ML20065B246
| ML20065B246 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 09/10/1982 |
| From: | Rosolie E NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8209140318 | |
| Download: ML20065B246 (9) | |
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.' DOCKETE0' UNITED STATES OF AMERICA USHRC NUCLEAR REGULATORY COMMISSION - -
BEFORETHE'ATOMICSAFETYANDLICENSINGBOAR@ 13 P2I34 '
) 0FFIC{(F g SjcRgg WASHINGTON PUBLIC POWER SUPPLY SYSTEM ) Docket No. STN -466.ANCH et. a_1. ) CPPR-134
_ ) (47 Fed Reg 35567 (1982))
l (WPPSS Nuclear Project No. 1) ) _
REQUEST POR HEARING AND PETITION FOR LEAVE TO INTERVENE Introduction
- 1. By application dated May 6, 1982, the Washington Public Power Supply System ("WPPSS"), acting for itself and as agent for co-owners, applied for an operating license for a pressurized water nuclear reactor, designated as the WPPSS Nuclear Project No. 1. The reactor, located on the Department of Energy Hanford Reservation, is designed for an electrical output of approximately 1266 megawatts.
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- 2. On August 16, 1982, a notice of Receipt of Application for Facility Operating License; Availability of Applicant's Environmental Report; Consideration of Issuance of Operating License; and Notice of Opportunity -
for Hearing was published in the Federal Register in the Matter of the Washington Public Power Supply System, et. ah , WPPSS Nuclear Project .
No. 1. Docket No. 50-460. This notice set September 15, 1982 a.s the deadline ror petitions for leave to intervene and requests for hearings.
Pursuant to 10 CFR 2.714, the Coalition for Safe Power and its members (hereinaf ter known as the " Coalition") hereby submits its request for
. hearing and peitions for leave to intervene.
Wo Description of Petitioner la . 3. The Coalition is a non-profit citizens organization, founded CDg om 7 in 1969 to work for safe enerFy. Its work includes research and education.
p< The Coalition, through its officers and attorneys, has represented its ocr g members before the Commission as well as state agencies, on questions a n: I
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of nuclear power safety and licensing, and on electrical utility rates.
The Coalition has been granted f.tll party status in five. proceedings $ ~
before the Commission including the original applicat. ion for conatruction permit for the Skagit Nuclear Plants., Units 1 and 2.,the application for Construction permit for the Pebble Springs Nuclear Plants, Units
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I and 2, two license amendments for the Troj a Eociear Power Plant, and ;
the application for a Construction Permit for,the Skagit/Eanford Nuclear Project, Units 1 and 2. The Coalition has also, filed several Shou Ause a -
petitions with the Commission.. - ..,
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Status of Petitioner ,
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- 4. The NRC Staf f' has stated 'in its Answers to Req;ue:sts.s for , Hearings Filed By the Coalition for Safe Power, in the Matter of WPPiS Nuclear?-
Project Nos. I and 2, dated' April 7, 1982 and March 15, 1982' respectively, that the Coalition has met the standing requirements necessary to petition for leave to interevene in the Permittee requests for extension of construc-
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- t. ton permits. This matter is still pending before the Commission. <
Interest of Petitioner
- 5. The interests of the Coalition are, in-large part, predicated on the interests of its members. The Coalition has ueanbers-residing ,
throughout Oregon and Washington and at least one who is within the fifty mile radius of the plant site who has authorized the filing of this request of hearing and petition for leave to intervene. An affidavit from the Direct.or~of t.he Coalition so stating is attached _herdto. Members of the Coalition work, live, recreate and travel in the etivdrons of the WPPSS Nuclear Project No.1 site and eat foodstuffs, both dairy, produce and meat, grown and produced in the vicinity potentially impacted upon -
by the operation of the project.
i How These Interests May Be Affected
. 6. The above-stated intersts of 'the members and staff of the Coalition, and thus the Coalition iteself as their representative, may be affected 1
by the proposed operation and on-site storage of spent nuclear fuel of ,
the WPPSS Nuclear Project No. 1. The operation of a nuclear power plant at the site may endanger the health of Coalition members due to several
! factors, the first of which is the routine and accidental releases of
- low-level radiation from the plant which will contaminate the air, food and water sources upon which members depend. The safety and well-being
) of members may be adversly affected by the possibility of a nuclear accident
[ which may damage of destroy their livelihood, homes, other property and happiness. Recreation may bejeopardized by the project's impact upon
( the water and aquatic life of the Columbia River and the surrounding environment. A nuclear accident at the projecd may affect the economy 4
) of the region. Insurance would not adequately cover losses sustained by member's of the Coalition in case of an accident'. The proposed paints will place and excessive economic burden on members who are ratepayers
!- of permittee utilities.
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- 7. An Order granting an Operating License in thsi matter may subject l
! the Coalition and its members to undue risks to health, life and property -
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- interests.
Specific Aspects of the Subject Matter
- 8. The Coalition intends to file contentions on the following aspects
~' ' of the application for an Operating License for the WPPSS Nuclear Project No.1:
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! There exists no reasonable assurance that:
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5' A. Construction will have been in accordance with the rules and
( regulations of the Commission; Y ' '
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B. The project will be completed within the guidelines of _the construction permit; C. The project will be completed; D. That the Permittee posesses the technical ability to operate ,
the project in accord with the rules and regulations of the Commission; E. That the geology of the site has been properly assessed and' taken P
into consideration in the engineering of the project; F. That operation of the project will not endanger the public health and safety; G. That operation of the project will not be innimicable to the common defense and security of the public; H. That emergency reponse plans for the project are sufficient; I. That the production, on-site storage and disposal of nuclear wastes from the project will not endanger the public health and .,
safety; -
J. That the Somatic and Genetic impact of radiation release from
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the project will not endanger the public health and safety; K. That 'the Architect / Engineer has the technical ability to complete construction of the project in a safe manner; L. That the Permittee, and Architect'/ Engineer pssess the ability to confrom to NRC approved QA/QC proc'eedures for construction and operation; M. That operation of the project will not endanger other nuclear facilities located at the Hanford Nuclear Reservation; .
N. That operation other nuclear f acilities will not endanger operation of the project; e
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O. That the Permittee has the ability to eceply with safety requirements of TMI; P. That operation of the project will be in accordance with NRC rules and regulations; Q. The design of the decay heat removal system is adequate for accident and normal transcient conditions; l R. The safety-related electrical and mechanical equipment will be environmental qualified; S. That the actions specified in NUREG-0737 and NUREG-0660 are an -
adequate response to the safety deficeinies of the B & W design which were disclosed by the TFE-2 accident; T. That failures in the nuclear safety grade systems wil not create a situation beyond the ability of safety systems and will not disable safety systems; ,
U. That the systems interaction evaluation is adequate; V. That the nuclear steam supplier will not have supplied a system which will operate in accordance with NRC rules and regulations.
Effect of Intervention ,
'9. The Coalition's participation in previous and on-going regulatory proceedings is indicative of its ability to assist in the development of a sound record due to its familiarity with the process and the issues, and its access to expert witnesses. The Coalition's participation, for example, in the Trojan Control Building License Amendment proceedings resulted in additional safety measures being incorporated into plant modification designs. The Coalition's participation in the on-going construction permit for the Skagit/Hanford Nuclear Project, Units 1 and 2 would bring a thourough and contemporary understanding to the WPPSS I
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Nuclear Project No. 1 Operating License application.
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_onc lusions
- 10. The Coalition for Safe Power having established herein a standing of right under the Atomic Energy Act of 1954, as amended, the National Environmental Policy Act of 1969, and Chapter 10 of the Code of Federal Regulations, Part 2.714, is entitled to receive the hearing requested on the Washington Public Power Supply System application for Operating License for the WPPSS Nuclear Project No.1 and'a'n Order granting this petition for leave to intervene.
Respectfully submitted.
W Dated this day, the Eu e RosoJie, Director tenth of September, 1982. C ition for Safe Power o
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. g, 1 STATE OF OREGON ) ._ _
) as.
2 County of Multnomah )
3 1 Eugene Rosolie, being first duly sworn do depose and say as 4 follows:
5 1. That I am the Director of the Coalition for Safe Power and its
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6 duly authorized representative; and
! 7 . 2. That the foregoing petition was prepared under my supervision S and direction and that, to the best of my knowledge and belief, it and the 9 facts contained therein are true and correct.
10 . Signed:
11 12 [m e Euger)6 Rosolie/ Director 13 s Coalition for Safe Power 14 . : SUBSCRIBED AND SWORN to before me this tenth of September,1982.
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16 1, Notary Public for Oregon 17 My Commission Expires:f.22 -ff[
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Page 1 of 1 - AFFIDAVIT
I STATE OF OREGON )
) ss.
2 County of Multnomah )
3 I, Eugene Rosolie, being first duly sworn, do depose and say as 4 follows:
,5 1. That I am the Director of the Coalition for Safe Power and its 6 duly authorized representative; .
O 7 2. That the Coalition for Safe Power has members M o': live within 8 a fifty-mile radius of the WPPSS Nuclear Project No. I site, and as close 9 as twenty miles; and 10 3. That certain of these members have authorized the officers of 11 the Coalition for Safe Power to file the attached Request for Hearing and 12 Petition for Leave to Intervene on their behalf.
- 13 Signed:
14 15 sh Eugeg6 Rosolie/, Director 16 Coalition for Safe Power 17 SUBSCRIBED AND SWORN to before me this tenth day of September,1982.
18 19 ary Public for Oregon 20 Commission Expires: f 21 gg 21 22 23' 24 25 26 .
1 Page 1 of 1 - AFFIDAVIT I
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00CVETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARfh [h 1$ P254 In t e tter of )
0FFICE OF SECRETARY
) n0CFE ING & SERVICE WASHINGTON PUBLIC POWER SUPPLY SYSTEM ) Docket No. 50-%6 RANCH et. al. )
)
(WPPSS Nuclear Project No. 1) )
CERTIFICATE OF SERVICE I hereby cartify that copies of " REQUEST FOR HEARING AND PETITION IDR LEAVE TO INTERVENE" filed by the Coalition for Safe Power in the above captioned proceeding have been served on the following parties by deposit in the United States Mail, postage prepaid ~and first class, on the tenth of September, 1982.
Secretary of the Commission U.S. Nuclear Regulatory Commission Washington D.C. 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington D.C. 20555 s
j Nicholas S. Reynolds '
Debevoise, Liberman Suite 700, 1200 17th St. NW Washington D.C. 20036 wT]
Nina Bell Coalition for Safe Power a
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