ML19289C929

Amended Petition to Intervene in Proceedings Re Application. Petitioners Allege Substantial Interest & That Contentions Satisfy Criteria for Intervention.W/Suppl Petition for Expenses Reimbursement & Affidavit

ML19289C929
Person / Time
Site:	Susquehanna
Issue date:	01/14/1979
From:	SUSQUEHANNA ENVIRONMENTAL ADVOCATES
To:
References
NUDOCS 7901260260
Download: ML19289C929 (17)

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l g5 20 PUBLIQ DMW. RQQ1 Di THE MMTER OF:

THE APPLICATIO1 FOR AN CPEPATIMG

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j CLEAR REGUIMORY CClHISSION LICENSE FOR THE SUSQUEHA!OIA !ITCLEA16N %Y GEEPATDIG STATIQi BY THE $' c'[.>

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% 1978 COPPORATIOT f wt@ APPLICATION NO.5. s of AENDED PETITIOT FOR LEAVE 'IO DTTERVDE We, the follow 1m individuals, as individual persons arxi as representatives and marbers of a private, non-profit unincorporated orcanization known as SUSQUDIANNA CWIPCAM ADVOCATES, hereinafter referred to as SEA, hereby subnit and file our Amended ?etition for Imave to Intervene in the above-captioned matter. Our con-tentions are specified below. It is our position that said contentions meet the requirenents of the Nuclear Pegulatory Ccmnission for specificity and that the issues contained and rapresented by said contentions should be raised and fully discussed at the public hearings on the above-captioned matter.

I. Interest of the Petitioners As stated in our Petition for Imave to Intervene and Request for Hearing, we have a definite substantial interest in this matter. Petitioners live in and around Wilkes-Barre, Luzerne County, Pennsylvania. Petitioners are gainfully erployed in various occupations. Petitioners travel to and frcm the Wilkes-Barre area, scme-times traveling in close proximity to the proposed plant. Petitioners use public parks fcr recreational activities and use other areas for recreational activities, scme of which are in close proximity to the proposed plant. Petitioners drink water frcm reservoirs which is in turn derived frcm the area water shed scme of which is in close proximity to the preposed plant. Petitioners consume food, sane of which is grown in areas near the protrsed plant. Scme of the Petitioners cwn real property in the Wilkes-Barre area.

Petitioners financial, property and health interest would be affected by the cperation of the prepcsed plant and tre certain possible censequences of said cperation.

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.. qnm_._ R 2 A. n rne report does not discuss even possible off-site locations for dispccal or etcrage of acw-level radicactive waste. Further cre, the report ianores who will be responsible fcr raintenance and security cf such si:es, where such sites will be located, who will ecnitor such sites fcr pcssible enviren= ental contamination and how 1:ng such sites

, must be caintained. 'Ihus, paragraph two of cur original petition should be ad=itted as a contention.

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.Teither the ER nor the ? SAC discusses the 2dequacy cf the fuel cupply crer the projected life of the plant. The price of uranium fuel has risen apprcxicately 405 in the last sin years.  :.uch of ctr uraniun must be imported. '.le think that the adequacy of the .:upply, the source cf the supply (cenpany and country), tne current price Of fuel and the projected price, and the existing centracts for uranium fuel should be disclosed and discussed. Thus, paragraph four of our criginal petition should be adnitted as a contention.

EXPOSLTE CF IGKERS TO PADIATICN

7. The ennronmental report and final safety aralysis report are inadequate in that they do not detail the nunber of cancer and prenature deaths to be caused by exposure of maintenance workers to radiation.

The reports by PP & L do state that there will be exposure of workers who are working on Unit 2 of the station while thit 1 is in operation. The reprts are inadequate in that they fail to state why this exposure is necessary at all. IM centend that thit 1 should not begin operation until construction is canpleted on Unit 2.

BU1BER tmIE The Su:rary of Environ:mntal Considerations for the Uraniun Fuel Cycle of the ER does mention occupational exposure fran reprocessing. However, it does not state how many workers are to be affected,the extent of exposure per worker, and the nu:rber of cancer and premature deaths to be caused. We think that the environmental repcrt is inadequate and it does not detail the cbviously human costs of the operation of the plant. Thus, we think that nurber 9 in our original petition should be admitted as a contention.

NUMBER TEN A serious accident at the plant site involving a major release of radiation and the consegmnces of this are not even discussed in the ER or the FSAR of PP & L.

Studies showing that the risk is so small that this does not even need to be discussed are irrelevant. These studies have been in large part discredited and regardless of the extent of the rirk the extent of the possible damage denands disc"ssion of this possibility.

We want to know the consequences of such an accident in terms of the health, welfare and employment of people of the Wyaning Valley Area. We want to know who will bear the costs of injuries and damages to health, property and liberty in the event of a major accident which could contxtinate the entire Wyardng Valley rendering it unfit for use ard causing an indetenunate nu:rber of cancer ard prerature deaths.

Thus, we think that paragraph 10 in our original petition should be admitted as a centention.

5F. Lux.crf FIRE - hL6 13 and 14 Accordmg to Pennsylvania Power and Light Wmts the Security Plan for the SSES has been subnitted as a separate document withheld frcm public disclosure pursuant to Federal Regulations.

However, it is our contention that we have a right to kncw and the public has a right to know the following facts cencernire the security arrangenents:

1. How many people will be hired to work on the security force at the plant?

2. How will said security force be armed?

3. The costs of said security force?

4. Who will bear the costs of said security force-the stockholders or the rate payers?

5. What k m d of plans have been made for security clearance of workers to be hired to be part of the security force, how much these investigations and procedures will cost, and who will bear the cost?

assumcs ::uch lower price for uraniun fuel than is now in existence. Even given these factors, the cost of the nuclear plant is only clightl;- lower than the cost of coal plants. We thir* that these alternatives should be re-examined.

Thus, paragraph 15 of our original petition as amended should be admitted as a contention.

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a disaster for const:mers as mil as for the envircr: ment. There are proven alterna-tives to nuclear peer which are safer, cleaner, and cheaper. It is our ccntention that we should use these alternatives and that the application for an operating license by the Pennsylvania Power and Light Cagany for the Susquehanna Steam Electric Station sfruld be denied.

21 THE MAT E R OF:  : NUCN REGCLAICE CCMMISSICN 2E APPLICATICN FCR MI CPEPATEG  :

LICENSE EUR SiE SCSQUEIGNNA ST;C2AR  :

27RATEG STATICN BY U!E  :

PERSPl"ANIA PCWER MD  :

LIG?I CCPSCRATICN  : APPLICATION 10. of 1978 AFFIDAVIT We, tha undersicned, Petitioners in the abovnaptiened matter, hei q-duly swe m , affirm that all statements confim ed in the amended Petition and the Supplerental Petition are true and accurate to the best of cur knowledce, information and belief.

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