ML19210E482

Petition to Intervene.Urges Commission to Hold Adjudicatory Hearing Re Hazards of Steam Tube Degradation.Certificate of Svc Encl

ML19210E482
Person / Time
Site:	Point Beach
Issue date:	11/26/1979
From:	Falk K WISCONSIN'S ENVIRONMENTAL DECADE
To:	NRC COMMISSION (OCM)
References
NUDOCS 7912050091
Download: ML19210E482 (2)

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BEFORE THE NUCLEAR RECULATORY COMMISSION I

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PETITION FOR LEAVE TO INTERVENE AND PETITION FOR HEARING

=23=3E33=====E=33===E=E====3======3E==3ES=3=2=E=3332===3=2=23==3======S=3 Petitioner WISCONSIN'S ENVIRONMENTAL DECADE, INC., pursuant to ss.

10 CFR 2.100 through 2.105 and chapters 50 and 51, hereby petitions the Nuclear Regulatory Commission (" Commission") for leave to intervene in the above-captioned proceeding in which the licensee Wisconsin Electric Power Company has applied for an amendment to its operating license by filing dated November 2, 1979.

The petitioner is an organization of citizens throughout the State of Wisconsin, including members who reside in the vicinity of the licensee's Point Beach Nuclear Reactor Unit 1, the plant which is the subject of the aforementioned operating license and proposed amendment thereto.

The petitioner seeks to intervene in said proceeding on behalf of itself and its members, particularly those residing in the vicinity of the Point Beach Unit 1 plant on the grounds that (1) they have a legally protected interest in the amendment application proceeding which is likely to be affected by the outcome of the proceeding; (2) the petitioner's interests are not now being adequately represented by the existing parties; and (3) the granting of this petition would not delay or prejudice the interests of the licensee to adjudicate the merits of its amendment application.

The petitioner respectfully requests that all documents previously filed in this regard by the licensee and that all further documents and filings 3j7 7912050 09 ,

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pertaining to this matter be served upon its attorney at her office at 114 East Mifflin Street, Madison, WI, 53703.

Furthermore, the petitioner respectfully requests the Commission to hold an adjudicatory hearing to determine the public health and safety im :ts of the proposed licensee amendment application because of the significe hazards posed at the Point Beach Unit 1 plant at this time as a result of steam tube degradation.

Dated this 26hth day of November, at Madison, Wisconsin.

WISCONSIN'S ENVIRONMENTAL DECADE, INC.

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'KATHLEEN M. FALK General Counsel 114 East Mifflin Street Madison, WI 53703 608-251-7020 I hereby certify that on November 26, 1979, I personally deposited in the United States First Class Mails a copy of this document as well as a copy of the Response of Petitioner Wisconsin's Environmental Decade, Inc. to November 23, 1979, Letter of Applicant Wisconsin Electric Power Company (Steam Generator Tube Degradation Matter)", dated November 26, 1979, to Mr. Sol Burstein of Wisconsin Electric Power Company, 231 W. Michigan, Milwaukee, WI 53202.

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