ML19261A679

Second Amended Petition to Intervene,Supplementary Except Where Noted,To 781115 Petition.Addresses Contentions Re Need for Power,Alternatives.Notice of Withdrawal,Affidavit & Certificate of Svc Encl

ML19261A679
Person / Time
Site:	Columbia
Issue date:	01/10/1979
From:	Garrett S HANFORD CONVERSION PROJECT
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19261A680	List: ML19261A679 ML19261A684
References
NUDOCS 7902060045
Download: ML19261A679 (8)

Text

-

s...,

W..

c= m UiiITEL STATES OF r anICa @ N1/10/7fr\

~.. - IIUCLEAR REGULATch? C0miISSIOli --

'i 6- JAN 17 1975 >G'il SEFORE TE ATO..:Ic s,.n.TY ,wL ace.:sn.G naul -

_, s .

., s w=

, p' e ,g

% w s In the Matter of ) N

) Locket 2;o. 50-397-CL #-

71ASEI:!GTON PUELIC P07lER ) w#*

SUPPLY SYSTEM ) /GEiLED PETITIOJ FOR Lif.VE

) TO I.iTEhVE2 (7!PPSS Nuclecr Project No. 2) ) (A=encuent No. 2)

Petitioners Creg Earby and Susan M. Garrett, acting on their own behalf and on behalf of the Hanford Conversion Project, sub-mit these amendments to their First Anended Petition to Intervene (Nov. 15, 1978) pursuant to 10 CFR 2.714(a)(3) and the Orders of this Licensing Board. These Amendments are supplementary to, and do not super ede, the First Amended Petition, except where speci-fically noted.

I. 2.IIbCEllJ.NEOUS A..L;DdQ'TS .

A. The business address of the Hanford Conversion Project is 4312 SE Stark St. , Portland, Oregon 97215. (Supersedes Ac. Pet.)

B. Sections III(A) through III(J) of the First Acended Pe-tition refer to non-routine, as well as routine, operation of twP-2.

C.Section III(J) includes reference to additive effects re-sulting from operation of the Fast Flux Test Facility.

D. Addition to Sections VI and VII: Petitioners believe that due to (1) limited access of lihC Staff to information pecu-liar to the region and (2) the perhaps unavoidable tendency of URC Staff personnel to have professional backgrounds and exten-sive contacts in and with utilities and the nuclee r industry, T.he NRC Staff will not adequately represent Petitioners' points of view or interests in t is proceeding; there are no other pr.rties any more likely to do so, and no other petitioners to intervene.

E. Addition to the first full sentence on p.17 of the First Amended Petition:'.' . .through the year 2000 (end study, fis. c.=),

and a reduction in 33% of the basic load by 2000 (p. 17.4). By 2000, the Northwest 'could achieve 96 percent electrical geners-tion from renewable /1.e., non-thermalf energy sources.' (Ga0 study, p. 6.23)."

F. Line 8, Insert p. 2 to First Amended Petition: insert "with its tributaries" after "which."

II. ATTAC E.E:iTS .

A. Ilotice of 7/ithdravtal of Helen Vozenilek.

3. Affidavit of Doug1cs harber.

79020600 6

3/. SIS: Information provided at pp.11 through 19 of the First Amended Petition still provides the basis for this contention,

>lus information provided at pp. 19 through 23 which now p ovices the basis for both Contention I ( Teed for Poi.er) and II (Alter-natives).

COSTE3TICIT H: ALTEF ATIVIS (Supersedes)

Intervenors contend that Applicant and the URC have failed to prepare a rigorous exploration and up-to-date, objective e-valuation of alternatives to the oceration of ...iP-2. Such al-ternatives include, inter alia, ('a) deferral of operation; (b) non-operation; (c) conservation; (d) increased use efficien-cy; and (e) domestic solar applications.

Applicant and the 3RC have conse suently ingored or failed to adequately develop and explore new and significant availacle in-formation which substantially affects conclusions reached at earlier stages in this proceeding. Failure to take a "hard look" at adverse data violates the dational Environmental Policy r.ct, 10 CFR Part 51, and CEO Guidelines; this results in failure to meet standards reguired for issuance of an operating license as articulated in Sec. 2133(b) of the Atomic Energy Act of 1964, 10 CFR 50.40, 50.42(a) , anc 50.57.

ELSIS: Unchanged.

CONTENTICII III: COST-EE"EFIT AHALYSIS (Supersedes)

Intervencrs contend that neither the Acclicant nor the JRC

~

has prepared a rigorous, up-to-date, or ob[ective cost-cenefit analysis of .l5P-2 operation. The analyses are inaceguate in that they have ignored or failed to ades uately develop and explore new and significant available information which suustantially affects conclusions reached at earlier stages in this proceed-ing. Among the deficiencies are the following:

(1) The analysis overstates the benefits of .. 2-2 in that (a) alleged need for li..P-2 po.aer, the primary benefit assumed, is illusory and unsucstanticted prior to, anc prc'cably beyond, 1985; (b) alleged tax benefits are spurious; (c) employment benefits for Richland residents are minimal and nonsalaried; and (d) benefits of the Information Center are questionable at best.

(2) The analysis understates or ignores many of the costs of operating l<3P-2 including, inter alia, (a) the actual cost of

?lUP-2 power per kilowatt-hour; (b) costs of decccaissioning; (c) costs of spent fuel storLge and disposal; and (d) environmental and health costs of unnecessarily or prematurely accine to the region's accumulation of spent fuel and radioactave effluents.

(3) The analysis understates or ignores the benefits and availability of alternatives to operating l..P-2; such alterna-

tives include, inter alia, (a) deferral of operation; (b) non-operation; (c) conservation; (d) increased use efficiency; and (e) domestic solar applications.

(4) The analysis overstates the costs anc difficulties of developing the above alternatives.

The Applicant anc the liRC heve conse s uently failec to take a "harc look" at adverse data anc to objectively eveluate options, violating NEPA,10 CFR Part 51, and CEQ Guidelines; this results in failure to meet standcrds required for issuance of an opera-ting license as articulated in 10 CFR 50.40, 50.42(a), and 50. 57.

BASIS: Unchanged.

CONTEUTIO:I ,I_y: SEIS:,IICITY Intervenors contend that WWP-2 fails to meet reguirements of NRC regulations to assure seismic capability of plant design in that new and adverse seismic-related data developed during plant construction was not properly reported and/or was not fac-tored into site evaluation or plant design analyses. Such fail-ure violates re s uirements of 10 CFR 21.21, Part 100 (applicable through 50.54(h)) , 50.33, 50.34, 50. 54, 50.71, 50.109; this re-sults in failure to meet standards re s uired for issuance of an operating license as articulsted in 10 CFR 50.40, 50.42(a), anc 50.57.

HASIS: (Supersedes) See attached Affidavit of Louglass Barber, (incceporated herein by reference) a staff member of the reputa-ble national organization Clergy and Laity Concerned in Eudene, Oregon. Intervenors will. require the advantages of ciscovery to develop further reliable infonnation.

C0;.TE::TIOIT 2: U/LITY ASSUh.iUE nJL 11.2dISThTIVh UJ..ThQuS (Supe seced Intervenors contend that Applicant has failed to demonstrate compliance or ability to comply with IiEC regulations res uiring technical, managerial and aininistrative controls necessary to assure safe operation in that the construction of <di?-2 has been plagued with mismanagement, quality assurance fraud and negligena ,

labor strife, and critical audit recorts. Such failure violates 10 CFR Part 50, Appendix 3; 50.34(a) and 50.34(b) and re s ults in failure to meet standcrds required for issuance of an operating license as articulated in 10 CFR 50.40, 50.42(a), and cO. 67.

BASIS: (Addition) The U.L. General Accounting Office recently rublished an audit highly critical of ?iPPSS management procedures.

"F urther criticisms have been developed in an aucit report on ,,

7;?PSS managment prepared for the federal Bennevill Po..er accanis-tration (to which Il3P-2 power is to go) by Theodore carry a As ,,

sociates, scheduled for release by Februtry 1979. A draft of to2

"...saac report, according to the associated Press (12/9/75),

4

iPPSS appeared to be overstaffed and inefficient, used accr ac-counting procedures, had theft problems and did not kee'p other public agencies infonned of its activitie s." The report was withheld from public view by 'liPP55 cansgement in Dec.1975.

Intervenors require the benefits of discovery to develop the full implications of this and related information which has been permitted to come to public view.

COIRE]TIQU H: RADICLOGICAL EFFE. CTS (Super::edes)

Intervenors contend ; hat (1) due to Applicant's failure to demonstrate managerial and administrative controls necessary to assure safe plant operation, Applicant has failed to demonstrate that ?iUP-E will meet the standards of 10 CFR Part 20; (2) the genetic and sematic effects of radiation to be pro-duced by 'llHP-2 operation have been inadequately considered; (3) the presence on or near the Hanford reservation of nu-merous other nuclear facilities constitute a residual risk not anticipated by regulations in that the additive effects of ra-diation from all facilities must be considered;dRC's inadequate analysis results in violation of NEPA and 10 CFR Part 51; anc planned and existing (4) the presence of otherAnuclear facilities subj ects the public to greatly increased risk of accidental release of re-diation in that there is a risk from Sash facility which must be evaluated under NEPA; NRC's inadequate analysis results in vio-lation thereof.

The above failures violate : EPA,10 CFR Part 51, and CEO, guidelines; this results in failure to meet standards required for issuance of an operating license as articulated in 10 CFR 50.40, 50.42, end 50.57.

Respectfully submitted,

(/lllf A A Y 2)QY Susan M. Garrett, cro se ani on 'ce-half of Hanford Conversion Project and Creg Larby Dated this loth day of January,1979.

5

9 *1,,

UNITED STn?ES OF AsSRICA Ne,8 hUCLEAR REGULAIORY COLIaSIGN  %

• • • . T Ak DAN 17 E'

- IS7 J> ";;

u l +%,

!= =.

Br. FORE THE AT0mIC AhD SAFr.TY LICENSING BOAnD S t-s f b/ en u

In the Matter of )

)

WASHIhG10h PUBLIC r0WEx )

SUFFLY SYSTEM, etal. , ) Docket No. 5 0-397-OL (WPPSS Nuclear Project No. 2) )

a0TICE OF WITHDRAWAL Notice is hereby given that due to personal reasons .the undersigned withdraws her apcearance in.the above-captioned matte Furthermore, she authorizes Creg Darby to represent her personal interests in the matter.

Respectfully submitted, Helen Vozenilek

U:dTr.u STATES OF #EPlCA :UCLEAR REGIH AbRY CC:MSSICII Before the Atomic ity and Licencine Boa"d In the Matter of )

Washington Public Power ) Docket No. 50-397 CL Supply Syste= )

(WPPSS Nuclear Proje^t No. 2) )

)

Affidavit of Ocuelas Barber I hereby certify the followirg to be true to the best of my personal Icowledge:

'4hile drilling for water at the WPPSS 82 site, first good cold water was found. Then as the drilling continued, the pipes got so hot that the water was '

heated to 90* before it reached the surface. It was suspected thatthe pipes were heated by hot air passire through fissures and faults in the rock. Subsequently an aerial survey of the site was done and they found that indeed WPPSS #2 was located directly over a =ajor fault line.

My information oc=es frc= workers at Hanford via friends and relatives.

Because of their jobs they wish to re=ain anonymous.

Respectfully sub=itted, u

f., t 0 r, ~~

e 3

Of una c0 cit"c W t

,6 JAN 1? 1979- > 3 Ct*m gn 1 ~ l 4 #NcoW

(

/

i &

v i