ML18025B289

Motion for Leave to Intervene in Proceeding Re License Amends to Allow Onsite Storage of Low Level Radwaste for Five Yrs

ML18025B289
Person / Time
Site:	Browns Ferry
Issue date:	01/15/1981
From:	Curott D, Curott U AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
NUDOCS 8101200070
Download: ML18025B289 (6)

Text

ACCESSION NoR FAC IL:50-259 50-29 AU

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CUR TTID ~ RE CUROTTgJ

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REC IP ~ NAME REGULAT 1Nf-OHHATIOtu DISTRIBUTION TEN (RIDS)

'810120007u DuC ~ DATE: 81/01/15 NOTARIZED:

NO Browns Ferry truclear Power Station~

Unit li Tennessee Prow>s Ferry "ruclear Power Station, Unit 2i Tennessee rowns Ferry Nuclear Po~er Stationi Unit 3i Tennessee AUTrluR Af'FILIATION Aff{ 1 iation Unknown Atfi 1 iacion Unknown rrEGIr'IENI AFFILIATION Commiss>oners DOCKET 05000259 050Q0260 05000296 S UBJECT: Motion for leave to intervene in proceeding re license amends to allow onsite storage of low level radwaste for five yrs ~

DISTRIBUTION CODE:

OS03S COPIES RECEIVED:LTR ENCL Q SIZE:.

TITLE: Filings (Not Or ig by NRC)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The, Matter Of:

TENNESSEE VALLEY AUTHORITY Browns Ferry Nuclear Plant Units Nos.

1, 2 and 3

Docket Nos.

50-259 50-260 50-296 PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING.

TO:

Secretary of the Commission United States Nuclear Regulatory Commission

.Washington, D.C.

20555 ATTENTION:

Docketing and. Services Branch Pursuant to the provisions of 52.714 of 10 Code of Federal Regulations and the Commission's Notice of Consideration of A'mendments to Facility Operating Licenses, dated December 4,

1980, the undersigned petitioner (or each of the undersigned petitioners, if more than one) petitions for leave to intervene in the above styled proceeding; and requests a hearing on the request of Tennessee Valley Kuthority (TVA) for amendments to its

licenses, and respectfully states as follows:

I.

Petitioner wishes to intervene in all aspects of TVA's reguest for amendments to Facility Operating License

@503 8101100 O~

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Nos.

DPR-33,. DPR-52 and DPR-68; which proposed amendments

'would'ntail

-modification of the authority provided by paragraphs' B'(5)

'nd 2.D(3) of Licenses DPR-33, DPR-52 and DPR-68 and related license conditions and technical specifications, to authorize the licensee to store onsite the'low. level radioactive waste generated from operation of the Browns Ferry Plant for a period of. f'ive.

years.

2'..

Peti;tioner is an adult citizen of the United States of America and'. resident and/or property owner in the geographic area in close: proximity to the Browns Ferry Nuclear Plant, residing at the address shown below petitioner's signature to this petition.,

3'..

The personal health and safety of petitioner, and of his or her descendants, whether now living or yet unborn, may be affected by this proceeding; Petitioner's.

home, occupation/

recreational activities, guality of lif'e, property, financial and other interests may, be affected'y this proceeding.

Petitioner is a customer-of'ither

a. rural el'ectric system or of a. municipally owned electric system which purchases and obtains its electricity from TVA.

Petitioner is dependent upon drinking water and water for household

purposes, the source of which may be affected by this proceeding; and is dependent.

upon milk, meat, fruits. and vegetables grown and-raised in close proximity to the Browns Ferry Nuclear Plant, and which may be affected by this proceeding.

Petitioner is dependent upon air.for breathing,'hich may be affected by this, proceeding.

,Petitioner'owns property which is subject to damage and/or loss in value as a result of this proceeding.

4.

Any order which may be entered in this proceeding,.

if such order grants TVA's request for lice'nse amendments, may affect petitioner's. interest by increasi'ng the health and safety, risks to petitioner by increasing the on-site radioactive inventory and'ncreasing the risk of radioactive contamination to petitioner and'is or her descendants,,

increasing the risk of fire, air contamination, water poll'ution and other dangers to petitioner and his-or her descendants.

5.

For the foregoing reasons,. petitioner has a right to be a party to this proceeding and this petition should be granted.

6.

A hearing should be held, on the TVA's request for license amendments because this is a proceeding for amendment of. a l'icense to operate a nuclear facility and which involves a

I significant hazards consideration.

7.

Service of any document required or permitted to be served on petitioner in this proceeding may be served, on peti-tioner (or on the first named petitioner, if more th'an one), at

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