ML20196D675

Response in Opposition to Licensee Request for Summary of Disposition of Air & Water Pollution Patrol Opposition to Licensee Application for Amend to License NPF-39 & Exemption to App J of 871218. *

ML20196D675
Person / Time
Site:	Limerick
Issue date:	02/09/1988
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20196D667	List: ML20196D663 ML20196D675
References
OLA, NUDOCS 8802180031
Download: ML20196D675 (11)

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AIR and ~ WATER m.

W Pollution Patrol Feb. 9, 1988 88 FEB 16 P12:04 U.S. Nuclear Regulatory Commission ( U ' .., ~ 4.

Washington, D.C. 20555 "X" D i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Administrative Judges Honorable Sheldon Wolfe, Chairman Dr. Richard F. Cole Dr. George Forugson 7./ The Matter Of PHILAD0LPHIA ELECTRIC COMPANY (Limerick Generating Station, Unit 1)

(Docket No. 50-352-OLA (TS Iodine)

AWPP'S RESPONSE IN OPPOSITION TO LICENSEE'S REQUEST FOR

SUMMARY

DIS-

?OSITION OF AWPP'S OPPOSIT:ON TO L7.CENSEE'S "APPLICATION FOR AMMEND-MENT OF FACILITY OPERATING LICENSE NPF-39 AND EXEMPTION TO APPENDIX J OF DECEMBER 18, 1985."(AWPP REFERS TO APPEAL AS "THE R I APPLICATION)

AWPP is categorically opposed to summary disposition of our oppo-sition in instant matter for all the reasons included in all submiss-ions AWPP made to the Board, which we ask be included as well here by reference.

AWPP's effort to show that on-site or off-site radioactive iodine releases near or exceeding specification limitations have been by a very significant quantity caused by, and have been highly contributed to from iodine activity in the reactor coolant, and, thus, that the downgrading of reporting requirements for iodine spikes would have an adverse effect upon the public health and safety.

The fact that the Staff of the NRC recommended the Amendment prematurely, and without statistically researched basis, together with the Licensee's selfish ratior.alization in "The RI Application",

namely,PECO uses the rationalization that because of the long time associated with obtaining the full power license they should be allow-ed to bend the rules agreed upon for their license to operate.

The Licensee (in its December 29, 1987] objections to Request for Production of Documents by Air and Water Pollution Patrol and its request for a Protective Order is crippling the effort of the Admin-8802100031 080209 2 PDR ADDCK 05000 0

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/ istrative Judges to have a properly rounded feeling of all the facets AWPP feels are involved in reusons to deny the amendment. If the Lic-ensee, as is its only defense, states the.Amendemnt does not make chan-ges in operation or otherwise, why is Licensec fighting for the Amend-ment, why is Licensee expending such effort, and why is Licensee ob-jecting to AWPP requests for production of documents which it ration-alizes is not required by 10C.F.R.SS 2.740 .(c) and 2.741 (d)? And at page 2, item D the Ligensee states a discovery review will not lead to admissable evidenge, evidently Licensee wants to do character-istic, dangerous P.E. action in being both Judge and jury. On the other hand P.E. objects to what P.E. calls an "unspecified report' by Radiation Effects Renearch Foundation. Licensee has had time to find that report designated as Report 9-87 of above Research Foundation and excuses itself for wanting to ignore it. Copy relating to that re-port is enclosed, as well as 2 recent reports involving RI in milk and other areas, relating to that report (Enc-1; Enc-2).

Further, in the same December 29, 1987 item, Licensee gives its own reasons why Lt will not produce documents. Our requests and their responses to our request included by reference with Licensee skirting the requests by writing, page 3 bottom: "In any event Licensee has no documents responsive to these three requests". What does "In any event... mean, and AWPP pleads that the decision by the Licensee to not send doucments we asked for is a default on the procedure requiring Discovery, as stated in AWPP's January 5,1988 report relating to P.E.

Without def ault on timeliness, and submittal of Discovery requests.

researched documents the Amendment would allow action which is not based on research. AWPP asked for such research documents which Lic-ensee should have available if it was done at all. The fact that the Licensee did not provide such documents indicates there are no such documents which were used as the basis for decisions as they relate to this amendment, J

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The newspapers are full of the slovenly careless' operation of the Licensee. It is too late to allow Licensee to hide behind the protection law permits in proper operation and management. Just as criminals lose certain rights because they could be a danger to the community, Licensee must, even in this case, be judged on Licensee's merits,inadditiontoothprevidence,notonloopholes.

The President of the Enstitute of Nuclear Power Operations, Zack P. Pate has really already decided whether Licensee merits any changes of any kind. In fact, Mr Pate wonders whether Licensee should be all-owed to operate because the Licensee operation has "been an embarras-ment to the industry and the nation". It also states that Licensee 1: flirting with disaster at the Peach Bottom plant and setting the stage for another TMI. Licensee operation at Limerick, as per Licen-see Event Reports which Licensee now wants to reduce as it relates to Radioactive Iodine shows evidence of the same careless operation.

Hundreds of Licensee Event Reports, in particular, showing personnel either do not know how to operate monitors or handle them to keep them in safe operating order (see chlorine LERS)

As it relates to monitors, AWPP calls attention to the NRC letter of September 16, 1987 to Mr. Robert Anthony, denying his re-quest for reports relating to radioactive iodine releases at Limer -

ick. To deny such records as they may be affected by the Radioact-ive Iodine concentration in the recirculating reactor coolant water (RRCW) is crippling our effort to show that releases of RI in an accident involving the Recirculating Reactor Coolant can go out the recombiner stacks, and would be indicated in such records. Such records could be taken into considerntion as it relates to action re public safety and whether the Amendment Licensee wants should be granted. Studies of such records could show whether monitors are properly calibrated, sequences of calibration, and method used.

As it relates to calibration and quality control of radioactive Io-

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(4) dinemonitorN,~Liceneeestatedithadnodocumentstoindicatethe monitors were not regularly checked for proper response,& leak rate.@

Previous experience with Licensee's effort to obtain an ammend-

-ment turned out to indicate bad faith, as seen in the August 5, 1986 letter of Robert'N. Bernaro from the NRC to Mr. Edward G. Bauer, Jr.

of Philadelphia Electric describing where Licensee purposely misled the NRC with'information on which the NRC granted an amendment. Sub-sequently it was found Lic4 nsee statements were false in many counts.

o This false affair had to'do with testing of valves involved with the RRCW where leaks impinge on release of Radioactive iodine from the RRCW.

As it relates to leaks from the RRCW in which there is varying amounts of R.I. (Radioactive Iodine) the Staff and Licensee differ to some extent on whether or not inferior cladding is responsible for R.I. accumulation in the RRCW, however, in an NRC Information Notice No.86-103 suppliment 2 of November 19, 1987, it describes degrada-tion in the RRCW system "resultihg from boric acid corrosion". In that report leaks are described as containing increased radioactivity, leaking into the air-no doubt containing Radioactive Iodine. The fact is, Licensee did not consider boric acid corrosion as increasing release of radioactivity from the RRCW (containing R.I.) so that the improvment in cladding, nuclear fuel, manner of handling that the Licensee depends upon does not cover the corrosion effect on the RRCW with potential for R.I. release due to leakage as above.

On the other hand the corrosion might still be due to radioac-tive Iodine, since boric acid is a weak acid and if it had any corr-osive action, it would be minimal, possibly indicating R.I. is re-sponsible for the corrosion in the report.

It is a fact, therefore, that the reason for radioactive releases and causes of leaks is not fully known, thus care in spikeing and need for more rather than less reporting is necessary for safety.

@ See NRC INFORMATION NOTICE No. 88-02, dated FEB. 2, 1988

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Licensee, Event Report dated June 19, 1987~(Report No.87-017) further indicates Licensee does not have' monitors under control and the consequences of an accident there6y that makes R.I. in RRCW important; quote: "This LER report.s a partial Nuclear Steam Supply Shutoff system Isolation on a high radiation signal due to an unknown cause."

Further, the report fr Thomas Martin, Division of Radiation Safety describes leaks i'n the RRCW with release of radiation to outside walkway. There was a peak release rate of 178.6 micro curies per second for 45 minutes out the stacks on which~the Licensee report stated the release did not exceed technical specification limits, but it is not stated whether the limit refers to one release or yearly total release. The above relates to Inspection No. 50-352, of 2/6/86.

The basic material fact, above and beyond the statements forgo-ing, is that the Licensee's record, after analysis by its own peer

. group, indicates it is, as the old saying goes, an accident waiting to happen. In this regard falsification of records (see ENC-3)involv-ing velding at the Limerick reactor, in particular, defective concrete surrounding the reactor vessel, and inadequate repair including dam-age to re-inforcement rods, together with cutting out sections of the circular reactor vessel itself, has so compromised the structural in-tegrity of that critical presnure vessel, thatan accident at Limerick because of that patched-up reactor vessel, is not only probable but highly possible. It is for this reason that AWPPis seeking a Cong'ress- .

ional Investigation of that defective reactor vessel. Even before the

. Pate report, AWPP wrote NRC Chairman Lando Zech , that Licensee Pros-ident Lee Everett must be removed as one of the conditions before _e-start of Peach Bottom as well As removed from all authority and resp-onsibility in the operation of the Limerick reactor.

ATR D WATER LLUTION PATROL

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$ e ..X Frank R. Romano, Chairman FR/JC t

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%quency of Fctel and Nonf7tEl Thhrdd Canc rs from Children'a Con?umption of Milk and w-tcr contamunateu uy Th:rafor2, drpo;ition per equera meter gite multipli1d Basia: Cow ing:ste 1-131 from tbout 45 equara mettra per dry.

by 45. Cow transfsrs 1/100 to crch litar of cilk (1 litcr = 1.06 quart). Ther2 form the ing stion gits divided by 100.

Result: The concentration per liter is 45/100 of deposition per square meter, or about half.

For each 100 picocuries (pci) of radio-iodine consumed, about 25 pCi are deposited in the healthy child's thyroid gland (Radiation and Human Health, John Gofman, p.644). The child's thyroid weighs about 2.5 grams. The average energy of the emitted beta radiation is 0.189 mey (gamma rays from iodine in the thyroid deliver their dose mostly beyond the thyroid).

The residence of the iodine is 10 days or less. Therefore, a child's thyroid-dose per picocurie of Iodine-131 deposited in the thyroid is 0.04 millirad (mrad), according to the formula in R&HH, page 419.

The dose causing 1 case of fatal thyroid cancer is 27,000,000 thyroid-millirads for children. (Basis: A childhood whole-body cancer-dose of 75 rads, divided by the fraction 0.00279, from R&HH, pages 344 and 346.)

For each fatal case, there will be an additional 8 nonfatal cases of thyroid cancer (R6HH, p.361). _. _

500 picocuries 1,000 picocuries i 5,000 picocuries Consumption j 100 picoeuries j per liter per liter per liter j per liter  ;

of milk or j  ;

water j j j j

thy. dose = 1 millirad thy. dose = 5 millirads l thy. dose = 1 M 11 rads l thy. dose - 50 millirads One liter l l fatal thy. cancers fatal thy. cancers j fatal thyroid cancers (1.06 quart i fatal thy. cancers j j

= 5 in 27,000,000 - 10 in 27,000,000 e = 50 in 27,000,000 per liter) l = 1 in 27,000,000 l who drink who drink i who drink

. who drink e i 540,000

1 in 5,400,000 = 1 in 2,700,000  ! = 1 in l ,! l nonfatal thy. cancers j nonfatal thy. cancers j nonfatal thy, cancers j nonfatal thy. cancers 400 in 27,000,000 l = 40 in 27,000,000 = 80 in 27,000,000 j

j = 8 in 27,000,000 l l

= 1 in every j = 1 in every j = 1 in every 337,500 l = 1 in every 67,500 l 675,000 j l

3,375,000 l  ;

1 I J 1

thy. dose = 35 millirads j

! thy. dose = 70 millirads !j thy. dose = 3SO millirads 7 liters, or j thy. dose = 7 millirads j fatal thy. cancers fatal thyroid cancers j fatal thy. cancers j j 1 each day j fatal thy. cancers

= 35 in 27,000,000 = 70 in 27,000,000 = 350 in 27,000,000

= 7 in 27,000,000 j l for 1 week l - l in 3,857,000 l

= 1 in 771,000 = 1 in 385,700  : = 1 in 77,150 l l l nonfatal thyroid cancers nonfatal thy. cancers j nonfatal thy. cancers j l nonfatal thy. cancers j

-280 in 27,000,000 = 560 in 27,000,000 = 2,800 in 27,000,000 j = 56 in 27,000,000 l l l

= 1 in every 48,200 j = 1 in every 9,643

= 1 in every 482,000 j = 1 in every 96,428 l l

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t hy. dose = 30 mrads

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j thy. dose = 150 mrads j thy. dose = 300 mrads j thy. dose = 1,500 millirads 30 liters,or j fatal thyroid cancers j fatal thy. cancers j fatal thy. cancers j 1 each day j fatal thy. cancers

= 150 in 27,000,000 = 300 in 27,000,000 j = 1,500 in 27,000,000 for month j = 30 in 27,000,000 l l

180,000 90,000 = 1 in 18,000

= 1 in 900,000 l

= 1 in l

= 1 in l l nonfatal thy. cancers a nonfatal thyroid cancers l non-fatal thy. cancers j nonfatal thy. cancers j

= 12,000 in 27,000,000 j = 240 in 27,000,000  ; = 1,200 in 27,000,000 l

= 2,400 in 27,000,000 l 22,500 = 1 in every 11,250 = 1 in every 2,250 l = 1 in every 112,500  ; - 1 in every l l Committee for Nuciear Responsibility, Inc. y- j .

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r- - p C6mmittee fir NucIcar Responsibility, Inc.fwr.a.m -3bG i A non-proSt educational orgentzati-e since 1971. M '

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P.O. Box 540, Yachats, Oregon 97498 fatvw24 * ~~~-'

Correspondence Address: P.O.B.11207, San Francisco, CA 94101 -

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Dear Friend of C.N.R.,

[g 0 Z Z "/l. Z^ =C , Fall 19 m

\ e - The big news which we predicted for you last fall (and again in i April) is coming to pass: a major concession toward radiation realism has 7,,n"*,7,g"g.,g7,; erupted out of the heart of the radiation research community. Some of you have been steadfastly pressing with the Comittee since 1971 for this type Board of Directors of event. \

John W. oofman Chainnan Prot Ernorrtus of Med<al l

Physes. Urnersity ot e - The new Technical Report 9-87 out of the Radiation Effects )

cai,f. et serneter Research Foundation -- formerly the Atomic Bomb Casualty Comission - l

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, arrives at the conclusion on page 35 that'the United Nations' whole-body un~ers,tr of sournern cancer-dose of 10,0C0 person-rads per f atal cancer is an underestimate of C ' i' '. risk by about 16-fo' h. The RERF authors are Drs. Dale Preston and D.A. ~i

"*"d' go, ,"uIs' ~

Ittory " ~ Pie rce . risk Esiimates~ are Their

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n'HehyfcTd'se o "indeed to mine.

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oeneral Pa o - One must expect a vi 8orous effort by all the quasi-official R. ,h stanwd un es,ty radiation committees to discredit the new report, regardless of its source.b, Frances Tertton Farenthold

• Remember that I, too, was within the official radiation community when I

1. g,",% ,','f , was furiously attacked for quantifying the implications of the "permissible o d n ings. ' dose" and for stating "laws" of carcer-induction by radiation - laws which Prol Emeratus of the radiation comunity now uses.

Physms urbersity , '

of Massethusetts )

soi.e w. xaisn e - I hear that attacks upon the new RERF, report started immediately -

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, p ,, g within the radiation community, and already I've been helping science .

smmunoiogy reporters to understand the report's highly tettinical presentation - its achard uan uccarthy language, its basis, and its meaning. CNR is bound to be in the thick of- .

[,*,',"y',v s y, ngressmar' the c6 ming fray. (Meanwhile, my own technical papers on the recent human lan McHarg evidence have passed "peer review" on their scientific merits...but still casirman. oepairment of.tandscape await acceptance for publication by Health Physics.)

Arenatecture a negoner -

Plannutg. University e - A non-technical paper on an extremely important subject is enclosed

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uanorary reno, for you. It is potent information against the forces which are trying harder than ever to convince the press and the public that there is a safe Science Po6cy Foundat,on H

threshold dose" of radiation.

-unus Peuting

, - . ...g .. ..'At' ~s t'aks~ are millions of ~ 11ve's','ove r ' time'. "This'~me'aiis' thitl 'even gne*,',c e'"

y if you and I and CNR's other support P 9 each were physicians practicing Harold Urey (1893-1941) medicine for 100 YEARS. we could not a as much for human health as we can I Noc+1 tauraa'* do together by helping to straighten out the radiation issue. Your Im7v'sIcYm,stry generous support for the work is needed. ..and is deeply appreciated. -I 'epe

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ga**'gtv,o{

oeorge Wald /N uoe.i teureate Hogges Prol of Biology.

Henard Unwersity j8g / 6 With warmest go d wishes, y

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Organlaational alfmation

/)M 3 J hn W. Gof n, airman

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d'"'**f*"*"* P.S. e - On the back of this letter s part of another new CNR publication; cins ere ia.4,ductibi it straightens out the dangerous myth that common X-ray exams are "egyl~ valent ac hippy tWro'vHe foWithTo'p'i'e~iF'3Y'J1nt;o the the extra radiation do includes references) for your physicians, mammographers, and dentists.

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AIR and WATER l Pollution Patrol BROAD AXE, PA.

EAld-- 3 Here are facts backed by official documentation to prove there has been an apparant fraud by Philadelphia Electric (P.E.) involv-ing crucial, safety related welding infractions at the Limerick nuclear reactor.

On November 10, 1976, reacting to an unannounced Nuclear Reg-ulatory Commission (NRC) inspection report, Mr. Robert Carlson, of the NRC, wrote a letter (it hm 1) to P.E. Vice-President for Ens-ineering and Research, Mr. Vinpent Boyer. In that letter, Mr. Carl-son notified Mr. Boyer of serious violations in mandatory construc-tion procedures involving welding infractions in the on-going con- ,

struction at the Limerick reactor. (See Inspection Report No. 50-353/76-06 (item 2), and in partucular "Notice of Violation", Appen-dix A, Part A (item 3) of Mr. Carlson's letter.

As discussed under Part A, the most glaring example of repeat-ed welding violations had to do with the welding of safety-related items by non-qualified welders, using unapproved methods in contempt of specified procedures.

In this most glaring example, detailed on Page 5 of "Summary of Findings" under 76-06-01 (item 4), inspectors were recording as O.K. improperly performed welds. On learning of these repeated vio-lations from workmen, the tRC inspector, over the objection of Phila-delphia Electric, demanded an immediate inspection of questioned welds, and found them to Fe grossly deficient...but recorded as O.K.

(described in item V aboves .

On Decemb'er 15, 1976, Vincent Boyer responded to Mr..Carlson's l November 19 notice of violations, by writing to Mr. James P.O. O'R-l oilley, Director, NRC Office of Inspection and Enforcement, at Reg -

ion 1, King of Prussia, Pa. (item 5). Mr. Boyer wrote, "the inspec-l tor involved is no longer employed by the contractor and a reinspec-tion of all other work performed by him has been accomplished where l accessible". (see p 1 & 2 of attachment 1 of Mr. Boyer's Dec. 15, 1976 letter (item 6) (underlining mine).

The Air & Water Pollution Patrol, a Pennsylvania incorporated

, environmental group is intervening before the NRC Atomic Safety and l Licensing Board contending a high potential for accident exists at l

Limerick. This situation exists because P.E.'s Vice-President Boyer should have requirred inspection of all welds, both accessible and inaccessible, which now, at great risk, are embedded in concrete, l and are no longer accessible for inspection.

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AIR and WATER Pollution Patrol BROAD AXE, PA.

(2) 50-353--Welding--76-06-01 (cont.)

And now,seven years later, in order to counter our contention, P.E. has suddenly changed its story. Mark Wetterhahn, P.E.'s coun-sol, in correspondence of April 27, 1983 (item 7), responding to gunstioning by the Licensing Board relating to the possible impact of safety at Limerick, emphatically stated, "all welds inspected by the particular inspector, not only accessible welds were re-examined" (underlining by P.E.). (See p. d3& 46)

. .o Apparantly to further remove any doubts caused by our insistent contention, a follow-up letter of May 20 (item 8) from P.E.'s Counsel to the licensing Board, contained various work records, in particular Finding Report No. N 093 (ltem 9), that was stated to be sent as ab-solute proof that all welds... accessible as well as inaccessible wolds were inspected (see p.2 of May 20 letter, lines 7,8,9,10, 11).

(Raport No. N093 does not even discuss inaccessible welds.)

In an order dated July 26, 1983, the Atomic Safety and Licensing Board, in spite of ordering that Air & Water Pollution Patrol's wel-ding contention be thrown out, requested affadavits from Philadelphia Electric to affirm their emphatic statements contined in their April 27 letter that "all welds...not only where accessible were re-exam-

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innd" (* item 10)

Unable to substantiate, via affidavit, information which had pre-viously and repeatedly been submitted as fact, Philadelphia Electric, through its Counsel Mark Wetterhahn's letter to the Atomic Safety and Licensing Board, dated August 19, 1983 (item 11) wrote:

In the course of preparing to respond to' the Atomic Safety and Licensing Board's request contained in its Second Special Prehearing ord-er (LPB-83-39) dated July 26, 1983, at 38-39 for an affidavit to verify the statements contained in Counsel's May 20, 1983 lette'r to the Licen-sing Board, it was learned that all inspections performed by the subiect quality control inspector had not been identified and, therefore, not re-in-spected as previously believed. (underlining AWPP's)

As a result of Philadelphia Electric Counsel's August 10, 1983 letter above, and the Air & Water Pollution Patrol's request for re-consideration of its Quality Assurance Contention, identified as AWPP VI-1, the Atomic Safety and Licensing Board reversed its posi-tionthrough its October 28, 1983 "Memorandun and Order Confirming Rulings Made At Prehearing Conference".(item 12)

AIR and WATER Pollution Patrol BROAD AXE, PA. -

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• 50-353--Welding--76-06-01 (cont.)

As can be seen on p5 of.that order, our Quality Assuranca Con-tantion was only "partially admitted" thus eliminating an extremely .

carious known concrete defect (item 13) in the drywell wall surround- )

ing the primary containment enclosing the reactor core, i The partial contention, after eliminating concrete and other re-lated infractions, however, was more than just a contenti.on. .It was a proven fact, as we made knovh to the Atomic Safety and Licensing Board, that (as the contentiom reads)" Applicant has failed to con-trol performance of welding and performance there-of in accordance ,

with Quality Control and Quality Assurance procedures and. require -

mants, and has failed to take proper and corrective and pre.ventive actions when improper welding has been discovered".Itenc 14 & 15'is a confused attempt, via "engineering analysis " to cover one such failure.

Just as at Zimmer, Air & Water Pollution Patrol has hundreds of doc,umented infractions of specified procedures in concrete work -

and safety related welding.

Just as at Zimmer,it is already known there have been slip-shod inspections of safety related work.

Just as at Zimmer, it is already known there tuve been falsifi-cation of records.

Just as at Zimmer, workmen have anonymously reported completed and inspected as 0.K work which was later shown to be improperly .

done.

Just as at Zimmer, there was deliberate sabotage. -

Just as at Zimmer, so-called qualified workers were found.to be performing improper welds and performing welding procedures for which they were not qualified.

And just as at Zimmer, the Contractor, the Applicant, and in-spectros by-passed safety codes and standards, ignored their own i

quality assurance program, and then covered up flagrant violations, through false statements.

And just as the Nuclear Regulatory Commission was part of the whole sorid Zimmer indictment of the nuclear establishment, that same Nuclear Regulatory Commission, during much the same time was meting out gentle responses to infractions at Limerick.

And this same federal agency, while watching Zimmer and Phila-l

9 AIR and WATER Pollution Patrol BROAD AXE, PA.

(4) 50-353--Welding--76-06-01 (cont.)

delphia Electric (as stated in the Inquirer, Jan. 24, 1984) repeat-edly refused to insist, on safe nuclear standards even when workers and others submitted evidence of contempt for specifice. procedures in safety related construction work. (We may nave a Limerick work-er who might testify to this) .

While Philadelphia Elec d ric has, as ordered by the Atomic Safety and Licensing Board, placed all discovery documents we re-quested at 2300 Market St. in Philadelphia, the time alloted to Air and Water Pollution Patrol to ferret out all the details was totally insufficient, so that we could not fully search out the welding affair.

We have. repeatedly pleaded with the Atomic Safety and Licen-sing Board (one motion for extended time is in right now) but have been refused. This is consitant with NRC non-cooperation.

'AWPP h'as enough information, documents, logs, etc, so we could help direct.where more~information is. Such an effort for the peo-ple of Montgomery County and Philadelphia to avert an accident fron known fraudulent welding and other consturction defects, would be a highly necessary effort to avert possible tragedy.

Air & Water Pollution Patrol is very small in membership and is at the end of out-of-pocket money. We cannot hold on any longer l

without Federal or Congressional aid, not in money but in a com-plete investigation at Limerick, similar to that done at Zimmer.

It would be a shame to allow negligence, contempt for public safety, dereliction of duty by the NRC, and selfishness of Philadelphia Electric, to go unchallenged simply by default.

! Sincerely yours, AIR & WATER FOLL'JTION PATROL

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FraM R. Romano, Chairman i

61 Forest Ave.

Ambler, Pa. 19002 l

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