ML20100H530

Appeal from Refusal of NRR to Act on 841223 Petition to Serve Show Cause Order to Start Proceedings to Revoke Low Power License NPF-27 & 850225 Request for Reconsideration & for Order from Commission

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 Pril, 5,1985

. 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- I 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-I ens (Seeour hea lth letter and safety Daltroff under3/25/85) to Denton PECs's imminent ascension

, predicting to levels a full power above 5 % , l.

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:-

i Conditions required under the license have not been satisfied as follows:

IMPIGEMENT REDUNDANCY LOADS IN REMORE SHUTDOWN ON PIPES & SUPPORT CAPABILITY 3 (Torrey/ Pines)3/8/85R.E.Ma 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 as indicated below mm$

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 to - INapotion 85-11 possible diesel fire pum'y flywheel crack,p.5; troubleshoot-

- 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 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, i W Repeated isolation of RWCU as in LERs85-25,85-27( "causfe of event remains 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 85-24 and LERs, 84-05,39,and 85-07 to.o 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 Oct GAS ,Sga]f gu 1, o,c eting Serv.,PEco, p sp[t

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