ML20028F183

Notification of Intent to File New Contentions Based on New Info in SER Suppl.Certificate of Svc Encl

ML20028F183
Person / Time
Site:	Skagit
Issue date:	01/25/1983
From:	Hovis J HOVIS, COCKRILL, WEAVER & BJUR, YAKIMA INDIAN NATION
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8301310229
Download: ML20028F183 (6)

Text

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%Ce;[ffjc$;.._1vf" Ei UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PUGET SOUND POWER & LIGHT ) Docket Nos. STN 50-522 COMPANY, ET AL. ) STN 50-523

)

(Skagit/Hanford Nuclear Power )

Project, Units 1 and 2) )

INTENT OF YIN TO FILE NEW CONTENTIONS BASED ON NEW INFORMATION IN SSER YIN gives notification of its intention to file new contentions regarding the following matters:

1. SSER fails to determine, specify and resolve the nature and extent of the health and safety questions involved in the operation and construction of Skagit/Hanford.

2. SSER fails to provide within the SSER the staff's perception of the nature and extent of the relationship between each unresolved generic safety question and the eventual opera-tion of Skagit/Hanford reactor.

3. The SSER, applicant and staff have failed to properly consider and address health and safety questions regarding the*

eventual operation of the reactor under scrutiny as regards cumulative dosages and health and safety questions resulting from past operation of close-by nuclear weapon production 8301310229 830125 PDR ADOCK 05000522 TSO3

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facilities, the present operation of "N" Reactor, FFTF, and Purex Plant, the future operation of WPPSS, and the storage of nuclear wastes at the defense production areas, present nuclear waste storage areas in the Hanford Reservation and the prospective establishment of an extremely hazardous nuclear waste dump nearby.

4. That it is improper to proceed with licensing procedures and the granting of the CP until the unresolved safety issues specified in Section 3 of Skagit/Hanford SSER-3 are resolved.

5. That the question of exclusion area authority and con-trol has not been resolved and contentions of YIN show a question exists.

6. Present examination has not demonstrated that no potentially hazardous geological structure exists, or that danger from earthquake is not potentially dangerous. Examination of the May Junction and other areas has not been completed by examination consistent with best methods available to the science of geology.

7. Regarding earthquake danger it has not been demonstrated that the foundation stability at the site is suitable for required seismic structure support.

8. Travel times for cesium and strontium and other nuclides in the groundwater are not correctly stated in SSER.

9. SSER fails to provide a probability risk assessment and commitment to perform PRA does not consider a public risk assess-ment.

DATED this 25th day of January .

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m 6,, se , / 'N W JAMES B. HOVIS,/f f ,. H,o v i s , Cockrill, Weaver & Bjur Page 2 Attorney for Yakima Indian Nation

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PUGET SOUND POWER & LIGHT ) Docket Nos. STN 50-522 COMPANY, _E T _A L . ) STN 50-523 (Skagit/Hanford Nuclear Power )

Project, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that:

) INTENT OF YIN TO FILE NEW CONTENTIONS BASED ON NEW INFORMATION IN SSER in the above captiened proceedings has been served upon the persons shown on the attached list by depositing copies thereof in the United States mail on January 25, 1983, with proper postage affixed for first class mail.

DATED: January 25, 1983.

. /N:Y_A /

pAMES B. BOV)6, of

f ovis , Cockrill, Weaver & Bjur Attorney for Yakima Indian Nation 316 North Third Street Post Office Box 487 Yakima, Washington 98907 (509) 575-1500 l

l CERTIFICATE OF SERVICE t

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COMMISSION Secretary of the Commission Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 LICENSING BOARD '

John F. Wolf, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board 3409 Shepherd Street Chevy Chase, MD 20015 Dr. Frank F. Hooper Administrative Judge Atomic Safety and Licensing Board School of Natural Resources University of Michigan Ann Arbor, MI 48190 Mr. Gustave A. Linenberger Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 20555 Washington, D.C.

APPEAL BOARD Stephen F. Eilperin, Esq., Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Christine M. Kohl Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Reginald L. Gotchy Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 NRC STAFF Lee Scott Dewey, Esq. ,

. Counsel for the NRC Staff Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 s

3 INTERESTED STATES AND COUNTIES Washington Energy Facility Site Evaluation Council Nicholas D. Lewis, Chairman Mail Stop PY-11 Olympia, WA 98504 Kevin M. Ryan, Esq.

Washington Assistant Attorney General Temple of Justice Olympia, WA 98504 Frank W. Ostrander, Jr., Esq.

Oregon Assistant Attorney General 500 Pacific Building 520 S.W. Yamhill .

Portland, OR 97204 Bill Sebero,. Chairman f Benton County Commissioners P. O. Box 470 Prosser, WA 99350 APPLICANTS F. Theodore Thomsen, Esq.

Perkins, Cole, Stone, Olsen & Williams 1900 Washington Building Seattle, WA 98101 David G. Powell, Esq.

Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue N.W.

Washington, D.C. 20036 l

James W. Durham, Esq.

Senior Vice President General Counsel and Secretary Portland General Electric Company 121 S.W. Salmon Street Portland, OR 97204 Warren G. Hastings, Esq.

Associate Corporate Co,unsel

. Portland General Electric Company 121 S.W. Salmon Street l Portland, OR 97204 i

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Richard D. Bach, Esq.

Stoel, Rives, Boley, Fraser & Wyse 2300 Georgia Pacific Building 900 S.W. Fifth Avenue Portland, OR 97204 OTHER Nina Bell, Staff Intervenor Coalition for Safe Power Suite 527, Governor Building 408 S.W. Second Avenue Portland, OR 97204 Ralph Cavanagh, Esq.

Natural Resources Defense Council 125 Kearny Street San Francisco, CA 94108 Terence L. Thatcher, Esq.

d NWF and OEC 708 Dekum Building 519 S.W. Third Avenue Portland, OR 97204 Robert C. Lothrop, Esq.

Attorney for Columbia River Inter-Tribal Fish Commission Suite 320 8383 N.E. Sandy Boulevard Portland, OR 97220 l

Canadian Consulate General Donald Martens, Consul 412 Plaza 600 Sixth and Stewart Streets i

Seattle, WA 98101 1

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