ML13149A057
| ML13149A057 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/29/2013 |
| From: | Lodge T Citizens Environmental Alliance of Southwestern Ontario |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 24589, 50-346-LA, ASLBP 13-928-02-LA-BD01 | |
| Download: ML13149A057 (5) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of: ) Docket No. 50-346-LA FirstEnergy Nuclear Operating Company ) May 29, 2013 Davis-Besse Nuclear Power Station, Unit 1
)
Regarding the Proposed Amendment to Facility Operating License )
NOTICE OF FILING OF INDIVIDUAL AND ORGANIZATION DECLARATIONS IN SUPPORT OF STANDING OF CITIZENS ENVIRONMENTAL ALLIANCE OF SOUTHWEST ONTARIO Notice is hereby given of the filing of the declaration of Derek Coronado, as individual member of Citizens Environment Alliance of Southwestern Ontario, and of Richard Coronado, signing as Director of the same organization, in support of standing of the group as a Petitioner in this license amendment proceeding. These declarations were inadvertently omitted from the initial, May 20, 2013 petition filing.
/s/ Terry J. Lodge Terry J. Lodge (OH #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fax (419) 255-7552 Tjlodge50@yahoo.com Counsel for Intervenors UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) Docket No. 50-346-LA FirstEnergy Nuclear Operating Company ) May 29, 2013 Davis-Besse Nuclear Power Station, Unit 1
)
Regarding the Proposed Amendment to Facility Operating License )
CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing NOTICE OF FILING OF INDIVIDUAL AND ORGANIZATION DECLARATIONS IN SUPPORT OF STANDING OF CITIZENS ENVIRONMENTAL ALLIANCE OF SOUTHWEST ONTARIO were deposited in the NRCs Electronic Information Exchange this 29th day of May, 2013 and were served upon the following by the EIE.
Office of Commission Appellate Mail Stop O-16C1 Adjudication Washington, DC 20555-0001 Mail Stop O-7H4M Hearing Docket U.S. Nuclear Regulatory Commission E-mail: hearingdocket@nrc.gov Washington, DC 20555-0001 E-mail: ocaamail@nrc.gov Office of the General Counsel U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop O-15D21 U.S. Nuclear Regulatory Commission. Washington, DC 20555-0001 Mail Stop T-3F23 Edward L. Williamson, Esq.
Washington, DC 20555-0001 Mary Spencer, Esq.
Paul S. Ryerson, Chairman Mitzi Young, Esq.
E-mail: paul.ryerson@nrc.gov Lloyd Subin, Esq.
Michael F. Kennedy Jeremy Wachutka, Esq.
Administrative Judge John Tibbetts, Paralegal E-mail: michael.kennedy@nrc.gov E-mail: edward.williamson@nrc.gov Nicholas G. Trikouros mary.spencer@nrc.gov Administrative Judge mitzi.young@nrc.gov E-mail: Nicholas.trikouros@nrc.gov lloyd.subin@nrc.gov jeremy.wachutka@nrc.gov Office of the Secretary of the Commission john.tibbetts@nrc.gov U.S. Nuclear Regulatory Commission FirstEnergy Service Company. Citizens Environmental Alliance (CEA) of Mailstop: A-GO-15 Southwestern Ontario 76 South Main Street 19 Ottawa Street Windsor Akron, OH 44308 Ontario Canada N8Y 197 David W. Jenkins, Esq.
E-mail : djenkins@firstenergycorp.com Green Party of Ohio 2626 Robinwood Avenue Morgan, Lewis & Bockius Toledo, Ohio 43610 1111 Pennsylvania Avenue, NW Washington, D.C. 20004 Dont Waste Michigan Kathryn Sutton, Esq. Stephen Burdick, Esq. 811 Harrison Street Timothy Matthews, Esq. Monroe, Michigan 48161 E-mail: ksutton@morganlewis.com Michael Keegan sburdick@morganlewis.com E-mail: mkeeganj@comcast.net tmatthews@morganlewis.com Beyond Nuclear 6930 Carroll Avenue Suite 400 Takoma Park, Md. 20912 Kevin Kamps E-mail: kevin@beyondnuclear.org Paul Gunter E-mail: paul@beyondnuclear.org
/s/ Terry J. Lodge Terry J. Lodge (OH #0029271) 316 N. Michigan St., Ste. 520 Toledo, OH 43604-5627 (419) 255-7552 Fax (419) 255-7552 Tjlodge50@yahoo.com Counsel for Intervenors UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of: ) Docket No. 50-346 FirstEnergy Nuclear Operating Company ) May 20,2013 Davis-Besse Nuclear Power Station, Unit 1
)
Regarding the Proposed Amendments to Facility Operating License )
ORGANIZATIONAL DECLARATION OF CITIZENS ENVIRONMENT ALLIANCE OF SOUTHWESTERN ONTARIO IN SUPPORT OF PETITION TO INTERVENE IN FENOC LICENSE AMENDMENT REQUEST Under penalty of perjury, I, declare as follows:
1( l*c..ba.rd CoCDifJ<<do
- 1. I am authorized by Citizens Environment Alliance of Sou hes ePAOntario (CEASO),
0 . IJ 0 a. /V 0'" r 1(.7 , to sign this Declaration. CEASO is fonnally and officially opposed to the request to the U.S.
Nuclear Regulatory Commission by Davis-Besse Nuclear Power Station, owned by FirstEnergy Nuclear Operating Company (FENOC), to amend its nuclear power plant operating license to allow for a steam generator replacement project slated for 2014.
- 2. CEASO has 40 active members, some of whom live within the miles of the Davis-Hesse nuclear power plant site, including DeC ek C DCO nQ!fl_O , whose declaration is being submitted to the NRC along with this Organizational Declaration. CEASO is concerned that if the NRC grants FENOC permission to amend the Davis-Besse license, that the operation of the nuclear power plant could adversely affect the health and safety and the integrity of the environment in which CEASO's members live.
- 3. In order to ensure that the license amendment decision for Davis-Besse is protective of the interests of CEASO members in a safe and healthy environment, CEASO fonnally seeks to intervene on behalf of the member who has attached a declaration and intends, on behalf of its members, to take any legal actions necessary to ensure the NRC proceedings involving the proposed license amendments are conducted fairly, efficiently and in a manner that provides the full consideration of all issues that could affect the safety and health and the health of CEASO members and their living environment.
CITIZENS ENVIRONMENT ALLIANCE OF SOUTHWESTERN ONTARIO By fficehel (Signature plus o L D. rtdor d in organization)
/'i{ /13 Date
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of: ) Docket No. 50-346 FirstEnergy Nuclear Operating Company ) May 20,2013 Davis-Besse Nuclear Power Station, Unit 1
)
Regarding the Proposed Amendments to Facility Operating License )
)
DECLARATION OF Derek Cocon£tJD IN SUPPORT OF PETITION TO INTERVENE IN FENOC LICENSE AMENDMENT REQUEST I, Dere.k C.ocoVJadg hereby make the following statements under the penalty of perJury.
- 1) My name is Derek CordlcJ,I am a member of Citizens Environment Alliance of Southwestern Ontario. .I i)O /-/4/1 4Je. 'VI'Moc, ON tAnaJo..
- 2) My residence is located at N9ft ".fb1 1.r1J3 which is within fifty (50) miles of the Davis-Besse Nuclear Power Station. I participate in recreation and business activities within that 50-mile radius.
- 3) FirstEnergy Nuclear Operating Corporation (FENOC) has applied for an amendment to the Davis-Besse operating license technical specifications related to replacement of a steam I
generator at the power plant, scheduled for 2014.
- 4) have safety and environmental concerns about the Davis-Besse plant's operations. I do not believe adequate information has been disclosed about the steam generator project. Also, I
lessons about the steam generator failures at the San Onofre plant have not been adequately explored or incorporated into the Davis-Besse plan. believe the proposal may pose unacceptable I
risks to the environment and public health and my personal health and safety.
- 5) hereby designate Citizens Environment Alliance of Southwestern Ontario as my representative in this license amendment proceeding. My interests will not be adequately represented without this action to intervene and without the opportunity of Citizens Environment Alliance of Southwestern Ontario to participate as a full party in this proceeding on my behalf.
Signature