ML20052A275

Exceptions to ASLB Initial Decision.Certificate of Svc Encl

ML20052A275
Person / Time
Site:	Susquehanna
Issue date:	04/21/1982
From:	Halligan T CITIZENS AGAINST NUCLEAR DANGERS
To:
References
NUDOCS 8204280111
Download: ML20052A275 (2)

Text

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,, April 21, 1962,

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s UNITED STATES ~ OF AMEF.ICA NUCLEAR REGULATORY CO:0:ISSICN '

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e i BEFORE THE ATOMIC SAFETY AND LICE'! SING BOARD IN THE MATTER OF PENNSYLVANIA' POWER & LIGHT CO. BZPMICK ATOMIC PO'E PLANT AND SUSQUEHANNA U';ITS 1 & 2 ALLEGFENY ELECTRIC COOPERATIVE INC. DOCEIT NOS. 50-357 & 50-3EE CITIZENS AGAINST NUCLEAR DANGERS

' EXCEPTIONS ~ TO THE ASLB INITIAL DECISION AND' RESPONSE TO APPLICANTS OPPOSITICN TO EMERGENCY EVACUATION PLAN'iING In accordance with the directives and provisions of paragraphs nos. 224 and 225 of the ASLB Order (page- 118), served April 13, 1982 (and received April 16, 1982), the Citizens Against nuclear Dangers (CAND) hereby file exceptions to the Initial Decision of the ASLB.

A' brief in support of the exceptions shall be filed within the thirty day period allowed.

The main contention of CAND~ is that the ASLH did not comply with the national Environmental Protection Act (NIPA ) in its decision esting, and as a result the Initial Decision is flawed!

The ASLB has published a less than meticulous document that does not address the requirements of NEPA.

The ASLB did not evaluate the environmental assessments that are relevant to the several contentions under review in this. license application case.

The ASLB did not take into consideration available alternatives, which is the basic process of decision making mandated by NEPA.

m The Initial Decision is laced with phrases that are t o; complete opposite of the true facts. 9 O

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/ .- - 2 The Nuclear Re6ulatory Commission, the Applicants, and especially the Commonwealth of Pennsylvania played major roles in concealing facts about adverse environmental impacts that the public was entitled to know under federal and state environmental ' laws, which in turn the AS_B should have elicited and evaluated.

The issues and contentions in this case do not involve minor technicalities, they involve major public health and safety issues.

1 Thus, 'CAND is justifiably concerned when the ASLB does not take the relevant environmental laws seriously. The NEC and its boards are ob11,6ated under.NEPA to ref rain from manipuistin6 the data in thei.r ..

findin6s and conclusions in the Initial Decision in a misleading fashion. It appears, however, that this ASL3 report is the end resu'_t of a fixed predetermination to Grant an operatin6 license!

Therefore, CAND will presently submit a brief taking exception with certain of the ASLB conclusions and findin6s. They will be identified with particularity, and the ASLB will be petitioned to revise certain parts of the Initial Decision in conformity with NEPA.

~ Respectfully submitted I

%J DLn Dated: April 21, 1989 "orrespondeny jr CERTIFICATE OF SERVICE I hereby certify that copies of Citizens Acainst Nuclear dan'gers Exceptions To The ASLB Initial Decision And Response To Applicants Opposition To Emergency Evacuation Plannine have been served. on all parties to this proceeding by deposit in the U.S~. mail, first class, this 21st day of March,1982

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