ML20147F510
| ML20147F510 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 09/28/1978 |
| From: | Blum S CAROLINA ENVIRONMENTAL STUDY GROUP |
| To: | |
| References | |
| NUDOCS 7810200008 | |
| Download: ML20147F510 (5) | |
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UNITED STATES OF AMERICA 2
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- NUCLEAR REGULATORY COMMISSION p
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q gW4 In the Matter of
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DUKE POWER COMPANY
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(Amendment to Materials License
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Docket No. 70-2623 SNM-1773 for Oconce Nuclear Sta- )
tion Spent Fuel Transportation
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and Storage at McGuire Nuclear
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Station)
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CONTENTIONS OF CAROLINA ENVIRONMENTAL STUDY GROUP Pursuant to.the Rules of Practice before the Nuclear Regula-tory Commission, Carolina Environmental Study Group (CESG) has heretofore filed a Motion which was taken as a request for hear-ing.
Further, we have filed a memorandum, explicating our posi-tion on our petition to intervene, in a document dated September 7,
1978.
In a Board Order, dated September 22, 1978, the Board required a supplement to petitions for leave to intervene includ-
.ing list of contentions.
CESG makes the following contentions:
Transportation of spent nuclear fuel from the Oconee facility to the McGuire facility le an environmental hazard, requiring an environmental impact statement, since it is a major federal action
.which threatens the health and safety of intervenors members and citizens of the entirc region between the two facilities, in that it increases the radiation dosage to the population therein in var-ious ways.
The NRC should seek to limit radiation dosage to the population, and therefore this permit should be denied.
Radiation dosage increases according to the surrounding population, the dis-tance of' transportation, the duration of transportation, the pack-aging of the product, and, potentiaily, by accidental breach of Ytl0 M oV
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t the container.
We contend that there is no need for transportation at all, since the Oconee facility occupies a large site, and onsite stor-age'should be possible and is greatly desirable.
If transporta-tion from the Oconee site is required, another site close by Oconee should be selected, in that the materials should travel for the least possible distance.
If spent nuclear fuel is to be transpor-ted, then applicant should be required to move only its oldest spent fuel, in that older fuel is less radioactive than newer spent fuel.
If transportation is required, then the times of travel should be specified so that there are the fewest other vehicles on the roads.
If transportation is required, a study should be made to determine the route which avoids all centers of population 1
and hazardous intersections or the best combination of these two goals.
Intervenor contends that no thorough study of potentially hazardous intersections has been made, and no route around them has been drawn.
In particular, on information and belief, the intersection of Interstate 77 and Interstate 85 is such a partic-ularly hazardous intersection, which will be traversed by trucks
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carrying spent nuclear fuel, if applicant has its way.
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l Intervenor further contends that the cask and truck packages have not been thoroughly and rigorously tested for purposes of determining reliability in highway accidents.
On information and belief, the particular cask to be used is not the cask that has been tested in highway accidents, or under such conditions.
Rather, it
-is a cask used for industrial usage within the plant.
The cask proposed is not one which would have resistance to high speed im-pact, and particularly to impact in the most vulnerable portions
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of the cask.
Intervenor further contends that no thorough study j
of radiation' dosage has been calculated from such cask and truck j
assemblics to persons likely to be in proximity to the cask and in particular to co-current travellers (in parallel lanes of in-terstate highways) or to persons stal]ed in traffic near such an 4
assembly (traffic jams in Spartanburg).
Intervenor contends that the foregoing requires a full scale environmental impact state-1 ment and study preparatory thereto.
Based on the foregoing contentions, Intervenor moves the l
Board to order applicant to prepare a full scale environmental impact statement.
Subsequent thereto, should applicant continue l
with its application, Intervenor moves'the Board to require App-l licant to keep spent nuclear fuel from Oconee at Oconce.
Should Board not require this, Intervenor moves the Board to restrict applicant as outlined in the foregoing contentions so that the spent nuclear fuel is transported as safely as possible.
Dated:
SeptemberSD-1978.
BLUM AND SilEELY by 4
SIZELLEY BLUM 0
418 LawBuilding 730 East Trade Street Charlotte, NC 28202 (704) 376-6591 t,
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<i:Y VERIFICATION l,1 s,,
Shelley Blum
, afflant herein, the attorney for Applicant, in the foregoing and attached
. series of Contentions, being first duly sworn, deposes and says that the affiant has read the attached material and knows the contents thereof; that the matters set forth therein are true of affiant's own knowledge except as to those matters alleged therein upon Information and belief, and as to those matters, the offiant believes them to be true.
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,s g stIELLEY B
M Subscribed and sworn to before me this M
day of
/~^ D, 19 et com 6 ha NOTARY f'UBLIC v
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CERTiflCATE OF SERVICE
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s I hereby certify that copies of the attached in tl} C aptioned ngtj'jl% & L e 1
been served on the following by depositing same in the"p te g atds ma,i,1 yi's Qep,$
aq 4
,2y day of x, o /r,,. z,, e 197f.
s Robert H. Lazo, Esq., Chairman Brenda Best Atomic Safety and Licensing Board Carolina Action 1710 East independence Boulevard 11, S. Hucicar Reaulatory Commission 6
Washington, n.c.
20555 Charlotte, florth Carolina 28205 Dr. Enn(th A. Luehke Jeremy Bloch Atomic Safety and Licensing Board Safe Energy Alliance 11 S. llutlear Regulatory Commission 1707 Lombardy Circle l
Washington, D.C.
20555 Charlotte, North Carolina 28203 Dr. Cadet H. Hand, Jr., Director Richard P, Wilson Boderla tiar i ne Iahoratorv of Californla Assistant Attorney General Post Office Box 2f 7 State of South Carolina i
91923 2600 Bull Street Bodega Bay, California 6
Columbia, South Carolina 29201 Mr.
Jesse L. Riley, President Carolina Environnental Study Group Chairman, Atom,ic Safety and Licen-85fi Henley Place sing Appeal Board Charlotte, Florth Carolina 28207 ti. S. Nuclear Regulatory Ccmm,ission Washington, D,C.
20555 rdward G. Ketchen, Esq.
Mr. Chase R. Stephens Counsel for NRC Regulatory Staff Docketing and Service Section Office of the Executive Legal Director Office of the Secretary U. S. lluclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington D.C.
20555 Chairman, Atomic Safety and Licen-William I..
Porter, Esq.
Associate General Counsel sing Board Panel U.S. Nuclear Regulatory Commission Duke Power Comnany Post Office Box 2178 Washington, D.C.
20555 Char 1ot te, t! orth Caroli na 28212 1
J. Michael McGarry, ill Debevoise and Liberman Anthony Z. Rolsman, Esq.
Idatural Resources Defense Council Suite 700 917 15th Street, N.W.
806 15th Street, llorthwest Washingten, D.C.
20005 Washington, D.C.
20005 b
SHELLEY BLUM