ML20117L042

Forwards as Further Evidence to Support 841223 & 850225 Petitions Requesting Issuance of Show Cause Order to Initiate Proceedings to Revoke License NPF-27.W/o Encl

ML20117L042
Person / Time
Site:	Limerick
Issue date:	05/09/1985
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Harold Denton Office of Nuclear Reactor Regulation
References
CON-#285-013, CON-#285-13 OL, NUDOCS 8505160058
Download: ML20117L042 (1)

Text

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Yr. Harold J.Dsnton, Dir. NRC ON. 'Jucloor Reactor Reg. Msyh9rt%985

'Jashington, D.C. 20555 .e:

i Phila. alec.coNmerick

Dear Mr.Denton,

Gen. Sta. D NM 15 41:;o 2 ,,

We are again calling your attention to our petition of 12/23/84 and our 1 further. petition of. 2/25/85 requesting that you issue a sh6 ~ e order to  :

initiate proceedings to revoke low power license NPF-27 isU }s..Eleo.

Co, for its Limerick plant, unit /1. 7e are enclosing a copy o1 letter ,

4/27/85, to*Hugh L. Thompson as further evidence to back up the need for this order; The evidence which we submitted to you conclusively proves that PICo is ,

not qualified to operste the plant safely en d the license should be revoked  ;

until equipment, esployee,and process deficiencies have been completely reme- i died. The present operation of this P lant by PEco is a present and continuing

! - threat to our health snd safety.

6 py addition we now cito PEco's violatiogf eations of Itcense NFF-27s (

1. C.l Limerick will operate in violation of3 throh*Ihe use of Schuylkill River water for cooling during the low flow season,and by demand 4ng releases l r

from the Blue Marsh reservoir,and by renouncing its ageoment to the " river follower mode" with the Delaware River Ba sin Commission . 0PEco's applications temperature limit.

of 3/15/85 and 4/23/85 to DRBC call- for removal of the 59  ;

I ^ 's!*rltt *ft!P*iR" Inst!2ri$*8'd"d"*""h'h" leuws 3/19 a 4/26/85 The operation of Limerick with dependence on Schuylkill water for l k.D.  !

l cooling will enda ger n the health and safety of downstream water users by l l threatening the bi ogical life of the river and drawing upon reserves of l drinking water,and onsuming water needed by industry to maint,in jobe.

1. G. PEco's. use of Schuylkill water is inimical to family and community l services and community health and safety because of the threat to publio water i supply. Even in this time of drou.tht Mr4V.S. Boyer, PEco V.P. called upon DRVC in his written statement on 5/7/85 for "squitable demands upon all ta- l poundsents" despite PICo's igygesent with DRBC to be limited by flow condi-t tions in the Schuylkill. This Mn violation of PEco's agreement with DRBC and in violation of the conditions of ge NRC license. .  ;

1. R. Furthermore, PEco is in violation Appendix B of license NPF-27 i Geot. 31 of thd Appendix requires that3'the licensee shall prepare and re- (

cord an environmental evaluation" before making such an application as this one to change the consumptive dea n nds on the Schuylkill river. f

! Sect. 5 3 requires "an asseessent of the environmental impact" and "NRC ap-  ;

• proval of the proposed changes in the form of a license amendment incorpora-  !

ting the appropriate revision to the SPP" (2nvironmental Protection Plan)

PEco's application to DRDC violates b*oth of these requirements of Appendix B.

l As further evidence of the threat to the health and safety of the publio [

from this consumptive use of Schuylkill water and Blue Marsh reserves, we cite j the testimony of Mr. David C. Yaeck . Executive Direetor,Chegter County #ater Se-  !

sources Authority, in oppos ition to the removing of the 59 restriottom and i

the release of Blue Marsh water for Limerick consumption. He testified at the e DRSC hearing on 5/7/85 in #est Trenton as to the inviolate base that alue Marsh  !

water constitutes for public agter resource planning in Chester County. He  ;

i said that a temporary request by PEco had the potential of becoming peraament,  !

o and hisD-69-21C publie agency is completely opposed to PRCo's modifiention of DRBC CF, (See DRSC transcript 5/7/85) f j Docket

#e are enclosing a copy of our 4/29/85 petition to ALAE on this matter. f On 5/2/s5 ALAS. dismissed our petittes and advised us to submit it to your office.  ;

ces NRC ALAB,A5&B, Counsel, Docketing , PEco,DRBC Respect y yours,_ >

Cthere on Serv. List ,4p -

4) l ' 90 Wylan,Pa. lid $