ML18025A076

Letter Enclosing Supplement to Petition for Leave to Intervene of Colleen Marsh Et Al Outlining and Listing Contentions

ML18025A076
Person / Time
Site:	Susquehanna
Issue date:	01/12/1979
From:	Marsh C - No Known Affiliation
To:	Silberg J Office of Nuclear Reactor Regulation, NRC/SECY, Shaw, Pittman, Potts & Trowbridge
References
Download: ML18025A076 (7)

Text

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January 12, 1979 Secretary of the Commission U, S. Nuclear Regulatory Commission Washington, D. C.

20555 Att'n.: Docketing on Service Section Executive Legal Director U. S. Nuclear Regulatory Commission Washingto'n, D. C.

20555 d"

0po Jay Silberg, Esquire Shaw, Httman, Potts, Trowbridge 8r. Madden 1800 M Street,, N.W.

Washington, D. C.

20036 Re:

P, P, 8r,L. Co.,

et al Docket Nos. 50-387 d 50-388

Dear Gentlemen:

Enclosed please find Supplement to Petition for Leave to Intervene and list of contentions in above matter.

Sincere ly,

< r, In Re:

Pennsylvania Power Light C and Alleghany Electric Cooperative, I Q.

Susquehanna Steam Electric Station,

. Units 1 and 2.

UC LEAR REGULATORY COMMISSION DOCKET NOS. 50-387 and 50-388 SUPPLEMENT TO PETITION FOR LEAVE TO INTERVENE OF COLLEEN MARSH ET AL,,OUTLINGAND LISTING CONTENTIONS NOW come Colleen Marsh and Eleven Others, Petitioners herein, and Supple-ment their Petition For Leave To Intervene to include the following contentions:

1.

The proposed project creates an unreasonable risk of harm to the health and safety of Petitioners and other members of the public due to the following specific reasons or bases:

A.

Applicants design fails to resolve the problem of pump flywheel missiles generated by coolant pump overspeed in the boiling water reactors which poses an un reasonable risk of harm to the health and safety of Petitioners and others.

The electrical braking proposed by Applicant is not sufficient to prevent this problem.

B.

Applicant fails to provide adequate on-site storage facilities in its design to safely store both high and low level radioactive materials.

The disign contemplates tempoxary storage on-site of low level materials, yet since no avenues remain open for applicant to dispose of al1, radioactive waste, spent fuel and materials elsewhere, the Applicant may have to store the spent materials longer, up to 10 to 15 years,,than it is prepared safely to contain and monitor for such a period of time on-site.

C.

Applicant has failed to provide, or demonstrate in its application, adequate plans for the safe transportation in connection with the radioactive materials produced in connection with the operation of Susquehanna Steam Electric Station.

D.

Applicant's design fails to solve the problem of flow-induced vibration in the core, thereby creating in-vessel sparger failure.

2.

Applicants proposed facilities creat+an unreasonable risk of harm to the private property of Petitioners and other members of the public located within 50 miles of facilities for all the reasons set for in Paragraph One, A-D of this Supplement to P etition.

3.

petitioners and the Public are exposed to unreasonable risk of harm to p ersonal safety and property due to the protection of the Power Company under the Federal Price-Anderson Act which limits its liability.

4.

Due to the facts and circumstances set forth in Paragraph'-One, A-D, Applicants proposed facilities violate this Commission's Standards for protection against radiation set down in 10CFR 20. 1 et seq.

and 10 CFR 20. 105 (a) which pro-vides for permissible levels in unrestricted areas and the environment around the Facilities.

0 page 2

5.

Applicants proposed Facilities are unreasonably costly and uneconomical both to Petitioners and the public due to the following reasons and bases:

A.

The output of electricity to be produced by the proposed facilities, in re-lation to cost, willbe lower than electricity generated by existing forms of energy and therefore more expensive to Petitioners and others.

B.

The projected cost of facilities of Applicant fails to account for, or in-clude, the expected cost of decommissioning the facilities after its estimated useful life of 30 years.

Such cost is at least equal to the cost of construction and willbe borne by future consumers and taxpayers.

C.

The facilities are unnecessary and wasteful as the electric capacity of PP&L in 1977 was 40% greater than customer needs and demands from existing facilities.

Latest projections'f energy use and requirements during the next 30 years for the PP8r.L service area, the period equal to the projected plants "useful life", show that PPRL can meet the needs of its customers through existing facili-ties and sources without investing in a costly and unreasonably dangerous nuclear facility.

D.

Pennsylvania UtilityCommission regulations would permit Applicant to base its rates, in part, according to capital. investment in facilities, and thereby double utilityrates for PPRL as its total investment for all facilities willbe doubled after completion of the projected facilities.

This cost willbe borne by local PPRL customers, yet the unneeded electricity willbe sold outside of the PPRL service area.

6.

The Applicants fail to adequately. provide plans for informing the public as to evacuation procedures including drills and warnings in the event of radiation leakage.

AFFIDAVIT STATE OF PENNSYLVANIA COUNTY OF LUZERNE SS:

The undersigned, being duly sworn, deposes and states that she is one of the Petitioners named in the within Petition, and that the facts there-in contained are true and correct to the best of her knowledge and belief.

Sworn to and subscribed before me this/4 day of Janu y -1979.,

~P(

KATHRYNF. FARRELL, Notary Public Wilkes Barre, Pa.

18701 Commission Expires Jan. 29, 1983

UNITED STATES OF AMERICA NUCLEAR R GULATORY CQ.+iISS IO.'n the Hatter of PENNSYLUA¹A POWER AND LXGEZ CO~ilPA<AY Docket No.(s) 50-387 50-388 (Susquehanna Steam Electric Station, Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that 1 have this day served the foregoing document(s) upon each person designated on the official serv'ce list compiled by the Office of the Secretary of the Commission in this proceeding in accordance. with the requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the Nuclear Regulatory Con ission's Rules and Regulations.

D"ted at Washingto

.C. t day of ffice t

p f the Secretary oz the Commission

UNITED STATES OP AMEP.ICA NUCLEAR REGULATORy COi 1ISS ION In the Matter of PFNNSVLVANIA POBFR A>D LIGHT COMPANY, ET AL.

(Susquehanna Steam Electric Station, Units 1 and 2)

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Docket No. (s) 50 387 50-388 SERVICE LIST Charles Bechhoefer,'sq.,

Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Dr. Judith H. Johnsrud Co. Director, Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Glenn O. Bright Atomic Safety and Licensing Board U.S.Nuclear Regulatory Commission Uashington, D.C.

20555 Hs. Colleen Harsh 558A R.D.

P4 Mount Top, Pennsylvania 18707 Dr. Oscar H. Paxis Atom"'c Safety and Licensing Board U.S". Nucl'ear P'egulat'ory Commxssi'on

>iashington, D.C.

20555 Counsel-:- for -NFC--'t~

--'ffice of the Executive Legal Director U.S. Nucleax Regulatory Commission

$i'ashington, D.C.

20555 Jay E. Silberg, Esq.

Shaw, Pittman, Potts 6 Troorbridge 1800 "MY Street, N.H.

Llashington, D.C.

20036 Hrs. Irene Lemano~'icz The Citi'zens Against Nuclear Dangers P.O.

Box 377 RD 1'em<ck'; Fenn'syIvani'a" 18603 "

Gerald Schultz, Fsq.

Susouehanna Environmental Advocates 500 South. River Street hilkes-Barre, Pennsylvania 18702 Hr. Thomas H. Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Commoncrealth of Pennsylvania P.O.

Box 2063 Harrisburg, Pennsylvania 17120