ML20024E870

Informs That Due to Limited Financial Resources,Intervenor Must Drop Contention I-8 Re Adequacy of Facility to Withstand Loss of Offsite Power.Contentions I-15 & I-33M Will Not Be Litigated

ML20024E870
Person / Time
Site:	Limerick
Issue date:	08/31/1983
From:	Dorsey J DORSEY, J.A., LIMERICK ECOLOGY ACTION, INC.
To:	Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel
References
NUDOCS 8309070151
Download: ML20024E870 (3)

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DOCKETED USNRC L.Aw omcas

• . 107 315 788.7800 0FFICE OF SECRtiART 00CKETING & SERVICE August 31, 1983 3 RANCH Judge Lawrence Brenner Judge Richard-F. Cole Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Judge Peter A. Morris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555 In the Matter of l Philadelphia Electric Company (Limerick Generating Station, Units 1 and'2)

Docket Nos. 50-352 and 50-353 _

l Gentlemen, l

l In its Second Special Prehearing Conference Order, l July 26, 1983, the Licensing Board admitted three of Limerick Ecology Action's (LEA) contentions -- I-8, I-15, and I-33M.

I-8.

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The Board admitted this contention "for the purpose of litigating whether the plant is adequately designed to withstand LOOP," given its concern that "if outage times are underestimated, inadequate compensating measures may have been provided." The concerns stated by LEA in this contention l and in contention 3 of its "new PRA contentions" (related to

!_ the data base.used..to calcula.te.the frequency of LOOP) are both relevant to the Board's concern.

There are other potential contributors to the problem of LOOP as well, not properly treated in the external initiator analysis in the applicant's Severe Accident Risk Assessment (SARA) .

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Brenner, page 2.

These inIclude:

1) ~ impact into transmission facilities or switchyards by aircraft;

2) hurricane-induced LOOP, which is particularly important, since the probability of recovery of power will likely be small, due to the large number of locations at which the power grid is affected by a hurricane and the need to repair most or all of them in order to restore power;

3) the strong likelihood that a safe shutdown earthquake will be accompanied by by LOOP, since the SSE acceleration of 0.15g for Limerick is very close to.the median ground acceleration capacity that is assigned to seismically-induced LOOP (occurring due to failure of ceramic insulators in the 500/230-kV switchyard).

Unfortunately, LEA does not have the financial resources to hire an additional consultant, someone trained to compe-tently evaluate whether the Limerick plant is designed to adequately withstand LOOP, and must therefore drop this contention as reformulated by the Board.

It is LEA's hope that the Board will exeFcise its power to inquire into health and safety matters'sua'sponte, in order to assure that operation of the facility will not cause undue risk to the health and safety of the public.

I-15. e The Board admitted this contention for the limited purpose of " determining whether leakage past closed main steam isolation valves is a problem for Limerick and, if so, what measures should be taken."

As the Board is' aware 7 LEA submitted this contention because of its concern regarding inadequate search for interfacing LOCAs. The Limerick design includes an MSIV leakage control system. LEA is unaware of any significant safety problem j

related to MSIV leakage at Limerick, and does not intend to litigate thic contention as reformulated by the Board.

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Brenner, page 3.

I-33M. ,

Since the Board admitted this contention, which is related to the timing of modification of ADS logic in the Limerick facility to eliminate the need for manual actuation to assure adequate core cooling, the Applicant has agreed to make the necessary modification. prior to fuel load (see Applicant's August 10, 1983 letter to the Board). Consequently, there is no need to litigate this contention.

Sincerely, Ju ith A. Dorsey Connsel for Limerick Ecology Action xc: All parties of record e

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