ML20078K297
| ML20078K297 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/12/1983 |
| From: | Anthony R ANTHONY, R.L. |
| To: | |
| Shared Package | |
| ML20078K290 | List: |
| References | |
| NUDOCS 8310190044 | |
| Download: ML20078K297 (1) | |
Text
PlL }.MC&l/N6 SCARutctt-
~
U S. NUCLEAR REGULATORY ' COMMISSION ATOMIC SAFETY AND LICENSING BOARD RE: Phila. Electrio Nuclear Plset Docket # 50-352 Limerick - Units 1 and 2.
00 ED
_353 RESPONSE BY R L. ANTHONY AND F0E TO THE Bo @ 'S MEMORANDA AND ORDERS OF SEPTEMBER 13; AND OCTOBER 5 AND CALLS FROM TBS lE 14AIPf3Gh'. 7 ana 121983 0FFICE OF SECRt.iis -
In its memorandum of Oct.5 the Board saif,'%
kbuticipate the like-lihood that its request to defer the hearing beyond December 1983 will be denied given the insubstantial reasons it has advanced to date in support of its re-quest. "
We presume that the Board was referring to our request for more time to reword contentions as well as scheduling of hearings after the December holidays.
We want the Board to. understand that we will do our best to meet their prefer-ences but there'are obstacles for us which we will attempt to clarify.
In the first place we have never had any affidavit from Pnila Electric r
that they a tually know where the ARCO pipeline is located.
Only on Sept 1.
c were we supplied by PECo with ~ documents in discove:ry which included a letter
~
of 6/7/79 from -LeRoy A.'Christman with ARCO's pipeline alignment sheet- (we were not shown this sheet) in which he said in part,
...we deem the drawing to b9 approximate...... to determine the exact location either in a given area or overall, please advise and we shall make arrangements to stake the pipeline centerline for your-survey crew to tie the line into your site plan: "
There.was no evidence that PECo has ever taken advantage of this offer.
We must presume, therefore, that all the calculations in 'FSAR are based on an ence call of 10/ pipeline's ' location.'When I asked Mr.Wetterbahn in the confer-es-timate of the 5'whom I should contact at PECo to ask for an affidavit to certify the exact location of the line, he said that he did not think anyone at PECo would make such a certification. I said that as far as I could see,PECo did not know whether the line was 800 feet from the #2 reactor enclosure or. 900-or 500 feet or closer. We assert that the Board and we have a right to know i
the exact location and to have affidavits from Bechtel and PECo staff that the-y have seen the line or that it has been reliably marked and they show proof of the depth it is burieds also.
~
We request that the site visit referred to on Sept.13 include-an actual walk along the pipeline right of way where it appro ches the plant and specfic a
evidence of its location. Without proof at the site we cannot check PECo cal-I
.culations on pressure from an explosion or best impact,especially if 6he line-is closer than they have assumed. Even accepting PEco* estimate of location their figures on the amount of fuel from a pipe rupture are off by 4 or 5 times since our study of the topographical map shows the pipe to be drained north.of a break between 7,000 and 8,000 feet and south at least 1,000.
PECO has figured Jg _only 2,,000; feet,both north and south together.
.. c a.
We trust that the Board can see our predicament.
We do not know how to g
reword our contentions until we know the exact location of the pipeline next o
to the plant and high points from which drainage would occur.
If it turns out h
that PECo will have to re-estimate the results from a break,we will have to wait for their figures unless they accept ours.
In short we will only have y
data on the scope of the pipeline problems after the plant visit and public o
hearings next week. Following these we will work 'as swiftly as possible but ME will be hard pressed to meet a written testimony deadline before late November.
ma.o Oc M er 12,1983 Respectfully yours, Box 186 Moylan, Pa.- 19065 b
~
,