ML20049H523
| ML20049H523 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/22/1982 |
| From: | Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8203030258 | |
| Download: ML20049H523 (8) | |
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BEFORE THE COMMISSION In the Matter of
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Docket No. 50-397 1
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REQUEST FOR A HEARING g
j On February 5,1982 an Order Extending Construction Completion Date -
Washington Public Power Supply System Nuclear Project No. 2 (WNP-2),
dated danuary 27, 1982, was published in the Federal Register granting the request made by the Washington Public Power Supply' System on Sep-tember 4, 1981.
Pursuant to 10 CFR 50.55(b), 10 CFR 2.714 and as cla-rified by correspondence between Mr. Eugene Rosolie, Coalition for Safe Power and Mr. A. Schwencer, Chief, Licensing Branch #2, Division of Licensing, Nuclear Regulatory Commission on November 27 and. December i
2,1981 the Coalition for Safe Power (Coalition) requests a public j
hearing be held in this matter.
Petitioner The Coalition for Safe Power is a non-profit citizens organization, founded in 1969, to work for safe energy.
Its work includes research and education.
The Coalition, through its officers a/d attorneys,..has i
represented its members before the Commission, as wel.1 as state agen-cies, on questions of nuclear power safety and licensing and electric utility rates.
The Coalition has been granted full party status in four proceedings before the Commission, has filed several Show Cause and rule-making petitions and currently has a petition pending before the Commission on WMP-4.
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Interest The interests of the Coalitior are predicated on the interests of its members. The Coalition has at least one member residing within a 20-1 mile radius of the WNP-2 plant, others who reside within a 60-mile ra-dius and yet others who live throughout Oregon and Wash-in'gton.
Certain of these members live within close proximity to the Columbia River, on which the facility is located.
Members of the Coalition are ratepayers whose electric bills include payments for WNP-2 through Bonneville Po-I wer Adminstration charges.
Coalition members live, work, travel and recreate in close proximity to WNP-2.
Members eat foodstuffs grown and produced in areas that would be impacted upon negatively by the poten-tial operation, normal or otherwise, of WNP-2. The Coalition's work itsel f is conducted in part in Richland, Washington due to the location of the Local Public Document Room there.
Affidavits from some of these members are attached hereto.
Effect upon Interest The above-stated intersts of the members of the Coalition, and thus the Coalition itself as 'their representative, are affected by the continued construction ~and potential operation of the facility.
To date, construc-
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4 tion at WNP-2 has been poorly managed, inadequate to assure public safety, and conducted under severe financial constriints.
There is no reason to believe that any of these three aspects of WPPSS construction has im-proved or will change.
Thus, the continued construction and possible operation of WNP-2 will impact on Coalition members interests by placing on them economic burdens, danger of loss of life, employment and happi-ness, and increased health hazards.
Furthermore, full public hearings on the extension of the construction permit completion dates would be in the public interest.
Much public
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s attention and concern has been focused on the WPPSS plants, particularly on WNP-2 due to its history of safety problems.
The people of the North-west are aware that the plant has suffered construction difficulties but -
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do not know, and are concerned with',' the ' extent of the potertial danger
' osed by the continued construction and hotential operation of the faci-p t
lity.
A public hearing at this time on whether there is in fact good i
i cause to grant an extention for completion dates would allow issues of
~ mangement, fiancial ability and plant safety, all of which have affecte'd WPPSS's ability-to complete the plant within the original. provisions of the Construction Permit, to be examined in a contested ca.se hearing with expert witnesses provided by both Licensee and intervening pafties.' Thus, both the interest of Coalition members and the general public interest would be served by granting the Coalition's rr for hearing and pe-3 tition for leave to intervene.
Specific Aspects & Contentions The specific aspects of the Order $xtending Construction Completion Date -
WNP-2 which will affect the interests of petittioners include the fol.
lowing:
Health and Safety
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- 1. Delays of 12 months due to WPPSS violations.of NRC regulations do not-constitute good cause.
The Licensee was granted 'a construction permit on the basis of their ability to construct a safe nuclear plant.
- 2. The NRC Staff ignored its cwn inspection reports and enforcement ac-tions in wrongly concluding that good cause existed in granting the'WPPSS request.
- 3. The NRC Staff ignored WPPSS's construction history in concluding that f
t "neither the probability nor the consequence of postulated accidents i
previously considered will be increased nor will any safety margins as '
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sociated with this facility be -decreased."
- 4. WPPSS lacks the techni, cal ability to complete and/or operate the -
facility in.a safe manner.
Management
- 5. Delays in construction have been under full control of WPPSS manage-ment.
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- 6. WPPSS lacks the management ability to complete and/or operate the facility in a safe manner.
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Financial
- 7. WPPSS lacks the financial ability to-complete and/or-operate the facility in a. safe-manner.
8.
NRC Staff ignored WPPSS's' financial condition in concluding that "neither the probability nor the consequence of postulated accidents previously considered will be increased nor will any safety margins associated with this facility be decreased."
Concl u-ions This request meets the requirements of 10 CFR 2.714 and is a matter of i
great public interest in the region and therefore should be granted.
l Respectfully submitted, i-Dated this 22nd day of Februa ry, 1982.
CoaMtion f6,ie Eugyp* Rosol r Safe Power i
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STATE OF OREGON
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I, Eugene Rosolie, being first duly sworn, do depose and say as follows:
That I am the Director of the Coalition for Safe Power and its duly authorized representative and that the foregoing petition was prepared under my supervision and direction and that, to the best of my knowledge and belief, it and the facts contained therein are true and correct.
WW Euggpe Rospie, Director CoaTition for Safe Power 8
SUBSCRIBED AND SWORN to before me this 8 0 day of' February, 1982, q
A A 2be V 2 Notary Public for Oregon My Commission Expires: 2./3/86
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UNITED STATES OF AMERICA CWcd NUCLEAR REGULATORY COMMISSION I.
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BEFORE THE COMMISSION
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In the Matter of
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1 WASHINGTON PUBLIC POWER SUPPLY
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Docket No.50-397 SYSTEM
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(WPPSS Nuclear Project No. 2)
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CERTIFICATE OF SERVICE I
areby ce.rtify that on February 23, 1982, Coalition For Safe Power's REQUEST FOR A HEARING has bedn served upon the persons listed below by depositing copies thereof in the United states mail with proper first class postage.
l Harold Denton, Director Office of Nuclear Reactor Regulation j.
l U.S. WRC Washington D.C.,
20555 Secretary of the Commission U.S. NRC Washington D.C.,
20555 Exective Legal Director U.S. NRC l
Washington D.C.,
20555 Robert Ferguson WPPSS 3000 Ceorge Washington Way Post Office Box 968 Richland Washington,99352 An // o E
Eugehe Rosolie Dated this 23rd day of Coalition For Safe Power February, 1982