ML20081B073

Statement of Matl Facts as to Which There Is Genuine Issue as to Contention I-62.Certificate of Svc Encl

ML20081B073
Person / Time
Site:	Limerick
Issue date:	10/24/1983
From:	Lewis M LEWIS, M.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20081B075	List: ML20081B073 ML20081B187 ML20081B199 ML20081B207
References
NUDOCS 8310270268
Download: ML20081B073 (2)

Text

0

'JNITID STATE OF A: ERICA 3 Q _3 gg/g55 N'JCI.ZAR RIG *JIATCRY CD:GIESIT!

3efore tha Atomic Safety a:s Licensine 37ard DOCKET,ED USNRv In the Matter of philadelphia Ilectric Company ) Dockets. s. g g 3 yhd y 2.

(Limerick Generating Station Units 1 and 2.) g.,. g ,; c g ,y,.

INTERY NOR'c c?ATEENT O? TH: MATERIAL FACTS AS TO WHICH IT IS -CONTEETED THAT .

TH7RE E(ISTe A CENUI'IE ISSUE TO BE EARD AS TO CCNTENTION I-62. (?Tc in 3'<!R .)

1. Pressurized thermal shock is a condition that results from the introduction of cold coolant into or onto a hot pressure vesselwhile pressure is or becomes high. (Intervenor's Statement at A.4)

2. Thermal stresses are produced in the vessel walls when cold coolant is introduced into or ato the vessel.(E.)

3. Stresses are produced when the vessel is subjected to high pressure, but these are not the only stresses that must be considered in an analysis and other stresses may by cumulative.

4. High reactor vessel pressure,during cold coolant injection,does not occur if the jet pumps mix the coolant adequately or there are to obstructions to proper nixing. (IntervenorStatementatA.5)

~

5. The thermal and pressure stresses are not combined with other considerations that have appeared recently such as How does intergranular stress corrosion pipe cracking affect the total stress during a FT5? How does the maneuvers recently instituted to increase fuel burnup affect fluence calculations? '4 hat is the effect of submersion in cdd river water due to equipment failure due to thermal stresses?

(See IniTrvenor Statement at A.5 and A 4.)

6. The Applicant and the NRC staff have consistently and continuously assumed without adequate analysis that the neutron fluence in a 3WR will cause less embrittlement than in a P'.IR ignoring any conflicting data er consideration such as the thickness in a 3RR of the RFV wall is less than that in a FWR arri therefore will require less fluence to affect a greater percentage depth adversely.

(See Intervennr Statement at A.4 and A.5) 7 The applicant and the staff have consistently used assumptions in place of actual analysis of experimental data. (See Intervenor Statement at A.12) 8310270268 831024 PDR ADDCK 05000352 O PDR

/

3. The affect of the Applicant's ani the staff's consistent ard continuous 00CKETED ignoring of data and considerations that contradict the danger to a 3*.l3 of USNRC FIS produces an inadequately assured conclusion that FIS is not a dan 6er..

in 3Was. (See I thru 7 above.) '83 Odi 26 Ai0:24

[6[,Tf_ '13! Cfd' ,

+ ...J4',  ;,

Hespectfully submitted, -

/

~, .

~

/t:L'!in.'t / A.t. l.(. m.* I Marvin I. Iewis 6504 3:adford Terrace Phila 7A 19149 (215) cU 9 5964 I, Parvin I. Lewis , hereby certify that I have place Intervenor's

1) Statement of Material Fr. cts 2)StatementinSupport 3)Affadavit '

4) Resume'

5) aebuttal to Applicant's Motion for summary Disposition of contention I-62 In the LE yall, First Ctssa on this date 'O ~ Z I ' 3 .

,

• p/ '

U '1 harvin I. Iewis 9

e$

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