ML20083J131
| ML20083J131 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 01/10/1984 |
| From: | Bell N NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8401160199 | |
| Download: ML20083J131 (5) | |
Text
couETED us s 14 J$ 12 M0:03
- UNITED STATES OF AMERIC.^.
NUCLEAR REGULATORY COMMISSION BEFCRE THE ATOMIC SAFETY AND LICENSING g-Q,[A BR In the Matter of
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WASHINGTON PULwIC POWER SUPPLY SYSTEM
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Docket No. 50-5080L
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(WPPSS Nuclear Project No. 3)
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INTERVENOR'S FURTHER SUPPLEMENT TO PETITION FOR LEAVE TO INTERVENE, DATED JANUARY 10, 1984 Pursuant to Memorandum and Order of the Licensing Board in the above-captioned case,, dated December 6, 1983, the Coalition for Safe Power (Coalition) hereby submits the information required by the Atomic Safety and Licensing Appeal Board Order of November 15, 1983 (ALAB-747) vacating' a portion of the Licensing Board's April 21, 1983 Order granting the Coalition's untimely petition for leave to intervene.
The Coalition asserted in its criginal Petition that it would make a valuable contribution to the proceeding as. required by f actor three of 10 CFR 2.714(a); the Appeals Board remanded the matter, requiring a further showing by the Coalition.
The Coalition had stated that it had a former WPPSS worker who would participate in the proceeding and was in the process of identifying other expert witnesses in the areac of radiation, health physics, geology, seismology, hydrology, engineering, fisheries and nuclear safety.
Petition at 7, 8.
In its brief on the appeal, the Coalition further clarified that the former WPPSS werker was Stuart Sandler.
Intervenor's Answer to Applicant's Appeal, dated October 27, 1983 at 7.
The Answer also named several other consultant / witnesses and potential witnesses.
8401160199 840110 03 PDR ADOCK 05000500 0
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Answer at 7, 8, 9.
This inf ormation is incorporated by reference as supplemental information in support of the Petition.
As explained therein, retention of witnesses requiring substantial fees has not occured due to the construction halt at the project.
If the proceeding goes forward, the Coalition intends to call - tha f ollowing witnesses:
- 1. Stuart Sandler of Portland, Oregon, to support accepted
' contention Nos. 11 & 12, admitted by Licensing Board Order dated September 27, 1983.
MF. Sandler is a welding engineer, educated at. Ohio State University with experience in nuclear construction sites, including WPPSS Nuclear. Project No.
2, and certif.ied by the American Welding Society in SMAW and GMAW processes.
Mr.
Sandler is an e': pert in matters of quality assurance of welding, in particular the assurance that applicable codes and standards
-are incorporated in welding and quality assurance procedures.
Mr. Sandler will review (f or the purpose of assisting in the preparation of cross-examination as well as direct testimony) the procedures utill:ed at WNP-3 f or welding and welding inspection and will testify on whether industry standards have been used.
Mr. Sandler will also review QA/QC and NRC inspection documents and testify on the quality of weldments at the project.
2.
Jack Smith: PhD of Portland, Oregon, to support accepted contention No. 16.
Dr. Smith is an aquatic toxicologist with
' graduate degrees from Harvard University.
Dr. Smith has broad experience with analysis of discharges into waterways, the control of chemical pollutants and the ecological impacts.
Dr.
V Smith' acted as a consultant to the Coalition, providing the L
[ primary research for contention 16, as stated therein.
Dr.
Smith's initial review of the Applicant's application and NRC Staff review documents is summarized as sollows:
The tolerance levels used by the Applicant (Environmental Report Sections'5.1 and 5.3) for a variety of fish and other aquatic organisms are with one exception lethal limits.
The' concept of sublethal but still damaging temperatures or chemical
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concentrations is ignored.
Similarly, the concept of synergistic
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impacts of'the present combination of individually toxic substances 'is ignored.
In table 5.3-1 either the average or the maximum' projected mixing one concentrations of the heavy metals
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are in excess of EPA water quality criteria with the maximum projected discharge levels of nickel in excess of either the EPA I
Water-Quality Criteria or the WNP-3 NPDES permit. The actual
. situation may be f ar worse than reflected in the table due to use i
of improper ambient concentrations.
Furthermore, if the duration of the low flow condition is expected to be on the order of 7 days (see footnote page 5.3-1) the situation represented as i
maximum would more nearly in fact become average during.this period.
Also in table 5.3-1, the maximum chlorine concentration is-projected to be 2.5 times greater than the EPA Water Quality Criteria of.O.OO2 ppm.
I Dechlorinization of cooling water blowdown is to be achieved l
by reduction with sulfer dioxide.
Wnile the ef f ects of sulf ate resulting from this reaction are discussed, those of the more
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toxic sulfite are ignored, assuming unrealistically that all the i
sulfer dioxide will be consumed in the reduction.
While it is stated (pg. 5.1-6) that "during normal plant operation, little or i
no nutrients will be added and no effect on the aquatic ecosystem will occur" phosphorous concentrations in the river will be increased significantly.
A relatively well documented phosphorous threshold for slowly flowing waters is 0.05 ppm and since ~ the phytoplankton population in the Chehalis River is already reported to be dominated by blue green algae (pg. 5.1-3) which~do not require nitrogen for metabolism the additional phosporous would be expected to result in additional growth of these algae.
These are some of the significant water quality and aquatic biology conflicts which have not yet been resolved.
The information provided in this supplement, including j
references to the Answer filed by the Coalition on October 27, 1983', is in no way a representation of the Coalition's entire case.
The Coalition reserves the right to expand on the scope of
. the testi mony of the above-named experts, to utilize additional
d.
experts and to base its case in part on cross-examination and other trial procedures.
Respectfully. submitted, Dated this' day, the~10th M_
of January, 1984 Nina Bell, Staff *Intervenor
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UNITED STAT.ES-OF AMERICA 00yEcg 2 NUCLEAR REGULATORY COMMISSION 9b9P
.BEFORE'THEATOMICSAFETYANDLICEgN
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LFFICE Dr SE,-a WASHINGTON PUBLIC POWER SUPPLY SYSTEM
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MWEEkt3 Ndii<50-5080L 3 RANCH (WPPSS Nuclear Project No. 3)
- )
CERTIFICATE' OF SERVICE I hereby certify that copies of "INTERVENOR'S FURTHER SUPPLEMENT TO PETITION FOR LEAVE-TO INTERVENE., DATED JANiiARY 10, 1984" in L
the above-captioned proceeding'have'been servad on the following by deposi t in the United. States ' mail, first class. postage
. prepaid, this 10th of._ January, 1984.
.Morton Margulies, Chairman Gerald Sc.enson,' Manager Atomic Safety & Licens2ng Board
. Washington Public Power Supply Nucle'ar Regulatory Commission 3000 G.
Washington Way Washington D.C.
20555 Ri chl an :1, WA 99352 Frederick J.
Shon Dr. James Carpenter Atomic Saf ety & Licensing 1 Board Atomic Gafety & Licenssi.g Board Nucl ear Regul atory ' Commi ssi Sn Nu, clear Regulatory Commission Washington D.C.
20555 Washington D.C.
20555 Nicholas Reynolds
. Nicholas D.1 Lewis Debevoise & Liberman EFSEC Chairman 1200 17th Street NWI' Ma'11 Stop PY-11 Washington D.C.
20^'6 Olympia, WA 98504 Donald Hassell, Counsel Docketing & Service Section Executive Legal Di.ector Nuclear Regulatory Commission Nuc) ear Regulatory Commission Washington D.C.
20555
.t Washington D.C. 20555 Atomic Safety & Licensing Appeal Atomic Safety & Licensing
, Board _ Panel Board Panel _
Nuclear Regulatory Commission Nuclear Regulatory Commission Washington D.C.
20555 Washington D.C.
20555 Kevin Ryan Attorney General *n Office Mail Stop AQ-04 Temple of Justice Ol ympi a, WA 98504 I
L ina Bell '
Coalition for Safe Power i