ML20235G585

Awpp (Romano) Answers Licensee Argument II as Per Order of 870522 Re Representational Standing.* Urges Licensee to Show Cause Why Cable Pulling Necessitates Greater Air Leakage from Reactor Openings

ML20235G585
Person / Time
Site:	Limerick
Issue date:	07/05/1987
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
CON-#387-3976 OLA, NUDOCS 8707140304
Download: ML20235G585 (6)

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AIR and WATER cm.

Pollution Patrol BROAD AXE,PA. 87 JUL 10 A9:07 July 5, 1987 U

UNITED STATES OF AMERICA cov T, T

NUCLEAR REGULATORY COMMISSION )

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

In the Matter of PHILADELPHIA ELECTRIC COMPANY Docket No. 50-352-OLA l

(Limerick Generating Station (Iodine Spikes)

Unit 1) l AWPP (ROMANO) ANSWERS LICENSEE ARGUMENT II AS PER ORDER 0F_MAY 22, 1987 RE " REPRESENTATIONAL STANDING" Now that the Nuclear Regulatory Commission has vacated Li- I censee Argument I and thereby upholds the democratic right of an American citizen to not be denied the opportunity to oppose eff-i orts of a high organization's legal manuvering on a technicality involving NRC, Staff, Secretaries, Licensee, etc., AWPP responds to Licensee Argument II.

In Argument 11, Licensee argues that AWPP has not met the requirements for " representational standing" in spite of the fact that Romano has represented Air and Water Pollution Patrol I as its designated chairman, and intervenor on two seperate con-tentions. To indicate fruther representation, AWPP (Romano) also sought but was denied intervention on the hazzards of as-bestos and vinyl chloride in this same Limerick Licensing pro-l ceeding. Those issues are now being investigated _through the U.S. EPA, with Licensee still objecting.

i Licensee alleges that prior participation by an organi-i zational intervenor in an earlier proceeding does not establish

) its interest with regard to a separate, subsequent proceeding

! for the same facility.

i However, Licensee knows very well that AWPP's participa-i tion is not based on one proceeding, but on closing the Limer-ick reactor. Inasmuch as Frank Romano started the Air and Water i

Pollution Patrol and as its only chairman, AWPP (Romano) sim-ulates the same PECO effort by Lee Everitt.

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AWPP (Romano) Answers Licensee Argument II continued.

l The Licensee knows very well since incorporation over 15 years ago, AWPP opposed the reactor from ground breaking on-wards. Because of many construction faults, for example in welding (76-06-01) and improperly proportioned concrete (76 09) ,which left Limerick with a patched up reactor vessel, AWPP's '

active interest in his, AWPP members, and the public safety has been further encouraged by gross obvious mismanagement that re-l cently culminated in control room supervisors usi'ng security guards as lookouts while they slept at the controls.  ;

Knowing the carelessness of the Licensee via hundreds of LER's, how can the NRC permitP. ammendments that could lessen the margin of safety resulting from careless increades in iodine spikes because of decreased reporting of such spikes? Subse-quent to the Licensee request for the iodine spike amendment PECO's real mismanagement surfaced with conditions that the NRC was forced to' describe as "beyond management control". As a result, Licensee must be forced to abide by the strict letter of the license granted---that is, no amendment except one that would increase safety.

Licensee questions whether members of AWPP exist, or "that AWPP is anything more than Mr. Romano himself and perhaps his own family". AWPP (Romano) will not take the time of Judges in postulating whose breakthrough defense tactics spawned Argu- l ments I and II, other than the same " Licensee". Further in this year of the Constitution the rights of the individual is still s

- to be considered were it necessary.

Licensee asserts AWPP's concierns regarding personal health and property value loses is wholly conclusionaty. But Liceness also calls the Chernobyl accident effects.conclusionary, But l

as it relates to conclusions, AWPP has predicted the possibility of Chernobyl effects for 15 years. PECO attempts to create the impression it only wants to question whether AWPP has demonstrated

, i a concrete interestawhen in fact Licensee desperately wants to L__________-_.___-___________.

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1 AWPP (Romano) Answeres Licenax1 Argument II continued i l

l remove AWPP's constant, watch dog effort. 1 On page 16 of Licensee's May 20, 1987 effort to deny AWPP opposition to Ammendment re iodine spikes, Licensee suggests even l the Chernoybl accident does not prove AWPP's members are concerned about the instant proceeding which could permit Licensee to allow release of more radioactive iodine, with loss frequency of report-ing those higher than normal releases to. keep from the public in-formation whose currency could mean the difference in leaving the I area of an accident.

Licensee states that AWPP's allegation that the requested amendment " seeks to decrease the safety guidlines in the NRC regu-lations" is untenable on its face inasmuch as the application does not involve a request for an exemption from any safety requirement, but while not seeking total exemption from any safety requirement, it does make safety related changes in a safety requirement.

Changing the reporting requirements from the time (or times as happens so of ten at Limerick--see 1986 LER's) when they occur, to annually, it will be reported as a yearly figure that could meet the requirement for a year. But a high un-expected iodine release could exceed the one-time limit, be it hour or day or week limit.

Such a release in excess could cause damage to unprotected thyroid on the one hand and other organs, in particular,in pregnant women when fetal life-lasting injury is possible.

While AWPP's concern goes beyond its members--Romano, its chairman has a special personal interest in that my property with-in ten miles of Limerick where I might, on the one hand, be adverse-ly affected by a one-time high presence of radioactive iodine, or long-time lower concentration. On the other hand, an accident at Limerick as AWPP has warned, will result in wholesale reduction of property values--or even, as at Chernobyl, result in preventing return to the area for indefinite years with great personal loss.

The argument of Licensee (see page 18) regarding the inef-

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(4) l AWPP (Romano) Answeres L'.censee Argument II continued:

festiveness of long standing interest, or the qualification in the standing of an organization for judicial review is passe now that the world knows a nuclear reactor is a daily threat, no matter where it is. Certainly 10, 20, 30 miles.from a reactor is suff-icient to be a daily threat from an accident. And when, in the l case of PECO management which resulted in control room supervisors showing utter contempt for specified safety procedures to the point where it was beyond management, this relaxing ammendment, unbeliev-ably' offered by the NRC, no doubt on the now disproven basis of better operating conditions and good management, must now be de-

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nied.

Generic Letter No. 85-19, dated Sept. 27, 1985 with enclosure re REACTOR COOLANT SYSTEM, 3/4.4.8 SPECIFIC ACTIVITY, LIMITING CON-DITION FOR OPERATION. . .at 3.4. 8b requires Less than or equal to 100/ E microCuries per gram of gross radioactivity. With the in-creased finding of high concentrations of Radon, and with increased findings of Gross Alpha activity in well water of Montgomery County the ammendment to allow increased iodine spikes will naturally in-crease gross radioactivity. Nowhere does Licensee indicate they have tested the effect of increased radon and Gross Alpha, together with increased iodine spikes as it relates to exceeding gross radio-activity in the Limerick area.

Because of Licensee's mismanagement record in construction and I supervision, together with recurring malfunctions of various detec-tors for hazzardous entities, for example, such as a phosgene detec-tor that was set at 50 units when it should have been 4, Licensee does not merit relaxing safety, since the entire control room could.

4 have been killed before the alarm went off. The LER's in just chlor-ine gas detector malfunctions alone numbered over 25 in 1986 alone.

Because of malfunctions that are excused away, because of known Licensee mismanagement, and because of falsification of statements, and even the indiscretion ~. of some NRC officials in excusing actions that could result in accidents, AWPP is calling for a Congressional I

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AWPP (Romano) Answers Licensee Argument II continued:

Investigation into the patched-up reactor vessel at Limerick caused by cutting steel sections out of the reactor vessel looking for poor concrete, 1800 tons of which went into the wall surrounding that reactor vessel. The reactor is a General Electric (GE) re-actor , recently reported by the Cleveland Plain Dealer of May 30, 1987 to have faults which GE's nuclear engineers kept secret.

This Congressional investigation effort has been started by AWPP with Congressman Lawrence Coughlin of the same County as Limerick, who on June 17, 1987 at the request of AWPP wrote to Lando W. Zech, Chairman of the NRC, wherein proof of the withholding of faulty GE design of the Limerick reactor vessel is given.

If the reactor vessel at Limerick, whose integrity was compro-mised by cutting out sections of the circular steel shell ruptured due to high pressure at 100% power, there would be a radioactive iodine spike from the runaway reactor that would exceed the iodine spike of Chernobyl that circled the earth.

Lastly, AWPP urges Licensee to show why cable pulling necess-itates greater air leakage from the reactor openings in Limerick 1, that brings on the lodine spike problem. The cable pulling oper-ation is stated to be necessary to expedite construction of Unit 2, even though Unit 2 construction still has not been fully cleared either by Governor Casey, the Pa. P.U.C.---or by DER's review of the Point Pleasant Pump situation.

Without' sufficient water as may be the case, neither Limer-ick 1 or 2 could operate safely, thus threatening me, my family, members of AWPP, and the general public with massive doses of radio-active Iodine and other radioactive nuclides.

Respectfully submitted, AIR & WATER POLLUTION PATROL

._ w <tff a k R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002

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IR and WATER u,y, i F Pollution Patrol h BROAD AXE, PA.

July 5, 1987 W JUL 10 A9:07 nrn h0Lr: '5 i

UNITED STATES OF AMERICA "A W ' j NUCLEAR REGULATORY COMMISSION  ;

j BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I

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In the Matter of PHILADELPHIA ELECTRIC COMPANY Docket No. 50-352-OLA l (Limerick Generating Station (Iodine Spikes)

Unit 1) 1 I

I AWPP (ROMANO) ANSWERS LICENSEE ARGUMENT II AS PER ORDER l OF MAY 22, 1987 RE " REPRESENTATIONAL STANDING" i

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We certify the above has been served on the latest service list by First Class Mail by deposit in U.S. Post Of fice with and .with~

j out' attachments as is appropriate, Air and Water Pollution Patrol bb.jg f

Frank R. Romano, Chairman FRR/jch I

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