ML20126K940
| ML20126K940 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/26/1985 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#385-974 2.206, NUDOCS 8507300523 | |
| Download: ML20126K940 (1) | |
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U.S. NUCLEAR REGUIATORY CCL *ISSION ret PHIIA,ELEC CO. Limerick Gen. Sto. Units 1 cnd 2 DOCKET # 50-352,353" July 26,198f APPEAL BY R.L. ANTHONY /F0E TO THE COMMISSION FROM THE ISSUING OF 8 EXEMPTION b PROND CERTAINT REGULATIONS TO PECO AND A FIEDING OF NO SIGNIFICANT IMPACT AND DENTAL 'bb AN ENVIRONMENTAL IMPACT STATEMElff,BY THOMAS M.NOVAK,NRC DIV.0F LICENSING, 6/27/85.
M 29 P1 :16 W
As an intervenor in the Liserick licensing process R.L. Anthony /F0E appeals to 7
the Commission from the issuing of 8 " exemptions from certain requirementsJof 10< CFRu Part 50" to PEco for Limerick Unit 1 by the NRC Division of Licensing,0fficiaW[f' Nuclear Reactor Regulation, on 6/27/85 as recorded for NRC by Thomas. M.Novak, Asst.Ifi.,"in the. Federal Register 7/2/85, pages 27388; 27,389, 27390.
We also appeal NRC's finding and conclusion (p.27390) that (it)"has determined rat to prepara an environmental impact statement for the requested exemptions," and
" conclude (s) that the requested. actions will not have a significant effect on the quality of the human environment".
REQUESTED RELIEP. We appeal to the Commission to revoke the actions of the Division of Licensing in issuing the 8 exemptions and NRC's conclusion that these will have no significant impact on the human environment. We petition the Conuitssion to reverse this dacision and to order tne preparation of an environmental impact statement. We assert that the granting of these exemptions undermines the integrity of the NRC's supervision of nuclear reactor regulations and jeopardizes the public health and safety in violation of NEPA and the Atomic Energy Act. The NRC &ctions indicate a willingness to go along uncritically with the applicant'l requests and to bend the regulations for the sake of me applicant's financial interest at the expense of the public's interests and safety.
In its grantirg of these exemptions and refusal of an imp et study NRC has made judgments that "any alternative to (these) exemptions will have either no environmental impact or greater environmental impact" without undertaking an environmental study to determine the impacts of granting the exemptions and the impacts of alternatives. This un supported judgment is stated
- In relation to all 8 exemptions, Fed Reg.7/2/85 27389, 27389,27390 NRC,therefore,hri. no basis for issuing the exemptions on the assumption of no environmental harm. NRC must revolte the exemptions and require an environmental impact statement.
Radioactive Releases f rom accidentstand Routine Operation. NRC has ' evaluated the im-pact of plant' accidents in relation to the exemptions and has mistakenly concluded that there is no increased risk to the public from radioactive releases. In addition NRC overlooked apparently,the ef fect of these exemptions on routine rele ses of radio-j a
active effluents. The risks to the safety of the public f rom routine releases are point-ed out in our 4/30/85 Petition to ASLB on these releases and our 7/2/85 Brief in sup-port of our appeal to ALAB on these releases. Both of these documants are relevant here and are incorporated here in their entirety by reference.All of the exemptions increase tu the risk of radioactive releases-to the public environment. For example Exemption A (FR 7/z.
.M leaves the refueling floor urequiped to maintain a vacuum. This means that
- leakage 27338 g
a-f rom the primary containment might travel by way of the refueling area and be vented o
to the outside evironment in the absence of the standby gas treatment system. Exeremption b
8 could contribute too, to the risk of leakage to the refueling floor in the event of the f ailure of automatic isolation of hydrogen recombiner lines wtjich penetrate dentain-g ment without the backup of redundant isolation valves.
h ALTERNATIVES.NRC dismissed any consideration of alternatives to the 8 exemptions. This constitutes in practic lly all instances a negligent disregard of the public safety to N
a M
satisfy PECo's need to speed up the low power and test operating process in order to produce electricity at the soonest moment. The allowing of jumpers as a safety measure [gf La o in Exemption C, and the downgrading of seal testing in D subject 9 the public to risk not allowed under NEPA,AEA or NRC regulations.
In all 8 exemptions where there is a chance for the installa tion of adequate equipment NRC must insist on on these alternatives.
cc NRC.Staf f Counsel, Docketing Serv., PECo Respectfully a tmit e Others on Serv. List.
Box 186 Poylan,Pa.19065
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