ML18026A310
| ML18026A310 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/10/1980 |
| From: | Johnsrud J Environmental Coalition on Nuclear Power |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8010210515 | |
| Download: ML18026A310 (25) | |
Text
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ENYIRONMENTALCOALITIONON NUCLEAR POWER Co.Directora:
Mr. George Boomtma-R.D. <<1, Peach Bottom, Pa. 17563 717.548.2836 Dr. Judith Johntrud-433 Orlando Avenue, State College, Pa. 16801 814-2374900 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of PENNSYLVANIA POMER and ALLEGHENY ELECTRI C (Susquehanna Steam
'Units 1
and 2) c Docket Nos. 50-387 50-3BBS l
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AND LIGHT COMPANY I
COOPERATI VE, INC.
Electric'tation, I
DOCIaETQD uBNpc ocT p atg Officet~ of the S~re IZ
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8 E;:6-n I GI ECNP INTERVENORS'ESPONSE TO APPLICANT'S MOTION TO RESUME DISCOVERY'ON SAFETY ISSUES
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The Applicant has asked the Board to resuscitate the discovery process an safety issues in the above-captioned proceeding and to order intervenors to complete responses to interrogatories within one month.
ECNP urges the I icensing Board to deny the Applicant's request, as being untimely and con-trary to the Board's prior order of October 30, 1979.
The basis of the discovery discords.that have marred this proceeding lies in the large numbers of Applicant's interrogatories which have been required to be answered within an unreasonably indeed, impossibly--
short time period by the citizen intervenors who have been denied funding and other procedural assistance and access to virtually all documents sought by intervenors on discovery.
The Board has already ruled on the matte now at hand.
On October 30, 1979, this Board postponed discovery on health and safety issues until the end of the environmental phase of the proceeding (LBP-79-31, 10 NRC 597; also noted in ALAB-613).
Although ECNP has continued and now continues to object to the burdensome and unreasonable and unnecessary total number of interrogatories imposed, it was in part this postponem nt of a portion of the excessive burden that ultimately enabled ECNP to fulfillthe Board's order to respond to the interrogatories on environmental issues.2 The environmental hearings have 'not yet even been scheduled, much less completed, and hence the environmental'hase is far from ended.
Furthermore, Intervenors learned of this motion via newspaper headline, Harrisburg Patriot.
2 See note on p. 2.
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~C@ 4 gQ s$ "ia in the aftermath of the still-ongoing Three. Mile Island, Unit 2, acct<
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March 28, 1979, additional time should be allotted to all intervenors <<
the end of the environmental phase to review the status of safety conteng~
and to submit new and revised contentions based at that time upon the stat<~
of the Applicant's compliance with the TMI Lessons Learned and short-and long-term actions to enhance reactor safety; ECNP suggests to the Board that, following the completion of the environmental phase an appropriate period of time be set aside prior to the resumption of safety-related discovery for all intervenors to review Applicant's compliance with the NRC Action Plan Develo ed as a Result of the TMI-2 Accident (NUREG-0660);
the Letter to All Licensees of 0 eratin Plants and A
licants for 0 eratin Licenses and Holders of Construction
- Permits, Dated September 5, 1980, from D.G. Eisenhut, Office of Nuclear Reactor Regulation; and with directives relating to Anticipated Transients without Scram (ATMS), interactions between control rod drive systems and non-essential control air systems, and varied and numerous other safety issues pertaining to Boiling Mater Reactors which may have arisen or been exacerbated by reactor operating experiences by that uncertain future tine.
It will be well over two years, at the minimum.
before the environmental phase has been cenpleted from the time of the original filing of safety contentions in this proceeding, two years filled with events that the NRC had been confident in that innocent year of 1978 would never take place.
In addition, the ECNP intervenors are, as the Comnission well knows, presently engaged in assisting the Comnission to do the job it failed to do in the licensing of TMI in several other TMI-related administrative proceedings.
The TMI-1 Restart hearings have just begun and are expected to continue in evidentiary session for some six months.
For these several
- reasons, the Applicant's motion should be denied.
ECNP requests the Board, instead, to order a safety review as outlined above at the conclusion of the environmental phase and prior to resumption of dis-covery on safety issues.
Respectful ly submitted, Dated this I/<
day of October, 1980 Judith H. Johnsrud, Co-Director 2
ECNP notes that ALAB"613 at P.
17 n.
15, states that the Board's action has "left the Coalition obligated to make discovery on only five contentions-"
V C,
CERTIFICATE OF SERVICE I certify that copies of ECNP INTERVENORS'S
RESPONSE
TO APPLICANT'S MOTION TO RESUME DISCOVERY ON SAFETY ISSUES are being deposited in the U.S. Nail, first class, postage paid, this ~l.@
day of October, 1980, to all parties in this proceeding.
',.Ac~F /y /-8'~D Judith H. Johnsrud Charles Bechhoefer, Esq.
- Chairman, ASLB Panel US Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn 0. Bright ASLB Panel USNuclear Regulatory Coomiss,ton Washington, DC 20555 Dr. Oscar H. Pari s ASLB Panel US Nuclear Regulatory Comnission Washington, DC 20555 "Atomic Safety and Licensing Board Panel US Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Board Panel US Nuclear Regulatory Comoission Washington, DC 20555 Jam s
M. Cutchin V, Esq.
Office of the Executive Legal Di rector US Nuclear Regulatory Comnission Washsington, DC 20555 Docketing and Service Section Office of the Secretary US Nuclear Regulatory Comnission Washington, DC. 20555 Gerald Schultz, Esq.
Susquehanna Envrionmental Advocates 500 South River Street Wilkes-Barre, Pa.
18702 Mrs. Irene Lemanowicz Citizens Against Nuclear Dangers C/0 Mr. Thomas Halligan PO Box 5
- Scranton, Pa.
Mrs. Colleen Marsh 558A RD4 Mountain Top, Pa.
18707 Mr. Thomas M. Gerusky Bureau of Radiation Protection'epartment of Environmental Resources Comnonwealth of Pennsylvania PO Box 2063 Harrisburg, Pa.
17120 Jay Silberg, Esq.
Shaw, Potts,
- Pittman, and Trowbridge 1800 M St.
NW Washington, DC 20036 sA t ~ ~
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Samual Chilk, Secre tary U.S. Nuclear Regulatory Commission Nashington,D.C.,
20555 Nr, Chilk, T. am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when I will be able to speak.
Thank You, p
Samual Chi1k, Secre tary U.S. Nuclear Regulatory Commission Nashington,D.C
~, 20555 Nr. Chilk, I am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when l will be able to speak.
Thank You,
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20555 Nr, Chilk, I am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when I will be a'ole to speak.
Thank You,
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Samual Chz.lk, Secretary U.S. Nuclear Regula.atory Commission Nashington,D,C.,
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Please inform me when and where these hearings will take place, and when l will be able to speak.
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Samual Chilk, Secretary U.S. Nuclear Regulatory Commission Washington,D.C.,
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Nr, Chilk, I am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when l: will be able to speak.
Thank You,
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Samual Chi1k, Secre tary.
U.S. Nuclear Regulatory Commission Nashington,D.C.,
20555 Nr. Chilk, I am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when 1 will be a'ole to speak, Thank You,
Samual Chilk, Secretary U.S, Nuclear Regulatory Commission Nashington,D.C.,
205/5 Nr, Chilk, 1
am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these Thank ou,
Samual Chilk, Secre tary U.S. Nuclear Regulatory Commission Washington,D.C.,
20555 Nr. Chilk, I am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when I will be able to speak.
Thank You,
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Samual Chilk, Secre tary U.S. Nuclear Regulatory Commission Washington,D.C.,
20555 Nr. Chilk, I am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when I will be able to speak.
Thank You, asF~
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Samual Chilk, Secre tary U.S. Nuclear Regulatory Commission Nashington,D.C.,
20555 Nr, Chilk, I am writing to request time to make a Limited Appearance Statement at the licensing hearing's for Pennsylvania Power and Light's Nuclear Plant in Berwick, Pennsylvania.
Please inform me when and where these hearings will take place, and when I will be able to speak, Thank You, P.8
UNITED STATES OF A~KRICA iiUCLEAR R" GP ATORY COD>'ISS ION In the <!atter o
PENNSYLVANIA POWER AND LIGHT COMPANY (Susquehanna Steam Electric Station, Units 1 and 2)
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Docket No. (s) 50-387 50-388 CERTI:- ICATE OP SERVICE I hereby certify that I have this day served the foregoing document(s)
W upon each person designated on the of=icial serv'ce list compiled by tne Ozfice of the Secretary of the Co~ission in this proceeding in accordance with t'ne requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the Nuclear Regulatory Commission's Rules and Regulations.
Dated at Washington, D.C. this day of JCZ Officd oft'the Secretary of the C -.;..ission
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UNITED STATES OP Ar1ERICA NUCLEAR REGULATORY COi EMISSION In the Matter of PENNSYLVANIA POWER AND LIGHT CO%'AhY, ET AL.
(Susquehanna Steam Electric Station, Units 1 and 2)
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Docket No. (s) 50 387 50-388 SERVICE LIST Charles Bechhoefer, Esq.,
Chairman Atomic Safety and Licensing. Board U.S. Nuclear Regulatory Commission Li'ashington, D.C.
20555 Dr. Judith H. Johnsrud Co. Director, Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S.Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Counsel for NRC Staff Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Jay E. Silberg, Esq.
Shaw, Pittman, Potts
& Trowbridge 1800 "M". Street, N.U.
ilashington, D.C.
20036 Pennsylvania Power and Light Company ATTN:
Mr. Nor;an 4'. Curtis Vice President Engineering and Construction 2 North Ninth Street Allentown, Pennsylvania 18101 Ms. Colleen Marsh 558A R.D.
A/4 Mount Top, Pennsylvania 18707 Mr.
Thomas J. Halligan Correspondent CAND P.O.
Bo..
5 Sacranton, Pennsylvania 18501 Gerald Schultz, Esq.
Susquehanna Environmental Advocates 174 Machell Avenue Dallas, Pennsylvania 18612 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania P.O.
Box 2063 Harrisburg, Pennsylvania 17120 Albert E. Vogel, Jr.,
Esq.
Assistant Attorney General Dept. of Environmental Resources P.O.
Box 2357 Harrisburg, Pennsylvania 17120
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.Samuel Chilk, Secretary Docketing 8 Service Branch U.
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Nuclear Regulatory Commission Washington DC 20555 t
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Dear Nr.
Chi 1 k:
I am writing to request time to make a Lim'ited Appearance Statement at the licensing hearings for Pennsylvania Power and Light's Susquehanna Steam Electric Stations 1
and 2
now under construction in Berwick, Pennsylvania (Docket numbers:
50-387 and 50-388).
Please inform me when and where these hearings will take place and when 1 will be able to speak.
I also would like to request that time be made available in the evenings andlor on weekends for these statements to insure greater public input.
k Thank you.
I look forward to hearing from you soon.
Sincerely yours,
~(~llANs M. NUERTH 4 40 E.
North St, Bethlehem, Pa )Spl8 Acknowi9cfSed by@eh..i...(Y.......~
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO?'MISSION In the Matter of PENNSYLVANIA POWER AND LIGHT COMPANY (Susquehanna Steam Electric Station, Units 1 and 2)
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Docket No. (s) 50-387 50-388 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document(s) upon each person designated on the official service list compiled by
~
the Office of the Secretary of the Commission in this proceeding in accordance with the requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the Nuclear Regulatory Commission's Rules and Regulations.
Dated at Washington, D.C. this day of i
Vj Egg/7M 0 fice "o e Secretary of the Co
'ssion
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UNITED STATES OP AtSRICA NUCLEAR REGULATORY COMMISSION ln the Matter of PENNSYLVANIA POWER AND LIGHT COMPANY, ET AL.
(Susquehanna Steam Electric Station, Units 1 and 2)
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Docket No.(s) 50 387 50-388 SERVICE LIST Charles Bechhoefer,'sq.,
Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Judith H. Johnsrud Co. Director, Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Glenn 0. Bright Atomic Safety and Licensing Board U.S.Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Oscar P. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Vashington, D.C.
20555 Counsel for NRC Staff Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Vashington, D.C.
20555 Jay E. Silberg, Esq.
Shaw, Pittman, Potts
& Trowbridge 1800 "MY Street, N.W.
Vashington, D.C.
20036 Pennsylvania Power and Light Company ATTN:
Mr. Norman 5'. Curtis Vice President Engineering and Construction 2 North Ninth Street Allentown, Pennsylvania 18101 Ms. Colleen Marsh 558A
'R.D.
f/4 Mount Top, Pennsylvania 18707 Mr.
Thomas J. Halligan Correspondent CAND PE Oe Box 5
Sacranton, Pennsylvania 18501 Gerald Schultz, Esq.
Susquehanna Environmental Advocates 174 Machell Avenue
- Dallas, Pennsylvania 18612 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania P.O.
Box 2063 Harrisburg, Pennsylvania 17120 Albert E. Vogel, Jr.,
Esq.
Assistant Attorney General Dept. of Environmental Resources P.O.
Box 2357 Harrisburg, Pennsylvania 17120