ML082320066

Request for Hearing and Leave to Intervene Submitted by Thomas Saporito

ML082320066
Person / Time
Site:	Turkey Point
Issue date:	08/18/2008
From:	Saporito T Saporito Energy Consultants
To:	NRC/SECY/RAS
SECY RAS
References
50-250-LA, 50-251-LA, License Amendment 1, RAS 1005
Download: ML082320066 (3)

Text

August 18, 2008 Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Adjudications Staff RE: Request for Hearing and Leave to Intervene Docket Nos. 50-250 and 50-251 Turkey Point Nuclear Plants NOW COMES, Saporito Energy Consultants (SEC) by and through its undersigned President Thomas Saporito pursuant to 10 CFR 2.309 (d) and (f),

and hereby submits this Request for Hearing and Leave to Intervene with respect to Federal Register/Vol. 73, No. 146/ Tuesday, July 29, 2008/Notices.

Standing 10 CFR 2.309 (d)(i), The name, address and telephone number of the requestor or petitioner.

Thomas Saporito, President Saporito Energy Consultants 1030 Military Tr. #25 Jupiter, Florida 33458 Voice: (561) 283-0613 Mailing Address:

Thomas Saporito, President Saporito Energy Consultants Post Office Box 8413 Jupiter, Florida 33468-8413 Voice: (561) 283-0613 10 CFR 2.309 (d)(ii),

The nature of the requestors/petitioners right under the Act to be made a party to the proceeding:

Thomas Saporito is a U.S. Citizen and therefore has an inherent right under the Act to be made a party to the proceeding. Thomas Saporito is the President of Saporito Energy Consultants (SEC) and therefore SEC has a right under the Act to be made a party to the proceeding.

1

10 CFR 2.309 (d)(iii),

The nature and extent of the requestors/petitioners property, financial or other interest in the proceeding:

Thomas Saporito and SEC have real property and personal property and financial interests of which can be adversely affected should operations at the Florida Power & Light Company (FPL) or licensees, Turkey Point nuclear plants cause a release of radioactive particles into the environment. Moreover, such and event could render the requestors/petitioners home and property unavailable for human contact or use for many years or forever. Additionally, such and event could forever compromise the environment where the petitioners reside, live, and do business.

10 CFR 2.309 (d)(iv),

The possible effect of any decision or order that may be issued in the proceeding on the requestors/petitioners interest:

The possible effect of any decision or order that may be issued in the proceeding could substantially protect the interests of the Petitioners environment, property, and economic viability.

Contentions 10 CFR 2.309 (f)(1), A request for hearing or petition for leave to intervene must set forth with particularity the contentions sought to be raised.

Contention #1 Petitioners contend here that the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed amendments, although administrative in nature, could directly or indirectly result in substantive changes to the Technical Specifications that preserve safety analysis assumption.

Contention #2 Petitioners contend here that the proposed amendments create the probability of a new or different accident from any accident previously evaluated since the proposed amendments may change the physical plant or the modes of plant operation defined in the facility operating licenses.

Contention #3 Petitioners contend here that the proposed amendments involve a significant reduction in a margin of safety since the removal of the technical notes may reduce margins of safety.

2

Respectfully submitted, Saporito Energy Consultants Thomas Saporito, President Post Office Box 8413 Jupiter, Florida 33468-8413 Voice: (561) 283-0613 Email: saporito3@gmail.com 3