ML20010F400

Response in Opposition to ASLB 810814 Directives & Motions on Testimony & Public Hearings Conference.Date That Correspondence Is Required to Be Mailed Is Incorrect & Only Two Aspects of Contention 2 Are Listed for Consideration

ML20010F400
Person / Time
Site:	Susquehanna
Issue date:	08/27/1981
From:	Halligan T CITIZENS AGAINST NUCLEAR DANGERS
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8109100139
Download: ML20010F400 (4)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CO:GISSION N)g fh ({ ; g , . V , g C: x . i & SeM et 6 TFORE THE ATO"IC SAFETY AND LICENSING BOARB; 4f 3 E P 0 019M"12" F_.

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PENNSYLVANI A PO' DER & LIGHT CO. BER'4ICK ATOMIC and SUSQUEHANNA UNITS l' #

ALLEGHENY ELECTRIC COOPERATIVE, INC. DOCKET NOS. 50-3S7 & 50-388 CITIZENS AGAINST NUCLEAR DANGERS RESPOhSES TO ASLB DIRECTIVES ~

AND MOTIONS ON TESTIMONY AND PUBLIC' HEARINGS CONFERENCE The ASLB'in its Memorandum of Au6ust 14,1981, has orred in at least two instances. One, the date that this correspondence is required to be mailed is stated as August 25th. Forty days in advance of October 6th is August 27th. Much more importantly, the order of consideration of intervener contentions at public hearings incorrectly lists only two aspects of Contention 2, to be examined in the first and eleventh order. The fact is, there are three separate aspects of Contention 2, as we well know. So, there is some oversi6ht on the pact Of the ASLB in schedulin6 It is our understanding that the Coalition will cross-examine and possibly present a direct case at the commcncement of the hearin6s concernin6 cesium, cobalt, iodine end the other radioactive l garbage to be dumped into the Susquehanna River.

l Much later in the proceedin6s, in the eleventh order of business, the Citizens are plannin6 to present the'ir case conccrning the radiation dan 6ers to pre 6nant women and the unborn that will be caused by the Berwick Nuke. The Citizen: will in a timely fashi$n file direct testimony with resumb, etc. on this part of Contention 2.

Also, presumably at that time, the Chlorine aspect of Contention 2 will be debated, proveded the ASLB, amon6 other things, Brants the ,

I 8109100139 810827 PDR ADOCK 05000387 G PLR MNf#f

2 Citizens' motion for the pro;octiva ordor, filed Au5ust 16,1981.

The Citizens oppose the Applicants latest motion to dismiss the Chlorine part of Contention 2. Their overreaction on discovery is further evidence that the PP&L is desperately tryin5 to avoid bein6 forced to present incricinating testimony under oath on the chlorine problems before the ASLB', subject to a test of truthfulness by cross-examination. Thousands of persons downstream who will be drinkin6 the river water containin5 Berwick's exc1ssive amounts of Chlorine (turned to Chloroform when mixed with chemical pollution in the river) deserve definitive explanstions from the NRC in direct testimo'ny, from the PP&L in direct testimony, aad from the Commonwealth of Pennsylvania in direct teatimony on this subject. The ASLB should direct them to do so, and the Citizens herebv move the ASLB' to order the above parties to tentify accordingly!

One Sood reason for this is because the PP&L on/or about August 14, 1981, signed a Consent Decree with the Pennsylvania Department of Environmental Resources admittin6 to sustained po11utin6 of the Susquehanna River from their Sunbury electric power plant.

i There have also been scoren of major pollution violations of the Clean

-Streams Act by the PP&L over the years, where they have also admitted they were ~ guilty as charged (consent decrees) of comtacinatin6 Susquehanna river water. The PP&L has a very bad track record.

l The Chlorine issue cannot go uncortested by the government!

l ASLB decisions must reflect a real concern for obtaining a l

complete record on the drinking water issue in the public interest, or face public skepticism and wrath, and, of course, the inevitable

! delays to licensing that court appeals from these a86rieved people t .

l uill entail. The same can be expected from a65rieved citizens in i

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3 the case of the UHV transmission line leases that apparently were fraudulently obtained. But, that aspect will be a matter for the FCC' and the Federal Bureau of Investi6ation to deal with, not the ASLB.

The Citizens certainly oppose the Applicants unexpected summary disposition motion concernin6 the low-level radioactive relea se s part of Contention 2, and likewise oppose the Applicants unexpected motion to summarily dismiss Contention 17 (UNV transmission). The Citizens will oppose any attempt to dismiss Contention 4 (need for power and alternative ener6y) that may be in the works by the NRC, and also stron61y oppose the Applicants attempt to deny the Citizens-the opportunity to cross-examine on the decommissionin6 contention.

There are also other Applicant motions to dismiss aimed at the other interveners that were unexpected.

The timetable called for in Part 3 of the Au6ust 14th ASLB Order cannot possibly be properly and strickly adhsred to by the interveners with all of the above licted complications. Therefore, the citizens

move the ASLB to convene one more pre-hearing conference at i Wil k e s- Ba rre . Pa. by September 10th, to rectify the situati3n by clarifyin6 the ambi6uities involved, allow the Citizens and other interveners to respond in opposition directly to these unfair attempts

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to scuttle the public hearings, by the above cited unexpected surprise motions of the Applicants that~ have just cropped-up, which in turn are makin6 the issues more and more confusin6 by the day!

If there is to be an inte1116ent, coherent and open public hearin6, as there certainly should be on all the issues, ghen there l

has to be a termination of the Applicants grossly unfair tactics!

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4 Finally, the Citizens novo tha ASLB to publish a comprehensivo order on the subject of the Limited Appearance State nents that will explain in laymans terme every detail and procedure involved and promptly distribute the document to the approximately two-hundred applicants who requested to testify!

Respectfully suhaitted Dated: Au5ust 27, 1981 M4 CorIespondent[/

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g CERI'IFICATE OF SERVICE I hereby certify that copies of Citizens Against Nuclear Dangers Responses To ASLB Directives And Motions On Testimony And_ Public Hearings Conference have been served on all parties to this proceedin5 by deposit in the U.S. mail, first calss, this 27th day of Au5ust, 1981.

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COULD THIS BE PP&L's NEW PUBLIC INFORMATION CENTER ?

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