ML20054H297

Request for Reconsideration of 820601 Special Prehearing Conference Order Denying Contentions.Misinterpretation, Technicalities & Typographical Errors Caused Misunderstanding.Proof of Svc Encl

ML20054H297
Person / Time
Site:	Limerick
Issue date:	06/16/1982
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8206230210
Download: ML20054H297 (3)

Text

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~.%iM' AIR and WATER W

Polution Patrol W'

BROAD AXE, PA.

c2 IN 22 P2:01 UNITED STATES OF AMERICA M5h%

NUCLEAR REGULATORY Co MISSION ATOMIC SAFETY AND LICENSING BOARD 3 R M,C-:

IF THE MATTER OF PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Docket nos. 50-352 OL Units 1 and 2) and 50-353 OL Re:

SPECIAL PREHEARING CONFERENCE ORDER OF JUNE 1.1982 l

Intervenor AIR & WATER POLLUTION PATROL (ROMANO) states that misinterpre-tation, technicalities, and typographical errors caused misunderstanding.

In-tervenor requests reconsideration of denied contentions, or portions thereof, clarification submitted this June 16, 1932 as follows:

V-4(AWWA)

Relative to statement in June 1, 1982 Order, top of page 147, "Intervenor (AWPP) asserts that Applicant has improperly averaged temperature data in evalu-ating the meterological effects of the cooling tower plume, and by so doing has not adequately studied the potential for air crashes resulting from turbulence created by cooling tower discharge, changes of Visual Flight Rules (VFR) condit-ions, and carburetor icing potential.

Staff argues that the contention is with-out basis in that temperatures are not averaged in calculation of plume effect,s."

It further states that "Because the contention is erroneously based on the prem-ise of the alleged use of average tenperature to calculate plume characteristics, the Staff reco:maends denial of this contention".

Note: The important point is not whether the contention is erroneously ba-sed, but does the contention point out a hazzordous contidition not fully consid-cred. Further, I referred not, to just air crashes--but dangerous. flying condit-

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ions, and restriction of freedon to fly into areas ' changed from permitted VFR conditions to non-pensitted VFR flying conditions.

To aid clarification re temperature (averaged or not), the Staff nust, first, reread my " Response to NRC and Applicant's Challenge to Romano (AWPP) Contentions",

l dated Dec. 21, 1981, in particular the last paragraph of the first page; the 2nd paragraph of page 2, and the first and 2nd paragraph of page 3 Second, nochere had the Applicant stated how often, irrespective of upper air " soundings" and com-puter runs, will there be marcinal Visual Flight Rule conditions changed to non-Vis-ual Flight Rule conditions... denying me, as a pilot, the freedon to fly at those tices, and endangering me as a result of decreased visibility and ceiling.

My con-tention, therefore, better clarified, is that relative to narginal VFR conditions i

cxisting during any day or night, the Applicant has made no studies that show there i

vill be no dangerous effect on me because of alteration of VFR conditions resulting from the discharge of millions of gallons of uater as vapor per day fro'm the oper-l l

ation at timerich.

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(2)

Response to Special Prehearing Conference order of 6/1/82--contd:

At bottom page 147 (last paragraph) the Anplicant states nothing is alleeed

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to show ein v releases from the cooling tower would affect what I stated, namely,

" c ha n..; c s in Visual Flight Rule conditions."

.In answer I did not at all a lle:'e...

I stated the absolute scientific principle (and NOT for just anv release) that re-lease of noisture into the air at, or near dewpoint conditions, will result in con-densation of the moisture with subsequent format;on of clouds, rain, dangerous air-craft clear ice, or snow... depending on the temperature, as Applicant admits in ref: LGS, LPOL 5.1.4.2.1 (page 5.1-25); second paragraph of page 3.1-26; in partic-ular 5.1.4.2.3 re changes in visibility and ceiling to change marginal Visual Flight Conditions to nor.-Visual Flight Conditions. The essential ingredient in cy conten-tion is stated in the last sentence, bottom page 5.1-23 and top of 5.1-24 Re my assertion of adverse e f f ec ts f rom radionuclides that could be released by the Limerick reactor oneration, again, the technicality variation on manner of t i, t i n;; the basis cannot invalidate the danger of nuclear emmissions and, in fact, I a l r eady am a f f ec t ed psyc:ologically in particular for my family and children and their children, tast nonth's referendum on the restart o f T'Il Un i t 1 in Ct=ber-land, Lebanon, 3rd Dauphin Counties in Pcansylvania demonstrates tuo out of three people are psycologically stressed sufficient to vote 50 to T:iI r es tart...j us t as pople are opposing start up of Limerick.

The Staff (p.149 top) states the contention should be admitted except that therc is insufficient " basis".

Staff misconstrues what I acant by the " highest con-centration of radioactive release".

Without challenging it...but irrespective of the.:trtmely c biguous "as low as reasonably achievable" standard, and not with-st.n !ing that " corrective action (same paragraoh) is recuired" when actual releas-es datiny any caler.dar quarter exceeds one-half the design objective-annual e_xpos-ure.

E iourver, fore and durine the corrective action when there has been abnormal b

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? inactive releases, no corrective action occurs in my concern for adverse L

lth effects alr ead; occurred and occuring.

And on p.

149, last paragraph... it

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" Finally Intervcnor's exanple, to support his ansertion that 'The body t te sat ffa ted by the avcrape a r.n u a l releases but by the highest enncentration of rad;cactive release,' is

= mingless."

Just as assigning ny state.nent to referen-ce in i.

ndix 1 instead of 10 CFR Part 20, the above cuoted statercat should have

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real, " T '. < body is not a f fe ct ed by the t e r- 'avercre annual release' which is just a nt irical r>vro ' ion, but scold absolutely be core adversley cffected by the act-ual.mJ. <.cidual exrosures possible in one eek for cxa nle, as cc pared to the 11 11 1 case divid>d by the 52

,eks."

The degree to which the state ent ra m

ias litt rally :irinterpreted is indicated by the superfluous effort to in form te

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.ted rmar botter of p.

149, "A,y radiation dose affects the body, whether

' r i 'd n a ort to n or a long term." I' u t the scr e total amount absorbed in 1

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1ojy t'uch ore adversley than that m e c ount spread over one year.

n Fur tiw r I ould act oc.ntervening on the b sis of health hazzards if I, and rill-i c-ef 7 c p p e =. e d to Linerict ere not af raid of every and all releas-1 ec, m : tic lar r,It es ich would, if recurring, cunt to rany order of rag-g

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AIR and WATER Pollution Patrol BROAD AXE, PA.

(3)

Response to Special Prehearing Conference Order of 6/1/82--contd:

nitudes over so-called projected annual releases.

As it relates to my use of an example involving "12 units of radioactivity (sic)", bottom of p. 149, the typographical error writing "2" instead of "12" in the fore part of that sentence, caused nisunderstanding.

The basis correctly written is that if the 12 units is the " annual release" shown as the expected summation of all releases during a stated 12 month period there is.a suggestion of small releases spread out over a whole year averaging one unit per month.

However, if the 12 units vere received in one calendar quar-ter, with corrective action " required" and no further releases for the balance of the year, it would still be regarded on paper, as withiir the 12 units permitted on the " annual basis".

But the health effect of the body,having received 4 units for each of the three months would be more adverse than when the 12 units are re-corded AS llAVING BEEN RELEASED in one year's operation.

f As it relates to my contention VI (Quality Assurance Deficiencies) not invol-ved in the June 1, 1982 Order, I want to. state that my seismic concerns which the Staff previously dismissed should be re-considered in light of the Diablo Canyon seismic fiasco, and particularly the. Zimmer Nuclear facility where quasi-fraudu-lent, and slovingly careless disregard for specific procedures and workmanship now justifiably prevents the opening of a practically completed plant.

Think of the disaster that such shameful violation of the trust of the NRC and the people of the Cincinatti area could have brought.

The same problems of seismic' nature, and quality assurance have been referenced in my previous statements of contentions re Limerick, and must now be given more weight in your deliberations.

Respectfully submitted b

Frank R. Romano, (AWPP)

I, 61 Forest Ave.

Anbler, Pa. 19002 4

646-1057(215)

I herefy certify that copies re Order of June 1, 1982 response for consideration 9

S vere sent first class to: Laurence Brenner, Esq., Dr. Richard F. Cole, Dr. Peter A. Morris, Fax Weiner, Atomic Safety and Licensing Board Panel, ?!r. Edw. G. Bauer, Jr., Troy B. Conner, Jr., Esq, !!r Charles Bruce Taylor, Dr. Judith Johnsrud, Thomas Cerusky, PEMA, Robert L. Anthony, Judith Dorsey, Esq., Donald S. Bronstein, James Neill, Esq., Calter U. Cohen, Robert Adler, Randall Brubaker, Joseph White, III, 3

Alan J. Nogee, Robert J. Sugarman, Atomic Safety and Licensing Appeal Panel, Docket-E ing and Service Section.

D.ted: June 16, 1982 F ra nk-R. Romano E

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