ML18026A047

Letter Enclosing Petition for Leave to Intervene And/Or Request for Hearing

ML18026A047
Person / Time
Site:	Susquehanna
Issue date:	09/07/1978
From:	Marsh C Citizens Against Nuclear Dangers
To:	Silberg J Office of Nuclear Reactor Regulation, NRC/SECY, Shaw, Pittman, Potts & Trowbridge
References
Download: ML18026A047 (8)

Text

September 7, 1978 Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D, C. 20555 Attention: Docketing and Service Section s6' >>gs >

Executive Legal Director

'U. S, Nuclear Regulatory Commission ~~pl> ~

Wa&ington, D. C. 20555 Jay Silberg, Esq.

Shaw, Pittman, Potts, Trowbridge and Madden 1800 M, Street, N, W, Washington, D. C, 20036 RE: PP5,L Co., et al.

Docket Nos. 50-387 and 50-388.

Dear Gentlemen:

Enclosed please find a copy of Petition for Leave to Intervene and/or Request for Hearing in thc above matter.

Sincerely,

In He: l~cnnsylvania Vow<<r 8. Light. Co. C LE A R RL'G U J ATORY and Allegheny Electric cooperative, Inc. COMMISSION Susquehanna Steam Electric Station, Units 1 and 2. DOCKET NOS, 50-387 and 50-388 PETITION FOR LEAVE TO INTERVENE AND/OR REQUEST FOR HEARING

. NOW come Petitioners, in accordance with 10 CFR Section 2. 714 et seq and Petition the United States Nuclear Regulatory Commission as follows:

1., Petitioners, adult individuals and sui juris, are residents of the Commonwealth of Pennsylvania, whose names and addresse's are more par-ticularly set forth in Schedule ".A", attached hereto and made a part hereof by r'eference thereto.

2. Petitioners reside in or about the County of Luzerne, Pennsyl-vania within a 50-mile radius of the proposed premises situate Salem Town-ship, Luzerne County, Pennsylvania whereupon Pennsylvania Power and Light Company and Allegheny Electric Cooperative, Inc. (hereinafter referr-ed to as "Applicants" ) desire to possess, use and operate two.boiling water nuclear reactors known as the Susquehanna Steam Electric St'ation,. Units 1:

and 2 (hereinafter referred to as "Facilities" ).

3. Petitioners are proper parties to this proceeding under the Atomic Energy Act of 1954 (the'"Act") as the nature of their right is based upon con-siderations of health, safety to persor'r and property, finance and environment not only of Petitioners, but of those members of the public who reside in Un-restricted Areas (as defined by the Act) in and about and/or surrounding', and in all events within 50 miles of the geographic area of the Facilities proposed by Applicants.

4. 'The interests of Petitioners which would be affected by the Appli-cants'ossession, use and operation of the proposed Facilities are as follows, to wit:

A. An unreasonable risk of harm to the'health and safety'of,Petition'crs, and other membersr.of the public as hereinbefore'stated; B. An unreasonable risk of harm to the safety of the private property of Petitioners and others, and the public property located with th6 50-mile radius of Facilities; C. The increased cost of electricity, to be borne by Petitioners and others of the public who are customers of Applicants. is far greater than other electr'icity produced by existing forms of energy;

e page 2 D. The outPut of elect,ricity to be Produced by the Pr Qposed Iiacji ities of Applicants, in relation to cost, will be lower than electricity gener ated by existing forms of energy and therefore more expensive to Petitioners and others; E. The environment within the aforesaid geographic area of 50 miles may be contaminated and square miles of land and water may become useless all to the detriment of Petitioners and others.

5. The facts nnd circumstances upon which Petitioners hase thrit Petition are's follows:

'A. Applicants'roposed Facility violated this Commissions Standards for Protection Against Radiation set forth in 10 CFR 20. 1 et seq., and in par-ticular, 10 CFR Section 20. 105 (a) which provides for permissible levels in unrestricted areas and the envi'ronment around the Facilities.

B., Applicants'Summary of Environmental Consequences" (full range of accidents reported under N. R. C. =guidelines), filed with this Commission, sets forth in its Table 7. 1-17 "Assessment of Likelihood of Event" that 'ass

8. 1" accidents involving "small pipe" or "large pipe" are "extremely rare" whereas these accidents are common to the design of Applicants'acilities, the probability or likelihood is great, and the effluents emitted into the sur-rounding geographis areas would be in amounts and quantities prohibited by 10 CFR 20. 1 et scq..

C. Applicants design of &acilitics fails to resolve the problem of re-actor coolant pump overspeed in thc boiling water reactors, and thereby poses an unreasonable risk of harm to the health and safety of Petitioners and others.

D. Applicants have failed to ad quately respond to and,comply with this Commission's Notice of Violation issued to Applicants by letter of May 10, 1978, stemming from inspection of Facilities March 20-23, 19~V8, involving preliminary alignment of safety related core insolation= tolerance exceeding . 002 inches estab-lished by field engineer supervisor.

E. Applicants have failed to adequately respond to, and comply with letter of June 27, '1978 directing response to I. E. Bulletin.Number this'ommission's 78-10 in Re: Bergen Paterson product defects.

F. Applicanth'peration and use of Facilities i,s more costly and less efficient than the generation of electricity by existing forms of energy.

G. Applicants'peration and use of Facilities as proposed creates an unreasonable risk of har'm to Petitioner s and the public which outweighs those

pAgo benefits derived by permitting the Applicants to proceed with the Facilities.

V H. The applicants fail to adequately provide plans for informing. the public as to evacuation. proceduzes including drills and warnings in the event of radiation leakage.

6. An order by this Commission granting Applicants a facility oper-ating license for the Facilities would adversely affect the interests of Peti-tioners, as herein set forth, by permitting Applicants to possess, use and operate the aforesaid Facilities.

7. Petitioners desire to intervene in these proceedings as they re-

)ate to the specific items listed or identified herein.

WHEHEFOHE, the Petitioners respectfully request they be permitted to intervene in these proceedings, or in the alternative, be granted a hearing with respect to the issuance of'the operating license as the same relates to the interests of'Petitioners.

STATE OF PENNSYJ,.VANIA SS:

COUNTY OF LUZERNE 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~~day of September, 1978.

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THE SECRETARY OF THE COHNISSION

" 'US; NUC'LEAR: REGULATORY COHNISSION 9 DOCKETED USN2C ~ rica ~g ~ rr!<<<<=-

ATTN DOCKET I!NG AND SERVICE SECTION C,

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FO THE CITIZENS AGAINST NUCLEAR DANGERS (THE CI TIZENS) i,BERWICK PENNSYLVANIA HEREBY PETITION To INTERVENE BEFORE THE NUCLEAR REGUlATORY COH~ISSION IN THE APPLICATION FOR 4 FAC LITY OPERATING LICENSE FROH PENNSYLVAN?4 POWER AND LIGHT COHPANY AND 4LLEGHENY ELECTRIC COOPERATIVE INCORPORATED (DOCKET 450"367 4ND 450~368) TO OPERATE THK SUSQUEHANNA STEA<<i FLECTRIC STATIONS UNIT ONE AND TWO (BER~ICK PLANT) LOCATED AT SALEw TowNSHIP PENNSYLVANIA THK CITIZENS ALSO REQUEST THAT. PUBLIC HE4RINGS BE CONDUCTED BY THE NRC Ihl THIS" 'CASE. THE CITIZEtIS HAVE ACTIVELY PURSUED DEVELOPMENTS AT THE BERWICK PLANT FOR SEVERAL YEARS IN THE PUBLIC INTEREST, aND THE PUBLIC INTEREST I'IILL DEFINITELY BE EFFECTED BY THESE PROCEEDINGS, THEREFOREi THE CITIZENS SEEK STANDING IN THIS CASE BEFORE THE NRC ~

THE CITIZENS SPECI'FY THE REASONS WHY INTERVENTION SHOULD BE PERMITTED AS THg FOLLOAINGp

,1, THE MARKET VALUE AND PROPERTY RIGHTS OF CITIZENS IN THE EFFECTED AREAS ARE PLACED It< JEOPARDY BY THE BKRWICK PLANT

2. IF THE PUBLIC INTEREST IS To BE SERVED PUBLIC TESTIHONY IS REQUIRED UNDER THE RIGHT OF DUK PROCESS GUARANTEED BY THE US CONSTITUTION 3 THE EFFEcTs oN THE ENvIRONHKNT BY THE BERwicK PLANT HILL LINGER FGR GENERATIONSi AND THE EIS RUST BE CAREFULLY AND SCIENTIFICLY EVALUATED NOWT PL/<<NT THIE SAFETY OF THE SYSTKHS AND WODES OF DELIVERY AT THE BERWICK PLANT ARE THK PROPE;R SUBJECT FOR TESTIMONY BY EXPERTS>> WHICH THE CITIZKNS wILL PRESENT BEFORF THK NRCa THE CITIZENS IDENTIFY THE SPECIFIC ASPECTS OF THE SUBJECT I'IATTER AS THE PROBABLE DANGERS TO PUBLIC HK4LTH AND

• SAFFTY FROW THE OPERATION OF THE BERWICK PLANT CONCERNING>

STORAGE OF RADIOACTIVE FUEL 4ND R4DIOACTIVE WASTE ON THE PREMISES 2, TRANSPORTATION OF RADIOACTIVE MATERIALS TO 4ND FROH THK BERWICK 3 ~ CATASTROPHIC BREAKDOWN<<IN 4T THE BERWICK PI.ANT 4 ~ 'DEQUACY OF EVACUATION PLANS IN CASE OF ENERGENCIES 5 ~ OTHER KNVIRONNKNTAL HEALTH DANGERS c

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HRS IRENE LEHANOWICZ CHAIRPERSON TO REPLY BY MAILGRAM, SEE REVERSE SIDE FOR WESTERN UNION'S TOLL - FREE PHONE NUMBERS

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THE C IT IZENS AGAINST NUCLEAR DANGERS PO BOX 377 RD i.

BERN I CK PA 18603 22:O5 EST NGNCOt"P HGH TO REPLY BY MAILGRAM, SEE REVERSE SIDE FOR WESTERN UiVION'S TOLL - FREE PHONE blUMBERS