ML20151T690

Response of Intervenor Rl Anthony to PECO 880331 Response & NRC Staff 880404.* Denial of Applicant Motion for Summary Disposition & Application for License Amend Urged

ML20151T690
Person / Time
Site:	Limerick
Issue date:	04/25/1988
From:	Anthony R ANTHONY, R.L.
To:	Atomic Safety and Licensing Board Panel
References
CON-#288-6155 OLA, NUDOCS 8804290110
Download: ML20151T690 (2)

Text

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U.S. t'UCI T.AR REG 01ATORY COM.ISSIOY. . .. . ATOUIC., SAFETY AFD LICE':SIUC E0ARD DO L 6t. '.b'-

FlilLA.ELEC. CO. Limerick Cen.Sta. ro. 1 Docket No. 50-352 -8M (TS Iodine )

s e 27 P141tnP so. 87-550-03-LA 4/25/58 RESP 0"SE OF I? TERVENCR R0 PERT L. ATTrotg PECQ RESPgSE,3/31/S6, AFD NRC STAFF,4/4/88 uvw gpg Ir response to the board's order,3/17/86,ve answer PECo's response to the order and rRC Staff's,referdng to PEco's response as PE and the Staff's as ERC,as follows:

1. Le note tha t " iodine dose equivalent in the primary reactor coolant" is only used in PS (p.1.). Throughout the two responses the references are to iodine activity or iodine concentrations. We assume that PE,therefore,is aware that iodine spikes en-tail the presumption of dosages to employees and ,the public f rom any leakage in the prinary coolant system .We agree with this presumption and call the Board's attention to our previous warning that PECo's stack release limits are based on erroneous dis-tances on closest approaches of the public to the plant,at the railroad right-of-way, and the parking lot and entrance to the plant for visitc6rs and others with business.

2. In general we think that PE and FRC tave treated superficially the Board's re-quest for clarification,only reworking the affidavits submitted previously.

3. We repeat our request that the Board weigh PECo's ability to operate safely the Limerick reactor or to comply fully with NRC Technical Specifications. We ques-tion PECo's ability to supervise its employees and to protect the public as revealed in SRC's investigation of the dangerous operation of the Peach Bottom plant,which NRC ordered closed. The same dangerous lack of ' supervision applies to timerickas set forth in the warning letter to PECo from the Institute of Nuclear Power Operations, Zack T.Pate, Pres. , to Robert D. Harrison ,PEco Board,1/11/88 (p.8 from Conclusions):

A corporate culture had been allowed to develop,from the top down that down played, rejected,or ignored problems. Management was defensive from the top down. Problems frequently were not reported up the line organization,ac.d those that were of ten were not dealt with effectively. The climate fer this organizational behavior Was set from the highest levels of the corporate management.

4 PECo's response gives no reassurance that it can operate Limerick in compliance with TS, including the observing and reporting of Iodine spikes with reference to indication of flaws in nuclear fuel and potential for accidental release of radio-activity to the public environment. The watering down of TS in the amendment adds further risk to the health and safety of the public.

5. FRC (p.2) adds more disquieting information on nuclear fuel ar.d public safety a temporary increase in coolant iodine concentration is frequently observed at reactors where leaking fuel rods are present.

We ask the Board to consider the opera ting problems which seem inevitable f rom (NRC 8804290110 880425 D'%

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I p.2 ) viere an iodine spike could be concluded to be the result of power changes ,

rat!.er :han a warning of "the sudden f ailure of one or more fuel rods" which could involve a critical situation in the reactor which would demand irranediate action by the operators,perhaps emergency action.

6. SRC(p 3.) is also alarming from the point of view of public safety related to iodine activity. According to NRC, activity of 4 microcuries per gram requires plant shutdown,but does not specify how soon. In case the level should fall to .2 the plant could presumably continue operation without being reported to ERC until the 49th hour. Even then a potential, dangerous condition could exist in the reactor from accelerated fuel rod failures which could be discounted by operators as indicated by iodine spikes of .2 or less, merely reportable in "30 day and 92 day reports if the iodine activity exceeds 0.2 microcuries per gram for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or if this limit is exceeded for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in any consecutive 6 month period."

CONCLUSION. The responses of PEco and KRC appear to reinforce the dangers to safe operation of the Limerick plant from iodine activity in the reactor and the chances for_ errors in interpretation and operator reaction under the present TS. We urge the Board,therefore,to deny the applicant's motion for suur.ary disposition and to deny the application for a license cmendment.

Respectfully submitted, cci bRC Staff, Docketing, Board Panel,PECo ,[ ] , %g.

Box 166 Moylan,Pa.19065 4

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