ML20092P772

Motion for Admission of Contentions Based on JW Gallagher & Js Kemper Requesting Remaining Portion of License to Move Fuel to Refueling Floor,Insp & Storage of Fuel & Petition for Stay

ML20092P772
Person / Time
Site:	Limerick
Issue date:	06/18/1984
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8407090359
Download: ML20092P772 (1)

Text

DD U.S. NU C LIA3 REOU LLTLff C Cir3ISS ION...... ATCMIC dA?ETY AND LIC:.33 DG BOARD PHILA. ELEC. CO.

Limerick Gen. Sta. Units 1 & 2.

DOCEET #

50-552,353 June,18,1984 R.L. ANTHCNT/ FOE CONTENTIONS BASED ON NET MATTER,LETTEPs FRCM J.W.GALLAGHER/J.S.

G PSR,PECo., 6/7/84, EEQUESTING " RUM AIN15G PORTION OF THE LICENSE" (Part 70)

TO MOVE FUEL TO THE HEFUELING FLOOH, INSPECTION, AND STORAGE IN THE FUEL POOL, AND PETITION FOR A ST1Y.

o IMPROPER SUBMISSION.

To are in receipt of a copy of a letter, dated' 6 84, from J.F. Callaghe r/J.S.Kemper, PECo, tp N'RC R.G.Page, Chief Fuel Licensing, providing-

" pages to our application that have been revised." The subject 'in s " Lime rick....

Unit # 1 Special Nuclear Material License Application".

These kinds of revisions and additions to a. auclear fuel license <xonstitute orec tly t'he same kind of elimisating of The Board's jurisdiction and the partioi-was deplored by the Board in the failure of PEco to no-pation by intervenors as tify the Board of its origins 1 fuel licesce applicqtion 6/1/83 We request that the Board penalize PECo for its defiance of the Board's prerogatives and*.!its and(Part 70,Comm.Orderh' 2.M the Commission's.

opoeific orders,and its violation of intervenors' rights, CONTENTIONS BASED ON REVISIONS OF NHC MATERIALS LICENSE.

We note that the N

Inst revisions of License # SNM-1926 were dated 4/3/84 and were forwarded to the Besrd and parties by the NRC Staff Counsel en 4/10/84 The documents submitted uore a letter from R.G.Page,FHCe to E.G.Bauer,pBCo, and Materials License sheets by contrast cotting forth specific conditions. The above letter 6/7/84 suggests sweeping-changes in the conditions of the application and a ks their approval by 7/2/84,

s in order to satisfy a schedule of moving new uranium fuel from outdoor storage to the plant's refueling ' floor on July 9,1984, via am Attachment 1.;thus s.rd is left.out.

We take exception to this"short-cut"of the NRC regulations and the Board's roview. We ask the Board to find this letter impermissible and without validity in the fuel licensing process.

If there are to be revisions et,and additions: to this license, we move that they be submitted in the required form to the NRC Staff ocd the Board,with notification to the parties.

We have studied the contents of found fif teen.. revisions and conditions that will form the g Attachment 1. and have N " basis for "n5w contentions to protect the safety of the public and specifically ooy our health and interests.

We reserve the right to submit these to the Board 0

o-if and when revisions of the license' in the proper form ard submitted.

in:s:

Since the Board was gives jurisdiction in thia Part 70 process, we petition the Bo rd for a stay on any i=plementation of the revisions in Attachmen t 1,6/7/84 f

a ocr g letter,or any changes in the license.or the moving of the fuel into the plant,under 10 CFH Sec. 2 788.

We have satisfied the conditions of this section(above)and co add that PEC, will not be delayed in a reactor testing schedule of mid-Septemberc Cc:

Judges Brenner, Cole, Morris Respectfully ubmit ed, NRC Staf f 'ouns el, PECo,Co=mv. Penca., Phila.

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