ML17340B128

Amended Contention 1 Re Adequacy of Eis.Certificate of Svc Encl

ML17340B128
Person / Time
Site:	Turkey Point
Issue date:	04/20/1981
From:	Chonin N CHONIN, N.
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8104300482
Download: ML17340B128 (10)

Text

r 0 ~~/gp pO""'O,@gO ps'l UNITED STAT S OF AMERICA fate I NUCLEAR REGULATORY COMMISSION iso< ~

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Xn the Matter of ) Docket Nos. 50-250-S

) 50-251-SP FLORIDA POWER 6 LIGHT COMPANY ) (Proposed Amendments,.to

) Facility Operating L"'

(Turkey Point Nuclear Generating to Permit Steam G rQtor--'

Units Nos. 3 and 4) Repair) zP~,.

@c,t, /]l5 INTERVENOR'S AMENDMENT TO CONTENTION 1 >~s, ~~8 j~

COMES NOW the Intervenor and Amends his Contention , follows;~'

"I

1. The Elg failed to follow section 1501.7 of the NEPA i'e'gust s

lations in that the Staff failed to invite interested persons to participate in a scoping process in which the scope of the EIS was to be decided.

2. No record of decision was prepared for the Turkey Point Project in violation of 40 CFR 150'5.2.

3. The EIS is not,a programatic EIS and a programatic EIS is required as a result of the steam generator repairs that would .be required national'ly.

4. The final EIS fails to 'comply with NEPA in that the EIS does not address (to the fullest extent possible) all environmental effects of proposed actions as well as all irreversible and irre-trievable resources.

5. The EIS fails to look at the socio-economic effects upon Florida Power and Light rate payers. Such effects must be examined fully within the EIS because the project entails direct significant

~ ~

Ql II a.'

-J

'to 4

16. The final EIS fails to adequately discuss the environmental impact of a hurricane if one occurs during the repair process.

17,. The final EIS fails to consider the long term effects of a nuclear waste building next to biscayne bay.

LAW OFFICES OF NEIL CHONIN, P.A.

Attorneys for Intervenor Suite 1400 Amerifirst Bldg.

One S. E. 3rd Avenue Miami, Florida 33131 Phone: 377-3023 By Nei C onion DATED THIS THE M DAY OF APRIL, 1%HI..

AM 4l ~I

environmental effects which are intertwined with~ the socio-economic effects.

6. The EIS contains no glossary or table of definitions and consistently uses terminology beyond the ken of lay people.

7. The estimates of worker exposure provided for in the final EIS are unreasonably low.

8. The analysis of deaths and health effects likely to.result from the action is invalid because it is based on outmoded scientific information.

9. The economic analysis in the EIS is invalid in that't fails to consider the possibility that replacement or repair of the steam generators may be necessary a second time.

10. The entire EIS fails to comply with a,good faith consideration as is required under NEPA.

ll. The analysis of alternatives is inadequate under NEPA.

12. The final EIS as a whole fails to adequately address the impact of the steam generator repair on the human invironment because it tends to explore the positive effects that the repair will have while down-playing the .negative impact.

13. The EIS fails to adequately discuss the alternatives to the proposed action.

14. The EIS fails to adequately discuss the relationship between local short term use of man's environment and maintenance and enhance-ment of the long term productivity.

15. TheEIS fails to discuss the irreversible and irretrievable commitment of resources involved in the proposed action.

4> II ~~a UNITED STATES OF AMERICA NUCLEAR REGULATORY C019fISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250-SP

) 50-251-SP FLORIDA POWER 6 LIGHT COMPANY ) (Proposed Amendments to

) Facility Operating Licenses (Turkey Point Nuclear Generating ) to Permit Steam Generator Units Nos. 3 and 4) ) Repair)

CERTXFXCATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing, Xntervenors Amendment to Contention 1, was mailed by 'United States regular mail on this the addressees:

~day of April, 1981, to the following Marshall E. Miller, Esq. Administrative Judge Chairman, Atomic Safety and Licensing Board Panel U.S.. Nuclear Pegulatory Commission Washington, D. C. 20555 Vwg Dr. Emmeth A. Luebke, Administrative Judge 8 Q>s'wn Q

< I le

~ ~

J Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washy'ngton,. D. C. 20555 Dr. Oscar H. Paris, Adminstrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Mark P. Oncavage 12200 S. W. 110th Avenue

'Miami;, Florida 33176 Harold F. Reis, Esq.

Steven P. Frantz, Esq.

Lowenstein, Newman, Peis 6 Axelrad 1025 Connecticut Avenue, N.W.

Washington, D. C. 20036 Steven C. Goldberg, 'Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Ql OJ Atomic Safety and Licensing, Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Burt Saunders, Esq.

Assistant Dade County Attorney 1626 Dade County Courthouse Miami, FLorida 33130 Henry H. Harnage, Esq.

Peninsula Federal Building 10th Floor 200 S. E. 1st Street Miami, Florida 33131 Norman. A. Coll, Esq.

STEEL, HECTOR 6 DAVIS Co-Counsel for Licensee 1400 S. E. 1st National Bank Bldg.

Miami, Florida 33131 LAW OFFICES'F NEIL CHONIN, P.A.

Suite 1400 Amerifirst Bldg.

One S. E. 3rd Avenue Miami, Florida'3131 Telephone: 377-3023 j ~

r By Nei Chonin

4>'Oi wH-. ~

l