ML19323A240

Requests That NRC Issue Order to Show Cause & Order Enjoining Operation of Facility Because of Steam Generator Tube Degradation

ML19323A240
Person / Time
Site:	Point Beach
Issue date:	03/12/1980
From:	Falk K WISCONSIN'S ENVIRONMENTAL DECADE
To:	Moe M NRC COMMISSION (OCM)
Shared Package
ML19323A235	List: ML19323A240
References
NUDOCS 8004180130
Download: ML19323A240 (1)

Text

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WX 71082 DOC 15 NRC 9HDA TLXA015' .

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ICS IPM9NGZ CSP )PD 03/1 ?/80 1709 .

6082517020 PMS PETITIONTDBN MADISON WI 359 03-12 0509P EEST TO: U.S. -

sM F SEND VIA TLX OR DLRNUCLE AR REGULATORY CnMMISS ION, ATTN Fif.RY ANN IIMMY F717 H ST ~

WASHINGTON DC 205555 RE4NFOUNTT8EAOBCNBTLSAR303WER -

TTHIS PETITION SEEKS IMMEDIATE ENTRY OF AN ORDER TO SHOW CAUS CRDERR ENJOINING THE LICENSEE FROM RETURNIING UNIT D TO SERVICE THURSDAYMARCH 13 1980 OR THEREAFTER, TOO BE TF.MPORARILY EFFECTIVE It;ND ING WURTHER ORDER.

THIS PEITITION 2?33(D), 2234CA)IS BROUGHT BEFORE THE COMMSSION PURSUANT TO 42 USC AND 2237, WITHOUT PRIOR REQUEEST TO THE OFFICE OF R

NUCLEAR REACTOR REGULATION, BECAUSE THE STAFF HAS INDICATED INFORMALLY THAAT IT WILL NOT TAKE ANY ACTION IN THIIS FACILITY THEREFROMWILL HAVE C AN RE ALREADY RETURNED TO SERVICE BEFOREE TAKEN. ANMATTER AN APPEAL.

THIS PETITION IS FILED ON THE GROUNDS STATED IN OUR PREVIOUS FILINGS DtTED NOVEMBER 14 1979, NOVEM9ER 26 1979, DECEMBER 17 1979, JANUARY 8 1980 AND FEBRUARY 22 19980, WHICH ARE INCORPORATED HEREIN 8Y REFERENCE AND ON THE FURTHER GROUDS AS SET FORTH BEOW. ALL OF THEESE PRIOR FILINGSRA CDNCERN AND ISEDTHIS FILING BY THE AARE IMPELLED BY THE SIGNIFICANT SAFETTY AMER ICAN A FFW TUBES COULO PYS ICAL SOCIETY THAT THE " RUPTURE OF COURSE OF A LOCA." INDUCE ESSENTTI ALLY UNCOOLABLE CONDITIONS IN THE AS DESCRIBED IN OUR NOVEMBER 14 1979 FILING THE 1979 EXPERIENCE LNN EACTOTRS IT 1 VOIDED ALL OF WITH SERIOUS TU8ESTAFF DEGRED 'SATION.

.B AS ISS FOR CONTINUED OPERATION OF THAT REGARDS WAS THE THE LAST REMAINING DEFENSE IN LDCA WOULD GE WITHIN THE LICENSEE'S CONFINING NEWWALLTHEEORY THAT ALL OEFECTS'DURING A OF THE TUBESHEET. AS CESCR IBED IN OUR DECEMBER 17 1979 AND JANUARY 8 1980 FILINGS, EVEN THIS LAST DEFENSE FOR CONTINUED OPERATION OF UNIT I IS NOT VALID. IT MS LN PREVIOUSLY UNI T 2. 9EEN BELIEVED THAT NO SIGNIFICANT Tb8E PROBLEM EXISTED NOW THE MOST RECENT EXPERI ENCE AT UNIT 2 ON SIMILARLY VOIDS ANY 9 AS IS FOR CONT INUED OPERTHAT ATION OFFEBRUARY FACILITY AS 98 1 WEL L . ON THAT DAY, ONE TUBE . RUPTURED WITH A LEAK RATE REPORTED AAT 1G00 GPO AND SUBSEQUENT EDOY CRRENT TEST INSPECTIONS IDENTIFIED 35 i

OTHER TUBES WITH DEFECTS IN UNIT 2 THE UGESHEET. ALL OF WHICH WERE ABOOVE THE TOP OF j

TTHEREFORE LN3 IT 2 TO. SERVICE. AN ADJUDICATORY HEARING SHOULD BE HELD PRIOR CC GERALD C HARNOFF WfSCONS IN'S ENVIRONMENTAL DECADE INC BY HATHLEEN M FA 004? EST g