ML18030A413

Statement of Matl Facts Re Absence of Issue to Be Heard,In Support of Motion for Partial Summary Disposition of Contention 2 on Health Effects of Discharged Chlorine

ML18030A413
Person / Time
Site:	Susquehanna
Issue date:	11/06/1980
From:	Silberg J, Traviesodiaz ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML18030A019	List: ML18030A018 ML18030A164 ML18030A413 ML18030A473
References
NUDOCS 8011130350
Download: ML18030A413 (3)

Text

vember 6, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING, BOARD In the Matter of )

)

PENNSYLVANIA POWER LIGHT COMPAIPZ ) Docket Nos. 50-387 and ) 50-388 ALLEGHENY ELECTRIC COOPERATIVE INC. )

)

(Susquehanna Steam Electric Station, )

Units 1 and 2) )

APPLICANTS 'TATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CONTENTION 2 CHLORINE)

Pursuant to 10 CFR 52.749(a), Applicants state, in support

of their Motion for Summary Disposition of Contention 2 (Chlorine) in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:

1. The purpose for chlorinating the various water systems in the Susquehanna facility is to arrest the cumulative growth of slime-forming biolife on equipment surfaces and to disinfect the potable water supply and the sewage effluent. Affidavit of James Rios in Support of Summary Disposition of Contention 2 (Chlorine) ("Rois Affidavit"), para. 3.

2. The concern of Citizens Against Nuclear Dangers, the intervenor sponsoring Contention 2 (Chlorine), is that, "billions of gallons of mine acid drainage" and spills of "highly toxic chemical wastes" will flow into the Susquehanna River and "in turn necessitate massive increases in the use of chlorine at the

Applicants atomic power plant." Citizens Against Nuclear Dangers Motions and Replies to Interrogatories Concerning Contentions Nos. 2, 16 G 17", dated April 29, 1980.

3. The presence of mine acid drainage and spills of toxic chemical wastes which may be in the Susquehanna River does not result in any significant increase in the rate at which slime-forming biolife grows on equipment surfaces. Rios Affidavit, para 3 gal%

4. The presence of mine aciddrainage and spills of toxic chemical wastes which may be present in the Susquehanna River water does not change the amounts of chlorine required to dis-infect the potable water supply and sewage effluent. Rios f

'Affidavit, para. 3.

5. The presence of mine acid drainage and spills of toxic chemical wastes does not increase the amount of chlorine which will be used in the Susquehanna facility. Rios Affidavit, para.

3.

Respectfully submitted, SHAN, PITTMAN, POTTS 6 TROWBRIDGE Ja ' . SP.lberg Ma Pf. Travieso-Diaz Counsel for Applicants, 1800 M Street, N. W.

Washington, D. C. 20036 (202) 331-4100 Dated: November 6, 1980