ML20140B430
| ML20140B430 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/28/1981 |
| From: | Lewis M AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 8109140179 | |
| Download: ML20140B430 (6) | |
Text
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!arvin I. Lewis h,
6504 Ered ford Terr
7%i 149 F
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.N Aug y bJ 81.
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g Secretaty of the Commission
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':nt.ted states Euclear Regulatay Commissior$
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washington,D.C. 20555
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s This letter is my PETITION TO TNTERVENE IN F$'IJMEMC PERATING LICENSE henrings.xy right to intervene derives from Sec't18 N 9 of the Atomic 2nergy Act.
My interest and standing conform to 10CFM 2.714 (d )(1).
u Tho nature of the petitioner's right under the Act to be mEde a party to the proceeding:.
Throughout the Atomic Energy act, references abound concerning tho health ud safety of the publio.(Chepter 1 Section 3.d) I na a member of the public. I am in the' plume injestion sone '
This has been referred to as the ' ingestion pathway.'(44
. 5FR 350 i
Sootion 350.7 (b)).
It is called the
- ingestion Esposure p5thway in NURro 0654 YEWA REP 1 Rev 1 page 5-3.
My health and safety will not be adequately prei:soted by the operation of the 3,imerick
!!uclear Power Plant.
I chall point out the specific definiencies by which I base my visw of inadequate protedtion in my contentions later in this potition.
Further the ingostion of radionuclides from an e.ccident at Limerick i
is not the only dan 6er which I am subjec*:ed from the operation of
- Liberick, The accident described in Wash 740 Npdnte would ondanger my life where I liu and work.(Breach of Containment cocompanying a core meltdown.)
The nature and extent of the petitioner's property,
l f&nancial and other interest in the proceeding.
The financial interest that I believe most endanCered by operation of the Linerick units is my pension fund. This pension fund is heaviby invested in Ptco, the Licensen. Prco is constantly going back to the Pa Public Utility Co. mission for rate hikes.
An accident.of the msgnitude that occurred,at T5tI,,. occurring at Limerick would bankrupt Esco.
My pension fund would be
, sorely hurt.
I would get a reduced pension. I would be sorely hure. Never turning the plant on would probhbly cost so:no dividends, but would not cost anything near the price that a TstI2 accident at Limerick would cost, hh[kDOC o!Obbb!2 fs G
/I I 1 chall cho+ in my contentions how easity a v.ie
- .acAu m 6 7
jag cycuy nt Li serick. ____ __
2 The possible offoct of any ofdor of any order which may be cntored in the proceeding on the petitioner's inoract.
An order to Ellow operation of the Limerick nuclear gower Plant in the dangerous manner in which it was constructed and designed will affect me greatly. It will endanger my health and safety, it will cause me great worry, and it will endanger me financially.
My other interests in this case arv enumerated below:
A. I live in the greater northeast Philadelphia area. This area dis within the ingestion exposure pathway.
In the event of an accident at Limerick we will be exposed to radionuclidse in the air and water and perhaps food.
I have friends in the Limerick area. Lathe case of a limited evacuation I would be called upon to house and help my friends. This would cause me financial and other burdens for I would not turn my back on my friends in time of need.
B. I often travel in the L merick area to visit friends, acquain i
tances and business associates.
My health and safety should not be sompromised just because I am visiting friends of '
a doing business in the Limerick area.
C. I was a participant at the TMI1 poceedings at the discretion of the Board.
I believe that my participation in these present hearings would aid in the development of an adequate and complete record. My exclusion conversely may well cause the record to be incomplete.
I cwait confirmation of my intervanor status. Please put me on all appropriate milling and NRf lists until such notice.
My telephone number is CU 9 5964.
Please do not actify me by Erpress Mail or mail that I must sign for. I am very rarely home no I have a regular job.
It would take me a week to pick up Express mail from the Post Office in most cases.
First class in fine for ell notifications.
Very truly yours,
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M. l. L EAVIS 6504 BRADFORD TERR' PHILA., PA.19149
L F. OF CG3TUTICNS IN THE CFERATING LIgSSE HEARINGS PCR Limorick.
SU'BMITTED LY ticrvin I. Louio, 6504 Bradford Terraca,Thila.FA 1914 9.
100. The operation of the Limerick Nuclear povar Plant is a threat to the Gational Security and especially the security of the Northeast section of the United States of America.
A recently admitted danger from the atomic weapons program endangers the operation of nuclear pocor plants during peacetime and wartime.
101. The recently admitted danger is the chance of an electromagnetic phlse (EMP) from an accidental explosion of a nuclear device Ar above the United States would cause many systems based on transistor dev.cas to fail.
Much of the safety systems in nuclear power plants function thru the use of transistor devices.
(Ennrgy, Vulnerability and War FEMA Dec B0; Science Mag 29 May 81 Page1009 to 1012, June 81 Page 11161119, 13 Feb 81 P.
683.)
( TheDefense Monitor US Nuclear Weapons Accidents : Danger in our Midst Conter for Defense Information Washington 7D.C Vol X #5) 102'.
The chance for a Goof with a nuclear Weapon is high.(Phila Inquirer July 17, 81 Page SA Navy Goofs.)
The ZXP produced by an tecidental high level nuclear explosion would cause a common modo failure in the Limerfek Nuclear plant for any explosion in the skies of the Northeast United States.
Common mode failure io ax violation of the Single Failure Criteria (100FR 50 GDC Apcudix K,100FR 50,55 m and Ieee sta 279)( Alao see Edson Caso to Commissioners SECY 77 439, aug 17, 19777 103. Because the Limerick Nuclear Power Plant is a
- a. danger to the National Security biUviolatkB^theSinglePailureCriterion(100FR50GDC)
Limorick must not be allowed to operate.
104. A common mode failure -such as can be caused by an EMP-is a danger to the hesih and safety of the public in that enid failure can and will disable many or all engineeded cafety features which depend on transistors in their operation.
Limerick must not be granted an operating license because its operation would endanger 2Xaa the Health and safety of the public,.
105. The EIS and the FE3 for the Limerick Nuclear rower Plant is deficient in that the documents did not investigate the dangern of E4P to the Limerick Nutlear Powerplants. The FES hust be amended and comments' received of the amended version bedore the present proceedings may statt.
114. Bob Scarlos of the nac sta od that et #3 Am in thm morning if an e,orgcncycroce, the plantcporator could telephone the mann6ement before declaring antx evanuation of any other major emergency measure for the public.(Verbal communication Bob Searles (Seares?) NRC to Marvin I. Lewis August 20,1979 at anNRC Licensee meeting at King of Prussia on Emergency Plans. )
115.
The emergency plan is deficient in that the plant operator cuat contact off site management in many instances. This contact cust be made before any major emergency measure is instituted upon the public. This contact is timeconsuming and counterproductive to the safety of the public. This contact of on site personnel with off-ste management must not be accomplished before the en site operator is allowedto declare a site emergancy. The en-site operator must have the authority to declare an on-site and off-site emergency and institute evacuation without contacting off-site management. The delay caused in contacting off-alte canagement in an emergency can endanger the haalth adu safety of th public.
115. The telephone numbers of the off-site management are company ccnfidential and are not in the public emergency plan. This is ena more problem for the plant operator in an emergency. The oporator must be able to find the company confidential numbers of off-sitemanagement that the operator must contact in an cmcrgency.
116. To aid the operator of N Iclear plant find management numbero in an emergency, all off-site utngement telephone numbers chall be includedd in the emeggancy plans open to the public.
Alco all off-site managemett shall have listed telephone numbers that they may be contacted easily in the case of an emergency..
co 117. The monitoring in the area of Limerick is deficient in thct a transporta ton with spent fuel would produce so many conflicting readings near the plant site that the monitoring at the plant site could not be relied upon to protect the health gnd safety of the public.
118. The monitoring in the vicinity of Limerick must be upgraded to protect and warn the public in the case of a transportation accident with_ spent fuel from the Limerick site. This is especially l
important due to the congestion on the major roda in the area and the limited presence of smergency personnel.
119. The monitoring in the riz+d*+t vicinity of Limerick Plant must be upgraded so that in the case of a spent fuel transportation i
l accident in the area the monitoring is still able to discern the radionuc1& des emitted from the plant.
Li
.... m..u musv
15.6.
iha Licorick nuclcar n cotor moy cuffer a major branch of e
ito core due to rrescurized Thormal shock.
Praccurized Dornal I
Shockinaconditionwhichresults{pg3thb'vgggggductionof cold water into a hot, pressurized ramterhumani. (USNRC News delease I 81-108.)
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107. The NRC and its Staff has not investigated Boiling ~~~
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przmaxxinut water reactors for the dangers of pressurized Thermal chock as has been dont oc PwR's. 2kutygghis is a danger that has only been recently looked at for p 's due th an incident at Rancho Seco. The NRC has been recifs in its duty to investigate similar dangers for BeR's of Limerick design.
100. A similar investigation (comparable to the Pressurized thermal check investigations) must be d&ne for Limerick nuclear power plants.
Tho results of theinvestigation must be added to the SER and incorporated in the PES. The PES amendment then must go out for comments according to NEPA requirements and law.
109. The Limerick NuclearPower Plants may not receive an operating liccnde until and unless this new pressurised thermal shock ph nomena is proven not to andanger the health and safety of the public.
l 119.
Cheating has been unearthed at NRC licensing tests. The TMI Licensee petitions for leniency on the basis" Examinations in April consistent with NRC past practices for other licensing examinations. "
111~. The TMI licensee points out the poor testing practises chich are the standard for the ARC. (H. Dieckamp to Pa111dino August 20,1981.)
Poor testing practices of the NRC are no'c cufficient to provide assurance of qualified reactor operat&rs andcenior reactor operaters.
112. The Limerick [uclear Power Blants may not be granted a license until and unless the NRC can prove that the testing of RO's and SRO's is sufficient to assure qualified operators Unqualified operators would endanger the health and safety of the public.
113. There are many questions and inadequacies in the emergency plans for Limerick My contentions will not address the overall inadequacy or inpperability of the Limerick hoclear power plant energency plans. My contentions will address only specific flaws
'in the emergency plans that'make them obviously and xx immediately deficient and unworkable on their face.
1
120. The training of epont fuel truck drivare is such that thic trainic inerennes that danger of spent fuel accidents and thenby increases the danger to the health and safety of the public(iiUREG 0465) 121.
IK1EttM52 I respectfully subhit this list of contentione.
I plan to add further contentions as soon as I have researched thom adequately.
Please infona me of the cut-oof date for sub.iisd6cn of cntentions.
123.
Copy sent to Secretary for the Commission Executive Legal Director Troy B Connnor PICO 122. This petition is being pie.ced in the first dass mail ori 9-3-81.
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