ML20196A380

Appeals 880505 Order Dismissing Author Contention Re Iodine Spikes & Granting Amend to Licensee.Util Should Not Be Granted Amend Which Would Permit Less QC of Dangerous Aspect of Operation

ML20196A380
Person / Time
Site:	Limerick
Issue date:	06/07/1988
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#288-6575 OLA, NUDOCS 8806300025
Download: ML20196A380 (2)

Text

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'6575 AIR and WATER ( T.k C if.i Pollution Patrol "

BROAD AXE, PA.

800te M, I$960 :37 U.S.

NUCLEAR REGULATORY COMM g g '[ i',f,3 Washington, D.c. 20555 gantw ATOMIC SAFETY AND LICENSING APPEAL PANEL In the Matter Of PHILADer ellI A ELECTRIC COMPANY (Limerick ,Go. [ rating Station, Unit 1)

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

Air and Water Pollution Patrol (AWPP) follows Notice of Appeal re Memorandum and Order granting Licensee's Motion for Summary Dis-position of AWPP's contention regarding Iodine Spikes at Limerick.

The disposition was supported by Staff, since Staff asked Lic-ensee to file the instant change requirements for reporting Iodine Spikes in the reactor recirculating coolant at the Limerick Unit 1 Plant.

The Commission has concured there was "no significant hazard",

but such hazard motivated AWPP to file for a hearing.

The Order of May 5, 1988, dismissing our contention and grant-ing the Ammendment to Licensee now motivates us to appeal to your Board.

Our appeal is based on the need for notice to intervenors and j the public, via Licensee Event Reports that must be diseminated within hours of occurrence of Iodine spiking of any amount, as well as any incident that may affect iodine spiking.

The Amendment, however, would eliminate the Licensee Event Report except under conditions which AWPP feels compromises safety by being inadequately conservative.

AWPP further bases its appeal on the Staff's own statements that (1) "to eliminate unnecessary Technical Specification require-ments," it (had] determined that "the existing requirements to shut dcwn a 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 can be elimir,ated". The basis for its l

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Lotter of Juna 7, 1988 continusd: '

conclusion, the NRC stated, is that the "quality of nuclear fuel has been greatly improved over the past decade with the result that nor-mal coolant iodine activity (i.e. in the absence of iodine spiking) is well below the limit". AWPP, however, is concerned "in the pre- f sence of iodine spiking".

(2) The Staff and Licensee also take the stand that iodine fuel spiking had been considered ar important indicator of significant fuel cladding degradation but which degradation is no longer a problem.

But a recent finding revealed degratation of fuel cladding at Limer-ick,pame to AWPP's attention accidentally via the Philadelphia Inquirer at some uncertain time. With LER's the public would have been aler-ted and the exact time given.

Further, re fuel cladding, 10C.F.R. 50,7 2 (b) (ii) , "required the NRC to be immediately notified of fuel cladding failures that exceeded values or that are caused by unexpected factors. If there are other "unexpected factors", iodine spiking, therefore, involves more than fuel cladding, which means Licensee does not have full control, so that LER's are essential to early notification for public safety, j When and if such unknown factors, in conjunction with ' unexpected fuel cladding degradation result in unexpected runaway iodine' spiking, which in an accident involving loss of coolant, the situation could be disasterous.

In particular, quality control must include research for devel-opment of non-destructive fuel cladding, and certainly to discover what catch-all "unexpected factors" are that the Staff refers to above.

Areas within 10 miles of Limerck are being saturated with new -

developments-increasing numbers of people-decreasing the effective-ness of an already inadequate evacuation plan. Gov. Cuomo of New ,

l York has closed the Shoreham plant and Gov. Dukakis won't permitt Licensing of Scabrook because people can't be evacuated. Licensee i has forfeited its trust (Peach Bottom), it must now be made to adopt -

more stringent care. It must not be granta3 an ammondment which l w(uld permit less quality control of a dd.;erous aspect of its oper-l ation at Limerick.

Very truly yours, l

1 AIR ( pgTER PO V fPATROL Fra . 6 tiahd,daban l 61 Forest Ave Ambler, Pa. 19002 We certify the above has been served on the latest Service List L_