ML20082D801

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Corrected Page 26 of 831118 Brief Opposing State of Nj Public Advocate Contention
ML20082D801
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 11/21/1983
From:
Public Service Enterprise Group
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20082D798 List:
References
NUDOCS 8311230056
Download: ML20082D801 (1)


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(FES S5.2) as well as accidental releases (FES 57), it is incum-bent upon the Public Advocate to demonstrate significantly new information which would affect thc earlier analyses before this issue may be litigated. It is not sufficient for an intervenor simply to criticize an EROL as insufficient in detail.52/

Even assuming th-t this issue could properly be raised at the operating license stage, the bases cited by the Public Advocate, for example, the 1972 BEIR Report of the National Academy of Sciences, only serve to demonstrate that these well understood impacts are generic and raise no issue unique to Hope Creek.L"3/ Further, the AEC concluded in the Hope Creek FES:

The AEC staff has estimated the probable radionuclide releases from the Hope Creek Station based upon experience with comparable operating reactors and an evaluation of the radwaste system.54/

Evaluating radiological impact to man based upon average annual dose to the population, the AEC concluded:

Using conservative assumptions, the total man-rem from all effluent 52/ Moreover, the regulations themselves provide that the EROL need not repeat matters previously covered at the construc-tion permit stage. 10 C.F.R. S51.21.

5,3/ " Routine releases" constitute a generic problem and, as such, may not properly be considered in this proceeding, unless the intervenor can present "the best available evidence on health effects where this would seem important to the decision." See Public Service Company of Oklahoma (Black Fox Station, Units 1 and 2), CLI-80-31, 12 NRC 264, 277 (1980). Absent some showing of " specific environmental impact," compliance with Appendix I should govern. See Boston Edison Company (Pilgrim Nuclear Power Station, Unit 2), LBP-81-3, 13 NRC 103, 209-10 (1981).

54_/ FES S5.2.2.1.

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