ML18230B143
| ML18230B143 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/01/1974 |
| From: | Howell W Carolina Power & Light Co |
| To: | Barth C US Atomic Energy Commission (AEC) |
| References | |
| Download: ML18230B143 (9) | |
Text
UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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CAROLINA POWER
& LIGHT COMPANY
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(Shearon Harris Nuclear Power Plant,)
Units 1, 2, 3 and 4)
Docket Nos.
50-400 50-401 50-402 50-403 S TIPULATION The parties to the-.above proceeding, through their respective attorneys, hereby stipulate and agree to the following matters pertaining to the hearing scheduled for October 8, 1974, in'he above entitled cause:
1.
The following documents, copies of which have previously been served on all parties and the Licensing Board, shall be received in evidence without further identification:
(A) Revised Final Environmental Statement Shearon Harris Nuclear Power Plant Units 1, 2, 3 and 4
March 1974 (B) Safety Evaluation Shearon Harris Nuclear Power. Plant Units 1, 2, 3 and 4
December 22, 1972, including Supplement No. 1:
April 27, 1973 Supplement No. 2:
May 6, 1974 (C) License Application Preliminary Safety Analysis Report and Environmental Report, Shearon Harris Nuclear Power Plant, Units 1, 2, 3 and 4, submitted by Carolina Power Light Company to AEC on September 7, 1971, and Amendments 1,
thxough 39 dated August 5, 1974.
k (D)'Letter from E.
C. Hubbard, Director, Office of Water and Air Resources, North Carolina Department of Natural and Economic Resources, to J.
A. Jones, Carolina Power 6 Light Company, dated,Hay 2, 1974.
2.
Although the contentions in this proceeding at the present date include issues of Applicant.'.s financial qualifications to construct the facilities, the need for power and impacts of energy co related matters'.
The Applicant and the Regulatory Staff wi evidence at the hearing commencing on October 8, 1974, on n conservation of energy, the financialability of the Applic servation and 1 not introduce ed for power, nt to design and construct the nuclear power plant, the recently discovered geological P
fault and compliance with the ECCS acceptance criteria.
Evidence upon these matters willbe offered at a later time at a hearing session to be set by the Licensing Board't that hearing, evidence regarding Intervenor's Contentions No. 17, 18 and 19, which relate to need for power, conservation of energy and the Applicant's financial capacity will be entertained.
The hearing of October 8, 1974, will deal with evidentiary materials presented on the following contentions previously allowed in this proceeding:
C.l. (a)
The.monitoring and surveillance program proposed by
. the Applicant is not adequate to assess fully the radiological consequences of the proposed plant and to take proper remedial action to protect the health and safety of the public.
The surveillance program is deficient in that (1) there are too few monitoring
- sites, (2) the frequency of monitoring at these sites is too small, (3) the preoperational monitoring will not have been conducted for a sufficient period of time to establish and verify operational data, and (4) the monitoring proposed willnot determine the concentrations and biological magnification of radioactivity of all affected plant and animal life in the food chain in the vicinity of the proposed plant.
(b) The proposed monitoring system is inadequate in that provisions are not made for continuous and widespread monitoring sufficient to give the location, intensity, and flow of accidental radioactive emissions into the atmosphere or into the water system and to provide for adequate warning plans to the residents affected outside the immediate area of the proposed plant site.
(d) The proposal for construct;ion of the Shearon Harris Nuclear Power Plant, Units 1, 2, 3 and 4 is deficient in that it fails to prevent the entraining of fish and other aquatic organisms into the plant's cooling system from the reservoir either by proper screening of the coolant intake and/or reduced intake flows.
C.4.
Construction and operation of a nuclear facility at the proposed Shearon Harris site is unsuitable because of insufficient consideration of the prevailing wind direction in the area of the site.
C.14 with a high wind speed in the direction of Raleigh, it is impossible'o provide adequate emergency plans in the event of a design basis accident.
C.6.
The Applicant has not demonstrated that the water supply for the proposed facility willbe adequate, nor that adjoining streams willnot be adversely affected by the impounded waters which are proposed.
Specifically:
(a)
The Cape Fear River will not be able to provide enough
'supplemental cooling water in drought periods to adequately compensate for the net consumptive water loss produced by the operation of the proposed facility and still retain sufficient flow to support dependent aquatic and terrestrial animals and plants in the Cape Fear ecosystem.
(b) Due to recent settlement in the case of Conservation.
Council of North Carolina v. Froehlke, it is unknown at this time whether the B. Everett Jordan Dam (New Hope Reservoir) will be permanently operated as a wet or as a dry dam.
Should the Jordan Dam be operated as a wet dam, future impounding of water within the dam will significantly reduce water flow on the Cape Fear River and thus imperil the proposed plant's ability to provide adequate cooling water for operation, lessen the avail-ability of water to support'existing plant and animal life in the Cape Fear River ecosystem below the plant
- location, and increase the proposed temperature in the proposed make-up pond.
(c) Should the Jordan Dam be operated as a dry dam, the flow of the Cape Fear River will frequently drop below 50 c.f.s.
at exactly those times when the demand for water from the river to maintain the level of the make-up pond will be greatest.
At such times the plant will only be able to continue operating at enormous cost to the residents of the entire Cape Fear River VaXley.
(d) Since February 4, 1974, the date of the judgment in Conservation Council of North Carolina v. Froehlke, neither the Applicant nor the Staff has published or even undertaken, to the knowledge of Inteivenors, any studies as to the affects of that judgment on the construction and operation of the Harris plant.
Such a study, is imperative before a decision as to the adequacy of the water supply to the plant may intelli-gently be made.
C.8.
The Applicant's estimates of future levels of population within the 50-mile radius and especially within the 20-to 30-mile radius of the proposed site fails to consider a realistic growth rate for the area.
C.14 modifies C.4.
The foregoing contentions can be grouped by category as follows:
1.
Adequacy of Applicant's Radiological Monitoring Program 2.
Suitability of Site
)feteorological Conditions Population Conditions 3.
Sufficiency of Water Resources for Operation of Facilities 4.
Biological Impacts of Operation 3.
The parties have indicated below the names of persons that may be called as witnesses at the hearing.
A.
The Applicant willpresent witnesses to address the contentions as follows:
1.
Adequacy of Applicant's Radiological Monitoring Program Hr. B. H. Webster, Principal Engineer Radiation Control
2.
Suitability of Site - Meteorological Conditions Mr. B. H. Webster, Principal Engineer Radiation Control Population Densities Miss Carolyn W.'Anderson, Junior Scientist-Environmental Assessment 3'ufficiency of Water Resources for Operation of Facilities Hr. J.
H. Sell, Manager, Environmental Engineering 4.
Biological Impacts of Operation Mr. J.
M. Sell, Hanager, Environmental'ngineering The Applicant will also present. the following witnesses to respond to questions previously propounded by the Board:
Mr. R. J.
Stone
'enior Scientist-Siting Mr. T. H. Wyllie Site Manager, Power Plant Construction-Shearon Harris Nuclear Power Plant Construction Site Mr. M. G. Zaalouk Project Engineer, Nuclear-Nuclear Plant Engineering I Mr. N. B.'Bessac Manager, Nuclear Generation In addition to the above named individuals Applicant will have II available additional persons as required to provide complete information
. to the Board.
B.
i Intervenors 1.
Adequacy of Applicant's Radiological Monitoring Program Mr. David H. Martin North Carolina State University Faculty Mr. Carlos Bell - Professor, Environmental Engineering University of North Carolina at Charlotte Mr. Dayne Brown State of North Carolina 3.
Sufficiency of Water Resources for Operation of Facilities Mr. Edward Weiser - Faculty of North Carolina State University
C.
Regulatory Staff Donald G. Watson Battelle Memorial Institute, Richland, Washington Intervenors'ontentions C.l(a)(4) and C(l)(d) l David A. Baker Battelle Memorial Institute, Richland, Washington Licensing Board Questions
.and Intervenors'ontention 1
James C. Malaro
. Regulatory Staff, Bethesda, Maryland Intervenors'ontention C(1)(b)
James M. Cutchin Regulatory Staff, Bethesda, Maryland Licensing Board Questions William J.
Ross Regulatory Staff, Bethesda, Maryland Intervenors'ontention C(8)
David L. Schreiber Regulatory Staff, Bethesda, Maryland Intervenors'ontention C(6)
Robert A. Kornasiemicz Regulatory Staff, Bethesda, Maryland Licensing Board Questions and Intervenes 'ontentions 4 and 14 Robert W. Houston Regulatory Staff, Bethesda, Maryland Intervenors'ontentions C.l(b) and C(14)
, 4.
Written direct testimony as required by 10 CPR Part 2 shall be filed by the parties on or before Thursday, October 3, 1974.
5.
The parties may offer copies of documents and direct testimony in lieu of originals.
6.
The parties recommend the followin'g proposed agenda for the plenary evidentiary hearing.
(A) Opening Statement by Chairman of the Atomic Safety and Licensing Board.
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(B) Appearances of counsel for the parties (Applicant, AEC
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Regulatory Staff, and Intervenors).
(C) Identification of 'persons making limited appearances and their statements.
(D) Opening statement by counsel'for the Applicant.
(E)
Summary oral statement by 'Applicant (10 CFR 2, App. A, 5V(c) (1)).
(F) Opening statement by counsel for the AEC Regulatory Staff.
(G)
Summary statement on behalf of AEC Regulatory Staff (10 CFR 2, App. A, 5V(c) (2)).
(H) Opening statement by counsel for Intervenors.
(I) Introduction of Documents.
(See paragraph 1 herein.)
(J) Presentation of Applicant's Direct Case dealing with Intervenors'ontentions, cross-examination by Intervenors, and'Regulatory Staff and redirect by Applicant.
(K) Presentation of Applicant's Responses to Board Questions,
'ross-examination by Intervenors; and Regulatory Staff, redirect by Applicant.
(L) Presentation of Regulatory Staff's Direct Case dealing with Intervenors'ontentions, cross-examination by Intervenors and Applicant, redirect by Staff.
I (M) Presentation of Regulatory Staff's Responses to Board Questions, cross-examination by Applicant and Intervenors, redirect.
(N) Presentation of Intervenors.'irect
- Case, cross-examination by Applicant and Regulatory Staff, redirect and rebuttal.
(0)
Case in rebuttal, Applicant and/or Regulatory Staff.
(P) Concluding Summary by Applicant.
(Q) Concluding Summary by Regulatory Staff.
(R) Concluding Summary by-lntervenors.
(S) Closing procedural matters
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CAROLINA POWER LIGHT CO Date:
October
, 1974
. By W. Br Howell, A to ey Date:
October /, 1974 UNITED STATES OF &KRICA ATOMIC ENERGY COMMISSION REGULATORY STAFF By /
le(lr'-. +~
r7-i Charles A. Barth, Attorney CONSERVATION COUNCIL OF NORTH CAROLINA WAKE ENVIRONMENT, INC.
homas S. Erwin, Attorney