ML20032E432

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Petition to Intervene in Proceeding.Affidavits & Certificate of Svc Encl
ML20032E432
Person / Time
Site: Seabrook  
Issue date: 11/18/1981
From: Jordan W
HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8111200552
Download: ML20032E432 (21)
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Text

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DCLKETED UNITED STATES OF Af1 ERICA NUCLEAR REGULATORY COMMISSIOgj NOV 18 P5:08 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

~ T M T(

In the Matter of

)

)

dj'/,. PUBLIC SERVICE COMPANY OF ) NEW HAf1PSHIRE, et al., ) Docket Nos, p and 2) ) 50-444 OL I g" 6} d) (Seabrook Station Units 1 ) 50-443 OL i t2 a NOV191981 ) ) g-m C> A'>N PETITION FOR LEAVE TO INTERVENE BY TIIE NEW ENGLAND _ C.OALJTION ON NUCLEAR POLLUTION

1. The New England Coalition on Nuclear Pollution, Petitioner, on behalf of its approximately 500 individual nembers hereby petitions the Nuclear Regulatory Commission e

(NRC) for leave to intervene in proceedings for the issuance of en aperating license in the above-captioned matter, pur-suant to Section 2.714 of the NRC's Rules of Practice and Procedure, 10 C.F.R. 2.714, and the Commission's order of i October 19, 1981 (46 Fed. Reg. 51330).

2. Petitioner is an incorporated non-profit organization with members, trustees, science advisors, and supporting groups in the New England states and New York.

The Coalition is concerned about the da'ngers of nuclear energy and advocates the development of safe energy alternatives. Its major activities and goals are education of the public concerning nuclear hazards, energy conservation, and alternative energy b$ 8111200552 811118 I DR ADOCK 05000443 PDR

4 e sources. The Coalition has been an active intervenor in the construction permit proceeding concerni,ng the Seabrook plant.

3. Section 189 (a) of the Atomic Energy Act, 42 U.S.C.

S2239(a), requires that the Commission admit as a party "any person whose interest may be affected by the proceeding." The Coalition requests leave to intervene in order to protect its own interests as an organization and the interests of its members. Many members of the Coalitiqn live, work, shop, and pursue leisure activities in the area of the Seabrook nuclear facility and would be adversely affected by any ac-cident or serious problems in Its o'peration. The members of ~ the Coalition are concerned that the quality of their lives, including their personal health and safety, property and leasehold values, and business and employment interests may be jeopardized by a mishap at the facility. For these rea-sons the following individuals have authorized the Coalition to intervene on their behalf and request a hearing on the issuance of an operating license for Seabrook Units 1 and 2: Laura C. Crooks 6 Parker Street Newbury, Massachusetts James F. Fallon 131 Ocean Boulevard Hampton, New llampshire 03842 Eugene D. Finch South Road East Kingston, New Hampshire 03827 Stuart Meiklejohn 563 Exeter Road Hampton, New Hampshire 2

4-e Elizabeth Meiklejohn 563 Exeter Road Hampton, New Hampshire - John W. Parker South Road Rt. 84 Hampton Falls, New Hampshire Sara A. Parker South Road Rt. 84 Hampton Falls, New !!ampshire Ai1 of the above-mentioned individuals live within 8 miles of the Seabrook facility. Their affidavits are attached. Petitioner and the members named above believe that their ability to litigate the issu,es raised below is critical to the health, safety and property. interests of the Coalition and its members.

4. As required by 10 C.F.R.
2. 714 (a) (2), the aspects of the subject matter of the proceeding as to which NECNP wishes to intervene are set out below:

1. Risks caused by potentially adverse interactions between safety and non-safety systems.

2. The effects of a hydrogen burn or explosion on equipment important to safety..
3. All other aspects of the issue of hydrogen con-trol.
4. The requirement for consideration of accidents that are beyond the design basis of the plant (Class 9 accidents) in the Environmental Impact Statement, including the need for specific con-sideration of the consequences of such accidents without reference to probabilities, and the fact that the conseTiences of a Class 9 accident are so severe that the plant should not be licensed for operation.

Depending upon what is addressed in the'EIS, NECNP may challenge the projected consequences as well. 3

i

5. Seismic hazards at Seabrook which render the plant unsafe in its current design (particular-ly since this issue has not be'en resolved at the CP stage).
6. Emergency Planning.

7. Safety problems that arise as a result of the aging of the plant and equipment, including particularly steam generator tube degradation, pressure vessel rupture, and the failure to adequately consider aging in qualifying safety-related equipment.

8. The inadequacy of shutdown heat removal capability.
9. The reliability of onsite and offsite electrical power to operate heat re-moval equipment and other equipment impor-tant to safety. _._._.,
10. The environmental, seismic, and dynamic qualification of electrical and mechanical components important to safety.
11. Reactor vessel embrittlement (pressurized thermal shock).
12. Steam generator rupture.
13. Failures in Quality Assurance / Quality Control during construction.
14. Faulty construction work, including poor workmanship and the use of unqualified workers, particularly in the area of con-crete work.
15. Inadequacy of Quality Assurance for the operation ^f the facility.
16. Welding failures and inadequacies.
17. Hazards of excessive pressures in the reactor vessel.
18. The n.censee's lack of managerial com-petence and character to operate the reactors.

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19. The Licensee's lack of technical competence-to operate the reactors.
20. The Licensee's lack of financial qualifica-tions to operate a nuclear power plant.
5. For these reasons, the Coalition respectf.lly seeks leave to intervene in the above-captioned proceeding.

Respectfully submitted, .. ~. &s ' ,,./.. - b. William Sf' Jordan, III Ellyn R. Weiss HARMON & WEISS 1725 I Street, N.W. _Suitt 506 Washington, D.C. 20006 (202) 833-9070 Dated: November 18, 1981 1 0 P 5

WFLEIVEUN0V 16 I UNITED STATES OF AMERICA ~ NUCLEAR REGULATORY COMMISSION DEFORE Tile ATOMIC SAFETY AND LICENSING BOARD y ~ In the Mat.ter of ) ~ ) PUELIC SERVICE CCMPANY OF ) NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL ) 50-444 OL ) (Seabrook Station, Units 1 and 2) ) ) AFFIDAVIT OF

1. My name is C U M L b Cfevch.

I live at 1[ a r/m [ L lU b O NLf' D CLZ $*, which is4 miles T'col-hLO.cTH G from the proposed Seabrook nuclear power plant. My home is down-wind of the plant much of the time, particularly during the (Ef/ $ 21T o 2.MyfamilyandIhavelivedatthisaddrensfor/ years and in the general area of the Seabrook plant for h, ears.

3. My family and 7. ur.e the beaches near the Seabrook plant for l

recreational activities from time to time during the year, and we l l engage in other leisure pursuits of varioun types within a few miles of the plant appro:cimately [ Ore days each year. 4. I work at C4 b c c j_ , which is miles of the plant, and I am required to travel near the plant on my way to work and at other times for business purposes. W-4.- (LIJL l'h n t ". C t.%q S' L (.N N.@ , ') % t;&Ln c a L avu Tu%+ m cc t im a l -t 12 a o i d e' h ec !nBTtof*" h,.,onJd19 M mm

5. I am a member of the New England Coalition on Nuclear Pollution because I am concerned about the hazards posed by nuclear power, and particularly by the Seabrook nuclear power plant, to my own health and safety and that of my family. 6. I authorize the New England Coalition on Nuclear Pollution to represent my interests in operating license hearings before the Nuclear Regulatory Commission concerning the Seabrook plant and in related proceedings. 3 - -- --- - ~Oces<< ( <v6f T Sworn and subscribed to before me this /'.L day of. $ 4/g/c/[ 1981. -) \\c.il,.( f' dt?i. f Notary Public My commission expires .)/)s.) /, / 9 f $ j I i i 9 w- ,9 wy --e ,.c -.._y~. e_--- .--m w, ~ 4 -w-

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFDRE THE ATOMIC SAFEiY AND LICENSING BOARD ~ ) In the Matter of ) ) PUBLIC SERVICE COMPANY OF ) NEW HAMPSHIRE et a1 ) Docket Nos. 50-443 OL ) 50-444 QL ) (Seabrook Station, Units 1 and 2 AFFIDAVIT OF JAMES F. FALIDN I

1..My names is James F. Fallon._.1 11ve at 131 Ocean Boulevard, Hampton Beach (within the Town of Hampton), New Hampshire.

My home is about five miles northeast of the Seabrook nuclear power plant under construction, and thus downwind of this plant much of the time, particularly on hot days during the Spring, Summer and Fall. 2 I am the President and General Manager of Donovan & Fallon Corporation, a New Hampshire business corporation wholly owned by my mothen, who lives at the same address, which operates a i retail store at the same address catering to Summer vacationers and tourists from May to September every year. 3. My family and I have lived at this address and carried on our business at this address for fifty-five years. 4. I have been a Selectman of the Town of Hampton, Chairman of w-m --w ~ - + x +e w w~ m s v--v

the Hampton Municipal Budget Committee, Chairman of the Republican Town Committee of Hampton, President of the llampton Beach Chamber of Commerce, and President of the Kiwanis Club of the Hamptons. I have many friends in my neighborhood and throughout Hampton .about whose safety I care. 5. I am a member of the New England Coalition on Nuclear Pollution because I am concerned about the hazards posed by nuclear power generation, and particularly by the Seabrook nuclear power plant, to my own health and safety and those of my family, friends and customers, and to my family's business and property. 6. I authorize the New England. Goalition on Nuclear Pollution to represent my interests in operating license hearings before the Nuclear Regulatory Commission concerning the Seabrook plant and in related proceedings. 3 .%~ P / 4 ;s..... ). gC-__ a STATE OF NEW HAMPSHIRE ROCKINGHAM, ss. Subscribed and sworn to before me this thirteenth day of November, 1981. Notary Public \\, s. \\\\ c g

S. Seismic hazards at Seabrook which render the ple.nt unsafe in its current design (particular-ly since this issQe has not been resolved at the CP stage).

6. Emergency Planning.
7. Safety problems that arise as a result of the aging of the plant and equipment, including particularly steam generator tube degradation, pressure vessel rupture, and the failure to adequately consider aging in qualifying safety-related equipment.
8. The inadequacy of shutdown heat removal l

capability.

9. The reliability of onsite and offsite electrical power to operate heat re-moval equipment and other equipment impor-tant to safety.
10. The environmental, seismic, and dynamic qualification of electrical and mechanical components important to safety.
11. Reactor vessel embrittlement (pressurized thermal shock).
12. Steam generator rupture.
13. Failures in Quality Assurance / Quality Control during construction.
14. Faulty construction work, including poor workmanship and the use of unqualified workers, particularly in the area of con-crete work.
15. Inadequacy of Quality Assurance for the j

operation of the facility.

16. Welding failures and inadequacies.
17. Hazards of excessive fressures in the reactor vessel.
18. The Licensee's lack of managerial com-petence and character to operate the reactors.

4

5. Seismic hazards at Seabrook which render the plant unsafe in its current design (particular-ly since this issue has not been resolved at the CP stage).
6. Emergency Planning.

7. Safety problems that arise as a result of the aging of the plant and equipment, including particularly steam generator tube degradation, pressure vessel rupture, and the failure to adequately consider aging in qualifying safety-related equipment.

8. The inadequacy of shutdown heat removal capability.
9. The reliability of onsite and offsite electrical power to operate heat re-moval equipment and other equipment impor-tant to safety.
10. The environmental, seismic, and dynamic qualification of electrical and mechanical components important to safety.
11. Reactor vessel embrittlement (pressurized thermal shock).
12. Steam generator rupture.
13. Failures in Quality Assurance / Quality Control during construction,
14. Faulty construction work, including poor i

workmanship and the use of unqualified workers, particularly in the area of con-crete work.

15. Inadequacy of Quality Assurance for the operation of the facility.

l

16. Welding failures and inadequacies.
17. Hazards of excessive pressures in the reactor vessel.
18. The Licensee's lack cf managerial com-petence and character to operate the reactors.

i t f i 4 f (

5. Seismic hazards at Seabrook which render the plant unsafe in its current design (particular-ly since this issue has not been resc1ved at the CP stage).

6. Emergency Planning.
7. Safety problems that arise as a result of the aging of the plant and equipment, including particularly steam generator tube degradation, pressure vessel rupture, and the failure to adequately consider aging in qualifying safety-related equipment.
8. The inadequacy of shutdown heat removal capability.
9. The reliability of onsite and offsite electrical power to operate heat re-moval equipment and other equipment impor-tant to safety. _ _ _ _ _,,
10. The environmental, seismic, and dynamic qualification of electrical and mechanical components important to safety,
11. Reactor vessel embrittlement (pressurized thermal shock).
12. Steam generator rupture.
13. Failures in Quality Assurance / Quality Control during construction.
14. Faulty construction work, including poor workmanship and the use of unqualified workers, particularly in the area of con-crete work.
15. Inadequacy of Quality Assurance for the operation of the facility.
16. Welding failures and inadequacies.
17. Hazards of excessive pressures in the reactor vessel.
18. The Licensee's lack of managerial com-petence and character to operate the reactors.

4

UNITdD STATES OF A!.1SRICA NUCLEAR REGULAIORY C0l&ISS10N BSFUnE THS A101*IC SAFETY AND LIC4NSI!jG BOARD ) In the Matter of ) ) PUBLIC SERVICS C01'PANY OF ) NEW HAMPSHIRE, e al. ) Docket hos. 50-443 OL ) 50-444 OL ) ( Seabmok Station, Units 1 and 2) ) ) AFFIDAVIT OF EUGENS D. FINCH 1. Ey name is Eugene Davis Finch. I live o.n South Road, East Kingston, about eight miles west of the proposed Seabmok nuclear power plant. Hy home is downwind of the plant much of the time. 2. My family and I have lived at this address for thirteen years and in the general area of the Seabrook plant since 1933. 3. My family and I use the beaches near the Seabmok plant for recreational activities from time to time during the year, and we shop and drive in Seabmok within a few miles of the plant approximately fifty days each year, i 4. I am a member of the New England Coalition on Nuclear Pollution because I am concerned about the hazards posed by nuclear power, and particu.arly by the Seabrook nuclear power plant, to my own health and safety and that of my family. I l 5. I authorize the New England Coalition on Nuclear Pollution to represent c:y i l interests in operating licenso hearings before the huclear Regulatory Commission concerning the Seabmok plant and in related pmceedings. l C, 'S ( -,G..t g, g l

w. <.g;,.x. M.,i e to l

Sworn and subscribed to before me this /'- ' bay of 1981 '*y commission expires l

Unit d States of America ':' cIcar S:;nl:.tcry Co rtission licfore the Ato tic *iafety and I.icensin.: yourd In the tr.tter of Pub 3ic Service C:npany of D c':ct :!os. 50-443 0' Nov..anpshire, et al 50-444 OL Geabrook Station, Units 1 and 2 Affadavit of Stuart !!cil:lejohn . y nano is Stuart deilc3 cjohn. I live at f.G3 Exeter ':oa 1, ;lai,. ton :!cu lla spshire, uhich is '7-0 ni3cs fro 1 the proposed nuclear p 'ror p ant. ':y hone is often dounwind of t'c.c plant. :fy wife and I have lived et tt.is ' ~ ~ - ~ ~ ad. Ire:;s for thirtoon years. Members of our fa'tily use the beaches near tho Seabrool: plant for recreational activitics from tine to tine, and nearly all our daily cutdoor activities, of te.ich there ar nany, are within a few ni3es of the plant. ! an' retired. I an a nonber of the New ~ ngland CoaU. tion on ?!:cicar. r,11ntion because I an c ncerned abcut the hazards posed b: the Scabrook nuclear poner plant. to my ova health an.1 s: foty and th:.t <i. rty feni3y. I authorize the.N'or England (:oalition oa Nucicar Pollution to represent ny interests in operati.ng license hearin s before the ::ucler.r T'ogulatory Connission concernin: the Scabrook plant an1 in related statters. e f s'Es o / .i l l Stecrn to ani srbscribe tc before no tiis // day of A' ical. 1 - v2l a). v. +. { n'otary l' bl. c i fy cennission enpires I / *."V 2 ', y-e e y. -n. ..mw ,.--e-m--w.+ -m . + -9

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DEFORE Ti!E ATOMIC SAFETY AND LICENSING BOAllD ) In the Matter of ) ) PUBLIC SERVICE COMPANY OF ) NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL ~- ) 50-444 OL ) (Seabrook Station, Units 1 and 2) ) ) AFFIDAVIT OF

1. My name is 5lLQONCTl1Ybklk'bGYD til Sjk'{.bnSc)

I live at hamp&n ; W N , which is 7*S miles A]/V]Al from the proposed Seabrook nuclear power plant. My home is down-wind of the plant much of the time, particularly -durimg4he

2. My family and I have lived at this addreas for /.3 years and-49 tegene"ai areWhe_Seabrnok plant _for -

-years.

3. My family and T. use the beaches near the Seabrook plant for recreational activities from time to time during the year, and we engage in other leisure pursuits of various types within a few miles of the plant appro:vimately -

days each year. ) / L4 h L M' k 4. he d h i (t )titLMlt'sf-C'oM'[ ic!Lis__ mil es-s of thn pinnt, and I am required to travel near the .5 hi

  • l t t-v c ltu 'k C/c2-plant on my way to and at other times for businamp[rpo ce.- Y aczi,dn, u w a.1s o u.7mh a v<w a u -ynw &ny eid fuf AEn, Ay Mazjn taa- <y' cun a c u b,z2 a i E jt/nnk n w> il' L af e l' y. fea n o

ce i.si n i <- c a esnOn /5 imt.?any g acu,<w-i fa>wnc<<1cau - a%d.7,

5. I am a member of the New England Coalition on Nuclear Pollution because I am concerned about the hnzards posed by nuclear power, and particularly by the Seabrook nuclear power plant, to my own health and safety and that of my family.

6. I authorize the New England Coalition on Nuclear Pollution to represent my interests in operating license hearings hafore the Nuclear Regulatory Commission concerning the Seabrook plant and in related proceedings.

[i k/kfrWid Z,a. ?ol<TA./ ./ Sworn and subscribed to before me this // day of n,/ 1981. .k s \\ Notary Public My commission expires / - :% N 4 e m ..--w-- . ~ -,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DEPORE TIIE ATOMIC SAFETY AND LICENSING DOARD ) In the Matter of ) ) PUBLIC SERVICE COMPANY OF ) NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL ) 50-444 OL ) (Seabrook Station, Units 1 and 2) ) ) AFFIDAVIT OF d IN N M A~ 8 k

1. My name is 10 M dtl 74M/CL k.

I live at h78 O Y M PTOd FALL 3 , which is3.G miles sJ from the proposed Seabrook nuclear power plant. My home is down-wind of the plant much of the time, particularly during the K* C+0 d > l*75" Msfe$ IJI& 34 A.3 m My family and I have lived at this addrens forN N years and in 2. the general area of the Seabrook plant for 7_2-years. l l

3. My family and T. use the beaches near the Seabrook plant for recreational. activities from time to time during the year, and we engage in other leisure pursuits of varioun types within a few miles of the plant appro:cimately 300 days each year. - I*

l {o y y~ - p6Y Ap hs LM , which is miles 4. I work a l of the plant, and am required to travel near the l v plant on my way to work and at other times for business purposes. 1 a f tS C)f lg, m--, m

e

5. I am a member of the New England Coalition on Nuclear Pollution because I am concerned about the h'azards posed by nuclear power, and particularly by the Seabrook nuclear power plant, to my own health and safety and that of my family.
6. I authorize the New England Coalition on Nuclear Pollution to represent my interests in operating license hearings before the Nuclear Regulatory Comaission concerning the Seabrook plant and in related proceedings.

e Sworn and subscribed to before me this \\b4 day of LM% 1981. Meu; i Lu,, Notary l\\u ic My commission expires d d dI,{98) e e

e. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DEFORE Tile ATOMIC SAFUTY AND LICENSING BOARD ) In the Matter of ) ) PUBLIC SERVICE COMPANY OF ) NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL ) 50-444 OL ) (Seabrook Station, Units 1 and 2) ) I

l. '

I e ?/ -( / 7' AFFIDAVIT OF ~/749 i x' N.'< < 4 < > o " f.^ G - I live at ~> e < > / '< 9 o a',

1. My name is.

air .'rt//s , which is 9-miles TecN/; .h .: y - 4,3,rr,. from the proposed Seabrook nuclear power plant. My home is down-wind of the plant much of the time, particularly during the cOiNfe'*v 7_

2. My family and I have lived at this address for.? ? years and in I

the general area of the Seabrook ple.nt for. M years. l

3. My family and T. ur.e the beaches near the seabrook plant for i

recreational activities from time to time during the year, and we engage in other leisure pursuits of varioun types within a few " j ' " ' 1 t/5 miles of the plant approximately ' days each year. l 4. I work at , which is miles of the plant, and I am required to travel near the plant on my way to work and at other times for business purposes. I ~ \\ I

5. I am a member of the New England Coalition on Nuclear Pollution because I am concerned about the liazards posed by nuclear power, and particularly by the Seabrook nuclear power plant, to my own health and safety and that of my family. 6. I authorize the New England Coalition on Nuclear Pollution to represent my interests in operating license hearings before the Nuclear Regulatory Commission concerning the Seabrook plant and in related proceedings. .., ' t, c < i,c r q Sworn and subscribed to before me thisI k day of N{M% 1981. h L, ~ ~ Notary \\ I' bli~c My commission expires CM 1) \\ Ct F2_ / e 4 e 4

O a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ) In the Matter of ) ) PUBLIC SERVICE COMPANY OF ) NEW HAMPSHIRE, et _al., ) Docket Nos. ) 50-443 OL (Seabrook Station Units 1 ) 50-444 OL and 2) ) ) CERTIFICATE OF SERVICE I hereby certify that copies ~0f PETITION FOR LEAVE TO INTERVENE BY THE NEW ENGLAND COALITION ON NUCLEAR POLLUTION have been served on the following by deposit in the United States mail, first class, postage prepaid this 18th day of November, 1981. Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas G. Dignan, Esq. Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 l l i ' ~ % s,..s William S. Jordan, III l l HARMON & WEISS 1725 I Street, N.W. Suite 506 Washington, D.C. 20006 l l ,}}

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