ML17340B128
| 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
0
~~/gp UNITED STAT S
OF AMERICA NUCLEAR REGULATORY COMMISSION r
,@gO pO""'O ps'l fate I
iso< ~
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
Docket Nos.
50-250-S
)
50-251-SP FLORIDA POWER 6 LIGHT COMPANY
)
(Proposed Amendments,.to
)
Facility Operating L"'
to Permit Steam G
rQtor--'
Repair) zP~,.
@c,t, /]l5 INTERVENOR'S AMENDMENT TO CONTENTION 1
>~s,
~~8j~
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 Xn the Matter of (Turkey Point Nuclear Generating Units Nos.
3 and 4) 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.
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
- 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
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 DATED THIS THE M DAY OF APRIL, 1%HI..
By Nei C onion
4l
~I AM
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 FLORIDA POWER 6 LIGHT COMPANY (Turkey Point Nuclear Generating Units Nos.
3 and 4)
)
)
)
)
)
)
Docket Nos.
50-250-SP 50-251-SP (Proposed Amendments to Facility Operating Licenses to Permit Steam Generator 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 ~day of April, 1981, to the following addressees:
Marshall E. Miller, Esq. Administrative Judge
- Chairman, Atomic Safety and Licensing Board Panel U.S.. Nuclear Pegulatory Commission Washington, D.
C.
20555 Dr. Emmeth A. Luebke, Administrative Judge 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 8
Vwg Q
J Q>s'wn
< ~ ~Ile
Ql OJ
Atomic Safety and Licensing, Board Panel U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Docketing and Office of the U.
S. Nuclear Washington, D.
Service Section Secretary Regulatory Commission 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