ML18025A722

Letter Submitting to the Board Timely Request for Factual Information from the Applicants, and the Commonwealth of PA as the Interested State

ML18025A722
Person / Time
Site:	Susquehanna
Issue date:	05/22/1979
From:	Lemanowicz I Citizens Against Nuclear Dangers
To:	Bechhoefer C Atomic Safety and Licensing Board Panel
References
Download: ML18025A722 (7)

Text

C1t1zens . inst Nuclear Dangers P.O.Box 377, RD l, Berwick, Pa.

Nay 22, l979 Charles Bechhoe fer, Zsq., Chairman Atomic Safety and Licensing Board Docket Nos. 50-387 U.S. Nuclear Regulatory Commiss1on 5O-y88

'(la sh ington, D.C. 2O555

Dear Chairman Bechhoefer:

Pur suant to the preliminary schedule in Part lI of the Order of the Board, dated March 6, 1979, concerning discovery proceedings, the Citizens Against Nuclear Dangers hereby submit to the Board, and all participants on the service list, timely requests for factual information from the Applicants, and the Commonwealth of Pennsylvania as the interested state.

The attached items, number l thru 18, are directed to the Applicants; the PPL in most instances. The'emaining items, number l9, 2O, 2l, and 22, are d1rected to the Pennsylvania Bureau of Radiological Health, Department of Env 1 ronmenta 1 Resources.

Several of the requests are for catalogued data, some of which is probably available from computerized, retrival systems. Such detailed listings will aid the 'Citizens in determining 1f one or more of the

'isted documents in each category w111 be requisitioned as evidence, which in turn should assist the Board 1n arriving at proper decisions in th 1 s lie en sing ca se.

The Citizens submit that this preliminary backgr ound information is relevant to one or, the other of the admitted contentions, and necessary for the preparation of exhibits and testimony.

Yours truly

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Irene Lemanowicz, Chairperson Citizens A ga inst Nuclea r Danger s

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1

1. Provide the 'scientif1c results and the economic feasibility reports of PPB;L' experimental pilot pro]ect to produce j lectricity from solar powei generated by wind m1lls installed near Hazleton, Pa.

2. Send PP&L' Anthracite-fired plant feasibil1ty study, completed by the consulting firm of Skelly 8: Loy, Harrisburg, Pa.

Also, provide detailed reports of all other past and present experiments, conducted or financed by the Appl1cants, independently or as a )oint-venture, to gener ate electricity 'using energy sources other than atomic fission (include atomic fussion). Ve are especially interested Xn those ventures funded in part by the Federal government.

4. 'he Applicants a re requested to provide all documentation pertaining to the1r participation in any and all government sponsored energy conservation programs, such as the National Residential Energy Conservation Program and the Governor' Energy Council programs; as well as any industry sponsored, energy conservation programs.

5. 'le will need from PPBcL summarized financial reports outlining their methods of raising cap1tal to construct the Berwick plant which identifies the lending institutions and bond. brokers, etc.

6. Also, send financial iziformation on any turnkey type agreements concerning Berwick, between the Applicants and any vendor or contrpctor, such as the General Electric Credit Corporation, the Bailey Meter Company, or the Bechtel Corporation.

70 Forward a copy of the Annual Reports of the Allegheny Electric Cooperative, Inc. and the PPBL for the past ten years; and copies of the monthly.PP&L R~eorter from 1972 to the present.

8. We request an index of the Applicants'olicies that provide all types of commercial and governmental insurance coverage, including

.risk and self-insurance, on all aspects of the Berwick power plant properties and personnel, and its uranium fuel cycle.

9. Provide cOpies of Court Docket title pages for all'Federal and state court law suits, past and present, civil or criminal, in which the Applicants were, or are, a plaint,3 ff or a defendant involving litigation in all matters involving the Berwick atomic plant, including the supply of uranium, transmission line right-of-ways, anti-trust, accidents, and alledged defective manufacture or installation of plant components.

10. Furnish a ~catalo ue of all App1icant documentation, correspondence, etc., on all I aspects of the Berwick atomic power. plant sent to, or received from: the Pennsylvania Public Utility Commission, the Federal Power Commission, the Susquehanna River Basin Commission, the U.S. Army Corps of Engineers, the U.S. Securities 8:Exchange Commission, and the U,",S. Department of Energy. =

Il.. Id ~tl I'l p I I. t, t - pl communications, reports, ennouncemcnts, press releases, and all other records on file of public meetings, hearings, conferences, and sess1ons of any kind involving the Applicants and public officials, whether elected,

'. appointed, or civil service, at all levels of government,:.citing date,:

location, sponsorship and/or public involvement, that has in any way dealt with 'the Berwick atomic power plant.

12. Furnish summaries of the types of records cited above that deal specifically with sessions between representatives of the t PPBL and the Board of Supervisors of Salem Township, Luzerne County, Pennsylvania, during the past ten years.

l3. Forward copies of annual reports and scientific environmental studies and tests conducted to date for the Applicants in con Junction with the Berwick pro3ect s1te dealing with milk, air and water quality, aquatic and wildlife, etc., by the Ichthyological Associates Inc.,

Ithaca, N.Y. and: by Radiation management Corp. of Philadelphia, Pa.

l4. Send information describing the ongoing experimental pro)ect to study aquaculture in the warm-water outflow of power plants along .the

'I Susquehanna River. Ve are referring to the two year pro)ect which. is a Joint venture of PP8L, Kraft Inc., and the Franklin Institute.

include a copy of the contractual papers.

l5. Provide mining maps (small scale) w1th explanatory data, iDentifying exact .locations and boundry lines of the land sites that uranium exploration and/or mining {or option to mine) by all technologies, which has commenced or will be undertaken by the Applicant,s, their subs1diaries, agents, or as a point venture, in connection with the Applicants stated plans to become partially self-sufficent in the extraction and production of uranium for the Berwick atomic po~er plant.

'rle are referring to (but not limiting our request to) such agreements as the HemirrÃest Properties drilling and explorat1on program for some 400 contiguous mining claims covering about 8,000 acres of land in San Juan County, Utah.

l6. Furnish a transmission line (230,000 to 500,000volt) right-of-way listing, associated w1th the Berwick station, identifying the name and address of each Grantor { seller or lessor ) with a property line map (approximately 1" 100'cale) pinpointing the location of each tract.

Also list the Index-to-Deed Book number and. page number for each

Grantor-Grantee transaction document and/or Affidavit of Value for .

eminent domain cases, on file at 'the office of the Recorder of Deeds in the several Pennsylvania counties involved, namely: Susquehanna, Lackawanna, Lu ze me, Columbia, Yontour, Ão rthumbe rland, Snyde r, Ca rbon, Korthampton, Schuylkill and Lehigh. This informat,ion should be readily available at the Applicants'eneral Of fice, Right-of-b'ay Section s.

17. Forward a catalogue on the Applicant's participat,ion in research programs co-sponsored with the Electric Power Research Institute.

Also send summary reports of PAL's participation in research by High Voltage Power Corp. on extra-high voltage underground transmission.

18. Furnish a complete record of the manufacture of the atomic reactor pressure vessels purchased by the PP+L for Units l and 2 at Berwick.

Documentation should trace the pressure vessels from their present location all the way back to the foundries ~here they were forged, several years ago. Include a description of all welding modifications performed on the pressure vessels at all stages of the production process.

Document exactly the plant sites where the pressure vessels were welded and fabricated. Include concise pressure vessel weld inspection reports.

Ve also need to know the manufacturing role of pressure vessel work that may have been performed at the B. 4 N.Mount Vernon, indiana plant; xbe Chicago Bridge 4 Iron IIemphis, Tenn. plant; and, the Combustion Engineering Chat'tanooga, Tenn. plant; among other facilities.

19. Provide a catalogue containing a complete listing of the documents, reports and correspondence, etc., in the files of the Bureau of Radiological Health, Department of Environmental Resources (DER),

Commonwealth of Pennsylvan1a, on the subJect of PAL's Berwick atomic J

power plant.

I

20. >le also wish to obtain from. the Bureau of Radiological Health complete official documentation, including f1eld monitoring reports and m11k sampling results, on the affects of the radiation fallout in October, 1976 resulting from the Chinese bomb test of September 26, 1976.

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21. A1eo needed from tbe Bureau will be a curr ent cata~le ue of all relevant data compiled by the Bureau concerning radiation monitoring and milk sampling already conducted, plus on-go1ng survey results when they become available, dealing with the radiatian releases in the vicinity of the Three-iIile-Island plant since the I~arch 28,1979 accident.

22. From the appropriate office of the DER we also wish to obtain

. the public records pertain1ng to the Applicants permit application to d1scharge industrial wastes into the Susquehanna River from the Ber wick atomic power plant.

CITIZENS AGAINST NUCLEAR DANGERS R.D.¹1 BOX 377 BERWICK, PA. 18603 MAY 31, 1979 MRe CoR ~ STEPHENS'HIEF DOCKETING AND SERVICE, SECTION OFFICE OF THE SECRETARY 0

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~qQ U.S. NUCLEAR REGULATORY COMMISSION 3

tttASHINGTON, D.C.'0555 qyt~ gent RE; YOUR TELEPHONE REQUEST OF May 31, 1979 MR. STEPHENS:

I HEREBY CERTI FY THAT COPI ES 'F OUR LETTER DATED MAY 22 ~ 1979 ~

AND ATTACHED FIRST ROUND DISCOVERY REQUESTS (NUMBERED) HAVE BEEN SERVED ON ALL PARTIES (SERVICE LIST) .

SINCERELY, IRENE LEMANOWI(Z, CHAIRPERSON-C.A.N.D.