ML20235J049

Response by Intervenor Rl Anthony to Board Order of 870622.* Licensee Opposed to License Amend & Request Hearing to Form Basis for Board to Deny Request.Reduction of Control Over Iodine Spikes & Levels Is Threat to Health of Public

ML20235J049
Person / Time
Site:	Limerick
Issue date:	07/02/1987
From:	Anthony R ANTHONY, R.L.
To:	Atomic Safety and Licensing Board Panel
References
CON-#387-3992 87-550-03-LA, 87-550-3-LA, GL-85-19, OLA, NUDOCS 8707150378
Download: ML20235J049 (2)

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[h U.S. NUCLEAR REGULATORY COMMIS .[.ATOMICSAFETY&LICENSINGBOARD  ;

Judges S.R.Wolfe, R.F. Cole ,P. A. Morris 7/2/87 REs PHILA.ELEC.CO. Li merick Go Stb,Ni b.20 Docket No. 50-352

.p r ASLBP # 87-550-03-LA DOCN RESPONSE BY INTERVENOR ROBERT L. ANTHONY TO THE BOARD'S ORDER OF 6/22/87 I

In its memorandum and order of 6/22/87 the Board set a date for us to  !

reply to Argument II in the Licensee'.s answer of 5/22/87. I hereby submit our response.

l QENERIC LETTER No. 85-19 Thelicensee'sstatementof5/20/87 included {

k,etter,NRC, # 85-19 This letter sets forth. the rationale for PECO's roguest for a license amendment to change Appendir A of license NPF-39 We are opposed to this license amendment and roguest a hearing to form the basis for tho' Board to deny the request. The upshot of NRC's letter is,to lessen NRC and 1 licensee surveillance of and control over releases of radioactive' iodine by down-grading reporting from a licensee report on iodine spiking to merely recording in an annual report. Further lowering of standards of safety would result from deleting " information regarding fuel burnup by core region ".

Licensee's argument II challenges our standing to oppose the amendment. We assertthat we have standing as a threatened and aggrieved person. First we point out that the Chernobyl nuclear accident spread radioactive fallout all around the world. Any releases of radioactive iodine from Limerick would be added to the U.S.S.R. residue or that from any other accident in the world or routine releasea:from plants anywhere in the northern hemisphere. If NRC

. grants license amendments to other U.S. operating platrts similar to this one roguested by PECo as a result of letter 85-19,we will be endangered by the in-creased possibility of routine releases of radioactive iodine as a cumulative threat to our health and the health of our families , friends and neighbors. We ,

show below how the granting of the amendment would increase the chances for radio-active releases from Limerick,and consequently otr5er plants with lowered controls.

Wie assert that the amendment would cause PECo to discount the threat of iodine spikes. These spikes could be a warning of malfunction fuel cladding failure,and other causec of increased radiation products which could reach the outside atmosphere in an accidental or routine release from Limerick. Discount-ing iodine spikes could degrade employee vigilance in operating the plant. We do not need to remind NRC that it acted recently to close down PECo's Peach l Bottom plant because of PECo operators found sleeping on duty. We believe sin-ilar larity and threat to the public safety exists in PECo's operation of the g

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the samo company under parallol coployso Licorick plant under supervision by standards or lack of then. In tho light of PECo's operating record at Pacch Bottom we think that any removal of requirements to react to iodine spikes would involve increased threat to our health and safety. We assert that the Tech. Spec. limit is more needed than ever because PECo operstors are not all

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capable of being sufficiently alert to carry out " proper fuel management by licensee and existing reporting requirements ".( p. 1 . # 85-19) Nor do we think FECo employees can be depended on to see that,in connection with iodine spiking, " appropriate actions would be initiated long before accumulating 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> above the iodine activity limit",or that " the NRC (to) be immediately notified of fuel cladding failures that exceed expeeted values or that are i caused by unexpected factors ". Because of the uncertain reliability of PEco  !

management and operation there is serious doubt about control of iodine spikes and radioactive releases so that PECo could not guarantee " existing reporting should preclude ever approaching the limit". Further, there is no assurance in the case of PEco that it can meet the standard of NRC (# 85-19) that it be

" expected to continue to monitor iodine activity in the primary coolant and taks>

responsible actions to maintain it at a reasonabily low level."

In the event of accidental releases or leakage of radioactive gases from is further unreliability the primary containment to the secondary there in PEco's operation as witnessed by two Licensee Event Reports in May,87-13 and 87-16,and ten other similar isolations of the containment,perhaps most of these,like the ones in May caused by personnel error. Although in these two instances the containment isolated automatically there say be continuing risks that the integrity of secondary containment could be compromised by similar personnel error.Under emergency conditions and accidental releases from primary containment, radioactive iodine and other radioactive gases could escape from secondary containment into the outside air.v Therefore any reduction of controle over iodine spikes and iodine levels is a threat to my health and that of the. I community. The amendment should be denied.

l I assert that radioactive iodine releases from Limerick can threaten me with cancer even at my residence when combined with iodine releases from other plants in the vicinity,added to accidents at more distant plants. Since 1 au called upon to visit Pottstown and the immediate neighborhood of Limerick in connection with the plants public threat,I could be exposed to radioactive gases as close as two miles from the plant. An example of such possible close expos-ure will occur on July 15,a PEMA hearing on emergency planning at the hall across from the Pottstown hospital. I trust the Board will find I have standing to intervene because any compromising of iodine limits threatens my haalth and life I certify copies to: NRC eketing, Staff Counsel, Respectfully submitted PECo,F. om 600

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