ML20112K033
| ML20112K033 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/05/1985 |
| From: | Anthony R ANTHONY, R.L. |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#285-437 2.206, OL, NUDOCS 8504090306 | |
| Download: ML20112K033 (1) | |
Text
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I U.S. NUCLEAR. REGULATORY COMMISSION
/ o84 6 h ud 50-352j3536L Ras PHILA. ELEC. CO.
Lir; crick Nuclear Gun Stn.
Dockot No.
April, 5,1985 APPEAL BY R.L.ARTHONY/F0E FROM REFUSAL OF NRC DIRECTOR OF REACTOR REGULATIW TO ACT ON OUR PETITION OF 12/23/84 TO SERVE A SHOE CAUSE ORDER, AND OUR REQUEST FOR RECONSIDEBATION, 2/25/85J M FOR AN' ORDER FROK"T'NE COMMISSION.
On12/23/65 we submitted a petition to ti@ DIMor fiOLp,,gio,,,, g,_
P forcement to issue a show c use order to start proceedings to revoke low power a
j license NPF-27 We included substantiating ev$dence candcreferences to show that PEco is not able to operate the LimerickSMHEdtgdafely.
1 After a delay of li montha Mr.H.Denton replied that our petition did not require any immediate action and he declined to:take any immediate action.
We replied to Mr. Denton's letter on 2/25/85.asking for reconsideration and submitting further evidence from PE0c's operation to date, of the faults in equip-ment and opergtor performance which demonstrated further PEco's: inability to operate without 'endsugering the public,NHC staff, and PEco employees. In a 3/26/85
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1etter 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-j ens our he lth and safety under PECs 's imminent aseension to levels above 5 'JC,
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(See letter Daltroff to Denton 3/25/85), predicting a full power license tinApril.
i We hereby petition the Commission to order the-Director to issue a show l
cause order and to inutitute a hearing process on the revoking of the low power l
license.
We further petition the Commission to order the reactor to be held
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in a shut down state until a decision on revoking the license has been made.
l l
We present further evidence of PEco's inability to operate the reactor safelys, Conditions required under the license have r.at been satisfied as follows:
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IMPIGEMENTLOADSONPIPES& SUPPORT (TorreyPines)3/8/85R.E.MartintoPEco.
1 REDUNDANCY IN REMORE SHUTDOWN CAPABILITY 3 5 1.Schwencer to E.G. Bauer i
DETAILED CONTROL ROG( DESIGN REVIEW 85 SAFETY PARAMETER DISPLAY SYSTEK 85
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The reactor cannot be safely operated until there has been a complete check' Ny on all safety systems and re-training of operators and supervisors to eliminate l
pn.
the possibility of proceses and equipment failure with consequences for accidents as indicated below :
co
-Safety-related equipment removed from service without permission,Yiolation 85-02 and Control Roost HVAC system cha ge without NRC approval, Violation '85-03 l
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- INyction 85-11 possible diesel fire pun'y flywheel crack,p.St troubleshoot p.'it
- 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,Inspectio 85-08,l/15/85J o
- For 7$ hours without protection of volume level switch,
-14,1/18/85
- Tag-out operated by construction / craft personnel inste of 85-15, l
- M Repeated isolation of RWCU as in LEBs85-25,85-27( "cause of event rena a CG G under investigation") s.nd previous LERs 84-12',26,34,35,36
- Repeated scrams and half scrams from loss of power to safety systems, LEE l
85-24 and LERs, 84-05,39,and 85-07 l
l We petition the Commission to order a show cadse order and to require a hearing to take testimony as to the revoking of the licenseNPF-27,and in the j
interval to suspend opers, tion of the Limerick reactor.
N sp ct ubmitt Ces g Q Sp Staff Counsel, Docketing Serv.,PECo, j
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