ML20093A563

Suppl to 840518 Motion Opposing Applicant Motion for Partial Decision & Low Power License & Submission of Contentions on New Matter

ML20093A563
Person / Time
Site:	Limerick
Issue date:	05/30/1984
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8407100637
Download: ML20093A563 (1)

Text

U.S. NUCLIAR RECUI.AIORY COMMISSIOR . .. 1 TCMIC SAFETY AND LICE 3 SING 30ARD RC: PHILA. ELEC. CO. Dockot # 50- 352, 353 Limerick Con Sta. Unito 1 & 2.

M 'May 30 , 1984 l SUPPTIV?NT TO H.L. ANTHONY /F0E MOTION VS. APPLICAN1*3 MOTION FOR PARTIAL DECISION AND LOT POWER LICENSE,AND SG3 MISSION OF CONTENTIONS ON NEW MATTkkT5D 5r/18/84 Contantion 11. PEC'o has moved n'ranium fuel to the l'Slergk_pi e ithout uniting for a decision by the Commission on our appeal , dated 4/5/84,from the decisionoftheAppeal3oard(3/30/84). We believe that thhCommission - s n ;: . will ,

decide in our favor on the basis of PECo's procedtiral* violatiodst,aiid lack of roadiness to receive or store fuel. PE is not allowed to move or uncover the fuel under the license issuel.. And this license will be revoked when and if the Commission decides in our favor. ill the procedural violations as well as defic-iencies in PE's construction, equipment,sta.ff, procedures,and training as itemized in our Appeal to the Commission and otr Brief to the Appeal Board,3/28/84 are included in this contention by reference.

Contention 12. We assert that the dangers from an explosion on the railroad i have not been evaluated for the hazard .to fuel being transported from outside storage to the fuel hoistway in the plant, and uncrating there. We were prevented from esa=ining witnesses on the railroad blast during Cont. V 3aand b.(structural).

The missiles that can be launched as well'as overpressures, afford grave threats.

Cont. 13 The PE study of " issue 13" SEE (NUREG - 0991) forwarded by J.S.

Ecmper to 1.Schwencer,NHC, 5/4/84 evaluating the effects of high energy line,(HELB)~

breaks on " all possible combinations of control syatems" does not assess completely the risk because of the exclusion offlines which operate 2% or less above 200 F.

These are lines most subject to rupture because of the fluc tus. tion s !

and 275 pais.

in beat and pressure and they could trigger other breaks and bring the cumulative l consequences above the FSAR Chap.15 analysis. In addition the effects of HEL3 breaks on fuel han dling h ave not been evaluated, including breaks which could rup-ture the pipe tunnel over which the fuel must pass in entering the plant (south).

o@@ FSAR Fig.6.2-34 E

CO Cent.14. At the Commission meeting in Washington on 4/24/84 the progress of g the Limerick licensing proceeding,among others,was discussed.(See trans. p.38, 0

8 copy accompanying) The applicant estimates a fuel load date in August 1984 ; the mt

g Staff estimates construction completion in the spring of 1985 This discrepancy N

.O suggesta an unrealistic view of construction and turn over as well as a possible

~

$$ glossing over of safety issues which will not satisfy NRC requirements and dis-qualifies any consideration of an orpedited de. cision or low power fuel loading. p Addition to Contentions 6,7,and 9 from from ASL Appeal'3eard Memergadum and 5 order,5/7/84 Com=onwealth Edison (Byron. Docket STN 50-454,455 ).Much of this de-ision D.8 aR plies to violations od 1-apses in PE'supervis

"(QA) shortcomings.preclu*ded. .assuranc e. . cons truc+ ion of insee,ction,

• espe recti ed.

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