ML20117L042

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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  Constellation icon.png
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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gcK&rM Yr. Harold J.Dsnton, Dir. NRC ON. 'Jucloor Reactor Reg.

Msyh9rt%985 Phila. alec.coNmerick

'Jashington, D.C. 20555 i.e:

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

Dear Mr.Denton,

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 The present operation of this P ant by PEco is a present and continuing l

died.

- threat to our health snd safety.

6 eations of Itcense NFF-27s

(

py addition we now cito PEco's violatiogf

1. C.l Limerick will operate in violation of throh*Ihe use of Schuylkill 3

River water for cooling during the low flow season,and by demand 4ng relea es l

s r

from the Blue Marsh reservoir,and by renouncing its ageoment to the " river follower mode" with the Delaware River Ba in Commission.

PEco's applications s

0 temperature limit.

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

^ 's!*rltt *ft!P*iR" Inst!2ri$*8'd"d"*""h'h" leuws 3/19 a 4/26/85 I

k.D.

The operation of Limerick with dependence on Schuylkill water for l

cooling will enda ger the health and safety of downstream water users by l

l n

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

3 Geot. 31 of thd Appendix requires that 'the licensee shall prepare and re-(

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

f n

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 oppo ition to the removing of the 59 restriottom and s

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

is completely opposed to PRCo's modifiention of DRBC f

and his publie agency (See DRSC transcript 5/7/85) o Docket D-69-21C CF, j

  1. 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,_

l Cthere on Serv. List

,4p 4) 90 Wylan,Pa. lid $

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