ML20010C077

Motion for Partial Summary Disposition of Contention 2 Which Questions Magnitude of Facility Low Level Radioactive Releases.Certificate of Svc Encl

ML20010C077
Person / Time
Site:	Susquehanna
Issue date:	08/13/1981
From:	Silberg J ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8108190095
Download: ML20010C077 (5)

Text

~

{q August 13, 1981 i

g~

UNITED STATES OF AMERICA

' d,y NUCLEAR REGULATORY COMMISSION f r.g

,D d.

\. #

'h' BEFORE THE ' ATOMIC SAFETY AND LICENSING BOARD (I ^D

- g'b In the Matter of ) $ h 7

) #

PENNSYLVANIA POWER & LIGHT COMPANY 4 g Docket Nos. 50-387 IW and ')

) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )

) '

(Susquehanna Steam Electric Station, ) @

)

4f Units 1 and 2) ff

%._? '

ot.

A UG 1 4 Iggg * :

-f ~ :i gy A APPLICANTS

• MOTION FOR PARTIAL

SUMMARY

DISPOSITION OF _,

- %'D4 h '6 CONTENTION 2 (SOURCE TERM) O N

Pennsylvania Power & Light Company and Allegheny Electric Cooperative, Inc. (" Applicants") move the Atomic Safety and Licensing Board, pursuant to S 2.749 of the Commission's Rules of Practice (10 C.F.R. S 2.749) and the Special Prehearing Conference Order i of March 6, 1979, LPB-79-6, 9 NRC 291, 328, for summary disposition in Applicants' favor of the portion of Contention 2 in this proceeding that questions the magnitude of the lew-level radioactive releases from the Susquehanna Steam Electric Station 3

("S usquehanna") and particularly the amounts of cesium-137 and c5 1

Sub-5ll ll cobalt-60 that will be released into the Susquehanna River.

sequent submittals by Applicants will address the doses resulting from these low-level radioactive releases and the health effects of such doses.

As grounds for their Motion, Applicants allege that there is no genuine issue of material fact to be heard with respect to the magnitude of such radioactive releases, and Applicants are entitled 8108190095 810813 PDR ADOCK 05000387 G PDR

W.

to a decision in their favor on ther,as a matter of law.

This Motion is supported by the Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard (Contention 2) (Source Term), and the Affidavit of John C.

Dodds, both filed simultaneously herewith, together with all pleadings and other papers in this proceeding.

As set forth in the March 6, 1979, Special Prc. hearing Conference Order, supra, 9 NRC at 328, responses to this Motion are due three weeks from its filing date.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 1 w- / hQ Ja E. Silberd j '

Ma .s . Travieso-Diaz.

Counsel for Applicants 1800 M Street, N.W.

Washington, D. C. 20036 (202) 822-1000 Dated: August 13, 1981.

1 0.*f . '

o -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PENNSYLVANIA POWER & LIGHT COMPANY )

-)

and ) Docket Nos. 50-387

) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

(Susquehanna Steam Electric Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE f

This As to certify that copies of the foregoing " Applicants' Motion for Partial Summary Disposition of Contention 2 (Source Term)",

' Applicants ' Statement of Material Fact: As To Which There Is No Genuine Issue To Be Heard (Contention 2) (Source Term) ", and

' Affidavit of John C. Dodds in Support of Partial Summary Disposition of C.ntention 2", were served by deposit in the U. S. Mail First Class. postage prepaid, this 13th day of August, 1981 to all those on the attached Service List.

Jaf E. Silbe'rg

( [

f Dated: August 13, 1981.

&Co , -.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PENNSYLVANIA POWER & LIGHT COMPANY )

)

AND ) Docket Nos. 50-387

) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

(Susquehanna Steam Electric Sthtior., )

Units 1 and 2) )

SERVICE LIST Secretary of the Commission Dr. Judith H. Johnsrud U. S. Nuclear Regulatory Commission Co-Director Washington, D.C. 20555 Environmental Coalition on Nuclear Pcwer Administrative Judge James P. Gleason 433.Orlando Avenue 513 Gilmoure Drive State College, Pennsylvania 16801 Silver Spring, Maryland 20901 Susquehanna Environmental Advocates Mr. Glenn O. Bright c/o Gerald Schultz, Esquire Atomic Safety and Licensing Post Office Box 1560 Soard Panel Wilkes-Barre, Pennsylvania 18703 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Thomas J. Halligan, Correspondent The Citizens Against Nuclear Dangers Dr. Paul W. Purdom Post Office Box 5 245 GulphrHills Road Scranton, Pennsylvania 18501 Radnor, Pennsylvania 19087 Ms. Collean Marsh Atomic Safety and Licensing Box 558 D. j4 Board Panel Mt. Top, .aylvania 18707 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Jessica H. Laverty, Esquire Office of the Executive Legal Docketing and Service Section Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555

y ,,

+:,a . -

I Robsrt W.-Adler, Esquire Mr. Thomas M. Gerusky Director <

D partment of Environmental Resources Bureau of Radiation Protection Commonwealch of Pennsylvania Department of Environmental 505 Executive House Resources Post-Office Box 2357 Commonwealth of Pennsylvania-Harrisburg, Pennsylvania 17120 Post Office Box 2063 Harrisburg, Pennsylvania 17120 Jansa M. Cutchin, IV, Esquire Office of the Executive Legal Atomic Safety and Licensing Appeal Director Board Panel U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 2'0555 Washington, D. C. 20555 D Witt C. Smith

, Director-Pennsylvania Emergency Management Agency Transportation and Safety Building Harrisburg, Pennsylvania 17120 O

O i

-