ML19220A650
| ML19220A650 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/28/1977 |
| From: | Kepford C CITIZENS FOR SAFE ENVIRONMENT |
| To: | |
| References | |
| NUDOCS 7904240044 | |
| Download: ML19220A650 (4) | |
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UNITED STATES OF AMERICA
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q, M-N Before the Atenic Safety and Licensine Appeal Board g
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In the Matter of
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METROFOLITAN EDISON COMPANY,
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Docket No. 50-320 et al.
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(Three Mile Island Nuclear Station,
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Unit 2)
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INTERVENORS ANSWERS TO NRC STAFF INTERR03ATORIES AND REQUEST FOR PROTUCTION OF DCCUMENTS, SECOND SET Contention 5 1.
To date no witnesses Pave been secured by the Petitioners.
2.
The Final Safety Analysis Report (FSAR) of the Applicant.
3 FSAR 4
The basis for this conter. tion is a general understanding that in the world of co:sercini aviation, as new, larger, and more efficient airliners are produced, they are adopted fcr use.
Since the Lockheed C-5A has not been offered in a commercial version, it may reasonabl: he expected to not frecuent Harrisburg Inter-national Airport as a commercial aircraf t.
It may as a military plane. Ecwever, the DC-10 and L-10ll are much larger than the Boeing 720B which was the reference picne for hardening TMI //l&2.
These might be expected to frequert the airport.
Petitioners are in possecaion of no privy or secret information on thle subject.
However, acme of our membere who fly via con =ercial airlinero have noted the lack of Ford Trimotors, DC-30, DC 4c, DC 6n, Conatellationo and Stratrocruisers around certain large airports.
They have b en pr e cue r,b ly replaced by je'.-powered aircraf;.
It should be noted that former Socretary of Transportation Coleuan allcwec the Concordesupersonic airliner to land on a trial bnsie at Dullen International Airport.
Should this plane prove succenaful and gain acceptan.e, it, too, might reaconably g
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. be e.pected to frequent Harrisburg Internatione1 Airport.
Contention th 1.
See Contention S, 1, 2.
FSAR 3
FSAR Contention 7 1.
See Contention 5, 1,
2.
See Contention 2 3.
See Contention ?.
4 It in the petitioners' understanding that, fogknstance, hbrricane Agnes was subjected to seeding efforts prior to its arrival in Pennsylvanis in June, 1972.. Pe ti tioners are aware of no dats to suggest that such ceeding efforts incresced or leusened the damage due to Agnes.
However, the petitioners are also aware of no information which indicates that the s
the tampering with the weather will either maintain or increane reliability of the weather records of the past.
The petitioners are, as of this data, concerned about the possibility of floods caused by ice jame in the Lower Susquehanna Petitioners River caused by the coldest winter in over 100 years.
wonder if Three Mile Island is pre pared to withstand a severe ice flood.
It should also be noted that it is generelly understocd that many of man's surface constructions increase rate of runoff and thereby increase flooding.
Examplee are buildings, streets, parking lots, and so on.
By prevent!.ng abcorbtion of rainwater.
runoff is enhanced.
by the soil, oy covaring it up with asphalt, Contention 8.
1.
See Contention 9, l.
2.
Read C;ntention 8.
3.
Poncible documents to be relied upon are (a)
Reactor Safety Study, Draft end Final versions.
(b)
American Fhvcical Society Study of Heactor Enfety Study.
(c)
Union of Concerned Scientists review of the Renctor Safetv Study.
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-5 Contention 9.
1.
See Contention 5, 1.
2.
Final Enviror.~. ental Statements (U.S.A.E.C.) for Hancho Seco and San Onofre.
3 See above answer.
Contention 1 1_.
1.
See Contentionj, 1.
2.
Draft Environmental Statement concerni g Propoced Rule Making Action: Numerical Guides for Decign Objectives and Limiting Conditions fer Operation to Meet the Criterion "An Low ne Practicable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents," U.S.A.E.C.,
January, 1973 3
See 2., above.
4 See 2.,
above, page 1.11.
It is estimated that the factor of 10 will accrue due to the factors derived on page 1.11, above, and the fact that a river site is the "wors t case "
for eiting.
I, Chauncey Kepford, swear that the INTERVENORS ' ANSW2RS T' NRC STAFF INTERROGATCRIES AND REQUEST FOR Pft' DUCTION OF DOCU!ENTS, SECOND SET, are true and cosplete, to the best of my knowled,;e and belief.
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- t.f Chauncey IN} or[
433 Orlando Avenue State Colle.;e, Pa. 168r1 Representative of the Intervenora Subscribed to and cworn before me this 0. W/.
day of 7 ;i.
1977.
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CERTIFICATE OF SERVICE NOTICE OF ATP'-:AL I hereby certify that copies of PETITIONERS' FROM THE MEMORANDUM AND ORDER OF THE ATOMIC SAFETY AND LICENSING BOARD ORDER, FEBRUARY 16, 1977, and PETITICUERS' BRIEF IN SUF! ORT OF APPEAL, and INTERVENOR5' ANSWERS TO NRC STAFF INTERRCG ATORIE3 AND REQUEST FOR TRODl'CTION OF DOCUMENTS, SECOND SET, dated February 28, 1977 have been served on the f ollowirg by denosit in the U.S.
Mail, First Class, postpaid, this_j(,dayofMarch, 1977,.
Edward Luton, Eeq., Ch a irman George F. Trowbridge, Esq.
Atomic Safety and licensing Board Shaw, Fittman, Fetts &
U.S. Nuclear Regulatory Commission Trowbridge 1800 M Street, N.W.
Washington, D.C. 20555 Wcchington, D.C. 20036 Mr. Gustave A. Linenberger At. sic Safety & Licensing Atomic 52foty and Licensing Board Board Fanel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulhtory Washington, D.C. 20555 Comniccion Dr. Crnest O. Salo Washington, D.C. 20555 Professor, Fisheries Research Atomic Safety and Licensing Inctitute, WH-lO Appeal Board College of Fieheries U.S. Nuclear Regulatory University c Waehington Seattle, Weekington 98195 Commission Washington, D.C. 20555 Karin W, Carter, Asst. Attorney General 60cket370 and Service Office of Enforcement Section Eepartment of Environmental Resources Office of the Secretary 709 Health and Welfare Building Harrisburg, Pennsylvania 17120 U.S. Nuclear Re;ula tory Comminsioa Washington, D.C.
20555 Re'ary J. McGurren
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.s Nuclear Regulatory Commission Washington, D.C.
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Chauncey Keyford Tsepresentative of the F.nvironmental Coalition on Nuclear Power g
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