ML20011A232

Support for Contention 4 & Position on New Contentions. Motion for Summary Disposition of Contention 4 Should Be Denied Since Util Cancellation of Unit 2 May Be Best Solution.Certificate of Svc Encl

ML20011A232
Person / Time
Site:	Susquehanna
Issue date:	10/01/1981
From:	Halligan T CITIZENS AGAINST NUCLEAR DANGERS
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8110080340
Download: ML20011A232 (2)

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October 1, 1981 UNITED STATES. OF AMERICA NUCLEAR REGULATORY COMMISSION BEF0FE THE ATOMIC SAFETY & LICENSING BOARD IN THE MATTER OF @

'tTER & LIGHT BERWICK ATOMIO PENNSYL '.. <

SUSQUEHAI.NA UNI

&2

/As 1.

ALLEGHEl'K -

L, COOPERATIVE DOCKET NOS. 50 ~

9

• g*p[ Dgo 88 4

q 198% L' !ITIZENS AGAINST NUCLEAR DANGERS

~~

ON'4 , 81

% ,ae o5A SUPPORT FOR CONTENTION 4 '

• "$N5a' [ POSITION ON'NEW CONTENTIONS g6py;.-

s wish to present the fo11owin6 published acco MIN

[padi]

obout a major development affedtin6 the economics of commercial nuclear power as another justification for denying the pending motions in favor of summary disposition on Contention 4. -

iJ eWcontinuetobelievein nucleaf.'

. Edison said it would seek a rate b [a

• on peyd . power and its economic vitality in i

increase next month from the Masso-chusetts Department of Pubhc Utti-U t L O O b.L LE U >

' .the energy England, whichmix,larticularly-in is so heavily depenNewr

. ties to recover from its 550h00 cus-

. :l ' F- dent on expensWeimported oit,"said itomers the 5291 million that it has i

2d..A..' ,'

. Q{ I ' Thomas J. Galligan Jr., chairman and

. chief executiveofficer. .s-5 We cann'oi to however, expose the invested in Pilgrim 2 planning.

Galligan said the: rate increase f, would cost the average residential p ..

Ccompany 'and:our cus:omers to the ' customer St.70 a month for a decade.

Or "VIRSS. . '

fina=ci i risa =ad ==ceri iasies - - ^ite aeYGe#erai rraacis v.8<iiot1

, , now associated with continuing this 'ft,the Boston Clamshell Athance and unit," -

. s . n. . the : Massachusetts Public Interest BOSTON - Boston Edison Co. can- 2 Galligan said it **would be a tragel i *era fo*,S'bp a ed ou .

ce;ed construction plans yesterday ' d]~if Djcle,arpl ntswe e .131 grim 2 originally was to be one Y, l for what was to have been its secondI i nuclear power plant, saying it could , change, that could happen

• of four g hants to be built.in Pl'v-onMW eg cos Edison owns 59 percent of the pro- (and a flattening of demand for elec-not tolerate escalating construction costs and delays in federallicensin'g. l ' . posed 1,150-megawatt Pilgrim 2 that ' tricity in New England. had scaled Pulling out after e decade of delay. ! '*ould have be built ne t to . down the plan.to two plants in recent, !

i

. during whi6 time o :.ts' oared from 54 E Y out . , '-

Edison is one of 14 owners, but its .

g. , .

c. 5400 million to near!v % billion, the e slo is expected to mean the end , year,,s ,. ,..

' company scuttled plans to build the i ,,

. Pilgrim 2 plant in Plymouth, Mass., -

The demise of the P116 rim 2 plant at Plymouth, Mass. as described above, taust now be considered as a fateful alternative in the Berwick case. Cancellation of Susquehanna Unit 2 may well be the best solution for the PP&L. Contention 4 explicitly calls for an analysis of such an option. The ASLB has the responsibility to insure that all ar6uments cre heard on this option, and cross-examination takes place in order b

'8110080340 811001 PDR ADOCK 05000387 b 0\ a J PDR

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to. obtain as complete a record as possible. Theroforo, the Citizans move the ASLB to deny summary disposition on Contention 4. Its too impo'rtant an issue to try and sweep under the bureaucratic rug.

The Citizens hereby inform the ASLB that new contentions may be filed *oased on new information and the Safety Evaluation Report (SER)

Supplement No. 2 which states that there are still certain unresolved ca fety issues and also items on the NRC agenda that remain "open".

The citizens reserve the riSht, pursuant to the revised NRC rules and reSulations, such as the NRC Statement of Interim Policy, June 13, 1980,

" Nuclear Power Plant Accident Oonsideration Under NEPA;" to file new contentions on the fo110 win 5 items, if they ultimately prove to be unresolved durin6 the course of these proceedinsa. These items include all Outstanding Review Items designated, in Section 1.9 of the SER Supplement 2, as either " resolved pending documentation," " resolved via license condition," or, " additional information reouired." There are ~

thirty-eight such Outstandin6 Review Items at present.

! Also, new contentions may be filed on any of the SER Supplement 2 l

Sections 3 thru 22 if new information reveals that there are serious i

unresolved problems which develop involvin5 public health and safety l cffecting the. issuance of an operation license.

Respectfully submitted

&& +1.

October 1,1981 Correspondent. 6/

CERTIFICATE OF SERVICE I hereby certify that copies of Citizens Against Nuclear Dancers Supnort for Contention 4, Position On New Contentions have been served on all parties to this proceeding by deposit in the U.S. mail, this 1st day'of October, 1981.

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