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Category:Legal-Affidavit
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2023-09-26
[Table view]
Category:Legal-Petition to Intervene
MONTHYEARML19029A6611978-05-17017 May 1978
Submit Petition for Leave to Intervene Concerning Proposed Issuance of Amendment to Facility Operating License No. DPR-70
ML19029A6721978-05-11011 May 1978
Amended Petition to Intervene
ML19029A7071978-04-0404 April 1978
Unit #1 - Petition for Leave to Amend Petition for Leave to Intervene by the Township of Lower Alloways Creek
ML19029A7061978-04-0404 April 1978
Unit #1 - Petition for Leave to Amend Petition for Leave to Intervene by the Township of Lower Alloways Creek
ML19029A7051978-04-0404 April 1978
Unit #1 - Petition for Leave to Amend Petition for Leave to Intervene by Township of Lower Alloways Creek
ML19029A3801978-03-0909 March 1978
Public Service Electric & Gas Co. - Petition for Leave to Intervene by the Township of Lower Alloways Creek
ML19029A3791978-03-0909 March 1978
Public Service Electric & Gas Co. - Petition for Leave to Intervene
ML19029A3821978-03-0707 March 1978
Public Service Electric & Gas Co. - Petition of State of New Jersey for Leave to Intervene
1978-05-17
[Table view] |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of )
)
PUBLIC SERVICE ELECTRIC & ) Docket No. 50-272 GAS COMPANY )
)
(Salem Generating Station, )
Unit #1) )
PETITION FOR LEAVE TO AMEND PETITION FOR LEAVE TO INTERVENE BY THE TOWNSHIP OF LOWER ALLOWAYS CREEK A Petition For Leave To Intervene By The Township of Lower Alloways Creek, and Affidavit In Suppo+t Of Petition For Leave To Intervene By The Township Of Lower Alloways Creek was filed in this proceeding on March 9, 1978.
By Order dated March 22, 1978 the Atomic Safety and
~icensing Board Designated To Rule On Petitions For Leave To* Intervene granted a motion by the Division of Public
/ Interest Advocacy, Department Of Public Advocate, State of New Jersey, to extend to and including April 5, 1978 the time for filing A Petition For Leave To Intervene.
The motion that was granted also provided for extension of time to amend previously filed Petitions such as the
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one filep by Petitioner, Township of Lower Alloways Creek.
On March 22, 1978 NRC Staff filed an Answer To Petition For Leave To Intervene By The Township Of Lower Alloways Creek in which it concluded that the Petition For Leave To Intervene By The Township Of Lower Alloways Creek should be granted, subject to the Township demon-strating how its interest will be affected by this J?roceeding.
Petitioner hereby requests that its previously filed Petition For Leave To Intervene be amended by the addition of the following statement demonstrating how its interest may be affected 'by the results of this proceeding.
Petitioner contends that its original Petition and all the statements contained therein, when read as a whole, amply demonstrate how its interest may be affected, especially when logical inferences and conclusions are drawn. The interest of the Township of Lower Alloways Creek in protecting the health, safety and welfare of the public or any person within it, would be adversely affected if there were any accidents or nuclear mishaps at the Salem Unit #1, Spent Fuel Storage Area due to the requested
increase of storage capacity, which is the subject of this proceeding.
Any such accident or nuclear mishap will adversely affect or jeopardize the health and safety of persons and members of the public at or near the site by exposing them to bodily harm from the resulting radiation. Since the very site and the persons and members of the public so exposed are within the Petitioner Township, the Petitioner's interest in preserving their health, safety and welfare will be affected if the increase in spent fuel storage capacity increases the r+/-sk of excessive radiation, accidents and nuclear mishaps.
Petitioner through its contentions, maintains that such increased risk of excessive radiation, accidents and nµclear mishaps may result from the granting of application for the increased storage of spent fuel at Salem Generating Station Unit #1. The purpose of this intervention is to make sure that these risks are fully considered and that the public health and safety with
/'
which the Township is charged is properly protected against these risks.
WHEREFORE, the Petitioner, Township Of Lower Alloways Creek, respectfully requests that this Petition To Amend its previously filed Petition For Leave To Intervene, be granted.
Dated:~t/ I 19 78 LOWER ALLOWAYS CREEK TOWNSHIP BY: I~ I '.
w~~*~~~-
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Its. Attorney 67 Market Street Salem, NJ 08079
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of )
)
PUBLIC SERVICE ELECTRIC & )
GAS COMPANY ) DOCKET NO. 50-272
)
(Salem Generating Station, )
Unit #1) )
)
AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO AMEND PETITION FOR LEAVE TO INTERVENE BY THE TOWNSH+P OF LOWER ALLOWAYS CREEK SAMUEL E. DONELSON, being duly sworn according to law, deposes and says:
- 1. I am a duly elected member of the Township Committee of the Township of Lower Alloways Creek. I am also the Mayor of said Municipality and am authorized on behalf of the Township of Lower Alloways Creek to make this Affidavit.
- 2. To the best of my information, knowledge and belief the facts set forth in the foregoing PETITION I* -
FOR LEAVE TO AMEND PETITION FOR LEAVE TO INTERVE~E and the contentions contained therein are true and correct.
- 3. The aspect of the proceeding as to which inter-vention is desired is the request by licensee for an amendment to its Facility Operating License No.DPR-70 by application for increased capacity fuel rods dated November 18, 1977 supplemented by request for an amend-ment Facility Operating License No. DPR-70 dat~d December 13, 1977.
- 4. The facts relied upon as to both interest and contentions are set forth in the foregoing Petition For Leave To Amend Petition For Leave To Intervene, all of which are true and correct to the best of my information, knowledge and belief and I adopt them as my own statements.
Dated:
,~1978
. 0
!_.,,,.,.,,efc+a~--
- SamueiE:DOnelson,Mayor Township of Lower Allo;.vays Creek Sworn and Subscribed to before me this _{tii_ day of ~,d_ _ ,1978.
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_NOf~RY ,euB_L4G OF NH(imsEY:
MyCommis.~io_~;~~pirs;~ ~~[it. :z-8, 193 ~
f ,_ ' - (""'~' ~-. \
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter Of )
)
PUBLIC SERVICE ELECTRIC & )
GAS COMPANY ) DOCKET NO. 50-272
)
(Salem Generating Station, )
Unit #1) )
)
CERTIFICATE OF SERVICE I certify that copies of PETITION FOR LEAVE TO AMEND PETITION FOR LEAVE TO INTERVENE BY THE TOWNSHIP OF LOWER ALLOWAYS CREEK TOWNSHIP and AFFIDAVIT by Samuel E.
Donelson have been served upon the below listed persons by ordinary mail on , April Lf~_,1978 and those persons are:
Troy B. Conner, Jr., Esq.
Suite #1050
- 17 Pennsylvania Avenue, N.W.
Washington, D.C. 20006 Executive L~gal Director U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Dated: '19 78
