ML19209C031
| ML19209C031 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/29/1979 |
| From: | Keck H ANTI-NUCLEAR GROUP REPRESENTING YORK |
| To: | |
| References | |
| NUDOCS 7910110417 | |
| Download: ML19209C031 (7) | |
Text
,d Mus UNITED STATES OF AMERICA g
NUCLEAR REGULATORY COMMISSION
\\Y Ib Q
SERVEO Kpf 1979 Q
5 In the Matter of b
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METROPOLITAN EDISON COMPANY Docket No. 50-289 4
(Three Mile Island Nuclear Station, Unit No. 1)
PETITION FOR LEAVE TO INTERVENE 1.
The Anti-Nuclear Group Representing York, also known as ANGRY (Petitioner), on its own behalf and on behalf of its members, hereby petitions the Nuclear Regulatory Commission (NRC) for leave to intervene in the above captioned matter, pursuant to Section 2.714 of the NRC's Rules of Practice (10 CFR S2.714) and to the NRC's Order dated August 9, 1979.
2.
Petitioner is a Pennsylvania non-profit corporation located at 245
"!. Philadelf>hia Street, York, Pennsylvania 1740h.
It is a person within the meaning of 10 CFR S2.4(o).
Petitioner represents in excess of 300 active and supporting members, all of whom reside within 15 miles of Three Mile Island (TMI).
In addition, Petitioner regularly communicates with approximately 1400 interested individuals within approximately 25 miles of TMI.
The above members and individuals are residents, property owners, and owners of businesses within the above areas.
Its primary purpose is to raise the level of awareness of persons living in and around the City of York of the potential dangers to public health and safety represented by nuclear fission as a means of electricity generation and to oppose the use of nuclear fission in general.
It came into existence to fulfill the need felt by its founders for an organization that could 1130 122 wa.u m na.1h.%.:...m nauoyg
~
effectively address and respond to the full range of issues raised 1979.
by the near-disaster which occurred at TMI Unit 2 on March 28, Two of f.s members were consumer-intervenors in the proceedings before the Pennsylvania Public Utilities Commission which set allowable rates for Metropolitan Edison in the accident's aftermath.
It submitted a petition for rulemaking to the NRC requesting the preparation of an Environmental Impact Statement before the release into the atmosphere of radioactive gaseous fission products presently contained within the TMI Unit 2 reactor.
Petitioner has been in direct contact with the York County Board of Commissioners for the purpose of communicating the concern of its members over the sufficiency of the County's yet to be formally adopted Emergency Evacuation Plan.
3.
Petitioner represents the interests of its members and the individuals with which it regularly communicates.
These individuals are directly af fecte d by this proceeding since the operation of TMI hcs affected and will continue to affect their personal safety as well as the nature and quality of their lives, their property and leasehold values, their employment and businesses interests.
Petitioner, itself, is a person withi9 :he meaning of Part 2 of 10 CFR. 4.
Petitioner is concerned as to whether the corrective measures specified in the NRC's August 9 Order are sufficient to provide reasonable assurance that Metropolitan Edison can operate the TMI Unit 1 facility and whether the facility can be operated under any circumstances without endangering the health and safety of ts members and of the general public.
The analysis that the NRC has issued of the March 28, 1979
- 117, 1
7 I iJU s
3 near-diaster at TMI-2 place major emphasis on human error or management negligence as a contributory factor to the severity of that event.
Such revelations have raised substantial doubts in the minds of Petitioner's members as to Metropolitan Edison's management capability to operate a nuclear generating facility safety.
Petitioner is in particular concern with the sufficiency of NRC's August 9 Order in addressing all dimensions of the inadequacy of both Metropolitan Edison's specific operational practices and procedures employed during and immediately after the accident, as well as Metropolitan Edison's general attitude of complacency and unconcern for operating TMI-2 in a safe manner.
Petitioner is further concerned with Metropolitan Edison's failure during the course of the accident to adhere to the provisions c' its Emergency Plan, particularly those concerning the prompt communication of accurate information to appropriate state and local authorities.
Petitioner's concern extends to the adequacy of the Emergency Response Plans of local governmental units within a 20-mile radius of the facility, both at the time of the accident and at present.
Petitioner, therefore, has substantial concern over the sufficiency of the measures in the August 9 Order for assuring the adequacy of the Emergency Plans of both Metropolitan Edison and of local governmental units surrounding TMI.
Thus to the extent it fails to address adequately the subjects of Petitioner's the NRC's August 9 Order poses a substantial risk that
- concern, TMI-l will resume operation with no reasonable assurance that such an action would not seriously endanger the health and safety of Petitioner's members and of the general public
- 130 124 5.
Section 2(d) of the Atomic Energy Act (42 USC S2012(d))
provides that utilization of radioactive materials must be regulated "to protect the health and safety of the public."
Section 2(e) of the Act (42 USC S2012(e)) provides that regulation by the United States of utilization facilities is necessary "to protect the health and safety of the public."
Section 3(d) of the Act (42 USC S 2013 (d) ) states that one of the purposes of the Act is to encourage participation in the utilization of atomic energy "to the maximum extent consistent with...the health and safety of the public."
Petitioner's interest that TMI-l not resume operation until protection of the public health and safety can be reasonably assured is clearly within the scope of interests that the Atomic Energy Act was intended to protect.
6.
Petitioner seeks to intervene in this proceeding with respect to the following specific issues:
Whether the provisions of the NRC's August 9 Order a.
are sufficient to insure that Metropolitan Edison has the management capability to operate TMI-l without endangering the public health and safety and whether Metropolitan Edison, in fact, has such capacity; b.
Whether the provisions of the NRC's August 9 Order are sufficient to assure the adequacy of the Emergency Plans of both Metropolitan Edison and of surrounding governmental units and whether such plans are, in fact, sufficient.
Whether it is appropriate to consider an order to allow c.
TMI-l to operate before long-term actions are completed.
113J 125 7.
For all the foregoing reasons, Petitioner requests that it be granted leave to intervene in the proceeding held pursuant to the NRC's August 9 Order in regard to the TMI-l Nuclear Station.
Respectfully, ANTI-NUCLEAR GROUP REPRESENTING YORK
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Dated:
August 29, 1979 By holly S. Ked$, I.egislation Chairman A:: CRY 113]
126 AFFIDA7IT OF HOLLY S. KECK I Holly S. Keck, duly sworn, do state:
1 that I am Legislation Chairman of Anti-?uclear Group Representing York whose office is located in York, Pennsylvanin, 2.
that I have been authorized to sign a petition to intervene on behalf of the membership of Anti-!'uclear Group Representing York, 3
that I an aware of the contents of the Petiticn to Intervene and attest that the information contained therein is true and correct to the best of my. personal knowledge and belief.
Y
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e Holly 3. Keck SUBSORIEED A?!D S'il0R" to before T.e this 29th day of August 1979 l/,, / Y,.., / I' jll
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U:'ITED STATES CF A:.2RICA e
EUCLEAR REGULATCRY CCL2:ISSION ib
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-A gp'f ATCHIC SAFETY AI'D LICENSI::0 BOARD yp Ivan 'd.
Smith, Escuire, Chairnan 1
Dr. '/! alter H. Jordan,..: ember T;
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o. ry '* 6 e **s e Dr. Linda W. Little, '.' ember q\\
mp In the Matter of METROPOLITAN EDISON CC:.IFANY Dccket No. 50-289
( Three Mile Island Nuclear Station, :
Unit No. 1)
CERTIFICATE CF SERVICE I, Eclly S. Keck, hereby certify that I have this 29th day of August, 1979 served copies of the foregoing Petition For Leave To Intervene on each of the following persons by causirg same to be deposited in envelopes adressed to said persons, first class, postage prepaid, and deposited with the United States Postal Service.
Secretary of the Octmission United States Nuclear Regulatory Commission
lashington, D.C. 20555 Attention:
Chief, Docketing and Service dection Executive Legal Director United States Muclear Regulatory Commission Nashington, D.C. 20555 George F. Trowbridge, Esq.
Shaw, Pittman, Potts and Trowbridge 1800 M Street, U. 'cl.
Nashington, D.C. 20036
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Holly S. Kec2s Legislatior Chairman ANGRY P00R 28101 113J 128