|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20057G2071993-10-13013 October 1993 NRC Staff Response to Cajun Electric Power Cooperative,Inc Contentions.* Denies Util Petition for Hearing & Request to Intervene Due to Failure to Raise Contention Admissible for Hearing Under Stds Set in 10CFR2.714.W/Certificate of Svc ML20056G5371993-08-31031 August 1993 Cajun Electric Power Cooperative,Inc Amend & Suppl to Petition for Leave to Intervene,Comments & Request for Hearing.* W/Certificate of Svc ML20056G5021993-08-27027 August 1993 Response of Gulf States Utils Co to Cajun Electric Power Cooperative,Inc Amend to Petition to Intervene & Request for Hearing & License Conditions.* W/Certificate of Svc ML20056E7031993-08-17017 August 1993 Cajun Electric Power Cooperative,Inc Amend to Previously Filed Comments,Petition for Leave to Intervene & Request for Hearing & Conditions,On Notice of Consideration of Issuance of Amend to Ol,Proposed Nshc....* W/Certificate of Svc ML20056E7981993-08-0606 August 1993 Cajun Electric Power Cooperative,Inc Comments,Petition for Leave to Intervene & Request for Hearing & Conditions on Notice of Consideration of Issuance of Amend to OL & Proposed NSHC Determination....* W/Certificate of Svc ML20107K6961984-11-0707 November 1984 Motion to Reopen Record & Admit Three Contentions for Litigation Re Applicant QA Breakdown & Lack of Character & Competence to Operate Plant.Svc List Encl ML20098G5411984-09-28028 September 1984 Motion to Withdraw 12 Proposed Emergency Planning Contentions.Contentions Resolved by Enactment of State of La Act 825 & Revs to Peacetime Radiological Response Plan. Certificate of Svc Encl ML20087M4861984-03-26026 March 1984 Answer Opposing Joint Intervenors 840309 Contentions Re Offsite Emergency Planning.No Contention Meets Basis & Specificity Requirements of 10CFR2.714.W/svc List ML20082J1021983-11-28028 November 1983 Response Opposing Joint Intervenors 831108 Motion to Reopen Contention 8/9 Re Synergism Issue.Aslab No Longer Has Jurisdiction Over Subj Issue.Motion Fails to Meet Legal Stds for Motion to Reopen.Certificate of Svc Encl ML20078Q8361983-11-0707 November 1983 Motion to Reopen Contention 8/9 Re Synergism.Commission Rept on Cause of Disease & Possibility That Conditions Exist at Facility Requested.Certificate of Svc Encl ML20085D7021983-07-22022 July 1983 Motion to Reopen Contention 22 in Light of Newly Discovered Evidence ML20085D7211983-07-22022 July 1983 Memorandum Supporting Motion to Reopen Contention 22 Re Cracks in Plant Foundation.Plant Is Sui Generis.Safety Implications Re Plant Built W/O Pilings on Cracked Slab Unknown.Certificate of Svc Encl ML20079R2121983-06-13013 June 1983 Response to NRC & Util Answers to First Amended & Supplemental Contentions.Contentions Filed in Timely Manner. Certificate of Svc Encl ML20072A6281983-06-0707 June 1983 Answer Opposing Joint Intervenors 830531 First Amended & Supplemented Contentions.Unauthorized Filing Seeks to Add New Contentions Beyound Time Prescribed by Aslb.Contentions W/O Merit.Certificate of Svc Encl ML20073J6591983-04-15015 April 1983 Answer Opposing State of La,Louisiana Consumer League, Louisianans for Safe Energy & Gr Rothchild Contentions & Therefore Petitions to Intervene.Contentions Inadequate or Premature.Certificate of Svc Encl ML20069F0861983-03-15015 March 1983 Suppl to Petition to Intervene,Listing Contentions. Certificate of Svc Encl ML20070F8291982-12-17017 December 1982 Response in Opposition to State of La 821202 Motion for Extension of Time within Which to File contentions.Thirteen- Month Delay Would Significantly Interfere W/Timely Completion of Hearing.Certificate of Svc Encl ML20079N5381982-12-15015 December 1982 Proposed Contentions Re Financial & Technical Qualifications,Environ Qualification,Induced Seismic Activity,Prematurity of Application,Liquid Pathway Study & Generic Safety Issues.Svc List Encl ML20070H1601982-12-15015 December 1982 Contentions of State of La.Certificate of Svc Encl ML20066E9691982-11-12012 November 1982 Answer Opposing Joint Intervenors 820612 Motion to Reconsider & Reopen & State of La 820721 Petition to Intervene.New Contentions Must Be Rejected Per Commission 821108 Statement of Policy.W/Certificate of Svc ML20058J5181982-08-10010 August 1982 Response Supporting State of La 820721 Petition to Participate as Interested State,But Opposing Admission as Intervenor Except in Table S-3/high Level Waste Issue. Certificate of Svc Encl ML20062F7421982-08-0909 August 1982 Response Opposing State of La 820721 Petition to Intervene. No Good Cause Shown for Untimely Attempt to Raise Emergency Feedwater Sys Waste Disposal Issues.Certificate of Svc Encl ML20058D6631982-07-21021 July 1982 Petition to Participate as Interested State in OL Proceedings & to Reopen Proceedings to Precipitate Commission Rulings Consistent W/Recent Court of Appeals Decision.Notices of Appearance & Certificate of Svc Encl ML20054B6771982-04-15015 April 1982 Petition to Participate as Interested State.Specific Aspects of Subj Matter Listed.Certificate of Svc Encl ML20042B4211982-03-22022 March 1982 Answer Opposing Louisianans for Safe Energy 820306 Amended Petition.Affidavits Do Not Meet Necessary Showing of Personal Concrete Injury in Fact Required to Grant Standing.Certificate of Svc Encl ML20011A1081981-09-30030 September 1981 Petition to Intervene in Proceeding.Affidavit & Certificate of Svc Encl 1993-08-06
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20057G2071993-10-13013 October 1993 NRC Staff Response to Cajun Electric Power Cooperative,Inc Contentions.* Denies Util Petition for Hearing & Request to Intervene Due to Failure to Raise Contention Admissible for Hearing Under Stds Set in 10CFR2.714.W/Certificate of Svc ML20056G5371993-08-31031 August 1993 Cajun Electric Power Cooperative,Inc Amend & Suppl to Petition for Leave to Intervene,Comments & Request for Hearing.* W/Certificate of Svc ML20056G5021993-08-27027 August 1993 Response of Gulf States Utils Co to Cajun Electric Power Cooperative,Inc Amend to Petition to Intervene & Request for Hearing & License Conditions.* W/Certificate of Svc ML20056E7031993-08-17017 August 1993 Cajun Electric Power Cooperative,Inc Amend to Previously Filed Comments,Petition for Leave to Intervene & Request for Hearing & Conditions,On Notice of Consideration of Issuance of Amend to Ol,Proposed Nshc....* W/Certificate of Svc ML20056E7981993-08-0606 August 1993 Cajun Electric Power Cooperative,Inc Comments,Petition for Leave to Intervene & Request for Hearing & Conditions on Notice of Consideration of Issuance of Amend to OL & Proposed NSHC Determination....* W/Certificate of Svc ML20107K6961984-11-0707 November 1984 Motion to Reopen Record & Admit Three Contentions for Litigation Re Applicant QA Breakdown & Lack of Character & Competence to Operate Plant.Svc List Encl ML20098G5411984-09-28028 September 1984 Motion to Withdraw 12 Proposed Emergency Planning Contentions.Contentions Resolved by Enactment of State of La Act 825 & Revs to Peacetime Radiological Response Plan. Certificate of Svc Encl ML20087M4861984-03-26026 March 1984 Answer Opposing Joint Intervenors 840309 Contentions Re Offsite Emergency Planning.No Contention Meets Basis & Specificity Requirements of 10CFR2.714.W/svc List ML20082J1021983-11-28028 November 1983 Response Opposing Joint Intervenors 831108 Motion to Reopen Contention 8/9 Re Synergism Issue.Aslab No Longer Has Jurisdiction Over Subj Issue.Motion Fails to Meet Legal Stds for Motion to Reopen.Certificate of Svc Encl ML20078Q8361983-11-0707 November 1983 Motion to Reopen Contention 8/9 Re Synergism.Commission Rept on Cause of Disease & Possibility That Conditions Exist at Facility Requested.Certificate of Svc Encl ML20085D7021983-07-22022 July 1983 Motion to Reopen Contention 22 in Light of Newly Discovered Evidence ML20085D7211983-07-22022 July 1983 Memorandum Supporting Motion to Reopen Contention 22 Re Cracks in Plant Foundation.Plant Is Sui Generis.Safety Implications Re Plant Built W/O Pilings on Cracked Slab Unknown.Certificate of Svc Encl ML20079R2121983-06-13013 June 1983 Response to NRC & Util Answers to First Amended & Supplemental Contentions.Contentions Filed in Timely Manner. Certificate of Svc Encl ML20072A6281983-06-0707 June 1983 Answer Opposing Joint Intervenors 830531 First Amended & Supplemented Contentions.Unauthorized Filing Seeks to Add New Contentions Beyound Time Prescribed by Aslb.Contentions W/O Merit.Certificate of Svc Encl ML20073J6591983-04-15015 April 1983 Answer Opposing State of La,Louisiana Consumer League, Louisianans for Safe Energy & Gr Rothchild Contentions & Therefore Petitions to Intervene.Contentions Inadequate or Premature.Certificate of Svc Encl ML20069F0861983-03-15015 March 1983 Suppl to Petition to Intervene,Listing Contentions. Certificate of Svc Encl ML20070F8291982-12-17017 December 1982 Response in Opposition to State of La 821202 Motion for Extension of Time within Which to File contentions.Thirteen- Month Delay Would Significantly Interfere W/Timely Completion of Hearing.Certificate of Svc Encl ML20079N5381982-12-15015 December 1982 Proposed Contentions Re Financial & Technical Qualifications,Environ Qualification,Induced Seismic Activity,Prematurity of Application,Liquid Pathway Study & Generic Safety Issues.Svc List Encl ML20070H1601982-12-15015 December 1982 Contentions of State of La.Certificate of Svc Encl ML20066E9691982-11-12012 November 1982 Answer Opposing Joint Intervenors 820612 Motion to Reconsider & Reopen & State of La 820721 Petition to Intervene.New Contentions Must Be Rejected Per Commission 821108 Statement of Policy.W/Certificate of Svc ML20058J5181982-08-10010 August 1982 Response Supporting State of La 820721 Petition to Participate as Interested State,But Opposing Admission as Intervenor Except in Table S-3/high Level Waste Issue. Certificate of Svc Encl ML20062F7421982-08-0909 August 1982 Response Opposing State of La 820721 Petition to Intervene. No Good Cause Shown for Untimely Attempt to Raise Emergency Feedwater Sys Waste Disposal Issues.Certificate of Svc Encl ML20058D6631982-07-21021 July 1982 Petition to Participate as Interested State in OL Proceedings & to Reopen Proceedings to Precipitate Commission Rulings Consistent W/Recent Court of Appeals Decision.Notices of Appearance & Certificate of Svc Encl ML20054B6771982-04-15015 April 1982 Petition to Participate as Interested State.Specific Aspects of Subj Matter Listed.Certificate of Svc Encl ML20042B4211982-03-22022 March 1982 Answer Opposing Louisianans for Safe Energy 820306 Amended Petition.Affidavits Do Not Meet Necessary Showing of Personal Concrete Injury in Fact Required to Grant Standing.Certificate of Svc Encl ML20011A1081981-09-30030 September 1981 Petition to Intervene in Proceeding.Affidavit & Certificate of Svc Encl 1993-08-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20205D4901999-02-22022 February 1999 Transcript of 990222 Informal Public Hearing on 10CFR2.206 Petition in Rockville,Md.Pp 1-105.Supporting Documentation Encl ML20155E1631998-09-25025 September 1998 Petition Per 10CFR2.206 Requesting That Plant Be Immediately Shut Down & OL Suspended or Modified Until Such Time That Facility Design & Licensing Bases Properly Updated to Permit Operation with Failed Fuel Assemblies ML20202F0081997-11-28028 November 1997 Order Approving Transfer of License for River Bend Station, Unit 1 ML20211P2771997-10-15015 October 1997 Application of RR Mabey,Chapter 11 Trustee for Cajun Electric Power Cooperative,Inc,For Transfer & Amend of License ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements RBG-42925, Comment on Draft Reg Guide DG-5007, Perimeter Instrusion Alarm Sys. Word Splices Should Be Changed to Terminations1996-05-29029 May 1996 Comment on Draft Reg Guide DG-5007, Perimeter Instrusion Alarm Sys. Word Splices Should Be Changed to Terminations ML20097D8631996-02-0909 February 1996 Suppl to Withdrawal of Contention & Motion for Termination of Hearing of RR Mabey,Chapter 11 Trustee for Util.* W/Certificate of Svc ML20100D2221996-01-25025 January 1996 Withdrawal of Contention & Motion for Termination of Hearing of RR Mabey,Chapter 11 Trustee for Cajun Electric Cooperative,Inc.* W/Certificate of Svc ML20096G4991996-01-16016 January 1996 Joint Motion to Suspend Procedural Schedule.* Requests That Procedural Schedule in Proceeding Be Suspended,Pending Action by Bankruptcy Court at Following Scheduled Hearing on 960122.W/Certificate of Svc ML20113G0751995-10-26026 October 1995 Transcript of Interview of J Fisicaro on 951026 in St Francisville,La ML20093G3461995-10-10010 October 1995 Joint Motion to Extend Hearing Date & Scheduling Order.* Trustee & Gsu Request That Prehearing Schedule & Hearing Schedule Be Revised So That All Depositions Be Completed by 960623.W/Certificate of Svc TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20113G0631995-07-27027 July 1995 Transcript of Interview of J Mcgaha on 950727 in St Francisville,La ML20113G0601995-07-21021 July 1995 Transcript of Interview of CR Maxson on 950721 in St Francisville,La ML20113G0421995-07-20020 July 1995 Transcript of Interview of Dn Lorfing on 950720 in St Francisville,La ML20113G0371995-07-19019 July 1995 Transcript of Interview of as Soni on 950719 in St Francisville,La ML20086P6501995-07-17017 July 1995 Joint Motion to Extend Hearing Date & Amend Scheduling Order.* Requests That Prehearing Schedule & Hearing Schedule Be Revised.W/Certificate of Svc ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20113G0671995-06-16016 June 1995 Transcript of Interview of Wj Fountain on 950616 in St Francisville,La ML20113G0541995-06-15015 June 1995 Transcript of Interview of Jc Maher on 950615 in St Francisville,La ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20083M7811995-05-10010 May 1995 Submits Request for Reevaluation of Cities of Benton,Conway, North Little Rock,Osceola,Prescott & West Memphis,Arkansas & Farmers Electric Cooperative Corp on Anti-Trust Issues ML20080G8241995-02-0606 February 1995 Cajun Electric Power Cooperative,Inc Answer in Opposition to NRC Staff Response in Support of Gsu Motion for Summary Disposition.* Requests That Aslp Find Staff Response Inadequate.W/Certificate of Svc ML20078C7131995-01-23023 January 1995 Cajun Electric Power Cooperative,Inc Answer in Opposition to Gulf State Utilities Company Motion for Summary Disposition.W/Certificate of Svc ML20078C7821995-01-23023 January 1995 Cajun Electric Power Cooperative,Inc Concise Statement of Matl Facts to Which Genuine Issue Exists Accompanying & Supporting Answer to Gulf State Utilities Company Motion for Summary Disposition.W/Certificate of Svc ML20078C7261995-01-19019 January 1995 Affidavit of WT Ullrich on Behalf of Cajun Electric Power Cooperative,Inc.* Affidavit Re Past Performance of & Future Decommission Plans of Plant ML20078C7441995-01-19019 January 1995 Affidavit of Jm Griffin on Behalf of Cajun Electric Power Cooperative,Inc.* Affidavit Re Past Performance of & Future Decommission Plans for Plant ML20078C7861995-01-0909 January 1995 Gulf States Util Co Statement of Undisputed Facts in Support of Motion for Summary Disposition.* Util Intends to Safely Operate Plant within Requirements of Operating License ML20082H2341995-01-0909 January 1995 Gulf States Utilities Co Motion for Summary Disposition.* W/Certificate of Svc ML20077C0911994-11-17017 November 1994 Gsu Co Answer to Cajun Electric Power Cooperative 941107 Motion to Compel.* Requests Denial of Cajun Electric Power 941107 Motion for Reasons as Stated.W/Certificate of Svc ML20076N3141994-11-0707 November 1994 Util Motion to Compel Responses to follow-up Discovery Requests & Answer to Motion for Protective Order.* Util Requests That ASLB Issue Order Against Gsu/Eoi Re Discovery Responses.W/Certificate of Svc ML20076N4991994-10-31031 October 1994 Gulf States Utilities Co Second Supplemental Response to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* W/Certificate of Svc ML20078C9751994-10-28028 October 1994 Gsu Objections to Cajun Electric Power Cooperative,Inc Followup Discovery Requests & Motion for Protective Order.* Cajun Electric Power Discovery Requests Relate to Matters Outside Proper Scope.W/Certificate of Svc ML20078D3291994-10-28028 October 1994 Gulf States Utilities Company Second Supplemental Response to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories,Dtd 940908.* W/Certificate of Svc ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20080A2971994-10-13013 October 1994 Gulf States Utilities Company Supplemental Responses to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* W/Certificate of Svc.Related Correspondence ML20024J3081994-10-0303 October 1994 Cajun Electric Power Cooperative,Inc Motion to Compel Responses to Interrogatories & Production of Documents.* Requests Board to Issue Order Against Gsu Compelling Production of Listed Items.W/Certificate of Svc ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20073H2071994-09-30030 September 1994 Answer of Util to Motion to Compel Production & Provide for Addl Info Discovery.* Informs That Motion Should Be Denied. W/Certificate of Svc ML20073H0931994-09-29029 September 1994 Gulf States Utils Co Motion to Compel Answers to Interrogatories & Document Production Requests & for Other Relief*. Requests That Board Grant Util Addl Time to Conduct follow-up Discovery Based on Responses.W/Certificate of Svc ML20073H2301994-09-26026 September 1994 Notice of Appearance.* Undersigned Attys Enter Appearances in Proceeding.W/Certificate of Svc ML20073H2701994-09-22022 September 1994 Gsu Objections to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* Objects to Identified Interrogatories & Cajun General Instruction B.W/ Certificate of Svc.Related Correspondence ML20073H2121994-09-21021 September 1994 Gulf States Util Co Responses to Cajun First Request for Production of Documents Dtd 940822.W/Certificate of Svc. Related Correspondence ML20073H2631994-09-20020 September 1994 Gulf States Util Company Responses to Cajun Electric Power Cooperative,Inc Second Set of Interrogatories Dtd 940908.* Related Correspondence ML20072Q5061994-09-0606 September 1994 Gulf State Utilities Company Objections to Cajun Electric Cooperative,Inc. Interrogatories,Dtd 940822.* Gsu Objects to General Instruction B of Cajun Requests for Production of Document.W/Certificate of Svc.Related Correspondence ML20072Q4881994-09-0202 September 1994 Gsu Co Responses to Interrogatories Dtd 940822.* Informs That Responses Subj to Objections Filed by Util Dtd 940906. Related Correspondence ML20072P2201994-08-26026 August 1994 Gulf States Utilities Co First Request for Production of Documents to NRC Executive Director of Operations.* Requests Production of Documents as Listed.W/Certificate of Svc. Related Correspondence ML20072P2051994-08-26026 August 1994 Gulf States Utilities Co First Set of Interrogatories & Request for Production of Documents to Cajun Electric Power Cooperative,Inc.* Requests Production of Listed Documents. W/Certificate of Svc.Related Correspondence ML20072P2381994-08-26026 August 1994 Licensee Request for Board Approval of Written Interrogatories to Be Answered by NRC Personnel.* W/Certificate of Svc ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission 1999-02-22
[Table view] |
Text
e .
l l
00LKETED UNITED STATES OF AMERICA l"3NRC
,. NUCLEAR REGULATORY COMMISSIQ#
BEFORE THE ATOMIC SAFETY AND LICENSING BOM D DEC 22 A10 59
- ? . r .. 7 IN THE MATTER OF Docket Nos. 504458 OL; A SEir.'h 50-459 OIldl'4 GULF STATES UTILITIES COMPANY, et al (River Bend Station, Unit 1 and 2) (ASLBP No. 82-468-01-OL)
CONTENTIONS OF THE STATE OF LOUISIANA The State of Louisiana, appearing herein through William J. Guste, Jr. and other undersigned counsel, respectfully subiaits the following contentions:
CONTENTION 1 Applicants have " failed to allow for proper consideration of the uncertainties concerning the long-term isolation of high-level and transuranic wastes, and
... failed [ed] to allow for proper consideration of the, health, socioeconomic and cumulative ef f ects of f uel-cycle activities."1
- Basis Under the provisions of the National Environmental l l
I NRDC v. NRC, Civ. Action No. 74-1586 (D.C. Cir., April 27, 1982), slip opinion, pp. 11-12.
8212230192 821215 PDR ADOCK 05000382 C PDR 3
, e s
\
- 9, Pol-icy Act, (NEPA) 42 USC 4332 et,sig., i t las clearly required "that environmental conceras be integrated into the very "
)
process of agency decisionmaking" and that " environmental values and consequences [must] have been considered during;the planning stage." It is further clear under NEPA that the ,
contribution of the fuel-cycle to the environmental costs of ,
licensing an individual nuclear power reactor must be 3 considered. Applicant has failed to consider, and has not , ,
shown, the environmental cost of the uranium fuel-cycle with respect to River Bend Station, Unit 1.
CONTENTION 2 Applicants emergency plans do not provide reasonable assurance that appropriate measures can and will be taken in the event of an emergency to protect public health and safety and prevent damage to property.
Basis 10 CPR Part 50, Appendix E - Emergency Plans for Production and Utilization Facilities, Part III "The Final Safety Analys'.J Report" provides:
"The Final Safety Analysis Report shall contain plans for coping with emergencies.
The details of these plans and the details of their implementation need not be included, but the plans submitted must include a description of the elements set out in section IV [ Content of Emergency Plans] to an extent sufficient to demonstrate that the plans provide reason- ,
able assurance that appropriate measures 3 can and will be taken in the event of an ,
I s
} ,
)
V - g
, M a*
i
, q u~. ;
' emergency to protect public hqgil th and safety and prevent damage to property."
In its FSAR, Sec. 13.' 3, " Emergency Planning," applicant has
,'\ % , _;%
A faiUid ' to atfeguately address the requirements of 10 CFR Part a
50, Appendix E, III and I V, especially with respect to the evacuatibn ,is of, personnel, with special reference to patients in s East9l L'ouisiana State Hospital, and prisoners in Pointe Coupee fg g Parish Jail, West Feliciana Parish Jail and Dixon Correctional l' ) 1 3, '
.s Institute.
, CONTENTION 3 3.
Applicant has failed to adequately consider the
,\ effect of a release of radioactive materials into surface and
( ground drinking water supplies.
3 Basis c River Bend Station, five (5) miles south of St.
Francisville, Louisiana, is situated geographically and geologically in such a manner that release of radioactive 4 ,
materials would hava the potential to affect both surface drinking water supplies, namely the Mississippi River, and ground drinking water supplies, namely the Baton Rouge Regional Acquifer.
~,'
The Mississippi River serves as the sole source of 1 -
) drink. ir.g water for approximately 1 1/2 - 2 million people (the h fig'ure varies due to the seasonal influx of visitors, tourists a
6 and workers) and numerous commerical enterprises using this
'i wg'ter for food and beverage preparation and production, down s' s ,
f
- / '
l
, \,N
'\ t 7 )' [
(, m\ ' f -
e
- riv,er from St. Francisville, and additiopally is used by numerous industries which discharge varying quantities and types of effluents into the river. River Bend Station is directly situated on top of a shallow acquifer known as the Shallow Upland Pleistocene Terrace Deposit which recharges directly into the Mississippi River. Applicant has failed to adequately consider the effect of an accidental or planned release of radioactive materials on the health and welf are of those persons for whom the Mississippi River is the sole source of potable water, and has additionally failed to adequately consider the synergetic effect of such radioactive materials combining with industrial effluents discharged into the river.
Further, River Bend Station is situated in the recharge zone of the Baton Rouge Regional Acquifer, which is the sole source of drinking water for in excess of 400,000 1
persons and numerous commercial enterprises using this water !
l for food and beverage preparation and production. Applicant has failed to consider the effect of the contamination of the Baton Rouge Regional Acquifer by radioactivity on the health I and welfare of those persons and commercial enterprises for 1
whom this acquifer is the sole source of potable water. !
l CONTENTION 4 Applicants have not adequately considered the offect of a failure of the Old River Control Structure on the
4 safe operation of River Bend Station, Unit 4.
Basis l It is common knowledge to residents of South l
Louisiana that the Mississippi River is attempting to divert its flow in the vicinity of Torras, Louisiana, and divert its l course to and through the Atchafalaya River and onward to the Gulf of Mexico and is prevented from doing so only by an antiquated and structurally questionable barrier known as the Old River Control Structure. Should this structure fail, the Mississippi River would naturally divert its course away from its present channel, seriously reducing the flow of water through its present channel.
Applicants have failed to adequately consider the consequences of such a failure on the safe operation of River Bend Station, Unit 1, specifically, the effect of a reduced flow on the intake of cooling water, on the relative increase in thermal pollution resulting from the discharge of cooling water into a reduced volume of river water, and the effect of salt water intrusion into the cooling system.
CONTENTION 5 Applicant has failed to consider the effect of the resumption and continuation of construction activities on Unit 2 on the safe operation of Unit 1.
Basis
. T' 3 Section 1.1, " Introduction," of the Applicant's FSAR, Vol. 1 reads in pertinent part on page 1.1 -1 that:
" Unit 1 is scheduled for completition in Octobe'r 1983, and commercial operation is expected to begin in April 1984. Unit 2 is currently not scheduled and construction has been halted."
There is no indication has to whether or not construction has been permanently halted, or whether or not construction will resume again on Unit 2. It is therefore reasonable to assume that applicant may resume construction on Unit 2.
10 CFR 50. 34 (b) (6) (vii) provides:
"On or after February 5, 1979, applicants who apply for operating licenses for nuclear powerplants to be operated on multiunit sites shall include an evaluation of the potential hazards to the structures, systems, and components important to safety of operating units resulting f rom construction activities, as well as deceription of the managerial and administrative controls to be used to provide assurance that the limiting conditions for operation are not exceeded as a result of construction activities at the multiunit sites."
Applicant must therefore " include an evaluation of the potential hazards to the structures, systems, and components important to the safety of operating units resulting f rom construction activities" on Unit 2 as they will affect operations of Unit 1.
L 1
Respectfully submitted,
- WILLIAM J. GUSTE, JR.
Attorney General g BY: /
If DOUGL'ASgNDS$Y ff A3sistant Anorney GenerM Department of Justice Lands and Natural Resources
< Division 7434 Perkins Road, Suite C Baton Rouge, Louisiana 70808 (504) 766-8610 Dated at Baton Rouge, Louisiana, this 15th day of December, 1982 h
i I
i
- ..-.= .- . - - - - - . - -.. . - . - - . - . -
~
UNITED STATES OF AMERICA NUCLEAR REGULATORY ~ COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L
IN THE MATTER OF Docket Nos. 50-458 OL 50-459 OL GULF STATES UTILITIES COMPANY, et al (River Bend Station, Unit 1 and 2) ( ASLBP No. 82-4 6 8 0 L)
CERTIFICATE OF SERVICE I hereby certify that I have mailed, by first class mail, postage prepaid, the Contentions of the State of Louisiana to each Board member, all parties, and appropriate Commission' offices this 15th day of December, 1982.
\
. M TAN D00GLASg fNDSET Assistant .Rtorney Gener
- ____ _ _ _ _ _ _ _ _ _ _