ML20133F341
| ML20133F341 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/27/1985 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20133F304 | List: |
| References | |
| OL, NUDOCS 8510100202 | |
| Download: ML20133F341 (3) | |
Text
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AIR and WATER M
Pollution Patrol BROAD AXE, PA.
Sept. 27, 1985 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station and 50-353 Units 1 and 2)
AIR & WATER POLLUTION PATROL MOVES BOARD RE-OPENS RECORD ON ABOVE DOCKET BASED ON NEW PENNSYLVANIA DIVISION OF ENVIRON-MENTAL RESOURCES REGULATIONS RE GROSS ALPHA, RADIUM 226 AND RADIUM 228 The above contention concerns a significant new element being timely presented and having safety significance which can affect a previous Board decision which sumarily dismissed previous sub-mission.
Because this element has a make-sense basis, and specif-ically involves radiological health, safety, and environmental con-cerns, reopening of the record is merited.
This contention arises out of the Aug. 16, 1985 Pa. Division of Environmental Resources (DER) notification to community drink-ing water suppliers of a reduction in permitted gross alpha with involvement of Radium 226 and Radium 228.
All water companies serving at least 10,000 people and draw-ing from the Schuylkill River are involved, companies like Norris-town's Keystone Water Co., Philadelphia Suburban, City of Philadel-phia Water Co., etc.
This change was found necessary because natural radioactive nuclides such as Radium 226 and Radium 228 in Pennsylvania water supplies were higher than previously thought to be present.
As por Section 2.714 (a) (1) AWPP/ Romano has filed timely in that I, being sick on Aug. 12 and in the hospital twice (Aug.17 to 20th then back on Aug. 27 for major surgery).
I was released on Sept.
7th with convalesconse ordered for two to three weeks.
Thus I did not get the Aug. 16, 1985 DER notice until approximately the last week of September. Contentions are Romano responsibility for AWPP.
0510100202 051004 PDR ADOCK 05000352 Q
O AIR and WATER
'~
M Polluties Patrol BROAD AXE, PA.
(2)
AWPP moves Board re-open record re gross alpha, Radium 226, Radium 228:
This contention is timely necessitated by the danger to the public from finding of higher natural radiation, which with increases in radioactive nuclides due to Limerick operation can push the radio-logical concentration in drinking water beyond the 2 pico-curies per liter (pci/1) gross alpha which on checking for Radium 226 and Radium 228 could exceed the Maximum Radiological Contaminent Level to close off water supplies and thereby pose a health and safety problem.
This motion addresses a significant radiological, safety, and environmental issue.
The DER notice, regarding a change in monitor-ing previous to Aug. 16, 1985, signed by Frederick A. Morrocco,Cheif, Division of Water Supplies, DER Bureau of Community Environmental Con-trol, states: "Since the occurrence of Radium 228 is not well docu-mented, and Radium 228 is reportedly twice as radiotoxic as Radium 226, the public health is not adequately protected under the current monitoring procedures (Emphasis added).
Over a year ago, on June 26, 1984 AWPP/ Romano sought to enter a new contention relating to findings within 10 to 15 miles of the Limerick reactor of well water at least borderline for gross alpha concentrations of 5 pCi/l (MCL at that time).
AWPP indicated that any concentrations of nuclides that would increase the gross alpha activity would make wells, and also possibly the Schuylkill River, exceed the Maximum Contaminent Levels.
The Applicant (P.E.) responded that since gross alpha may be contributed to by Radium 226 the permissible range really was 15 pCi/1.
This figure was based on the quantity of Radium 226 always being in excess of Radium 228.
Also the effect of Radon was not entered.
However, the Aug. 16, 1985 newly installed McL has taken into consideration that the need to cut the gross alpha activity also in-volved the new finding that Radium 228 can be substantially higher than Radium 226---and now must be r,afety-compensated by reducing the
AIR and WATER M
Polluties Patrol BROAD E. PA.
AWPP moves Board re-open record re gross alpha, Radium 226, Radium 228:
permitted gross alpha to 2pci/1.
As it relates to protecting the AWPP/ Romano interest, and my capability to assist the record, this new radiological safety and environmental regulation has to do with my field of work, with no similar group contesting the effect of routinely released radioactive nuclides, as well as releases in unusual events at Limerick.
There-fore, re the new regulation, no other means exists to protect the AWPP/ Romano interest.
The Aug. 16, 1985 DER regulation also involves responsibility of water laboratories regarding results of radiological analyses and subsequent analyses when the MCL of 2 pC1/1 gross alpha is exceeded.
My experience and information on borderline gross alpha in wells in Montgomery County enables me to witness that the new regulation, can place many wells beyond the maximum contaminent levels for gross alpha, Radium 226 and Radium 228.
I can, with witnesses or even subpconed EPA and DER personnel familiar with the results of radio-logical tests on well water (and possible radon effect) in Montgom-ery County, assist in factual evidence re this contention.
Further, other existing parties, because of the very recent low-cring of the gross alpha with requirements for testing Radium 226 and Radium 228, have not perhaps become familiar or expressed need for the Doard to concern itself.
AWPP/ Romano, however, feels the higher than expected natural radioactivity in areas surrounding Lim-erick, coupled with releases from Limerick under full power opera-tion, or accident, could result in closing many wells and water sour-ces driven to exceed the MC1 for gross alpha, Radium 226 and Radium 228, such closing due to higher than permitted radiological concen-tration would cause great health, safety and environmental damage.
For all the above reasons AWPP/ Romano seeks expeditious re-opening of the record re this contention, irrespective of broadening or delay.
Respectfully submitted, AIL & WAgR}OLLUTION PATROL s
NenNk Nofnano, Chairman
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The attached has been served on the latest Service List.