ML18025B293

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Petition for Leave to Intervene & Request for Hearing on License Amend Requests
ML18025B293
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 01/16/1981
From: Brough G, Martin B, Pierson M
AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 8101200214
Download: ML18025B293 (8)


Text

REGULATu lNFOHMATION DISTRIBUTION "

TEN (BIDS)

ACCESSION NoR:8101200210 DuC.DATE: 81/01/16 NOTARIZED:

NO FACIL:50-25'rowns F er ry )tuel ear Power Station, Unit 1E Tennessee Browns Fer r y Ivuc I ear Power Stations Uni t 2E Tennessee 50 29 Browses Ferry Ivuclear Power Stationi Unit 3E Tennessee A T-.H~

~

AUTHUR Af FILIATION HARTINR8 ~ L ~

Affiliation Unknown BROUGHEG ~ RE Affiliation Unknown P IE,NSONi tl ~ 0 ~

Affi 1 i a t i on Unknown R4C IP ~ NAME HECIPIEN'I AFFILIATION DOCKET 05000259 05000260 05000296

SUBJECT:

Petition for ]eave to intervene It request for hearing on license anend requests'ISTRIBUTION CODE:

DSO>S CDI'IES RECEIYEU:LTR 8 ENCE g SIlE:

TITLE: Filings (Hot Orig by pRC)

NOTES:

RECIPIENT IU CODE/NAME ACTION:

Nt)HRIS, S ~

CLARKEH ~

INTERNAL: ASLAP Ill,E 0

D

~TON G FILE EXTERNAL: LPVR COPIES LTIR ENCL 5

2 1

1 RECIPIENT ID CODE/NAKE CLARKER ~ J ~

ASLB NRC PDR PUBLIC AFfAIRS NSIC COPIES LTTR ENCL JPg 22 1981 TOTAL NUMBER OF COPIES REQUIRE,D:

LTTR FNCL 17

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKHEh USMR"

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Bren r

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 8 JAN g g)g8) ~

3 AND REQUEST FOR HEARING.

OONA~,

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 Amendments to Faci*lity 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 hearxnij on 'the request i..;

~ n>>

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

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 lic'ense 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-area-in close proximity to the Browns Ferry Nuclear Plant, residing at the address shown below petitioner's'ignature 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 life, property, financial and other interests may be affected by this proceeding.,

Petitioner is a customer of either a rural electric system oe 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, 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.

4.

Any'rder 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 health and safety risks to petitioner by increasing the on-site radioactive inventory and increasing the risk of radioactive contamination to petitioner and'is or her d'escendants, increasing the risk of fire, air contamination, water'ollution and other dangers to petitioner and his or her descendants,.

5.

For the foregoing. reasons, petitioner has a right to be a party'o 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 facility and which involves a

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 than one), at

the. address given below said petitioner's signature.

Respectfully submitted, (signature)

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(name) ~Mal (address) J~P &P ViLLE APT64 9'SHuG (s,ignature)

(name)

DE581 E VA' (address) 5 I I C) ~ @ALLAH'I)I~~~Y Hue sV) LL~ AIa~S-<t

A copy of the foregoing petition has been sent by U.S.

mail to the following:

Executive Legal Director U.S. Nuclear Regulatory Commission Washington; D.C..

20555 H.S.

Sanger,. Jr.

Tennessee Valley Authority 400 Commerce Ave,

E llB 33C Knoxville:, Tennessee 37401