ML19257D486

Notifies of Decision to Appeal NRC 791109 Denial of Petition to Intervene.Submits Addl Supporting Info:Residence Is 26 Miles from Proposed Site & Must Protect Future Real Estate Investments

ML19257D486
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	01/03/1980
From:	Ryan Alexander AFFILIATION NOT ASSIGNED
To:	Rosenthal A NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8002040471
Download: ML19257D486 (2)

Text

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9f W, . ,5 January 3, 1930 ,-[ c. ,v g.p g-Atomic Safety and Licensing Anpeal Board E t@ k Alan S. Rosenthal, Chairman ~ 3 CY'M. h *h 3 g

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U.S. Nuclear Regulatory Commission

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Gentlemen In the matter of Houston Lightin & Power Co., Docket #50 h99.

Robert Alexander writes to inform the 3 card of his decision to appeal the Commission's denial (Nov. 9, 1979) of his Petition for Leave to Intervene.

Please consider the following points which will amend the deficiencifs of his initial filing and further elucidate his need to intervene in these proceedings.

(1) His family's residence is approximately 26 miles due East of the croposed site, well within the prescribed 50-mile radius.

(2) The Petitioner's main interest in these croceedings is manifested by his plans for future investment of nearly 3120,000 in real property by 1933 This real property will be located on Houston's southwest side. The petitioner's attempts to protect this investment will include the purchase of conventional insurance and the likewise prudent measure of prohibiting the presence of any and all nuclear liabilities, ie. Allens Creek Muclear Generatin; Station, that could render his holdings uninhabitable and largely worthless. The Apolicant's request to build ACNGS is a demonstrated risk that can only threaten the Petitioner's interests. He alone can fully represent this interest.

(3) As stated earlier in the initial filing, the Petitioner's literary expertise would enhance and assist in developing a sound record as pursuant to B2.71h(a)(1)(iii). He dealt intimately with the impact the Davis-Besse(Ohio) plant had upon the environment and particularly the economic conditions with regard to real estate values in that area surrounding the plant. This knowledgeability can surely aid these proceedings.

(4) As stated in paragraph 2 above, the Petitioner feels the absence of other likewise partisan realtors and investors will create a chasm to be gapped only by his participation.

(5) To reiterate, the Petitioner's participation will not broaden the issues nor delay the proceedings as pursuant to

.S2.714(a)(1)(v).

'The Petiti oner asks that the following points be admitted as his contentions in these proceedings: That the construction and subsequent oneration of ACNGS

1. will undermine and grossly devalue Petitioner's real 1866 I47 8ooso,g

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2. will irrecerabi:. v:.olate t 'r e na * ;rr ' >2,-50  :, ~

'he aree.(1he plant'c inezitable obralcscerce n neert 30 h 0 :/ ears a f te r i t s onening will render - luu~trnti-1 e.creare a bliahted and carthleno decert.);

3. will create ir.ot dir. ate ar.d unc ons titu tion'l e le c tric rate hiken and concomitantly preclude "he develornent of alternative energy sourcee.

la closine,. the Petitioner hereby reo;es*c 'urtbermore + bat he bo -Trented an extension of ti m, in additier 'o tha' leave cranted *o hi~ by the Board order of Lece~.ber li, 1979, to file n ~. o r o d e tailed quimle-entary trie f. 'i.s conter'ionn

'anar much cren+er 'lincussion.

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'cb e rt .ileynnder 109?< 1rior ?orest -!10<6 Mou-ton, TX 970h2 cc:

J. Grecory Copeland, Zsq.

Stephen . S o'r in ki , Esq.

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