ML20055B133
| ML20055B133 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/16/1982 |
| From: | Sugarman R SUGARMAN & ASSOCIATES |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8207200393 | |
| Download: ML20055B133 (2) | |
Text
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0 EO SUGARMAN & DENWORTH,-
W'E 803 ATTOR N EYS AT LAW RO D E RT J. SUG AR M AN suet C 680. NORTee ase g n sC AN SU L OING
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July 16, 1982 68 8
4 Mr. A.
Schwencer Chief, Licensing Branch #2 Division of Licensinc U.S. Nuclear Regulatory Commission Washington D.C.
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5 Re:
Del-Aware-NRC, Docket Nos:~ 50-352/353; Request for Additional Information - Point Pleasant Diversion Plan (July 9, 1982)
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Dear Mr. Schwencer:
b if-I have received a copy of your letter of July 9, 1982 I
addressed to Mr. Edward Bauer, relating to the Point Pleasant Diversion Plan.
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I wish to comment to you concerning the intentions of the staff with respect to the dimensions of its inquiry concerning the Point Pleasant Diversion Plan.
Your request indicates that the staff will
" consider any environmental impacts associated with changes to the Point Pleasant Diversion s
Plan".
It does not indicate clearly whether this includes the 5
addition of the Point Pleasant Diversion Plan to the scope of the staff's inquiry as a
change in the
- plan, but the implication is that only physical changes in the plan since issuance of the construction permits will be included in the staff's evaluation.
Such a limitation on the scope of inquiry by the staff is unjustifiable, in Del-Aware's view, under the l
Board's decision of June 1, 1982, and the facts and law.
j I,
therefore, wish to urge upon you the recognition 4
of the fact that the Point Pleasant Diversion Plan was not j
considered at all (except with respect to increased water-pf diversion) in 1974 because it was assumed that Point' Pleasant would be built with or without Limerick.
Since that is no I
longer the case, it is necessary for the staff to review e
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fi Mr. A. Schwencer -
f Page 2 July 16, 1982 Point Pleasant ab initio', and to evaluate the environmental impacts of the plant as a whole, as well the alternatives l
thereto.
In view of the Board's accelerated consideration of contentions related to operational impacts associated with changed circumstances regarding Point Pleasant and the
$2.206 Request filed by Del-Aware, both referenced in the second paragraph of your letter, it is respectfully submitted that your inquiry should be broadened to include these considerations, and that broadening should take place immediately.
Sincerely l
\\
l Robert J.
Sugarman RJS/nk cc:
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