ML19323A240
| 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: |
| References | |
| NUDOCS 8004180130 | |
| Download: ML19323A240 (1) | |
Text
WX 71082 DOC 15 NRC 9HDA
~
TLXA015' 00?)(4-05599dSO7? )PD 03/1 ?/80 1709 ICS IPM9NGZ CSP 6082517020 TDBN MADISON WI 359 03-12 0509P EEST PMS PETITION 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 IS BROUGHT BEFORE THE COMMSSION PURSUANT TO 2?33(D), 2234CA) 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 WILL HAVE ALREADY RETURNED TO SERVICE BEFOREE ANMATTER AN THEREFROM C AN RE TAKEN.
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 FILINGS AND THIS FILING AARE IMPELLED BY THE SIGNIFICANT SAFETTY CDNCERN RA ISED BY THE AMER ICAN PYS ICAL SOCIETY THAT THE " RUPTURE OF A FFW TUBES COULO INDUCE ESSENTTI ALLY UNCOOLABLE CONDITIONS COURSE OF A LOCA."
IN THE AS DESCRIBED IN OUR NOVEMBER 14 1979 FILING THE 1979 EXPERIENCE LNN IT 1 VOIDED ALL OF STAFF 'S.B AS ISS FOR CONTINUED OPERATION OF EACTOTRS WITH SERIOUS TU8E DEGRED ATION. THE LAST REMAINING DEFENSE IN THAT REGARDS WAS THE LICENSEE'S NEW THEEORY THAT ALL OEFECTS'DURING A LDCA WOULD GE WITHIN THE CONFINING WALL 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 PREVIOUSLY 9EEN BELIEVED THAT LN UNI T 2.
NO SIGNIFICANT Tb8E PROBLEM EXISTED NOW THE MOST RECENT EXPERI ENCE AT UNIT 2 ON SIMILARLY VOIDS ANY 9 AS IS FOR CONT INUED OPER ATION OFFEBRUARY 98 WEL L. ON THAT DAY, ONE TUBE. RUPTURED WITH A LEAK RATE REPORTED AAT THAT FACILITY AS 1G00 GPO AND SUBSEQUENT EDOY CRRENT TESTINSPECTIONS IDENTIFIED 35 OTHER TUBES WITH DEFECTS IN UNIT 2 i
THE UGESHEET.
ALL OF WHICH WERE ABOOVE THE TOP OF TTHEREFORE AN ADJUDICATORY HEARING SHOULD BE HELD PRIOR j
LN3 IT 2 TO. SERVICE.
CC GERALD C HARNOFF WfSCONS IN'S ENVIRONMENTAL DECADE INC BY HATHLEEN M FA 004? EST g