ML20031A077
| ML20031A077 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/09/1981 |
| From: | Traviesodiaz ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8109180366 | |
| Download: ML20031A077 (5) | |
Text
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.UCLEAR REGULATORY COMMISSION
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COCKEFED W
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-urEOREtTHE ATOMIC SAFETY AND LICENSING BOARD C SEP 1 11981 *
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-q, ci:e cf m n:retary C;;ha,; a b,i:e In the Matter of
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PEUNSYLVANIA POWER & LIGHT COMPANY
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Docket Nos. 50-387
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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.)
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(Susquehanna Steam Electric Station,)
Units 1 and 2)
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APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF MODIFIED CONTENTION 2 (CHLORINE)
Pennsylvania Power & Light Company and Allegheny Electric Cooperative, Inc.
(" Applicants") move the Atomic Safety and Licensing Board, pursuant to S 2.749 of the Commssion's Rules of Practice (10 C.F.R.
S 2.749) and the Special Prehearing Conference Order of March 6, 1979, LBP-79-6, 9.NRC 291, 328, for summary disposition in Applicants' favor of the chlorine portion of Contention 2 in this proceeding.
The chlorine contention, as modified by the Board's Memorandum and Order of March 16, 1981, LBP-81-8, 13 NRC slip op. at 12, states that "no assessment has been mde of the health effects of a higher level of chlorination [at the Susquehanna Steam Electric Station
't Susquehanna) "]
should a higher level become necessary because of b
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'N the discharge of organic wastes into the river upstream from the plant.
Nor have the quantities and health effects of trihalornethanes and halomethanes to be released been adequately assessed, at anticipated or higher-than-anticipated levels of chlorination."
As grounds for their Motion, Applicants state that there is no genuine issue of material fact to be heard with respect to the modified chlorine contention and Applicants are entitled to a decision in their favor on it as a matter of law.
This Motion is supported by the Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard (Contention 2 (Chlorir.e) ), and the Supplemental Affidavit of James Rios, both filed simultaneously herewith, together with all pleadings and other papers in this proceeding.
As set forth in the Mc:ch 6, 1979, Special Prehearing Conference Order, nuprt, 9 NRC at 328, responses to this Motion are due three weeks from its filing date.
Dated:
September 9, 1981.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 4
/7 By Jay E.
Silberg Matias F.
Travieso-Diaz Counsel for Applicants 1800 M Street, N.W.
Washington, D.C.
20036 Telephone:
(202) 822-1000
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r0cXEFED 3
D US.*me SEP 1 11981
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BEFORE THE ATOMIC SAFETY AND LICENSING BOAR O
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y::vi:e In the Matter of
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Docket Nos. 50-387
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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.)
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(Susquehanna Steam Electric Station,)
Units 1 and 2)
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CERTIFICATE OF SERVICE This is to certify that copies of the foreging " Applicants' Motion for Sunmary Disposition of Modified Contention 2 (Chlorine) ",
" Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard (Contention 2 (Chlorine) ) ", and
" Supplemental Affidavit of James Rios in Support of Summary Disposition of Contention 2 (Chlorine)", were served by deposit in the U.S. Mail First Class, postage prepaid, this 9th day of September, 1981 to all those on the' attached Service List.
'Ah Matias F. Travieso-Diaz' Dated:
September 9, 1981 s
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9
In the Matter of
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PENNSYLVANIA POWER & LIGHT COMPANY
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AND
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Docket Nos. 50-387
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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.
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(Susquehanna Steam Electric Station,
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Units 1 and 2)
)
SERVICE LIST 1
Secretary of the Commission Dr. Judith H.
Johnsrud U.
S. Nuclear Regulatory Commission Co-Director Washington, D. C.
20555 Environmental Coalition on Nuclear Power Administrative Judge James P. Gleason 433 Orlando Avenue 513 Gilmoure Drive State College, Pennsylvania 16801 Silver Spring, Maryland 20901 Susquehanna Environmental Advocates Mr. Glenn O.
Bright c/o Gerald Schultz, Esquire Atomic Safety and Licensing Post Office Box 1560 Board Panel-Wilkes-Barre, Pennsylvania 18703 U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Mr. Thomas J. Halligan, Corresponde3r The Citizens Against Nuclear Dangers dr. Paul W.
Purdom Post Office Box 5 245 Gulph Hills Road Scranton, Pennsylvania 18501 Radnor, Pennsylvania 19087 Ms. Colleen Marsh Atomic Safety and Licensing Box 558 A, R.
D.
- 4 Board Panel Mt. Top, Pennsylvania 18707 U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Jessica H.
Laverty, Esquire Office of the Executive Legal Docketing'and Service Section Director Office of the Secretary,
U.
S. Nuclear Regulatory Commission U.S. Nucle _ar Regulatory. Commission Washington, D.
C.
20555 Washington, D.C.
20535 l
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Rob &rt' W.sAdler+.Estfuire '
Mr. Thomas M.
Gerusky, Director Dspartment of Environmental Resources Bureau of Radiation Protection Commonwealth of Pennsylvania Department of Environmental 505 Executive House Resources Post Office Box 2357 Commonwealth of Pennsylva".ia Harrisburc, Pennsylvania 17120 Post Office Box 2063 Harrisburg, Pennsylvania 17120 Jadeb I.'.
Cutchin,..'IV f.. Esquire Office of the Executive Legal Atomic Safety and Licensing Appeal Director Board Panel U.
S. Nuclear Regulatory Commission U.
S.
Nuclear Regulatory Commissio8 Washington, D.
C.
20555 Washington, D.
C.
20555 DeWitt C.
Smith Director Pennsylvania Emergency Management Agency Transportation and Safety Building Harrisburg, Pennsylvania 17120 h
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