ML19029A600
| ML19029A600 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/11/1978 |
| From: | Lewis M - No Known Affiliation |
| To: | NRC/SECY |
| References | |
| Download: ML19029A600 (7) | |
Text
Marvin I. Lewi.#f :f; 0
~504 Eradford Terrace Phila. PA 19149 May 11,78.
Secretary of the Commission US NRC
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Sir:
11B Please add my name to the list of limited appearances in the Hearing on Spent Fuel Storage Capacity at Salem Nuclear Plant9'.
I also expect to find out why the Coleman?s were refused status as participants.
Please send me that information.
Ple~se send details of how, when, and where I may submit my testimony.
May I ask others to appear and supplement my testimony?
Will heal th effects anjd saf er;uards be allowed?
Marvin I. Lewws 6504 nradf ord Terrace Phila. PA 19149
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- STAT<:: OF 0S:L."'.W..:..RS:
May 17, 1978 The Honoraole Samuel J. Chilk, Secretary U. S. Nuclear Regulatory Commission.
Washington, D. C. 20555 Re:
Proposed Issuance of Amendment to Fac~lity Operating License Number DPR-70/Docket 50-272
Dear Mr. Chilk:
We hereby submit a petition for leave to intervene on behalf of the State of Delaware ex rel Delaware Department of Natural Resources and Environmental Control in the matter concerning the proposed issuance of an Amendment to the Facility Operating License Number DPR-70 (Docket 50-272).
The fact that an amendment to in-crease the nuclear waste storage facility capacity at the Nuclear Generating Station located along the Delaware River near Salem in New Jersey was brought to our attention earlier last week.
Since a breakdown in communication has resulted in our being made aware of the proposed action belatedly, we trust that your staff will honor our late request to participate in the capacity of an Intervenor as an Interested State with the right to examine and cross-examine witnesses regarding matters at issue in the proceedings.
I have enclosed twenty copies of My Petition for Leave to Intervene and request that it be granted.
Sincerely,
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Harry Otto, Ph.D.
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Manage Technical Services Section cc:
Hon. Austin P. Olney, Secretary Delaware Department of Natural Resources and Environmental Control Executive Legal Director U.S. Nuclear Regulatory Commission Troy B. Conner, Jr., Esq.
UNITED STATES OF AMER-NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
PUBLIC SERVICE ELECTRIC AND GAS COMPANY Proposed Issuance of Amendment to Facility Operating License Number DPR-70 Petitioner:
State of Delaware ex rel:
Docket No. 50-272 Delaware Department of Natural Resources and Environmental Control Counsel:
Tatnall Building, P.O. Box 1401 Dover, Delaware 19901 June D. MacArtor Deputy Attorney General Tatnall Building, P.O. Box 1401 Dover, Delaware 19901 PETITION FOR LEAVE TO INTERVENE AS AN INTERESTED STATE
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Petitioner is the State of Delaware ex rel Delaware I
Department of Natural Resources and Environmental Control and applies for leave to intervene pursuant to 42 uses ~2021 and 10 CFR 2.715(c).
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Petitioner has been delegated the authority and is charg with the responsibility of protecting, preserving, and enchancing the environmental resources of the State of Delaware under State law.
Petitioner is a contiguous State to the location of the subject facility.
- 3.
Petitioner recently learned that this application is before the Comm.ission.
Since no proceedings have taken place in this matter, Petitioner asserts that no prejudice to any party will result from granting this Petition.
- 4.
With respect to the above captioned matter, Petitioner has concerns regarding the possible impact on the environmental resources in Delaware of the proposed location of additional radioactive waste storage facilities along the Delaware River near Salem, New Jersey.
- 5. Peti.er asserts that the va19 interests herein stated would be adversely affected by the results of the pro-ceedings if Petitioner is not afforded the opportunity to present its concerns and participate fully in the conduct of the hearing, including the right to examine and cross-examine witnesses with respect to their cbntentions related to matters at issue in the proceedings.
- 6.
Petitioner asserts that it *.represents significant personal and proprietary* rights of citizens of the State of Delaware with respect to environmental matters, "and that such rights could be adversely affected by an order entered in the proceeding.
WHEREFORE, the State of Delaware ex rel Delaware Department of Natural Resources and Environmental Control requests this Petition be granted.
Date:
May 17, 1978 Respectfully submitted,
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J~u~e-D. MacArtor
/Deputy Attorney General
- Tatnall Building, P. 0. Box 1401 Dover, Delaware 19901 H. W. ~to, Manager Techni:a:l Services, Division of Environmental Control of the Department of Natural Resources and Environmental Control of the State of Delaware
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I SUPPORTING AFFIDAVIT STATE OF DELAWARE)
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COUNTY OF KENT
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BE IT REMEMBERED, that on this i7-u: day of May, A.D. 1978, personally appeared before me, the subscriber, a Notary Public for the State and County aforesaid, H. w.* Otto, who being by me duly sworn according to law, deposes. and says as follows:
I am the Manager of Techrt-ical Services for the Division of Environmental Control of the Department of Natural Resources and Environmental Control of the State of Delaware.
The State of **
Delaware is an interested State by virtue of being contiguous to the facility and wishes to participate in all proceedings in this matter as an interested State concerned with potential impacts on its citizens.
That the assertions, concerns and facts set forth in the above Peition for Leave to Intervene are true and correct to the best of my knowledge, information and belief, and that the above Petition for Leave to Inter'Vene is submitted in good faith by the State of Delaware ex rel Delaware Department of Natural Resources and Environmental Control.
H. W. Otto,
- anager, Technical Services of the Division of Environmental Contra of the Department o.f Natural Resources and Environmental Control of the State of Delaware SWORN TO AND SUBSCRIBED before me the day and year aforesaid, as witness my hand and seal of office.
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(;I Notary Public
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PUBLIC SERVICE ELECTRIC Ai~D GAS COMPANY
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(Salem Nuclear Generating Unit 1)
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50-272 r_ 'r: 2 docucnent: ( s ~
I hereby certify that I have this rl2y served up*::>il. each person dE!sig~;;~ted on the cf ;~ici2~i.
~-.~-:::~*.:-~. ::..! :. ~.-:~t co:nP1-1~cl by*
the Office of the Secretary of the Co~raissioc> l:: :.: !*: i.: pn.*c.:::edin,s in.
accordance with. the requirements 0£ Section 2. 712
~:£ 10 C:'i:'R ?art 2 -
Rules of Practice, of the Nuclear R'°'gulatory Cc:*.::::Lss.i.:J~-i.'s Rules and Regulations.
Dated. atY;f.Jashington, D.C. this
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/_7;,_:.7 day. of.laA/J_
I fl 197 f
.f In the Matter of PUBLIC SERVICE ELECTRIC AND GAS COMPANY
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(Salem Nuclear Generating Station, )
Unit 1)
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Docket No.(s) 50-272 SERVICE LIST Gary L. Milhollin, Esq.
1815 Jefferson Street Madison, Wisconsin 53711 Mr. Glenn 0. Bright.
Atomic Staf ety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
.Dr. James* C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina *27514 Counsel for NRC Staff U~S. Nuclear Regulatory Commission Washington, D.C.
20555 Troy B.. Conner, Jr., Esq.
Conner, Moore and Corber 1747 Pennsylvania Avenue, N.W.
Was*hington, D. C-.
20006 Honorable Mark *L. First Deputy Attorney General Department of.Law & Public Safety P.O. Box 141 Trenton, New Jersey 08070 William C. Horner, Esq.
67 Market Street Salem, New Jersey 08079 R. William Potter, Esq.
Assistant Deputy Public Advocate Department of the Public Advocate P.O. Box 141 Trenton, New Jersey 08601 Mr. Alfred C. :Coleman,. Jr.
Ms. Eleanor G. Coleman 35 "K 11 Drive Pennsville, New Jersey 08070 Ms. Ruth Fisher "The-Sun People" Alternate Energy Advocates South Dennis, New Jersey 08245
- Salem Free Public.Library 112 West Broadway Salem, New Jersey 08079 Richard Fryling, Jr., Esq.
Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101