ML20093A546
| ML20093A546 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/18/1984 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8407100620 | |
| Download: ML20093A546 (2) | |
Text
I %g C o r. w i d._-
C. c o U.S.
NUCLEAR RIGULATCRT COMMISSICI.... ATOMIC SAFETY AND LICENSING BOARD RE: PHILA ELEC. CO.
Docket #
50- 352, 353 Licerick Cen. Sta. Units 1& 2
{
MOTICE BY R.L. ANTHONT/?OE (In t no Delaware Valley) IN OPPOSITION TO APPLICA5T'S MOTION FOR AN SIPEDITED PARTIAL INITIAL DECISION AND ISSUANCE OF A LOW POWER LIC-ENSE FOR LOADING AND TESTING ;
AND SUBMISSION OF CONTENTIONS BASED ON NEW MATTEH.
% ' a -5 pg 39 In accordance with 10 C.I.R. Sec. 50 57 (c) with respect to the rights of parties to be heard on relevant contentions, R.L.inthony/F0E sub:atts the contentions bolow,and moves that these be admitted s.nd be given full hearing and$oNhideration, chile during this time no expedited partial initial decision be'made nor any low power license be granted for fuel loading and low power testimg.
We assert that PEC6's notion of 5/9/84 is in violation (Par #1) of 10 CFR 50 57 (c) in asking to operate " not to exceed 5 % of power" while Par. ( c) pro-vides for up to only 1 T, of full power.
Further the PEco motion and the state 505f*(k),(2),(3),
of' constmetion at the plant (Unit 1) do not satisfy 10 CFR (4),and (6),and (b),as specified below.
Contantion 1. The plant cannot safuly have fuel loading or any level of test-ing until ASLB determines that the structures are designed to withstand explosions from outside (Cont. 7 3a sud 3b) and the risks from such explosions have been miti-gated to the extent specified in Anthony /FOR Findings and donclusions 5/2/84, page 8, # l-6. ( 7 3a and 3b)
Cont.2.No fuel loading or testing until the " Independent Design Re iew Pro-v gram" has been carried through and construction verified in compliance with design.
This review has not yet begun and has only been recently approved by NRC ( See 5/15/84 etter A.Schwenee z to J.S. romper.)
l Cont. 3. Violations of FSAR in the,"tyn-over" process. ( See NRC Meeting He-Port 50-352/e4-33) 4/30/84 p.1 Para. 3, Appendix 1-Severity Level I7 Violattoa.
TA P Cont. 4. Missing information, NUREG-0737, Items II F 1. Attachments 1,and 2,
( noble gas monitors analysis of plant effluents.),and Item III.D.l.1 ( integrity cf containment of radioactive material). S**
5/9/84 letter 1/Schwencer-E.c. Bauer.
Cont. 4 a.NRC Inspection Report # 84-05,5/4/84 gt, ages p.1 Para.3 : " The 1 spections of the Radiation Protection Program found the majority of the program,
neoded to sup; ort fuel load and power operation,had not been established." PEco th-
- nnuot be allow to lo,d fuel until these requirements are satisfied. See # 84-05 8407100620 840518 D3 tails, p.2, p.3. ep.4. P.S.,p.6.,
and p.7 PDR ADOCK 05000352 O
PDR Cont. 5 PECO will not be ready to set up proceeaures unner anc veneric Le t-ter 83-28,7/9/83 (!!alem AT73 Events) until 6/1/84andexpects "proceedure will bo in effect by Sept. 1, 19 84 ". There is no assurance PEco will meet these require-i coats by a fuel loading deadline im September. (See letter 7.S.Boyer-Eisenhut 5/8/84 p o'5
-- 2 --
Cent. 6.
No fuol con bo lendcd until further chocks of quolity control in c:nstruction baye been carried out and there is assurance that equipment and struc-tures are safe for operation.
( See NRC Combined Inspection 84-17;84-05,5/10/84)
Dotails,and pages 3 through 5 (see Details).."..the prastice of documenting a nos-ecnforming condition and/or authotized rework / repairs on ASYE Code items on IPEN instead of NCR was' of concern to the inspector."
Also the lask of follow-up.and correction of welds passed in error by fa lty inspection leaves vulnerable points u
in the construction, including those now inaccessible, which must prevent fuel loading until they can te assertained to pose no liability for safe operatierr,be-yend any possible doubt.
Cont. 7 The integrity of welding as well as that of the Reactor Pressure Yessel are in doubt as specified in 4/18/84 memorandum to the Gommissioners from D.C. Eisenhut (See p.6 para.4;and para 5 for deficiencies in welding inspec-tionsand unresolved item in para. 6 and para.7 Cont. 8.
NRC letter 5/7/94 Thomas E. Murley -J.S. Kemper details viola-tions of regulations which disqualify any fuel loading untti they are completely rectified. Seven violations of severity level IV and seven of level 7 pe listed os page 27 All the violations and omissions detailed in this report make fuel leading out of the question from a safety aspect and they form the basis for this contention.
Cont. 9 NHC Inspections 84-14 and 84-04 dated 4/20/84 detail differences between as-butit systems and FSAR which also must stand in the way of fuel loading until they are corrected. (See page 9). This in pection also includes a number 3
of unresolved construction items and faulty equipment which must prevent fuel load-ing. The ability of the staff to handle radioactive material fa in questiotr tog,
cs shown by the throwing of containers of nuclides in a trash bin. ( page 10)
Cont. 10 NRC letter 4/30/84 7.T. Martin-J.S. Kemper,In p. 84-13 forms s
the basis for this contention that the security program at Limerick is not ade-quate to allow fuel loading.
Bases for Contentions
'hese contentions are based on new matterg and are therefore timely.
The motion for a low powerelicense was submitted only on 5/9/84.
No other partyhas raised the contentions above.
We are equipped to do ao and have demonstrated in these proceedings sur ability to raise issues of safety which other-cise would not be completely dealt with. The contentions will not broaden the issues but focus on: the necessity for plant safety before any operation,thereby protect-ing the public's interests and safety and welfare.
CC. Judges Brenner, Cole, Morris Spec. Del Respectfully submitted, 1
NRC Staff, M.J.Tetterbahn W,/,,
Others on Service List Bor 186 Moylan,Pa 19065 I
W^7 18,1984