ML20077M308

Suppl to 830630 Request for OL Hearing & Petition to Intervene.Contentions Propounded.Certificate of Svc Encl

ML20077M308
Person / Time
Site:	Beaver Valley
Issue date:	09/06/1983
From:	Johnsrud J Environmental Coalition on Nuclear Power
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8309120299
Download: ML20077M308 (4)

Text

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, , ENVIRONMENTAL COALITION ON NUCLEAR FOWER Co-Directors: Ms. Phyllis zitzer-Box 761, Pottstown, Fa. 19464 215 326-9122 00KEJE0 h

Dr. Judith Johnsrud-433 Orlando Avenue, State College,N 16601814 237 3900

! UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '83 g g ,

Before the Atomic Safety and Licensing Board In the Matter of )

DUQUESNE LIGHT COMPANY, et al .

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I ( Beaver Valley Nuclear Power Station, Unit 2) "'

0e 1g en e SUPPLEMENT TO THE REQUEST OF THE ENVIRONMENTAL COALITION ON NUCLEAR POWER FOR AN OPERATING LICENSE HEARING AND PETITION FOR LEAVE TO INTERVENE In accordance with the Memrandum and Order of the Atomic Safety and Licensing Board (ASLB), dated August 4, 1983, the Environmental Coalition on Nuclear Power (ECNP) here supplenients its June 30th,1983, Request for an Operating Licensing Hearing and Petition for Leave to Intervene.

At page four of its Memorandum and Order, the . Board states, "It is requested of Staff that it have set up promptly a local Public Document Room in State College, Pennsylvania of the type sought by ECNP.' The ECNP representative has now delayed completion of this filing for more than a month, in the expectation that the Board's order would be ful filled. According to the librarian of the Schlow Menorial Library on September 6,1983, no documents pertaining to Beaver Valley have been provided..

as of that date. ECNP has therefore been severely hampered in its ability to comply with the Board's schedule for the filing of contentions, due to other responsibilities and transportation limitations. We request the Board to permit additions to this filing, within reasonable limits , after the Staff has fulfilled its obligations to provide the documents and records pertindnt to this proceeding.

ECNP members residing within the fifty-mile radius of Beaver Valley 2 have been not -

jfied to submit affidavits regarding their interest and authorization of this organiza-tion to act on their behalf. Those affidavits are being sent to the Board Chairman separately.

The following matters are raised in contoe. tion that the Beaver Valley Unit 2 reactor should not receive an Operating License or be permitted to operate until these issues have been properly and completely resolved.

1. It is contended that interrelated financial associations and ownerships among the Applicant, the reactor vendor and other suppliers, specifically the Westinghouse Corporation, and financial institutions, specifically the Mellon Bank headquartered in Pittsburgh, are sufficiently great to constitute conflicts of interest with respect to the safe construction and quality of equipment utilized in the construction of 8309120299 830906 PDR ADOCK 05000412 G PDR G[]

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! Beaver Valley 2 and with respect to adequate assurance of safe operation of the plant.

2. It is contended that the economics of safe disposal of radioactive wastes that will be generated by the operation of Beaver Vallay 2 remain uncertain and that, in the continuing absence of either approved sites or demonstrated effeetiveness of such waste disposal, the Beaver Valley 2 nuclear reactor must not be permitted to receive an operating license. This cost uncertainty has not been fully and pmperly evaluated in the cost-benefit comparison with alternatives to the reactor as is

. required by the National Environmental Policy Act of 1969, and as is indicated in the California decision by the Supreme Court.

3. In view of the uncertainties remaining about the costs of safe disposal of the radioactive wastes generated by the Beaver Valley 2 reactor, the Applicant's pro-jections of sales of electricity to be generated by this plant are not adequate or accurate enough to sustain the issuance of an operating license for Beaver Valley 2.

4. The failure of the Commonwealth of Pennsylvania to assure the provision of safe

. isolation of low level radioactive wastes which will be generated by the Beaver Valley 2 reactor, the failure of the Applicant to provide assured isolation of such wastes, and the mandate of the Congressional Low Level Radioactive Waste Policy Act of 1980 that each state must be responsible for the management of these wastes after January 1, 1986, taken in combination, give insufficient assurance that the low level wastes which will be generated by the operation of Beaver Valley 2 will be properly and safely isolated from the environment; hence, the license must be denied.

5. It is contended that the health effects caused by the emission of radon gas into, the environment as a msult of the mining and milling and mill tailings piles created in support of the annual operations of Beaver Valley 2 remain uncertain in the absence of resolution of this issue (10 CFR 51.20 (e) Table S-3), and that the long-tem

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impact of this radon gas will be unacceptably detrimental to the health of future human beings. Absent resolution of this issue by the Courts, a license to operate Beaver Valley 2 should not be granted.

6. It is contended that the issue of systems interaction has not been resolved by the Nuclear Regulatory Commission and that the uncertainties of safe operation of Beaver Valley 2 are therefore too great to pemit issuance of an operating license for this reactor until the Comission has actually solved this issue.

7. It is contended that operability of auxiliary equipment necessary to the safe operation and shutdown of Beaver Valley 2 is dependent in part upon non-safety grade equipment whose performance cannot be relied upon to provide adequate protection of the public.

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8. It is contended that the probability and consequences of tce ocrurrence of pressurized thermal shock in Beaver Valley 2 have been inadequately and incompletely addressed by the Nuclear Regulatory Commission. In the absence of demonstrated proof testing in sufficient quantity to establish a margin of certainty, the risk of major accident to Beaver Valley 2 from this cause remains too great to permit the issuance of an operating license.

9. It is contended that the operational record of Beaver Valley 1 constitutes a basis 63r uncertainty as to the management capability of the Applicant to operate safely two reactors at this site. In the absence of improved performance of management, an operating license for Beaver Valley 2 should be withheld.

10. Evacuation planning and emergency response capability in the event of an accident exceeding design basis are insufficient to assure the health and safety of the public. A license should be withheld pending demonstration of full evacuation in which the entire population within the emergency planning zont has participated under adverse conditions constituting a worst case evacuation.

11. The potential for cumulative radiation exposures of residents of the Beaver Va'lley area in excess of perraitted levels as a result of the cperation of the two Beaver Valley units plus activities _ associated with the proposed and pending decom-missioning of Shippingport has not been properly assessed. Until the Applicant has demonstrated that such potential multiple exposures will not result in adverse health effects for the residents of the surrounding area, an operating license should not issue.

Respectfully submitted, fiaW/0/ -/Auml -

Dr. Judith H. Johnsrud fj Representative for the ECNP Petitioners Dated this O S* day of September,1983 D

O CERTIFICATE OF SERVICE C0j.gf I certify that copies of SUPPLEMENT TO THE REQUEST OF THE ENVIRONMENTAL COALITION ON NUCLEAR POWER FOR AN OPERATING LICENSE HEARING AND SlTISFfbg9 P3 :44 FOR LEAVE TO INTERVENE have been served on the parties by express mail or deposit in the U.S. Mail, first class, this 1bday of Septemktk)bI$Nd.i BRANCH

/96!? O Yw-l SERVICE LIST i

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! Morton B. Margulies, Chairman William A. Lochstet Atomic Safety and Licensing Board 119 East Aaron Drive U.S. Nuclear Regulatory Commission State College, Pennsylvania 16801 Wa.hington, D.C. 20555 George S. White Administrative Judge Ernest E.. Hill Box 58 210 Montego Drive Shippingport, PA 15077 Danville, California 94526 Ralph F. Walker Administrative Judge Paul W. P'urdom 1518 Fifth Street 235 Columbia Drive New Brighton, PA 15066 Decatur, Georgia 30030 Susan L. Hiatt Robert Perlis, Esquire 8275 Munson Road Office of the Executive Mentor, Ohio 44060 Legal Director U.S. Nuclear Regulatory Commission Jay Silberg, Esq.

Washington,-D.C. 20555 Shaw, Potts , Pittman , & Trowbridge .

l 1800 M Street NW Washington, D.C. 20036 {

Atomic Safety and Licensing Board Panel Thomas D. Aees, Esquire .

U.S. Nuclear Regulatory Commission Deputy Ge..eral Counsel Washington, D.C. 20555 17th Floor, Harristown 2 333 Market Street Atomic Safety and Licensing Appeal Harrisburg, PA 17120 Board Panel U.S. Nuclear Regulatory Commission Maxine Woelfling, Esquire Washington, D.C. 20555 Assistant Counsel 505 Executive House Docketing and Service Section Post Office Box 2357 Office of the Secretary Harrisburg, PA 17120 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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