ML20236R773

Suppl to Petitioner Response of 870702 to Board Notice of Hearing & Order of 870729.* Petitioner Lists Contentions Opposing Granting of License Amend to Tech Specs for Plant Re Matter of Radioactive Iodine Spikes

ML20236R773
Person / Time
Site:	Limerick
Issue date:	08/26/1987
From:	Anthony R ANTHONY, R.L.
To:	Atomic Safety and Licensing Board Panel
References
CON-#487-4886 87-550-03-LA, 87-550-3-LA, ALAB-828, GL-85-19, OLA, NUDOCS 8711240021
Download: ML20236R773 (4)

Text

'YN j U.S. NUCLEAR REGULATORY COMMISSION. . . ATOMIC SAFETY AND LICENSING BOARD Judges S.R. Wolf, R.F. Cole, P.A. Morris w ar -

8/26/87- ,

RE: PHILA ELEC.00. Limerick Gen.Sta. , Unit 1. Docket No. 50-352 - OL A J ASLBP No. 87-550-03gA AUG 31 P3 :2i SUPPLEMENT TO PETITIONER'S RESPONSE OF 7/2/87 TO THE BOARD'S NOTICE OF.; HEARING

.AND ORDER OF 7/29/87 A:

s The petitioner,R.L. Anthony hereby submits the following contentions in opposition to the granting of a license amendment to the Technical Specifications

,for Limerick Unit 1 in the matter of radioactive iodine spikes.

1. We refer to and incorporate all of the points'in our previous submissions.

On pages 1 and 2 of our 7/2/87 Response (A.7/2) we specifiedi the expectations in Generic Letter 85-19 which we had no confidence PECo employees could satisfy.

)

We now contend that the burden of proof is'on PECo to show that these expectations l 1

can be met in the light of the PECo employee misconduct,and deficiencies in management which resulted in the current suspension of the Peach Bottom opera- ,

1 ting license. This only reinforces the management and employee lacks which we

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noted in our brief for appeal ,7/2/85, p.3,(ALAB-828):

These violations at both plants ( Peach Bottom and Limerick) were rated at Severity Level III.. The two incidents at Peach Bottom involve deficiencies in oversight of radiological activities..,but the report.. concludes that these deficiencies pervade PEco's management and,therefore could be expeeted in a related form we believe at Limerick in relation to contractors and employees, i.e. " inade,quate oversight and control of contractor activities is not limited to the perticular facility management , but aaso involves corporate management".

2. c lodine spikes in the primary coolant can cause a surge in off-site Iodine-131 because there have been reported pathways for radioactive steam to penetrate the containment and reach the environment. Such releases of Iodine could add in to the routine releases to the environment recorded the Limeridc Annual Radiolog-ical Environmental Operation Meports.( See Poport of 5/86; units of PCI/CU, TABLE M _C-XIII, 7 weekly samples of ( .03 in air samples, and in milk samples 17 mon %hly readings from < 05 to 4.07 PCI/ LITER.)

66 C0 3 The limits on routine releases of radioactive gases from the Limerick 5 stacks have been set too high, thereby providing a base of Iodine, releases,ns chown in the Annual Radiological Reports, which could be added to,by accide'ntal-N

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releases from Iodine spikes that could reach dangetous levels in the environ- l

$ nent. The error in set point releases of radioactive gases from Limerick was built into the operation because the calculation of dosages is based on plant hy -

boundaries of 2400 and 2300 feet instead of the actual boundaries o g g railroad and the river where the.public can habitually have access to 900 feet '

and 1500 feet of the plant's exhaust stacks.(See ALAB-828,our petition 4/30/85,p.l.)

-- r -- l 4 A parallel error is built into the Annual Radiological Reports because the nearest approaches to the plant are recorded at 5 mile s( See deport 1986, TABLE C-XI, Croup I Limerick Si te , Boundary Loca tions, # 1053,#1151,# 1451,and

1. 3452.) The readings recorded for these boundary locations do not measure the exposure of members of the public, including myself,since I have walked along the railroad on a number of occasions,. The gaseous emissions from the plant have to carry only 900 feet to reach the public at that point. It is apparent, therefore, that the risk to the public from routine releases of Iodine-131 are considerably greater at the boundaries of the plant than la indicated from the readings recorded at the locations 5 miles from the stacks. This j means that any surges of radioactive iodine from spikes that escape to the out-cide atmosphere are added to existing levels from routine releases much higher than any recordings at PECo's monitoring locations which set the plant boundaries l at 2300/2400 feet.

I

5. The distortedly low recordings of Iodine at the plant boundarie, do not measure the threat to the public from the plants releases or the releases added to the atmosphere from other plant and even accidents at a distance such as Chernobyl.(A.7/2,p.l.),and ,of course,any iodine spikes which find a path to the atmosphere can bring Iodine-131 to levels to induce cancer,possibly resulting l in death. A letter from five doctors in Vienna in the New England Journal of .

l Medicine,Vol 316 No.7, 2/12/87, p 409, records that a study of cow 's milk de-livered to three Austrian dairies when the radioactive cloud panned over after the Chernobyl accident of 4/28/86 showed Iodine -131 at levels of 0 to 3550 Bq during the firs t two weeks aftor the event. Until there is an official figure on the residues in the PECo area .from the 3 Mile Island and Chernobyl accidents no change should be allowed in the Limericklicense to lower the standards for recording and reporting Iodine upikes.

i

6. Exerpts from an article by Jane dimmonds in New Scientist 23 April 1987, (See Attachments 1 and 2.)give some of the results to date from study of fall-out from Chernobyl and strese the dangers of thyroid cancer from Iodine-131.

The author speaks of the ongoing study by the United Nations committee on the Effects of Atomic Radiation (UNSCEAR) and there is mention (p.43) of the dis-  ;

cussion in scientic circles "that the gogg of radiation considered safe,(the limits) are much too high." a UNSCEAR on the world wide iapact of Chernobyl by the UN consultan t Dr.indre Bouvilli of Environmental Measuremen t Laboratory in New York will not be finished and assessed before the summer of 1988. No changes to relar the surveillance of Limerick l odine rele ases should be considered before the results of thia UN study are known.

On the basis of the points in the contentions above,I ask the Board to conduct hearings to consider further evidence which we can provide, cc: NRC Docketing, Staff,and PECo Respe,gt fully yours,g l w Mh MC--_o

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New Soentet 23 4011961 _

, 40 Europe calculates the health risk How will Chernobyl affect health? The increased risk of getting cancer over the next 50 years is probably the same as that from 70 days' exposure to naturally occurring radiation Jane Simmonds e - .

washed material out from the E ACCIDENT at "

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& radioactive cloud, depositing Chernobyl had a profound efTect on v.

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5' p' it on the ground. This gave levels of radioactivity that many people's lives. Most ;g '

were high compared with were worned about being -

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' had not ramed. This was escaped from the reactor. - -

particularly true in Britain, Eurppean agriculture has ,.,; L( where heavy rain washed sufTered as a result of the i.

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measures introduced .

' ' ' * ' activity onto the north and protect people from the ill-c .' west of England and Wales, effects of the radiation. Dairy

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and parts of Scotland and a'f ( .k farmers in Bavaria, reindeer 1 herdersin Lapland and sheep -

Northern Ireland. Outside 4 ~ ' / the Soviet Union, places with farmers in Cumbria were '# 1 s, 'We '* high levels included north-all affected economically. A .

east Poland, Romania, parts year after the accident, we

" w ..i;' i of Scandinavia, the south of can now consider what  : / l. ,4 West Germany, the north of

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happened, and estimate the

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-term effects on Europe. . -

.M# ' ' All the European countries lonfbe release of radioactive

, i materit.1 from Chernobyl . r .. m' , .. . monitored the contamina-I tion. They measured the

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started in the early hours of .. i 2 doses of external radiation in 26 Apdl 1986. It continued . .

n 4l' i the air that people might

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for about 10 days, with the first and largest release on the i a receive, and the concentra- l first day. A second peak of tion of various radionuclides radioactivity occurTed on the ninth day (5 May). in the air and on ground. In the early stages, the most The accident released a mixture of radioactive gases and hazardous radionuchde was iodine-131. Governments were particulate matter. These formed clouds of radioactive concerned, in particular, that young children might be material that spread over Europe, and virtually the whole of consuming harmful levels of iodine-131 by drinking fresh the northern hemisphere. The mitial release travelled to the milk from animals grazing contaminated pastures. Other north of Chernobyl, reaching Scandinavia on Monday 28 foods, such as leafy green vegetables and fruit growing in the April. Radiation readings, about 14 times higher than open, were also possible sources of exposure, normal, taken on the central and eastern coast of Sweden first European governments introduced countermeasures to alerted the world to the accident. Part of this contaminated limit exposure to radiation. These measures varied depending cloud then spread southwards over other parts of Europe, on the level of contamination and the standards that coun-reaching the southeast coast of Britain on Fnday,2 May. The tries apply to assess hazards. They included, for example, later releases from Chernobyl were also widely dispersed, this changing animals' diet from pasture to stored feed, {

instructing people to wash fruit and vegetables before eating time travelling to the east and south. In most countries in them. In countries where the levels were particularly high, the Europe, and em as far afield as Japan and the US, scientists recorded higher levels of radioactivity. authorities withdrew supplies of fresh milk and vegetables. At The amount of contamination in various countries the beginning of May, the British government advised people degnded on the distance from the stricken reactor and not to drink fresh undiluted rainwater for a few days.

whether it was raining when the cloud passed over. Where the lodine-131 has a halflife of only eight days; as the levels contaminated " plume" coincided with wet weather, the rain fell, governments became snore concerned with the longer-

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measurements made since Chernobyl on the theory, amount of zero, we om estimate the additional cance occur due to the Chernobyl eccident.

reaesium in the body. In our study, we employed risk factors based on an inter-Another useful measure to evaluate the effects of Cber- national scientific consensus (those nobyl is the total dose of radiation to a whole population. Scientific Committee on the Effects of Atomic Radiat on, i of the

'Ilese " collective doses" are in man-sieverts. We have UNSCEAR). calcu- From these, we conclude that toen will t;-

lated the collective doses in the first year after the accident, about 1000 extra deaths from cancer in the whole of the and the collective dose over all time (called the collective European Community due to the Chernobyl accident. This(

etTective dose commitment) for the populations of the coun- estimate needs to be seen against the background of cancers (

tries in the European Community. Again, we evaluated that would occur in the population even if the Chernobyl thyroid doses separately. In Britain, the collective efTective release had not happened. Over the next 50 years, about 30 dose commitment will be about 3000 man-sie,crts, of which million people in these European countries will die from about two thirds is due to exposure in the first year. For the cancer of one type or another. Because we will be unable to European Community, the figure is 78 000 man-sieverts. The pick out deaths due to the after efTects of Chernob highest doses are to the populations of West Germany such a high number, it will, therefore, be impossible to detect (30 000 man-sieverts) and Italy (27 000 man-sieverts). Both what the impact of the accident on health will be in the these countries have large populations, and received high European Community.

levels of contamination. These assessments are by no means the final word on the Radioactive Pathways consequences of Chernobyl. We have already started the The two main oathways contributing to the collective dose environmental longterm task of sifting through the mass of data from monitoring to find consistent, sequential sets are eaticg contaminated food and external irradiation from of measurements that will m1 prove our mathematical models deposited material. For the first year after the release from of how radioactive nuclides travel through the environment.

Chernobyl, the estimated collective efTective dose for the Also, we are assisting UNSCEAR to prepare a comprehensive European Community as a whole is less than 10 per cent of and detailed assessment of the worldwide consequences that from natural background radiation in a single year O accident.

(500 000 man-sieverts).

From these predictions of collective doses, we can predict Jane Simmonds leads a group of scientists at the National the effect of Chernobyl on the health of Europeans over the Radiological Protection Board at Chdtem, Oxfordshire, studying the next few decades. We based these estimates on observations consequences of the release of radionuclides to atrnosphere. Her of the risk of developing cancers as a result ofirradiation of "

various tissues at moderately high doses. Using such risk $*

n es and w aNed outIt Es factors, and interpolating between the observed efTects and 2: Soviet studies question the cancer risk Experts will meet to agree on method. Radiadon Protection Commission, said THEcould SCALE of the ultimately settleUkranian disaster ologies, as well as on idenufying a control last month that, so far, the exerc one of the most controversial scientific wrangles of recent population that is suitable for monitoring showed that individua times. Some scientists think that the limits, against those who received estimated.

the largest lower doses of radioac set by the international regulatory bodies, exposure to the Cbemobyl cloud.

Last summer, the Soviet Union released Researchers will be able to confirm this for the maximum dose of radiation consid-cred safe, are much too high. The reason is its first estimates of the long-term impact of independently onc that experts have cakulated the hmits from the disaster on the populadon most directly releases the dat the effects of the high doses of radioactivity affected-the 135 000 people evacuated- Scientific Committe such as those recened by victimsEuropean of the and the 70 million inhabitants of the Atomic Radiation (UNSCEAR) part of the Soviet Union, also committee is scheduled to produce a atomic World War. bombTheyexplosions during these have extrapolated the Second caught in the path of the cloud from detailed report by the summer of 1988. The consultant who will assess the data for results to much lower doses. Scientists are Chernobyl.

These estimates suggested that the UNSCEAR is Dr Andre Bouvilli at the now querying whether the relationship govermng the effects at high doses is Soviets could expect an additional 42 500 Environmental Measur directly proportional when extended scientists to low deaths due to cancer. At the time, stressed that the predictions Soviet According to in Newthe Bouvilli, York, promised data doses.

For some years now, the accuracy of scientists were making were preliminary be surprised if the have not yet predictions arrived. He about c .lculating factors affecting the risk to and defmitely tenta6ve. exposure to radiation were drastically The evacuees will suffer no more than a health recommended by the International Commission on Radiological Protection 0 6 per cent increase in the incidence of revised.

What researchers need is a comprehen.

(ICRP), have been under rtre. The precise cancer as a result of the accident. Among sive data bank showing the pattern of the forrn of the relationship between dose and the rest of the population affected the uptake of radioactivity by the body and the increase was predicted at between 0 03 and the probability of an effect is in doubt. 015 per cent. The reladve increase in the subsequent rate of decrease over time. This The ICRP estimates the risk of fatal cancer. induced by radiation, to be 125 per mortahty due to thyroid cancer could be requires repeated mea 10000 sieverts. The review of the data on as high as I per cent, suggested small Soviet whole-body accumulations monitors of trace which can radio-victims of the atomic bomb could double scientists.Now, the Soviet medical authorities activity such as radiocaesium. The Soviet the risk. Some observers believe the risk to reckon that these estimates may be between medical authorities have already begun this be even greater, perhaps five times the 10 and 20 times too big. They have reached work in Kiev in the Ukraine.

figure that is currently accepted. The acci. In Britain, the government has y,iven a dent at Chernobyl exposed thousands of the conclusion as a result of the first analy- f30000 grant to the health ph,ysics and Soviet citizens to significant doses of radio- sis of the radiadon doses ex perienced by the nuclear medicine unit at the Umversity of activity. Epidemiological studies now evacuees. The Soviet authorities have set up a Glasgow, for a two-year study which is under correct.way The should showhas Soviet Union whosc hypothesis agreed to is special medical centre in Kiev where using volunteers to chart the behaviour take part in an international conference doctors used whole-body monitors to of radiocaesium. Researc later this year, which will attempt to momtor the popula6on. They have put on work will validate the mat hammer out an acceptable protocol on how computer more than one million results. models used O to pred to carry out this long-term assessment. Leonid Ilyin, chief of the Sosiet Union's radioactivity.

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