ML20238D160

Intervenor Rl Anthony Request for Extension of Time for Discovery.* Extension Requested Due to Listed Obstacles Which Have Prevented Study of Matl Provided & Matl Missing

ML20238D160
Person / Time
Site:	Limerick
Issue date:	12/20/1987
From:	Anthony R ANTHONY, R.L.
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#188-5239 OLA, NUDOCS 8801040129
Download: ML20238D160 (2)

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U.S. NUCLEAR REGULATORY COMMISSION... ATOMIC SAFETI ARD LICE SING BOARD DCLKEl Q UWC PHILA ELEC.CO. Limerick Gen. Sta.", Unit 1.

DOCKET NO: 50-352 - OL A TS Iodine w E 23 Pye0/87 INTERVENOR R.L. ANTHONT'S RnQUEST FOR AN EXTENSIOE OF_7,IME FOR DISCOVERT hCNI5bG b CL To confirm our telephone conver ation with

s. Wilder and on advice from s

Judge > Wolfe we are' submitting this request for att extensi'on of time for discov-ery.

We ask the Board to take note of these obstacles which have prevented us from studying the material provided, also the mis sing material:

1. PE did not send any of our requests until after we called in November following up the Board's order of 11/20/87 We were told that material was in the mail but we did not receive it and had to call again.

Material was firally received on 12/10/87 The> sheets of readings were reduced and some were un-l

_ _ readable.

We received 12/18/87 sheets of print-outs for the stack and hot shop 1

L monitors which_.we h n o made use of in the paat days.We need more time to study

+hese.

The package with these sheets was mailed from PECo 12/4/87 addressed to my name but with an address 2343 Oakdale Ave.,Glenside,Pa. 19038. We trust l

that the Board will agree that we should not be penalized for this mistake. It

• was a miracle that it was finally directed to our post office.

1. A letter fronhM Z Wetterhahn,PECO, 12/2/87 stated that there had been.

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-- --nothing identifi~ed-'uM5=eur--itenr3--(10/25/87) whioh asked' for hourly readings

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of radioactive iodine levels on the plant property, including the plant entrances.

We are not satisfied with this response. We request all records of all these iodine levels at any time during plant operation.

We ask for information on how PEco measures the exposure of plant employees and visitors to radioactive iodine in the parking lots and at the entrances to the buildings.

3 We wish to call the Board's attention to a letter to E.G.Bauer,PEco from R.J. Clark on the subject of:0FFSITE DOSE CALCULATION MANUAL, REY. 4 (TAC NO.64657)

A copy of a safety evaluation and a technical evaluation by Idaho Tat. Eng. Lab.

were enclosed. The abstract of the latter,page i calls for a new revisions it is recommended that another revision be submitted by the licensee to address and correct the discrepancies identified in the review.

With respect to radioactive materials in particulate form in gaseous effluents,p.8:

It is not clear why the inhalation, meat cluded. A dispersion value of 1.82E-09/m,gnd vegetation pathways are not in-la used it, the calculation and it is not cle'ar if this is the maximum value.

Therefore,it is uncertain if the methodology for calculating the maximum dose to an individual due to the release of the above radionuclides provides reasonable assurance that the I

dose limits of Technical Specification 311.2 3 will not be exceeded.

The findings in this Idaho report cast doubt on dose calculations, levels of radioactive iodine at plant boundaries and release set points. Consequently we will need further discovery. For the above reasons we ask for an extension 8801040129 871220 PDR ADOCK 05000352

)$03 G

PDR l

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t of-the discovery period'to 1/22/88.

Respectfully submitted, co:

NRC Staff, Docketing, F. Romano,PBCo.

Box 186 Moylan,Pa. 19065 l

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