ML19254D173

Petition to Intervene by Newberry Township TMI Steering Committee.Psychological Impact Should Be Regarded as Reason for Nonreactivation of Facility.W/Affidavits & Certificate of Svc

ML19254D173
Person / Time
Site:	Three Mile Island
Issue date:	08/31/1979
From:	Cunningham J NEWBERRY TOWNSHIP, YORK HAVEN, PA
To:
References
NUDOCS 7910220465
Download: ML19254D173 (15)

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49 4pf UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION g IN THE MATTER OF: -

GENERAL PUBLIC UTILITIES  :

METROPOLITAN EDISON CORPORAT1urf  : Docket No. fd-il1.f j (THREE MILE ISLAND NUCLEAR  :

PCMER STATION:  :

PETITION FOR LEAVE TO INTERVENE The Newberry Township T.M.I. Steering Committee (Cou.mittee), on its own behalf and on behalf of its members and the following individuals on their own behalf, hereby petition 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.

IDENTITICATION OF PETITIONERS A. Newberry Township T.M.I. Steering Committee. This Petitioner is an unincorporated association whose members have specifically directed its Chairman to execute the attached affidavit on their behalf, which me=bers are all residents of Newberry Township, York County, Pennsylvania, all of which Township is virtually lying within a five (5) mile radius of the Three Mile Island Nuclear Power Station. The Committee's principal concern of relevance here is the potential health problems associated with the reactivation of Unit Number One located at rhe Three Mile Island Nuclear Station. The Co=mittee's concern is concentrated, for purposes of this Petition, to the issues of the psychological and emotional impact upon the citizens of Newberry Township if reactiviation of Unit Number One is authorized by the NRC in light cf the recent accident of March 28, 1979.

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b. Mickey Minnich; Richard J. Zlogar: Linda S. Carlisle; Virginia Phillips; C. Willis Wolfe; Linda I. Dominsoki; Patricia A. Smith; Donna K.

Umholtz; Colleen M. Clark; M. David Clark: and Michael L. Glock, M.D.

These Petitioners are residents of Newberry Township who all live within five (5) miles of the Three Mile Island Nuclear Power Station. The Petitioner's principal concern of relevance here is the potential health and economic problems associated with the reactivation of Unit Number One located at the Three Mile Island Nuclear Station. The Petitioners' concern is concentrated, for purposes of this Petition, to the attendant psycological trauma experienced by themselves during and after the March 28, 1979, accident and the psychological impact upon surrounding citizens in other communities resulting in bias and prejudice against siting new residential construction, new businesses, and buying improved real estate in Newberry Township as manifested by the decrease in new residential construction, non-existant real estate market and losses experienced by businesses in the Townsh'p.

INTERESTS TO BE AFFECTED All Petitioners are concerned that the reactivation of Unit Number One located at the Three Mile Island Nuclear Station will create a serious risk to the psychological well being of its members themselves and the general public which can seriously affect the health and econom. cal welfare of the area surrounding the Three Mile Island nuclear Power Station.

Thus the reactivation of Unit Number One located at the Three Mile Island Nuclear Power Station subjects the Petitioners to potential psychological and attendant economic risk.

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CONTENTIONS That the psychological impact upon members of the Committee and upon the individual Petitioners of the reactivation of Unit Number One located at Three Mile Island Nuclear Power Station in light of the March 28, 1979, accident which took place at the Three Mile Island Nuclear Power Station is an aspect which has never been adequately considered in any previous hearing. Moreover, the public bias and prejudice generated against the Newberry Township area as a result of the March 28, 1979 accident and the threat of the reactivation of Unit Number One has and will in the future affect the siting of new residential building, new businesses and the purchasing of existing improved parcels of real estate within the Township. As a result of the March 28, 1979 accident at the Three Mile Island Nuclear Power Station the real estate market within Newberry Township has become virtually non-existent and in the event Unit Number One is allowed to be reactivated, the market will be even further depressed. Petitioners contend that this phenomena is directly related to the psychological fear of the public to being closely located to the Three Mile Island Nuclear Power Station. Thus, this fear has and will be manifested in the future by a continuing depressed and/or non-existent real estate market. Petitioners contend that this too is an aspect which has never been adequately considered in any previous hearing.

CONCLUSION For these reasons, we urge tha'c the reactivation of Unit Number One located at Three Mile Island Nuclear Power Station not be approved.

Resp ectfu'lIy, -

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Jordan D. Cunninghamf Esq., q q33 FOX, FARR & CUNNINGHAM , (_ /1I

AFFIDAVIT NOW COMES Mickey Minnich, and being sworn on oath, deposes and says:

1. That he is the Chairman of the Newberry Township Three Mile Island Stearing Committee;

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2. ThathisaddressisR.D./{,Etters,NewberryTownship, York County, Pennsylvania;

3. That he is aware of the contents of the Petition to Intervene and attests that the information contained therein is true and correct to the best of his personal knowledge and belief.

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MickeyMinn[ch SWORN TO AND SUBSCRIBED BEFORE ME, this day of 0' 's" . 1979.

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AFFIDAVIT NOW COMES .

and being duly sworn on oath, deposes and says:

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1. That (he) (she) is a citizen and resident of Newberry Township, York County, Pennsylvania;

2. That (he,) (she) lives within approximately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (he) (she) is aware of the contents of the Petition to Intervene and attests t!.at the information contained therein is true and correct to the best of (his) (her) personal information and belief.

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SWORNTOANDSNSCRIBED BEFORE ME, this O './8 day of s.u*, 1979.

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AFFIDAVIT

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1. That (he) (she) is a citizen and resident of Newberry Township, Terk County, Pennsylvania;

2. That Otc) (she) lives within approximately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (he) (sg) is aware of the contents of the Petition to. Intervene and attests that the information contained therein is true and correct to the best of (his) (her) personal information and belief.

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day o L 4La F, 1979.

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1m AFFIDAVIT NOW COMES "7. and being duly sworn on v

oath, deposes and says:

1. That (he) (she), is a citizen and resident of Newberry Township, York County, Pennsylvania;

2. That (he) (she) lives within approximately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (he) (she). is aware of the contents of the Petition to. Intervene and attests that the information contained therein is true and correct to the best of (his) (her) personal information and belief.

SWORN TO AND SUB' SCRIBED BEFORE ME, this Od day of flu *(4 1979.

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Notary Public UNDA S. H4MllTON. New g

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AFFIDAVIT NOW COMES / .-

'a and being duly sworn on oath, deposes and says:

l. That (he) gis a citizen and resident of Newberry Township, York County, Pennsylvania;

2. That (he) (shej. lives within approximately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (he) (she) s is aware of the contents of the Petition to Intervene and attests that the information contained therein is true and correct to the best of (his) (hep personal information and belief.

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SWORN TO AND SIIBSCRIZED BEFORE ME, this - k day of t ur,/e b 979.

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Notary Public LINDA S. H4Yl'.T04. N$tuv Public MY C*hm bpkes Feb. 15. 1982 Maubw1 PA C@ % ,

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AFFIDAVIT NOW COMES / 'T . and being duly sworn on oath, deposes and says:

l. That ( (she) is a citizen and resident of Newberry Township, York County, Pennsylvania;

2. That ( { (g lives within approximately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (hf (she) is aware of the contents of the Petition to Intervene and attests that the information contained therein is true and correct to the best of (hg' (g personal information and belief.

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SWORN TO AND SLIBSCRIBED BEFORE ME, this - //

day of s..r.ok1979.

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AFFIDAVIT NOW COMES T kU, #&dd C and being duly sworn on

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oath, deposes and says:

l. That (he) (she) is a citizen and resident of Newberry Township, York County, Pennsylvania;

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2. That (he) (she) lives within approximately five (5) miles s

of the Three Mile Island Nuclear Power Station;

3. That (he) ( g is aware of the contents of the Petition to. Intervene and attests that the information contained therein is true and correct to the best of (his) (her) personal information and belief.

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SWORN TO AND SifBSCRIBED BEFORE ME, this .

day of //W e e 1979.

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AFFIDAVIT NOW COMES  !); - 2[ ![f!-- and being duly sworn on oath, deposes and says:

l. That g) (she) is a citizen and resident of Newberry Township, York County, Pennsylvania;

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2. That (he) (she) lives within approximately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (hg (she) is aware of the contents of the Petition to Intervene and attests that the information contained therein is true and 6 correct to the best of (his) (her) personal information and belief.

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t SWORN TO AND SUB$CRIBED BEFORE ME, this /

day of 6 64v 4 1979.

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AFFIDAVIT

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and being duly sworn on

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oath, deposes and says:

1. That (he) (s,he.)

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2. That (he) (she) lives within approximately five (5) miles 7

of the Three Mile Island Nuclear Power Station;

3. That (he) (she) is aware of the contents of the Petition

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to Intervene and attests that the information contained therein is true and correct to the best of (his) (her) personal information and belief.

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SWORN TO AND StfBSCRIBED BEFORE ME this W day of [(/.A"ej,1979.

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AFFIDAVIT

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oath, deposes and says:

l. That (he) (she) is a citizen and resident of Newberry Township, York County, Pennsylvania;

2. That (he) (she) lives within approxi:nately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (he) (she) is aware of the contents of the Petition to Intervene and attests that the information contained therein is true and correct to the best of (his) (her) personal information and belief.

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kN SWORN TO AND SUB$CRIBED BEFORE ME, this - [

day of [/LMLw 1979.

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AFFIDAVIT

and being duly sworn on NOW COMES - -

s oath, deposes and says:

l. That p (she) is a citizen and resident of Newberry Township, York County, Pennsylvania;

2. That (she) lives within approximately five (5) miles of the Three Mile Island Nuclear Power Station;

3. That (he) (she) is aware of the contents of the Petition

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to Intervene and attests that the information contained therein is true and correct to the best of (his) (her) personal information and belief.

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SWORN TO AND SUBSCRIBED BEFORE ME, this - kk day of /_ A& # N 1979.

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CERTIFICATE OF SERVICE AND NOW, this 31st day of August, I Jordan D. Cunningham, Esquire, l

i j Attorney for Petitioner, hereby certify that I served the within Petition or l

j Leave to I.tervene, by depositing same in the United States Mail, postage prepa b , at the post office in Harrisburg, PA, addressed to:

Secretary of the Comission United States Nuclear Regulatory Comission Washington, D.C. 20055 Geroge Trowbridge, Esquire Shaw, Pittnan, Potts and Trowbridge 1800 M Street, N.W.

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Washington, D.C. 2003 P , .

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g  ? % fh/ - a g , Erdan D.,Cunningha / Esquire

/' Attorney M r Pe ' toner 2320 North S- ond Street Harrisburg, Pennsylvania 17110

, (717) 238-6570 I d

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