ML20237B769

Requests Listed Info Re ASLB 871120 Memorandum & Order, Including Radiological Tech Specs Concerning 10CFR50,App 1 Requirements Involving Principle Alara. Related Correspondence

ML20237B769
Person / Time
Site:	Limerick
Issue date:	12/07/1987
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	CONNER & WETTERHAHN
References
CON-#487-5080 OLA, NUDOCS 8712170138
Download: ML20237B769 (3)

Text

' p rE ntneaccang g y m y AIR and WATER :c, st rec.

U5NRC

Pollution Patrol BROAD AXE, PA.

87 TC 14 P12:26 Dec. 7, 1987 0F4Cf f ,,,,

DOCKET % f. c. c r BR A Ntw Conner & Wetterhahn, P.C.

1747 Pennsylvania Ave. N.W.

Washington, D.C. 20006 In The Matter Of l Philadelphia Electric Company (Limerick' Generating Station, Unit 1)

Docket No, 50-352-OLA (TS Iodine) l

Dear Sirs:

Re the Atomic Safety and Licensing Board's November 20, l 1987 Memorandum and Order AWPP (Romano) asks for the following l l informational, a Abbreviation Code: (1) RI = Radioactive Iodine (2) RRCW = React'of Recirculating Coolant  ;

water' -

l (3) SRIA = Specific radioactive. Iodine activity (4) 800-12SR = No need for requirement to shut down the plant.if the SRIA exceeds limits for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12 month period.

A) Please provide a copy of Radiological Effluent Tech-nical Specifications (RETS) relating to 10CFR 50, Appendix one requirements involving the principle "as low as is reasonably acheivable". Regarding such

)

principle, please provide report by Radiation Effects Research Foundation as it drastically affects the principle of " as low as is reasonably acheivable".

B) Please supply records for 1986 and 1987 set point act-ivation tests on radio iodine monitors.in the area of the turbine stacks, containment, and at the site boundry.

~

C) Please provide record of false activation of monitor alarms, and records of improper set points on monitor recording instruments or alarms, as it :. elates to 800-12SR rule D) Please provide reports on what Staff and PECO considers one fatal whole-body cancer dose.

871217013e g71207 PDR ADOCK 05000352 c eda h 3 50

(2)

AWPP's requests for informational re ASLB Nov. 20 Memorandum continued:

)

E) . Provide Generic reports and Special reports detailing degradation of any constituent in a reactor coolant system, including instruments, guages, piping, valves, etc.  ;

F) Provide reports or studies on the degradation of ma-terials such as metals, and inparticular, valves, guages, or other components in a circulating reactor cooling system subjected to high radiation levels, as it may affect release of RI in an accident, as it affects the 800-12'SR rule.

G) Provide reports on reactor coolant leakage through pin holes, and causes for formation of pin holes, and leak-age theresfrom of RIJin,high spiking as:to permitting the 800-12SR rule.

f H) Provide reports on all known factors that affect speci-fic radioactive iodine activity (SRIA) in recirculating

• reactor coolant water (RRCW) and how each factor is con-trolled to demonstrate 800-12SP..-

I) For comparison purposes provide reports or records on RRCW radioactive iodine concentration previous to de-velopment of present type cladding upon which Staff and  !

P.E. depends to insure lower SRIA in the RRCW, as it relates to 800-12SR. Include metallurgical composition of old cladding VS new cladding.

J) Provide records to show new cladding and purer fuel is the only factor which is involved in SRIA in RRCW.

K) In view of the Staf f statamnt, and Licensee acceptance, that new type fuel cladding will reduce iodine spiking thus making it unnecessary to be concerned with shutting down Limerick I or any plant if coolant Iodine activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12 month period (800-12SR) , provide metallurgical reports on research j that validates such claim.

L) In view of statement that short term reporting require-ment "is no longer 1 considered necessary on the basis that proper fuel management by licensee and existing reporting requirements should preclude ever approach-ing the limit" of SRIA, inparticular RIA, for over 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12 month period, provide research and records to show validity of such conclusion on 800-12SR.

M) In view of the Staff and Licensee allegation that irr-espective of exceedance of coolant iodine activity limits for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12 month period, the regulation that h there is to be a plant shutdown can be bypassed--with no short term report necessary, provide research reperts

l

\ ,

1 l . (3)

AWPP's request for informational M) continued:

or records to demonstrate that as it relates to 800-  !

l 12SR can be applied'.

l N) In view of the statement of no significant hazard con-sideration, provide report on studies, ASTM method of test, re the effect of RI spikes on different metals, guages, valves, etc, contacted by the re-circulating reactor coolant that validates such statement.

1 0) Provide records on the effect of leaks in the re-cir-culating reactor coolant on concentration of RI, result-ing from release of steam, leaving RI behind in diff- 1 erent leakage rates.

1 P) Provide monthly records of gallons of reactor recircu-l lating coolant water lost through leakage, with con-centration of radionuclides, including radioactive l

iodine.

t Q) Licensee seeks to elimenate the existing requirement for shutting down a nuclear plant if coolant iodine +

activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12 month period. Provide studies which show that there is no adverse effect on public health irrespective of a how high the tradio-iodine activity concentration rea- l ches, and its effect in case of an accident at very I high concentration of RI.

R) In view of the fact that the grantingg of the ammend-  !

ment re permitting the concentration RI in the recir-culating reactor coolant water may exceed 800-12SR with an accident releasing such water, provide changes established in the evacuation plan to assure public safety.

Inasmuch as- the Licensee might be permitted to in-1 S) I crease RI in the RRCW, provide studies that were con-ducted to implement reduction of higher Radioactive Iodine concentration, as it relates to elimination of of 800-12SR.

T) Inasmuch as RI can be released via the blowdown of the cooling tower solids accumulating, provide records of frequence of blow down as it relates to elimination of 800-12SR.

Very truly yours, AIR & WATER P LUTION PATROL 1

.Fram R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 i c.c. Hon. Shelon J. Wolfe l l

Dr. Richard F. Cole Docketing & Service Section l Dr. George Ferguson- Robert L. Anthony <

Benj. A. Vogler, Esq. Edw. G. Bauer, Jr. Esq.

- - - - - . _ _ _ _ _ . _ _ _ _ , _ , , _ _ _ _ _ , _ , . , _ _ _ _ , , . , _ , , _ , _ _