ing radionuclides, and radiation therefrom.

My answer will also touch on Staff's apparantly acceptable position. I stated that the body has no way of knowing that an overdose resulting from an excess release on one day is not to be considered an overdose because the dose did not exceed what is allowed in 365 days. The Applicant misstakenly states that statement is an attack on the Commission's numerical guide in meeting the "as low as reasonably achievable" standards of 10 C.F.R. Part 50, Appendix 1.

Hevertheless, without attacking the standard, I feel it to be dangerously liberal and dangerously indicative of the lack of full control of nuclear reactor operation.

Certainly the Cornission did not intend the Applicant to enjoy the free-dom from rebuke when for some reason the calculated annual total quantity of all radioactive units above backgroundwas released in one week, or even one day...when such overdose, one year's worth, would affect me and my fanily's' bod.ies as a physiological response to an overdose, not able to rationalize annual totals.

I challenge the Applicant's operational ability to insure it can add up very snall safe releases toward an annual permitted total of small safe releases.

The Applicant further states there is no basis for requirring an indep-ent radiological program "to be imposed upon a facility licensee in addition

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(4)

Romano response to Staff and Applicant to the radiological nonitoring in Applicant's FSAR. Among others, the Applicant is proceeding on the basis of radionuclides in drinking water of the Environment Protection Administration published 7/9/76.

Those regulations, if not nade more protective, would permit use of "known" radiologically contaminated water for drinking from the Schuyl-kill river.

Known, that is, to the Applicant and the water purveyor...but not requirred to be nade known to those who drink the water...for up to months after that radiologically contaminated wcter is ' continued'to be used.

Not even considering accidental large releases, the contribution of the Applicant from the operation of the Limerick reactor, separately and together with all other releases and fallout from whatever source must be considered. A cumulative amount of radioactive units of small origins that add up to an unacceptable total requires that all the origins be pre-vented.

As it relates to contamination by other chemicals, including PCB's and related chlorinated organics, Applicant states I have no basis for asserting Applicant should be requirred to study the effects of contamin-ation by carcinogenic PCB's routinely used in transformers to be scatter-ed along micro-wave inducing transmission lines throughout Montgomery County areas threatening strean and well water contanination. Further EPA linits PCR's to fractions of parts per billion in drinking water.

l H. Ouality Assurance deficiencies:

l The Applicant states my contention attacked it's quality assurance pro-gran during the construction program.

I agree.

I attacked totally unacc-i eptable examples of slovingly, careless worknanship throughout all levels of operation, including supervision, inspection, etc., all of which stress me psycologically re the resultant increased possibility of accident at Lim-erick, and its effect on the lives of ro,mv family and associates.

The Applicant stated the latest infraction was "over three years ago" indicating the Applicant is unfaniliar with infractions called to their att-ention by the PRC within the past year.

For exanple, a Feb.'81 NRC report to Applicant relating an infraction"uhich deviated fron approved Installation proceedures".

Similarly the Applicant failed to meet the July 1981 deadline for the Linerick reactor warning system.

The Applicant's response suggests an apparant effort to minimize the ser-iousness of critical infractions such as inproper concrete placement in the crucial drywell wall of the containment surrounding the reactor vessel which has yet to be subjected to operation pressures. Further, contrary to the App-licant's "Three years ago" diversionarv statement, improperly poured concrete and improperly welded structures do not inprove with age.

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(5)

Romano response to Staff and Applicant THERE IS !!O OTHER CONTENTION THAT IS HORE TO THE VERY HEART OF SAFETY FOR THE PUBLIC THAN THE CONTENTION I MAKE OF AN OBVIOUS PATTERN OF CARE-LESSNESS EVIDENCED BY IRREFUTABLE NUCLEAR REGULATORY COMMISSION INSPECT-IONS AND REPORTS TO THE APPLICANT OF THOSE INSPECTIONS.

THIS VI CONTENTION MUST BE LITIGATED... FULLY...GIVING THE APPLICANT AMPLE OPPORTUNITY TO PROVE ALL INFRACTIONS WERE KNOUN AND ALL CORRECTED WITHOUT A SHADOW OF DOUBT...THE SAFETY OF THE PUBLIC BEING MORE IMPORTANT THAN PRODUCTION OF UNNEEDED ELECTRICITY.

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'W UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION

'81 DEC 28 A8:04 i

BEFORE THE ATOMIC SAFETY AND LICENSINGJBOKRD t Cil' er d PHILADELPHIA ELECTRIC COMPANY DOCKET NOS. 50-352 50-353 (Limerick Generating Station, Units 1 and -2) i CERTIFICATE OF SERVICE Copie.s of the foregoing have been mailed this date to the ~

following parties:

/Lawrence Brenner, Esq., Chairman Mr. Edward G. Bauer, Jr.

Administrative Judge Vice President & General Counsel U.S. Nuclear Regulatory Commission Philadelp.hia Electric Company Washington, DC 20555 2301 Market Street Philadelphla, PA 19101 Dr. Richard F., Cole Administrative Judge Troy B. Conner, Jr., Esq.

U.S. Nuclear Regulatory Commission Mark J. Wetterhahn, Esq.

Washington, DC 20555 Conner and Wetterhahn 1747 Pennsylvania Avenue, N.W.

<Dr. Peter A. Morris Washington, DC 20006 Administrative Judge U.S.

Nuclear Regulatory Commission Mr. Charles Bruce Taylor Washington, DC 20555 24 West Tenth Avenue

- Max Weiner j

Collegeville, PA 19426 Consurmers Education &

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Mr. Marvin I. Lewis Protective Assoc. (CEPA) 6504 Bradford Terrace 6048 Ogontz Ave.

Phila., Pa. 19141 Philadelphia, PA 19149 Atomic Safety and Licensing Atomic Safety and Licensing l

Board Panel Appeal Panel (5)

U.S.

Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 1

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Docketing

& Service Section James M. Neill, Esq.

Office of the Secretary Associate Counsel for Del-Aware U.S. Nuclear Regulatory Commission Box 511 Washington, DC 20555 Dublin, PA 18917 Environmental Coalition on Walter W. Cohen Consumer Advocate Nuclear Power

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Dr. Judith H. Johnsrud, Co-Director Office of Attorney General 433 Orlando Avenue 1425 Strawberry Square State College, PA 16801 Harrisburg, PA 17120

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Thomas Gerusky, Director Robert W. Adler Assistant Counsel Bureau of Radiation Protection

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Commonwealth of Pennsylvania, IER 4

Dept. of Environmental Resources' Sth Floor, Fulton Bank Building 505 Executive House, Third and Locust Streets P.O. Box 2357 Harrisburg, PA 17120 Harrisburg, PA 17120 5

Director Randall Brubaker Penna. Emergency Management Agency Assistant Counsel Basement, Transportation & Safety Commonwealth of Pennsylvania, DER Building 1315 Walnut Street, Room 1200 Harrisburg, PA 17120 Philadelphia, PA 19107 John Shniper Joseph H. White, III Meeting House Law Bldg. & Gallery 11 South Merion Avenue Mennonite Church Road Bryn Mawr, PA 19010 Schuylkill Road (Rte. 724)

Spring City, PA 19475 Alan J.~Nogee Robert L. Anthony The Keystone Alliance Friends of the Earth of the 3700 Chestnut Street i

Delaware Valley Philadelphia, PA 19104 103 Vernon Lane, Box 186 Moylan, PA L9065 Robert J.

Sugarman l

Del-Aware Unlimited, Inc.

I Judith A.

Dorsey, Esq.

Berle, Butzel, Kass & Case I

Limerick Ecology Action 2115 Bainbridge Street v

1315 Walnut Street, Suite 1632 Philadelphia, PA 19146 Philadelphia, PA 19107 Donald S. Bronstein, Esq.

William A.

Lochstet The National Lawyers Guild 119 E. Aaron Drive l'425 Walnut Street, 3rd Floor State College, PA 16801 Philadelphia, PA 19102

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F Dated:

December 21, 1981

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Frank R. Romano

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