ML18025B290

Petition for Leave to Intervene in Proceeding

ML18025B290
Person / Time
Site:	Browns Ferry
Issue date:	01/16/1981
From:	Beck N, Beck R, Martin J AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
NUDOCS 8101200091
Download: ML18025B290 (8)

Text

REGULATu I Nl-OR~lATION DISTR IUU l ION TEN (RI DS )

ACCESSIUM NBR:8101200091 DUC ~ DATE: 81/01/16 NOTARIZED:

NO DOCKET FACIL:50-259 Browns Ferry (uvclear Power StationE Unit 1E Tennessee 05000259 Browns Ferry Nuclear Po<<E r Stationi Unit 2i Te>nessee

- 05000260 0"296 'owns Ferr y

'1(>clear Po~er Stat ionE Uni t 3E Tennessee 05000296 A

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!!n'known RECIP.'(!A<<E REClr'IcNl'FFILIATION Commissioners

SUBJECT:

Petition for leave to intervene in proceeding, DISTRIdUTIDN CODE-DSODS COPIES RECEIVED:LTR ENCL TITLE: Fi 1 ings (Not Orig by (NRC)

NOTES:

SIZE: Q ACTION:

RECIPIENT 1D CODE/NAh(F (NORRIS p S ~

CL~RKsR.

COPIES t TTR EiuCL RECIPIENT I') CODE/NAhlE CLARK,RE J ~

COPIES Ll'TH ENCL INTERNAL: ASt AP I+E FL9 RLANTON F(

ASLB

(!RC PQR PUBLIC AFFAIRS EXTERNAL: LPDR NSIC JAN 33 tgst TOTAL Nu!~BEN OF COPIES

~E~UIRED:

LTTR ENCL 17

UNITED STATES 0 F Alt ERICA NUCLEAR REGULATORY COMMISSION poCHE%>

usH".-

g JAN $ 6)98l >

gee H the Sere&

gggtlag 4 Sct@e 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

,~K(",

~ PETITION FOR LEAVE'Q INTERVEN -

$6' AND JAN l 6 198]

3 REVUE'ST FOR HEARINC TO:

Secretary of the Commission United States Nuclear Reaulatory Commission Nashinaton, D.C.

20555 ATTENTION:

Docketing and Services Branch U.Si~ lNULAtOaf

/P COlVllS$IQH

/r Cu j Pursuant to the provisions of

$ 2.714 of 10 Code of Federal Regulations and the Commission's Notice of Consideration 0

of Amendments to Facility Operatina

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 Authority (TVA) for amendments to its

licenses, and respectfully states as follows:

1.

Petitioner wishes to intervene in all aspects of

~g TVA's reauest for amendment~

t:n Facility Operatina License

Nos.

DPR-33, DPR-52 and DPR-68, which proposed amendments would entail modification of the authority provided by paraqraphs 2.B(5) and 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 qenerated from operation of the Browns Ferry Plant for a per'iod of five years.

2.

Petitioner is an adult citizen of the United States of America and a 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 he affected by this proceedina.

Petitioner's

home, occupation, recreational activities, auality of life, property, financial and other interests may be affected by this proceedina.

Petitioner is a customer of either a rural electric system or of a municipally owned electric system which purchases and obtains its electricity from TVA.

Petitioner is dependent upon drinkina water and water for household

purposes, the source of which may be affected by this oroceedinc; and is dependent upon milk, meat, fruits and vegetables grown and raised in close proximity to the Browns Ferry Nuclear Plant, and which may he affected by this proceedinq.

Petitioner is dependent upon air for breathinq, which may be affected by this proceeding.

Petitioner owns property which is subject to damaqe and/or loss in value as a result of this proceedinq.

4.

Any order which may be entered in this proceeding, if such order qrants TVA's reauest for license amendments, may affect petitioner's interest by increasing the health and safety risks to petitioner by increasinq the on-site radioactive inventory and increasing the risk of radioactive contamination to petitioner and his or her descendants, increasing the risk of fire, air contamination, water pollution 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 qranted.

6.

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

siqnificant 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 than one),

at

the ":ddr:ss

~.v n b 'o.;: s-.id oeaiti.":ner.s s m;.tureo Respectfully sub~ittcd~

John R. Hain Rt, 1~ 3o:: 949 Shoffield, Alai 3~660

A co~7'Z '::h morc";sin"; ',.)c "Cion h".s been sent or UiSi n"il to ihe fille:.in".;:

B:ecu ive Le~-1 Director Ui S~.':uclcar

.". ~a~o~ Cox~ission

'.;ashin~ion,

d. C.

=05=5 ti ~

Se Sa-l r,erg uro Tennesse V~~ 'u hor'tj 400 Commerce Ave. Z 113 33C i~no:vrll e, YZ, 37401 C