ML20082N415

Request to Reopen Discovery on Contentions V-3a & V-3b Re Arco Pipeline & to Expand Contentions Per New Info Submitted by Util on 831128.Pipeline Should Be Relocated

ML20082N415
Person / Time
Site:	Limerick
Issue date:	12/01/1983
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8312070160
Download: ML20082N415 (1)

Text

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• ATOMIC SAFETY AbD LICENSING BOARD U.S. NUCLEAR REGULATORY COMMISSION RE: Phila. Electric DOCKET # 50-352, 353 Limerick Gen.:sta. Units 1 & 2 20(xf rEr U"iW REQUEST TO REOPEN DISCOVERY ON CONTENTIONS V-3a and 3b AN M XS 'D THESE IN THE LIGHT OF NE# INFORMATION FROM PECO DATED 11/2?f/8 C --6 P2:35 UNDicii 1d983 GOCKEnIng 5 55pyL A letter addressed to me from Mark J. Wetterhahn, dated 11/E8f5M en-closed an answer to Anthory/F0E Interrogatory # 12 submitted to PECoby me on July 24,1983 The wording of this question was:

Did any drilling or excavation on the site or PECo property strike or uncover the pipe? (ARCO pipeline)

PECn's answer was returned' on 8/8/83 from John M.Stipcevich and Vincent S.Boyer  : "No." The latter signed a sworn statement as to the accuracy of this answer and this accompanied it.

The answer to Interrog # 12 sworn to by Mr.Boyer on 11/23/83 and prepared-by him,Mr.Stipevich,and Neal Cody now informs us that the ARCO pipeline was uncovered, 15 feet of it from 6/22/83 to mid-September to install the supplement-al water pipeline underneath it.

It appears that PECo's answer of 8/8/83 was false. The supposed explana-tion is hard for us to understand or accept and it raises many new questions about PECo's construction practices as related to our contentions and the poss-ibilities of future PECo work around the ARCO line and the uncovering of it, with the chance for damage and rupture. This is PECO's explanation: "Since the work on the water supply pipeline was in progress at the time the answer was being prepared, the records reviewed had not yet been updated to refleet this activity.

We are troubled by this apparent lack of conta ct of PECo supervisors with what is going on at the Limerick site. We seriously wonder whether the ARCO pipe is exposed at this moment and whether an order to dig under it or bulldoze over it can be initiated without Mr.Stipcevitch's or Mr.Boyer's knowledge. We further raise the question for the future whether PECo will have cause to work around this pipe and uncover it. The supplemental water line is only one reason for PECo to open the ground at some point along the 3,500 feet or more of the' ARCO crossing of the site. In addition we are well aware that construction work or excavation by third parties is one of the more f requent causes of pipeline breaks.

We can see no oversight or reatraint on PECo's freedom to work over,under and be-m side this pipeline so long as the line remains on its property, granted ARCO has .

an interest in knowing about the operation and requires not'ification,but apparent-W@o ly goes along with any PECo suggestion.

n8 3ecause of these uncertainties as to the safety of the ARCO line and conse-o% cuently the safety of the nuclear plant because of the increasedchance of rupture M due to PECo's activities as indicated by the above new information provided by M

o PECo,ne have become convinced that the only workable solution is to relocate the ARCO pipeline aw ay fro = the nuclear site. We s& the Board to consider an order k< to this effect without further consumption of its time and ours in litigation,and Q in the absence of such an order, alternatively, reopen discovery on the ARCO pipe-line contention and expand it to encompass a study of all PECo facilities at the site next to or on top of the pipeline and whether there are controls over any approaches to the pipeline and whether they are working. '$

We move thattheBoardordertheARCOpipelinerelocted,orlackinh'ove.

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-eopendiscoveryonourARCOlinecontentionandexpanft H in d a Co. Judres 3reener, Cole, Morris , A.wodg6n.fr.. Wetter';ahn

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