ML19225B220
| ML19225B220 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/22/1979 |
| From: | Lemanowicz T CITIZENS AGAINST NUCLEAR DANGERS |
| To: | Bechhoefer C Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19225B221 | List: |
| References | |
| NUDOCS 7907240298 | |
| Download: ML19225B220 (1) | |
Text
.
Citizens A6ainst Nuclear rangers
'VRC gyBLIC D%fgg P.0.3 x 377, RD 1, serwi k, Pa.
May 22, 1979 Cha rles Bechhoefer, Esq., Chairman Atomic Safety and Licensin6 Board Docket Nos. 50-387 U.S. Nuclear Regulatory Commission 50-388 ila sh in6 on, D. C.
20555 t
Dear Chairaan Bechhoefer:
Pursuant to the preliminary schedule in Part II of the Order of the Board, dated March 6,1979, con arnin6 discovery proceedin; 0, the Citizens Against Nuclear Dangers hereby submit to the Ecard, 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 1 thru 18, are directed to the Applicants; the PP&L in most instances.
The remainin6 items, number 19, 20, 21, and 22, are directed to the Pennsylvania Bureca of Radiolo61 cal Health, Department of Environmental Resources.
Several of tne requests are for catalogued data, scae of which is probably available f rom computerized retrival systems.
Such detailed listings will aid the Citizens in determinin6 if one or more of the listed documents in each category will be requisitioned as evidenca, which in turn should assist the Board in arrivin6 at proper decisions in this licensing case.
The Citizens sub=it that this preliminary background infor:ation is relevant to one or the other of the admitted contentions, and necessary for the preparaticn of exhibits and testirony.
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Yours truly y
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Irene Lecanowicz, Chairperson p
Citizens Against Nuclear Cangers W P' E
415 2345 s
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1.
Provide the scientific results and the economic feasibility reports of PP&L's experimental :llot project to produce electricity f rom solar power Senerated by wind mills installed near Hazloton, Pa.
2 Send ??&L's Anthracite-fired plant feasibility study, completed by the consulting firm of Skelly & Loy, Harrisburg, Pa.
3 Also, provide detailed reports of all other past and present experiments, conducted or financed by the Applicants, independently or as a j oin t-v e ntu re, to Senerate electricity 1:ain6 ener6y sources other than atomic fission (include atomic fussion).
We are especially interested in those ventures funded in part by the Fedcral Government.
4 The Applicants a re requested to provide all documentation pertainin6 to their participation in any and all Government spon sored energy con se rvation programs, such as the National Residential Energy Conservation Program and the Governor's Energy Council pro 6 rams; as well as any induutry sponsored ener67 conservation programs.
5.
We will need from PP&L summarized financial reports outlining their methods of raisinr, capital to construct the Serwick plant which identifies the lendin6 inst'.tutions and bond brokers, etc.
6.
Also, send financial information on any tumkey type agreements concernin6 3erwick, between the Applic;nts and any vendor or contractor, such a s the Genercl Electric Cred.i c Corporation, the Balley Meter Ccapany, o r the Eechtel Corpo ration.
7.
Forward a copy of the Annual Reports of the Allegheny Electric Coope rative, Inc. and the ??&L for the pa st ten years; and copie s of the monthly ??iL Pa"nrter. f rom 1972 to the present.
4l5 235 w yywgg
8.
've request an index of the Applicants' policies that provide all types of cocaercial and governmental insurance coverage, includin6 risk and self-insurance, on all aspects of the Eervick power plant properties and personnel, and its uraniua fuel cycle, 9
'Frovide copies of Court Docket title pages for all Federal and state court law suits, past and present, civil or cria:.nal, in which the Applicants were, or a re, a plaintif f or a defendant involvin6 litiEation in all matters involvin6 the Eerwick atomic plata, includin6 the supply of uranium, transsission line right-of-ways, anti-trust, accidents, and alled ed defective manufacture or installation of 5
plant components.
10.
Furnish a catalogue of all Applicant documentation, correspondence, etc., on all aspects of the Serwick atomic power plant sent to, or received from: the Pennsylvania Public Uti,11ty Commission, the Federal Power Cocaission, the Susquehanna River Basin Cocaission, the U.S. A rmy Co'rps of En6 neers, the U.S. Se curities & Exchange Co'amission, and the 1
U.S. Depa rtment of Ener67-11.
Provide a catalocue of all company ainutes, transcriptions, memos, coacunications, reports, announcements, press relea ses, and all other records on file of public meetin6s, hearings, con f e ren c e s, and sessions of any kind involving the Applicants and public of ficials, whether ilected, appointed, or civil service, at all levels of governcent,.citin6 date,.
location, sponsorship and/or public involvement, that ha s in any way dealt with the Eerwick stoalc powe r plant.
19.
Furnish sua=a ries of the types cf records cited above that deal specifically with sessions between representatives of the ??&L and the Board of Supervisors of Salem Township, Luze rne County, Pennsylvania, g;P yygg_
415 236 during the pa st ten years.
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13 For'::ard copies of annual reports and scientific environmental studies and tests conducted to date for the Applicants in conjunction with the Berwick project site dealing with milk, air and water quality, aqua tic and wildlife, etc., by the Ichthyological A ssociates Inc.,
Ithaca, N.Y. and by Radiation Mana6ement Corp. of Philadelphia, Pa.
14 Send information de scribin5 the ongoin6 experimental proj ect to study aquaculture in the warm-water outflow of power plants alon6 the Susquehanna Riv er.
We are referrin6 to the two year project which is a joint venture of PP&L, Kraft Inc., and the Franklin Institute.
Include a copy of the contractual papers.
15 Provide mining maps ( small scale) with 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 cocaenced or will be u.nderta' ken by the Applichnts, their
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sub sidia rie s, agents, or as 8 joint venture, in con,nection with the Applicants stated plans to become partially self-sufficent in the extraction and production of uranium for the 3erwick atomic power plant.
We are referrin6 to (but not limiting our request to) such agreements as the Hemi/ifest Properties drilling and ovploration program for some 400 contiguous minin6 claims covering about 8,000 cores of land in San Juan County, Utah.
16.
Furnish a tranamission line ( 230,000 to Sco,0covolt) right-of-way listing, associated alth the 3erwick station, identifying the na=e and ocdress of each Gra: tor ( seller or lessor) with a property line map (app roxinately 1" - 100' scale) pinpcin;ing the location of each tract.
Also list the Index-to-Deed Ecok number and page nusber for each
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415 237
Grantor-Grantee transaction document and/or Affidavit of Value for eminent domain ca ses, on file at 'the of fice of the Recorder of Deeds in the seve ral Pennsylvania countie s involved, namely:
Susquehanna, Ieckawanna, Luzerne, Columbia, Montour, Northumberland, Snyde r, Ca rbon, Northampton, Schuylkill and'Lehi h.
This information should be 6
readily available at the Applicants' Gene ral Of fice, R1 ht-of-Way 6
Se ction s.
17 Forwa rd a catalogue on the Applicant's participation in re sea rch pro 6 rams co-sponsored with the Electric tower Research Institute.
Also send summary reports of PP&L's participation in research by High Voltage Power Corp.
on extra-hi h volta.ge under6round transmission.
6 18.
Furnish a 'omplete record of the ma.nufacture of the atomic reactor pressure ve ssels purchased by the PP&L for Units 1 and 2 at Berwick.
Documentation should trace tha pressure vessels from their present location all the way back to
- e foundries where they were for6ed several yea rs ago.
Include a description of all welding modifications performed on the precsure vessels at all stages of the production process.
Document exactly the plant sites where the pressure vessels were w 1ded and fabricated.
Include concise pressure vessel weld inspection reports.
We also need to know the ranufacturin6 cole of pressure vessel work tbat may have been perfo foed at the B.& W. Mount Vernon, Indiana plant; the Chicago Bridge & Iron Memphis, Tenn. plans; and toe Ccabustion Enginee ring Chat'tanooga, Tenn plant; among other f a cilitie s.
415 238
19 Provide a estalogue containing a complete 11stin6 of the documents, reports and correspondence, etc., in the file s of the Bureau of Radiolo61 cal Health, Department of Environmental Re sources (DER),
Commonwealth of Pennsylvania, on the subject of PP&L's Berwick atomic power plant.
20.
We also wish to obt.11n f rom the Bureau of Radiolo6 cal Health 1
complete of ficial documeritation, includin6 field monitoring reports and milk samplin6 results, on the affects of the radiation fallout in October,1976 resultia6 from the chinese bomb test of september 26, 1976.
21.
Also needed from t c Bureau will be a current catalogue of all relevant data compiled by the Bureau concernin6 radiation monitoring and milk saaplin6 already conducted, plus on-Soin6 survey results when they become ava$1able, dealing with the radiation releases in the vicinity of the Three-Mile-Island plant since the March 28,1979 accident.
22 From the appropriate of fice of the DER we also wish to obtain the public records pertaining to the Applicants permit application to dischar6e industrial wastes into the Susquehanna River from the Berwick stomic power plant.
415 239