ML20116P283

Petition to Reopen Record on Basis of New Info in Applicant Feb 1985 Semiannual Effluent Release Rept.Aslb Should Institute Hearings to Determine Adequate Stds & Methods & to Order Stay of Low Power Testing

ML20116P283
Person / Time
Site:	Limerick
Issue date:	04/30/1985
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
CON-#285-889 OL, NUDOCS 8505070566
Download: ML20116P283 (1)

Text

-

U.S. NUCLEAR REe0LAT!RY C0 EMISSION....... ATOMIC SAFETY AND LICENSING BOARD )

RE: PHILA.ELEC.CO. LIMERICK GEN.STA. Unito 1& 2 DOCKET No8 50-353,353 0L '

April 30,1985 PETITION BY ANTHONY /F0E TO REOPEN THE RECORD ON THE BASIS OF NW INFORrATION IN PHILA.ELEC. CO's SEMI-ANNUAL EFFLUENT RELEASE REPORT,FEB. 1995 I f

)

EFFLUEN'i RELEASE REPORT. Phila. Elec. issued its No.1 report 190fle0 8ary, covering 12/22/84 through 12/31/84. We were provided only part o report; the rest we had to request and it was received on 4/2/85,excgt g ghe" pages" referred to in R.A. Mulford, 2/22/85 memo ( last page trf rttaehn$gt,tge wele )

which we have not yet received.

GFFI 0F SECHtTAsv DEFICIENCIES AND ERRORS IN OFFSITE DOSE CALCUIATION. Our hea$ h C a N y are in danger because the methods for ca'1culating dosages at the site boundaries are not in keeping with the regthtions as follows:

Calculation of set points for isolation of reactor systema discharging gaseous and liquid effluents are distorted upward because thh site boundaries on which they are based .(Attachment D to the Semi-Annual Report No.1)are in error.

Attachment D., page 1 specifies the dose calculations " at and beyond the SITE BOUNDARY". This bound and 762 meters (p.7,8 Jor a$ry out is at 790 2,300 meters feet. (p.5 6,9,10)

Calculalions based or on about 2,400 these feet, bound-aries are completely inaccurate. The closest approach by individu als to the 8 about 900 feet from the south stack,and plant the next is on the railroad closest approachright is Oofgbout way1,500 on the Schuylkill River. The rail-road and river are both accessible to the public and are not part of the plant property,not owned by PECo. ( Att. D , Fig VI.A.1). Railway personnel ard at risk.

Calculations based on these erroneous boundaries disqualify the whole methodol-ogy, as on pages 5-10,and 25-33 Calculations on radiation poisoning from ea ting fish are underestimated (p.4)

Fish could be contaminated at the river effluent outlet at only one half mile from the 7 1ant, caught,and eaten on the same day. The "one day delay"is in er-ror,as is the distance (p.18 ) 1 9 miles. (See Fig. VI. A.1 )

The changes to ODCM cited in Attachment D 1 " allow LGS flexibility..in setpoint for isolation." This amounts to degrading the standards,with substantial increases in radiation risk to the public. We petition against this degrading against the modifications of release point weighting factor,and the ,and also averaging of emissions from north and south stacks. Since the nearest approach for the public is 900 feet a mass of gaseous radiation could travel this distance with little dispersion or dilution,directly from the south stack. Calculations in Attch.D, therefore,as set forth in the report are disqualified.

STANDARDS FOR REOPENING THE RECORD. We assert that the Board must grant our petition to reopen the record on radiation release standa ds r because (1) cur

( motion is timely since PEco's effluent report is new material which we could

$ not have had earlier, (2) radiation releases to the public constitute a crucial

-@@ hea lth and safetyhtgew ith potentially isolation fatal consequences, (3) a totally differ-to eut result,with lowered radiation setpoints, will result from calculations based cac A on the findings above.

< We petition the Board to reopen the record and to g g g hearings to

$. determine adequate standards and methods,and to order agstay of low power testing.

$$o cc8 NRCStaffCounsel,DocketinbtH.Denton, Respectfully submitted, .

PEco. LEA,others on Serv. L W A , %l l, Box 186 Moylan,Pa. 19065 ,

..- ._- . _ . _ . -_ _ _ - __