ML20073T368

Clarifies Contention 5 Re Ion Exchange Resin Reactor Coolant Polishing Sys,Per 10CFR2.206

ML20073T368
Person / Time
Site:	Zimmer
Issue date:	04/28/1983
From:	Gillman D AFFILIATION NOT ASSIGNED
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP), Office of Nuclear Reactor Regulation
References
820428-01, 820428-1, NUDOCS 8305110290
Download: ML20073T368 (3)

Text

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Directo r:6fi-NuclearJReactor Re6ulation u .  :.

United States Nuclear Regulatory Commission .

Washingtoni:D.'O .120555- m  : .: . 11 - - SERVED MAY 101983

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I 100FR2.206 Appeal of Doug G111 man's Five Cozitentions .

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Attn: . Atomic Safety. and ILicensing Appeal -. -Board!.c : .

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With respect. tb$ohn S.. EryeidIIi .cchairmang_ . **

Administrative' Judge letter.to se cdated April 14; 1983,

good cause. forldelaylinvolves many

issues . The . ..

i ststs.o f '.knowlddge labout :.en61neering :pzioblems : involved -

in tlielZimmer Power'Sta' tion - Unit 1 ( ZPS-1 ). has :  :

only developed si'gnificantly since October.24,1976.

Lookizig through the -Biohogical' Effects ~ o'f Ioni::ing Radiatiozi published'-ty thelnited Natiozis, the '.J mariety -of usagelof ' terms idescribing radiation effects yarie's from', paper to.: pap'ef. One' paper. deals ' strictly .

with: rad, another strictly'with rem, another l

strictly with Roent6en, another strictly with kernia.

l To date 'there :is-no uniformity of radiation standards.

in measuiementi Prom one manufacturer's men.suring instrument to the next', the measurement is only as good as-the existenee of'-that measuring machine. -

Any variation renders an-entirely different measurement, and there is no metallurgical quality control in- --

such instrtaments. The notion of 104 years being ..

the jurisdictional . period of. oversight over any; . .

nuclear: reactor installation raises the problem.of .. . . .

ho=esteading on sites:containing radioactiveidebris.

To claim any problem in " time is of the essence" .

in raising issues about some .nuchar reactor becomes absurd in f,erms of t p. longevity of radinctive emmissions over geological tim thich itJis the intent of the ..

, applicant and USNRC ' ignore.. This-is a serious

! contradiction. The state of biological knowledge. . .

-fne concept of genetic .

I is -truly a shadbles; interdependency 'only being stated recently by . .

Waddington, Stern and Roche. The summary disposition of major time effects of materials on biological forms is also purely a threat to national security becadse the common sense of the people will be assaulted by dictatorial-like disposition of; radiation-time -

' issues in bureaucratic 41egalese short shrift to beat the clock out of the office. This sort of petty p ro c eduralism , while attuned to the realities of ,

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i ad=inistrative work, nevertheless exposes unwittingly .

the reality of serious vac.cums in the. scientific .

community in which the prestige and ~ self-in64eest.

of academic strongholds over discoveries of work generating rindustrial ' outlays for g&ogy, power and control have destroyed the actual realities.of truth, validity and knowledge. All of these events occuring in a society: governed by.lcommunica.tions' mobbing events, in which the daily pzucession of life is governed by hysteria generation.by _to.pologically. unexamined information' flow structures,"and the self-interest:

of consumers , . government,: and . business. In e.this climate .of ractual .and .' sustained primitivism decisions.

ars being dictated by fear-reactions to .the_. inability to understand .the longexvity of. hysteria generation.

And so.. ironically, -while there is graat technologicic._

capability,.1) .is .being . deployed , -or .mo re: iaccurately, is cresonating with the . hysteria . generation. There.

ara..still . vast institutions claiming. people without their understa*d@g .the differenee. . between institutional I

ideniity and_ individual identity., The marketability .

of protoplasm .-has.inereased :in .such a coalety.. to the -

point where.today there hardly exists any frighheningly absurb sciencecfiction . scenario which is not being .

implemented.. The actual measure of; this . chaos is

. pictured.by stockpiling p.rotoplasm liquidation schemes by governments .which. vill not.. exist after any such-actuation. :Thus time is.of .the essencg in gaining a measure:of; perspective .-that to. implement any biosphere .p'oisoning scheme at: any time. becomes the .

vision or ' leadership that..the next generation..will accept. . . . - -

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The development of.a sound record has serious

-cpistemological. problems. if the. issue under inspection in radiation. Radiation.is known-to.be an aversive -

conditioning phenomenon in the laboratory. ..W hen :

radiation.or the' environment is. selected for or -

deployed, this is-the same as saying that it is desired, to obliterate the continuity of human knowledge. ,

The.develoument of a sound record can only occur ~

by maintaining tthat enviro.nment of natural backround radiation. : . Any increase. in the radiation will be , ,

speeding the 3rotoplasmic transition to a new form, .

not necessarily any fo're free fiom hysteria, emotionalism, ,

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or institutional chattel ' schemes,."than~ our present fop.,..

Furthemo ra, what is the sound record that the USE h;

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3 is raintaining shall exist after 104 years? After 104 years will our children see sanctimonious, church, te ple and mosque attending, spen:1k bank owners, pillars of their communities, buying radioactive sites

' to build schools to teach mosaic cloning of human cell lines? And wn't they be speculating protoplasm up and down on margin as well? What is the sound record the USERC claims will exist after 104 years?

The question of delaying the proceeding is simple. End the proceeding.

The five contentions as stated are clearly worded.

In particular, however, Contention 5 may be restated as follows:

Contention 5 The ion exhhange resin reactor coolant polishing system is a SAFETY-RELATED SYSTE per inspection of the Three Mile Island -Unit 2 failure; the operations and the instrument, control and power cables relating to the ion exchange system at the Zinmer Power Station

- Unit 1 are all SAFETY-RELATED SYSTES. (This contention recognizes that the ion exchange systems in a pressurized water reactor and a boiling water raactor are functionally the same.)

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j Director of Nuclear Reactor Regulation ATTH:

Atomic Board axi Safety and Licensing Appeal l

United StatesD.C.

Washington, Nuclear Regulatory Commission 20555 i

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