ML20112K033

Petition for Commission to Order H Denton to Issue Show Cause Order & to Institute Hearing Process on Revoking Facility Low Power License Based on 850225 Submittal of Further Evidence of Util Faulty Operations

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 Ras PHILA. ELEC. CO. Lir; crick Nuclear Gun Stn. Dockot No. 50-352j3536L

, 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 P fiOLp,,gio, ,,, g,_

forcement to issue a show c ause order to start proceedings to revoke low power j license NPF-27 We included substantiating ev$dence candcreferences to show 1 that PEco is not able to operate the LimerickSMHEdtgdafely.

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 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 j withholding of action on our petition amounts to a delaying tactic which threat-

)

ens our health and safety under PECs 's imminent aseension to levels above 5 'JC ,

l (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

} 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, i

Conditions required under the license have r.at been satisfied as follows:

l 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 l SAFETY PARAMETER DISPLAY SYSTEK 85

{

N The reactor cannot be safely operated until there has been a complete check' y on all safety systems and re-training of operators and supervisors to eliminate the possibility of proceses and equipment failure with consequences for accidents l

pn. as indicated below :

l

! co -Safety-related equipment removed from service without permission,Yiolation l g 85-02 and Control Roost HVAC system cha n ge without NRC approval, Violation '85-03 i - 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 l * - Tag-out operated by construction / craft personnel inste of 85-15, M

CG G Repeated isolation of RWCU as in LEBs85-25,85-27( "cause of event rena a 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 j hearing to take testimony as to the revoking of the licenseNPF-27,and in the interval to suspend opers, tion of the Limerick reactor.

N sp ct ubmitt j Y Ces g Q Sp Staff Counsel, Docketing Serv.,PECo,

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