ML18025B292

Petition for Leave to Intervene in Proceeding

ML18025B292
Person / Time
Site:	Browns Ferry
Issue date:	01/16/1981
From:	Colcock A, Freeman R, Muse N AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
NUDOCS 8101200095
Download: ML18025B292 (7)

Text

~l REGULAT LNI ORr1ATION DISTRIBUTION TFil (RIDS)

ACCESSION NOR:810120009m DUC ~ DATE: 81/01/16 NOTARIZED:

NO FAC IL:50 259 BrOWnS Fer ry I4uC 1 ear POWer Stat i Onr Uni t 1 2 TenneSSee

~)OO rOW~S Ferry ItruClear POWer StatiOnr Unit 22 TenneSSee

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owns Ferry Nuclear Power Station, Unit Sr Tennessee A

-;WAN AUTHE)R AFFILIATION MUS EN ~

Affiliation Unknown FREEMAN,RE L, Affiliation Unknown COLCOCKPA ~

"st Affi1iation Unknown REC I P ~ ",4AHc REC IP IrN T AF F ILIATION Commissioners DOCKET ¹ 05000259 05000260 05000296 SUSJECT: Petition for leave to intervene in Proceedings DISTRISiiTIUN CODE:

DSOIS COPIES RECEIVED:LTR g ENCL J I'ITLE: Filings (Not Orig by NRC)

NOTES:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 90

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In The Matter'f:

TENNESSEE VAL'LEY AUTHORITY Browns Ferry Nuclear Plant Units Nos. 1, 2 and 3

Docket Nos.

50-259 50-260 50-296 PETITION FOR LEAVE TO'NTERVENE AND REQUEST FOR HEA'RING

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TO:

Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C; 20555 ATTENTION:

Docket'ing and Services Branch ANl61981>>

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COAlhll5$~t Pursuant to: the provisions of 52.714 of 10 Code of.

Federal" Regulations and the Commission's Notice of Consideration of-Amendments 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 Authority (TVA) for amendments to its

licenses, and respectfully states as follows:

1..

Petitioner wishes to intervene in all aspects of TVA's request for amendments to Facility Operating License X OXOOO ~~~

Nos.

DPR-33, DPR-52 and DPR-68, which proposed amendments would entail modification of the authority provided by paragraphs 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 generated from operation of the Browns Ferry Plant for a period 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'rea:

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, quality of lif'e, property, financial and other interests may be-affected by this proceeding.

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 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 Nucl'ear Plant, and which may be affected by this proceeding.

Petitioner is dependent upon air for breathing, which 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.

An>> order. which may be entered in this, proceeding, if such order grants TVA.'s, request for license amendments, may affect petitioner's interest by. increasing the'ealth and safety 4

risks to petitioner by increasing the on-site rad'ioactive inventory and increasing the risk of radioactive contamination to petitioner and his or her descendants, increasing, the risk of fare;. axr contamination, water pollution and other-dangers to petitioner and his'r 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 license to operate a nuclear f'acility and which involves a

significant hazards consideration.

7'..

Service of any document reauired 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

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'.- A. copy of the foregoing 'petition has been..sent.

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'0 Executive Legal. Director U.S. Nuclear Regulatory Commission

. Washington, D.C.

20555 z

H.S.= Sanger, Jr.

- Tennessee Valley Authority 400 Commerce Ave.,

E llB 33C

. Knoxville, Tennessee 37401