ML20042A919
| ML20042A919 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 03/18/1982 |
| From: | Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8203240273 | |
| Download: ML20042A919 (8) | |
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erve r-UNITED STATES OF AMERICA ~7 NUCLEAR PIGULATORY COMMISSION In the Matter of ) '52 l'P 22 P1 :19 WASHINGTON PUBLIC POWER SUPPLY Docket.No. 50-46 SYSTEM, et al. ) , , , - I -13,4
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(WPPSS Nuclear Project No. 1) ) / s) ~ 9 I.:'l .sD -
REQUEST FOR HEARING l I--
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- 1. The Washington Public Power Supply (teg S) , in a letter dated July 21, 1981, to Harold Denton, Director, Office of Nuclear Reactor Regulation from G.D. Bouchey, Director of Nu-clear Safety, requested amendments to Construction Permits Nos.
CPPR-134 and CPPR-174 for WNP-1 and WNP-4, respectively, to ex-tend the latest completion dates for construction of the projects.
- 2. Pursuant to 10 CFR 55.55(b), 10 CFR 2.714 and the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2239 (a) , the Coalition for Safe Power (hereinafter refered to as " Coalition") hereby requests that a public hearing be held into the Matter of Exten-sion of Construction Completion Date for WUP-1, Construction Per-mit No. CPPR-134.
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Petitioner ------~.
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- 3. The Coalition is a non-profit citizens organization,;; j i
founded in 1969 to work for safe energy. Its work includes re-f search and education. The Coalition, through its officers and !
attorneys, has represented its members before the Commission, M. s as well as state agencies, on questions of nuclear power safety and licensing and electric utility rates. The Coalition has-
/I been granted full party status in four proceedings before the -
Commission includina the original application for construction B203240273 820318 PDR ADOCK 05000460 0 PDR
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permits for the Skagit Nuclear Pro ccts, Units 1 and 2, applica-tion for construction permits for the Pebble Springs Nuclear Po-wer Plants, Units 1 and 2 and two license amendments for the ,
Trojan Nuclear Power Plant. The Coalition has also filed several Show Cause petitions with the Nuclear Regulatory Commission.
Interests of Petitioner
- 4. The interests of the Coalition are predicated on the interests of its members. The Coalition has at least one member -
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residing within a 20-mile radius of the WNP-1 plant, others who reside within a 60-mile radius and yet others who live throughout Oregon and Washington. Certain of these members live within close proximity to the Columbia River, on which the facility is
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located._ Hembers of the Coalition are ratepayers whose electric utility bills include payments for WNP-1 through Bonneville Po- .
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wer Adminstration charges. Coalition members live,. work, travel
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and recreate in close proximity to WNP-1. Members eat foodstuffs grown and produced in areas that would be impacted upon negatively by the potential operation, normal or otherwise, of WNP-1. The Coalition's work is conducted in part in Richland, Washington.
Affidavits of some Coalition members are attached hereto.
Effect Upon Interests of' Petitioners
- 5. The above-stated interests of the members of th~e Coalition, and thus the Coalition itself as their representative, are affected 4
by the continued construction and potential operation of the pro-i ject. To date, construction at WNP-1 has been poorly managed,, ,
inadequate to assure public safety and conducted under severe financial constraints. There is no reason to believe that any of these three aspects of WPPSS construction will improve. Thus,
! the constinued construction and possible operation of WUP-1 will
s impact on Coalition members interests by placing on them economic burdens, danger of loss of live, employment and happiness and increased health hazards.
- 6. Furthermore, full public hearings on the extension of the construction permit conpletion date would be in the public interest. Much public attention and concern has been focused -
on the WPPSS plants due to a history of safety problems. The people of the Northwest are aware that the plant has suffered construction difficulties but do not know, and are concerned with, the extent of the potential danger posed by the continued construction and potential operation of the project. A public hearing at this time on whether there is good cause to grant an extension for completion dates would allow relevant issues of management, financial ability and plant safety, all of which
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have affected WPPSS's ability to complete the project within the original provisions of the construction permit, to be examined in a contested case hearing with expert witnesses provided by both Permitee and intervening parties. Thus, both the interest of Coalition members and the general public interest would be served by granting the Coalition's request for hearings and peti-tion for leave to intervene.
Specific Aspects of the Subject Matter .
- 7. The specific aspects of an order extending construction completion dates, should it be' granted for WNP-1 which would af-fect the interests of petitioners includ'e the following:
- a. The Permitee was granted a construction permit on the basis of its ability to construct a safe nu-clear plant and has, thus far, failed to do so.
- b. The' Permitee lacks the technical ability to com-
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plete and/or operate the ,roject in a safe manner.
- c. Delays in construction have been under full control of Permitee management. .
- d. The Permitee lacks the management ability to complete and/or operate the facility in a safe manner.
'c. . The Permihee lacks the financial ability to complete
' and/or operate the facility in a safe manner. .
1 f. The current financial status of the Permitee is threatened by previously unforseen circumstances.
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- g. Newly instituted work' incentive programs may affect continued construction and pctential operation of the project.
' Conclusions
- 8. This request meets the requirements of 10 CFR 2.714
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and being'a matter of great public interest in the region should
' therefore be granted.
Respectively submitted, i h Dated this ! day of Eugg e Rop lie, Director
, March , 1982. Coalition for Safe Power
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1 ST\TE OF WASHINCTON )'
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2 County of mkt mA .
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3 T, Dohad P)o acN o. , beine first duly
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4 sworn, do depose and say as follows:
___ 5_ I-)- That__I n am a membe.r-of 5 the5 Coalition =for-05afe-+ Power-;c a-T n s --- -
6 2) That I reside at M. 2. b oX NO6
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7 ,AK M CL WMHiNGTON 98908 ; and 8 .'t) That I hereby authorize the Coalition for Safe Power, 9 throuch its officers and attorneys, to represent my interests '
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10 before the Nuclear Peculato'ry Commission on any matter per-
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11 tainine to nuclear units 1,2 or 4 of the Washington Public 12 i ower Supply System, the Skacit/Hanford nuclear projects, 13 uni ts 1 and 2 and the construction or operation of any other 14 nuclear rower facility at the Hanford Yuclear Reservation.
15 - Signed:
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18 SUBSCPTBPD AND SWOPN to before me this 7/ day of N! ,,, %
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20 - - -
. Notary ~
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22 Publif for Washincton[f[
My Commission Expires: 4 23 ..
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-Page -1 of AFFIDAVIT-- COALITION FOR SAFE POWER kCp . _ _ , . .. . . . , . i -, SU:TE 527 400 S.W. 2nd
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' 1.CTATE Of h'ASitTNeTON )
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2 founty of Benton ) _
3 T, M. Terry Dana , beine first duly
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4 sworn, do depose anci say as foilows:
5- 1 ) That- T--am-a.-member of = the Coali ti on=for Safe-fower ; . ~ ~ - - -------
6 2) That I reside at 777 Me!Srray Apt.11 7
Richland, Washincton 993$2 ; and 8 3) That I hereby authorize the Coalition for Safe fower, 9 throuch its officers and attorneys, to represent my interests c 10 before the 'Juclear Peculator,s Commission on any matter per-11 talnine to nucicar units 1,2 or 4 of the Washington fublic ,
12 1 ower c uiply System, the st<acit/lianford nuclear rrojects, 13 uni ts 1 and ? and the construction or oferation of any other 14 n6 clear rower facility at the -Ilanford Vuclear Reservation.
15 Siened:
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18 SUDECPTHr*) ANO S'<0PN to I efore me this 12th day of . ,
I 19 January , 1992 ,
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. Notary futlic for 'e ashi ncton p 22 My Commission f x; i res: /O Af Tr5 23 . .
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Ar f10 AVT t- CO/ U 10N FC2 S.VE .eOVIER h,- ~ ^
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1 STATE OF WASliTNCTON )
2 County of 1/ h iN e , )
w cy 3 T, I,arry caffin 7 v y4))1 , beine first duly 4 sworn, do depose and say as Tollows:
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l-)- That -T-am -a-member of the-Coalition- for Safe--fower; -
6 2) That I reside at [M/) '/ _-/ /dd. '
7 ; and 8 ?) That I hereby authorize the Coalition for Safe Cover, 9 throuch its officers and attorneys, to represent my interests "
10 before the 'Juclear P.eculatory Commission on any matter per-11 tainine to nuclear units 1,2 or 4 of the Washington fublic 12 i ower Surply System, the Skacit/Hanford nuclear projects, 13 uni ts 1 and 9 and the construction or operation of any other 14 nuclear rower facility at the 11anford Yuclear Reservation.
15 Siened:
-16 - - - - = - - = = - - - - - - - - - - - - -- -- ^ =-
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l 18 SUBSC"It!r7 AND SWOPN to before me this L/
y day of .
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. N'otary y6hlic for Fashi nston.
v y Commission Expires:
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'- Page 1 of 1 - AFFIDAVIT COAUTION FOR SAFE FCWER Hs . SU:TE 527 M S.W. Dd g;. -
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UNITED STATES Or ..MERICA "?
NUCLEAR REGULATORY COMMISSION In the Matter of ) 22 W 22 P1sp WASHINGTON PUBLIC POWER SUPPLY Docket No. 50-460- M I
SYSTEM, et al. ) CPPR-134
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(WPPSS Nuclear Project No. 1) )
-CERTIFICATE-OF-SERVICE -- -
-I hereby certify, that Coalition For Safe Power's " REQUEST FOR HEARING",
has been served, on March 18,1982; by placing said document in the United States Mail, first class, , postage pre-paid; on the follcwing persons:
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O Secretary of the Consission A. Schwencer, Chief U.S. Nuclear Regulatory Comunission Licensing Branch 2 Washington, D.C. 20555 Division of Licensing U.S. NRC Executive h gal Director Washington D.C. 20555 U.S. Nuclear Regulatory Conunission-- - - - -
Washington D.C. 20555 Robert Ferguson WPPSS 3000 George Washington Way P.O. Box %8 Richland Wa 99352
- Denotes original Eugfne Rosolic Coalition For Safe Power Dated this 18th day
- of March,1982
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