ML20087F526

Application to File Contention Re Util Application to Store Fuel Outdoors.Fuel Storage Is Hazard to Community Due to Question of Whether Bldgs Can Withstand Overpressures & Impacts from Offsite Accidents

ML20087F526
Person / Time
Site:	Limerick
Issue date:	02/23/1984
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20087F504	List: ML20087F501 ML20087F526 ML20087F539
References
NUDOCS 8403190138
Download: ML20087F526 (1)

Text

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U.S. NUCL"AR REGULATORY COMMISSIOK - - ATOMIC SAFETY AND LICENSING BOARD RE: Phila.Eleo.Co. Docket # 352 E05 METED i Limerick Qan.Sta. Units 1 & 2. February 23 ,19si$.E -

i APPLICATIbE BY ANTHONY /F0E TO PILE A CONTENTION BASED,:05 NEW f~

PBCo's APPLICATI0F PART 70 TO STORE F7EL AT THE LIMERIf.,E [LANT D /8

-w CFFICE 0.; SEUsim . -

On February 21,1984 we were served by B'.H.Vogler,NRC staff [dE k ,ju k '

an"1MEFEED APPLICATION FOR SPECIAL NUCLELR MA'TERIAL LICENSE FOR LIMERICE GEN.

STA. UNIT NO. 1." (Docket N.' 70- 2988). 7e hereby apply to the Board to allow a filing of a contentiop based'on tnis new material on behalf of R.L.

Anthony and Friends of the Earth in the Delaware Valley.

1. The storine of nuclear fuel at the Limerick plant is a hazard t$ the community and me and my family personally because the Board is in the process of determining in evidentia yr hearings whether the safety related buildings can withsta nd overpressures and impacts from off-site accidents in Contentions Y 3a and V 3b. Until the Bogrd nas all the evidence and has ruled that these structures are built to withsta nd off-site accidents,no' fuel can be risked there.

2.The NRC Staff is in the process of ascertgining' verification from PEco that the plant " has been designed and co0structed in accordqnce with the reg-lations and Safety Analysis deport commitments". (Letter 1/10/84 D.G.Eisenhu:t to E.G. Bauer,Jr. requesting pla ns for verificatien within 30 days) Today we were informed by Edward Cullen of Mr.Bauer's staff that PE:lo plans to submit a proposal on the verification program by March 15. Until this verification y

has been accomplished to th'e satisfaction of the XRG t Staff no 'uel storage can be contemplated because of the hazard stated in Para.1,above.

3. The NRC Staff has recently raised ouestions about the cualification of the Limerick overhead cra nes for handling nuclear fuel sincethgr do not have the required load safety factor. No fuel can be brought to the site until this handling equipment has been strengthened, tested,and qualified as per regulations.

4. Even if the buildings and cranes are finally found to meet the NRC d$ standa dsr when the hearing and regulatory processes have been accomplished, E$$' no fuel can be . brought to the plant until the safety of the public is provided og y for by approved off-site emergency plans in the event of an accident which could

' a3 set off a fission process while fuel is being transported to or brought into or y the plant.Unless emergency plans are prepared and ready,the community cannot

' $@ be exposed to the risk of nuclear fuel and accidental release of radioactivity,  ;

I

<ob

• Cc: Judges Brenner, Cole , Morris, Re sp_ec tfully. submitted

• • U NRC Staff,M.J.WETTERHaHN,Commonwe a lth, City of Phila.,other on service list.

W- 4,M, Bor 186, Moylan ,Ya.190h l

l P SJe reques t this filing be added to the record as an exhibit when the hearings-l resume, 1

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