ML19290G630

Request to Deny Applicants' Motion for Summary Disposition of Contention 2 Re Chlorine Due to Studies Demonstrating Relationship Between Cancer Rates & Chlorinated Compounds in Drinking Water.W/Certificate of Svc

ML19290G630
Person / Time
Site:	Susquehanna
Issue date:	11/24/1980
From:	Halligan T CITIZENS AGAINST NUCLEAR DANGERS
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8012180160
Download: ML19290G630 (4)

Text

November 24, 1980 U'!ITED STATED OF AME ICA .  ;

NUCLEAR REGULATOEY CC:2ISSION In the Matter of PENNSYLVANIA FOWEh & LIG.T CO. (3erwick Ato=1citower Plant) and (Suscuehanna Units 1 shd 2 )

ALLEGHENY ELECTRIC COOPERATIVE, INC. (Docket Nos. 50$387 &i388 )

CITIZENS AGAINST NUCLEAR DANGERS FETITION AND MOTIONS ON SUMMAR? DISPOSITION Concernin6 the Applicants' motion for sum =ary dispos'ition on the ozone section of Contention 17, the Citizens petition the Licensing Board to issue a ruling on the =otion which apnears on page four of the Citizens' filing of Septembe r 10, 1980, to the Licensing Scard w.ich w reads: " . . . the ??&L has constructed spe cial sub-stations n'.ong the route of the UUV line s. These lines can be energized at 500 kV cnd higher and tested for occne levels during rain, sieit and sno. ( storas) prior to the publ'.c hearings, and the Citizens cove the Licensing Board to so direct the Applicants. Safety and environ = ental healtr tests should be conducted on the actual UHV lines by the EPA a nd the DOE , on behalf of the NRC', and results =ade public."

In our judgement this cotion is the cost icportant issue of substance to b;- brought before the Licensing Board in the two year durction of t.2ese proceedings. 'ie believe it takes precedent and aerits a definitive resolution at this ti=e, because, if orde red, the tests on the Ee rwick UHV lines will show c. .onclusive1v the .

exteny of the environmental dangers caused-by ozone. Sur a ry disposition, on the other hand, is not the .s.olution. In fact, it will simply be part of the problem. The Citizens also reaf fir = all 10 1 othe r crntentions against the Applicants ( . a sponre daT,ed Sept. - sM -i,95C

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a s suf ficient a rgument for disaissal of Applicants' rotion

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2 The Citizens now submit significant new information concerning the erviron: ental impacts of UEV transmission line s. Cn October 2, 1980 an expert biophysicist testifyin6 in Federal Court in Philadelphia cited scientific studies that indicate serious adverse effects caused by 500 kV transmission extendine 2,000 feet from the UH7 lines. This certifiable evidence convinced Judge Clarence C. Newcomer (Eastern District of Pennsylvania ) to grant an injunction stopping Philadelphia Electric (FE) f rom installing the UHV lines because the plaintif f's rights of due process had been violated. On Octoce r 21,19E0, U.S.

Supreme Court Cuctice Willias J. Erennan upheld that injunction rulin.1, The biortyricist's plsusible testimony of certifiab.le hu=an risk in :ne FE case uill' be obtained by the Citizens frc the Court records a nd incorporated into direct testitony on Contention 17. The FE lines in cuestion are simila r to the Be rwick UHV line s, and both of tnese t ran"rission sy tens are de signed to the interconnected at a subststion in l edish County, Pa. , thus making the FE case information cost relevant.

The Citizens hereby =ove the Licensing Board to deny the Applicants' succary disposition on Contention 2 (section on Chlorine) or at least dels: further conside ration on this catter until the U.S. Council on Environ: ental Quality publishes latter this vear their new studies linking chlorinated drinking water and cancer. These studies show that the relationships between cancer . rate s and chlorinated compounds in drinking water are below the safe level established by the EPA. Dr.

Robe rt Ha rris, s =erbe r o f the CE2's three ae=ber panel, said recent?v that the new government findings "are going to make the EPA standards look ridiculous." The Ci. tic. ens will include the se scientific findings in their direct testinony on Contention 2.

3 Furthermore, a sicnificant development has occurred recarding Contention 2.

A firm known as Synfuel Energy Corp. is planning to construct a $100 tillion fuel grade ethanol production facility on a 2OO- a c~re site in the Nanticoke Industrial Park along the Suscuehanna River, about 15 =iles upstrea= from the 3erwick nuke. This massive project will consume 18 =1111on bushels of corn a year to produce 45 millien callons of ethanol annually. By-products will include 175,000 tons of distillers dried grain and 120,000 tons of liquid carbon dioxide.

The hundreds of =illions of gallons of liquid wastes discharge.

f rom this Ethanol operation into the Suset- aanna River upstresa frc=

Berwick will,arong other things, cause a substantial increase in the cumulative growth of sline-forming biclife in the river that in turn will neces:itate a considerable increase in the chlorinstion of the vc rious "s te r ' reatment sy steas at Be rwick. The steady discharge frc:

Scrwick of this heavily chlorinated waste +eter will endanger t6e aquatic ecosystems downstream, and especially endanger the health of 15,00 people living in Danville, Pa. who receive their drinking water directly frca the Susquehanna River.

The Citizens will cite in direct testi ony at the public hearings the deteiled i pacts of this and several other planned upstreat projects that vill further desrsde the quality of river water that will be entering the 3erwick treatment systems. T he re fo re , the Cit zens cove the Licensing Board to deny the Applicants' cotion for summary disposition on the Chlorine part of Contention 2 Dated: Nove ber 24, 1980.

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I he reby certify that copies of Citizens Acainst ':uclear n.. ...

_?e*itice And Motions On Su==a ry Discosition have been se rve:i - .

following by deposit in the United States = ail, first class, this 24th day of :.?ovember,1980 r

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Dated: November 24, 1980. Ves4'e/W h m

( l SIP'7TCI LIST

'r. Cha rle s 3e chhoe fe r, E sq . Dr Judith .-i. Johns'rud

': r . 'llenn C. Eright- rs Colleen Ma rsh Dr. Oscar H. Paris Mr Ge rald Schultz, Esq.

r James M Cutchin, Es ;. Mr. J a'r Silbe r:, E sq .

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Sec. :: :.0 C o r .. Docketing & Service Ms. Ka rin J. Ca rter, Esc. '

A tocic Safety & Licensing Board Atcric Safety & Licensin.3 Appeal Board

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