ML20237G973

Air & Water Pollution Patrol Suppl to Opposition to Radioactive Iodine Amend for License NPF-39.* Concerns Expressed Re Unusual Sensitivity of Thyroid to Iodine. Licensee Does Not Merit Amend,Based on Util Past Conduct

ML20237G973
Person / Time
Site:	Limerick
Issue date:	08/21/1987
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
CON-#387-4259 87-550-03-LA, 87-550-3-LA, GL-85-19, OLA, NUDOCS 8709030056
Download: ML20237G973 (4)

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q AIR and WATER F

Pollution Patrol i

M BROAD AXE,PA.

67 AU^ 24 P3 :16 Aug. 21, 1987 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 4

BZFORE THE ATOMIC SAFETY AND LICENSING BOARD Administrative Judges Sheldon J. Wolf, Chairman Dr. Richard F. Cole Dr. Peter A.

Morris

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In the Matter of 4

PHILADELPHIA ELECTRIC COMPANY Docket No. 50-352-OLA I

(Limerick Generating Station (TS Iodine)

Unit 1)

(ASLB No. 87-550-03-LA)

AWPP (ROMANO) SUPPLEMENT TO OPPOSITION TO RADIOACTIVE IODINE AMENDMENT FOR LIMERICK UNIT 1 OPERATING LICENSE (NPF-39)

Attached please find the the above listed suppliment.

Respectfully submitted, IR_& WATER P ION PATROL Fran omano, Ch irman 61 Forest Ave.

Ambler, Pa. 19002 FRR/jch The above has bee'n served on the latest Service List without attachments.

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K$5$$$by PD bh -.

AIR and WATER Pollution Patrol BROAD AXE, PA.

August 21, 1987 U.S. Nuclear Regulatory Commission

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Washington, D.C.

20555 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i

Administrative Judges Sheldon J. Wolf, Chairman Dr. Richard F. Cole Dr. Peter A. Morris IN THE MATTER OF PHILADELPHIA ELECTRIC COMPANY Docket No. 50-352-OLA (TS Iodine)

(Limerick Generating Station (ASLB No. 87-550-03-LA)

Unit 1)

AWPP (ROMANO) SUPPLEMENT TO OPPOSITION TO RADIOACTIVE IODINE

. AMENDMENT FOR LIMERICK UNIT 1 OPERATING LICENSE. (NPF-39)

On August 25, 1986 AWPP filed its petition for leave to in-tervene and its motion for a hearing on the Licensee's proposed ammendment, namely, "no significant hazards consideration".

AWPP's petition stated concerns re me and my family's property owned 10 miles from the Limerick nuclear plant with possible health and financial loss, including threat to members of AWPP and the pub-lic.

To grant PECO the ammendment to raise the amount of radio-active Iodine it can release at any one isolated time or isolated times and have it be considered on the one year basis will create the possibilities associated with such higher than originally li-censed (opened ended), releases and the known adverse effects of radioactive iodine on humans and animals.

AWPP (Romano) feels the judges should know concerns of our group relative to the unusual sensitivity of the thyroid to io-dine, in that the gland readily absorbs iodine in.its need to con-trol thyroxine production necessary to normal body development.

In particular in the development of the fetus the thyroid even i

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AWPP (Romano) Supplement Re Iodine Spike Amendment-continued:

more avidly absorbs iodine, And when it is radioactive iodine, I

the radiation in the thyroid causes damage which adversely aff-ects prenatal development leading to hyperthyroidism and its various abnormal life conditions.

I have sons in the family-raising age, and excess releases could be a health factor close to me.

Specifically, the Nuclear Regulatory Commission must consid-er that allowable limits for radioactive iodine releases were set, and agreed upon, by PECO as a consideration of their NPF-39 license.

AWPP pleads that the Licensee does not merit the amendment, based on the Licensee's past conduct which includes f'lsification

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a of records; a management which the NRC,itself, in the control-room operator-sleeping scandal, stated the episode which could have re-sulted in anything including a run-a-way reactor, was due to the observed fact that discipline had degenerated to a point "beyond management control".

How can an operation fraught with devastating consequences in case of an accident and which so disqualified its-elf, be given any amendment which would decrease its need for greater care generally, and, specifically, greater care in control-ing higher radioactive iodine releases than permitted in its li-cense to operate.

As it relates to the Staff making a "no significant hazards consideration" f.inding with respect to this amendment, and indi-cating the Licensee sought the samendment at the behest of the Staff in Generic Letter 85-19 dated Sept. 27, 1985, AWPP (Romano) states the conclusion of the Generic Letter '85-19 did not keep in mind the aspect of repeated falsification of records by PECO. The letter predates the ultimate description of P.E.

operations, and contemptuous attitude proven by the psychology which had control room supervisors using security guards as look-outs while they slept.

The Staff in that Generic letter 85-19 did not at all take into consideration the fact that the release of radioactive iodine

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AWPP (Romano) Supplement Re Iodine Spike Amendment--continued:

in the TMI area, during the accident, was in the order of a thous-and times more than reported from subsequent animal studies, so that the effect had to be greater than the Staff's calculation of effects of radioactive iodine that the granted amendment would invoke.

It is hoped those miscalculations were not.used in the Staff conclusion of "no significant hazards consideration".

AWPP previously stated the danger of reporting iodine. spikes on an annual basis rather than at times when it occurs, as well as.

which

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other previouslymadepoints(aretobeincorporatedinthissupp-lement by reference.

1 Further AWPP (Romano) intervenes on the aspect of the suffic-iency of the use of potassium iodide as an antidote for radioactive i

iodine, and on the aspect as to the Licensee's position on the effect of protein bound-iodine when the iodine is radioactive, as well as the aspect of radioactive iodine in the body during its total decay time.

Very truly yours, A

& WATER POLLUTION PATROL f

Frank R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 1

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