ML20100H530
| ML20100H530 | |
| Person / Time | |
|---|---|
| Site: | Limerick |
| Issue date: | 04/05/1985 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8504090225 | |
| Download: ML20100H530 (2) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION R2: PHILA. ELEC. CO.
Licorisk Nuclect G n Sta.
Dockot No.
50-352,353 A ril, 5,1985 P
. APPEAL RY R.L.ANTdONY/F0E FROM REFUSAL OF NRC DIRECTOR OF REACTOR REGULATICE TO ACT ON OUR PETITION OF 12/23/84 TO SERVE A SHOW CAUSE ORDER, AND OUR REQUEST FOR RECONSIDERATION, 2/25/85 ; 6 POM. AN' ORDER FROM THE COMMISSION.
On12/23/85 we submitted a petition to the Director of Inspection and En-forcement to issue a show cause order to st' art proceedings to revoke low power license NPF-27 We included substantiating evidence and references to show that PEco is not able to operate the Limerick reactor safely.
After a delay of li months Mr.H.Denton replied that our petition did not require any immediate action and he declined to take gny immediate action.
WerepliedtoMr.Denton'sletteron2/25/85,askingforreconsiderationand submitting further evidence from PEco's operation to date,of the faults in equip-ment and opergtor performance which demonstrated further PEco's inability to operate without' endsngering the public,NRC staff, and PECo employees. In a 3/26/85 letter Mr. Denton again " decline (d) to take any immediate action".
It is now more than three months since our petition for a show cause order, and PEC's operating record contains many more reports of violations and repeated errors which at higher levels of operation could have brought on a serious accident and threat to the public health and safety.
We believe themDirector's withholding of action on our petition amounts to a delaying tactic which threat-ens our he lth and safety under PECs's imminent ascension to levels above 5 %, l.
I a
(See letter Daltroff to Denton 3/25/85), predicting a full power licensesa,Apri i
We hereby petition the Commission to order the-Director to issue a show cause order and to institute a hearing process on the revoking of the low power license.
We further petition the Commission to order the reactor to be held in a shut down state until a decision on revoking the lioduse has been made.
l We present further evidence of PEco's inability to operate the reactor safely:-
Conditions required under the license have not been satisfied as follows:
i IMPIGEMENT LOADS ON PIPES & SUPPORT (Torrey/ Pines)3/8/85R.E.Ma REDUNDANCY IN REMORE SHUTDOWN CAPABILITY 3 5 A.Schwencer to E.G. Bauer DETAILED CONTROL ROOM DESIGN REVIEW 3/
5 SAFETY PARAMETSR DISPLAY SYSTEM
$/
5 l
l The reactor cannot be safely operated until there has been a complete check' on all safety systems and re-training of operators and supervisors to eliminate the possibility of process and equipment failure with consequences for accidents E
mm$
as indicated below o
n.
-Safety-related equipment removed from service without permission, Violation 85-02 and Control Room HVAC system change without NRC approval, Violation 85-01
- For 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment isolation valves inoperable, Inspection 85-08,l/15/p.19
- INapotion 85-11 possible diesel fire pum'y flywheel crack,p.5; troubleshoot-to 85,
- For 7} hours without protection ef volume level switch,LER 85-14, 1/18/85 k
- Tag-out operated by construction / craft personnel instead of PEco,LER 85-15, W
Repeated isolation of RWCU as in LERs85-25,85-27( "causfe of event remains i
S under investigation") and previous LERs 84-12',26,34,35,36.
i g
- Repeated scrams and half scrams from loss of power to safety systems,LER to.o 85-24 and LERs, 84-05,39,and 85-07 We petition the Commission to order a show catse order and to require a (0
hes, ring to take testimony as to the revoking of the licenseNPF-27,and in the interval to suspend operation of the Limerick reactor.
uba t GAS
,Sga]f gu 1, o,c eting Serv.,PEco, p
sp[t Oct
.