ML19275A641
| ML19275A641 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 09/14/1979 |
| From: | Sheldon K PEOPLE AGAINST NUCLEAR ENERGY, SHELDON, HARMON & WEISS |
| To: | |
| References | |
| NUDOCS 7910180048 | |
| Download: ML19275A641 (17) | |
Text
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METROPOLITAN EDISON COMPANY, ) et al., ) Docket No. 50-289 (TEriie Mile Island Nuclear ) Station, Unit No. 1) )
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PEOPLE AGAINST NUCLEAR ENERGY PETITION TO INTERVENE By Order and Notice of Hearing dated August 9, 1979, the Nuclear Regulatory Commission ordered the Metropolitan Edison Company to maintain Unit 1 of its Three Mile Island nuclear power plant ("TMI-1") in a cold shutdown condition pending completion of hearings before a specially constitu-ted Atomic Safety and Licensing Board. The purpose of these hearings is to resolve a series of issues identified by the Commission as determinative of whether resumption of opera-tion at the plant would be consistent with the public health and safety. The order establishes that the procedures in subpart A of 10 CFR Part 2 will govern the TMI-l proceedings. Pursuant to 10 CFR 2.714, People Against Nuclear Energy (PANE) hereby petitions to intervene as a party. (1) The Nature of PANE's Right Under the Atomic Energy Act to be Made a Party to the Proceeding. PANE's right to intervene is established by Section 189a of the Atomic Energy Act, 42 U.S.C. 2239 (a) which requires the 1184 257 7910180 09'ff ?
Commission to admit as a party "any person whose interest may be affected by the proceeding." In this proceeding, PANE seeks to intervene on behalf of the following named persons, all of whom are members of the organization and have specifically authorized PANE to represent their interests: John M. Garver, Jr. 114 Park Circle Road Middletown, PA. James B. Hurst 617 Briarcliff Road Middletown, PA. Barbara G. Coaces 360 High Street Highspire, PA. Donald E. Hossler 501 Vine Street Middletown, PA. Marcella J. Heicher 326 Second Street Highspire, PA. Morris Field 504 Hemlock Hall Middletown, PA. Genevieve Burner Emerick 489 Willow Street Highspire, PA. Donald H. Konkle - 320 Elm Court Middletown, PA. Paola Louise Kinney 12 Ray Road Middletown, PA. Joyce Ann Corradi 2 South Nissley Drive Middletown, PA. Elizabeth Mae Chavey 114 Donald Avenue Middletown, PA. z3g4 25B
Affidavits which attest to these facts from the PANE members listed above are attached to this petition.
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(2) The Nature and Extent of the Petitioner's Property, Financial or Other Interest in the Proceeding. All of the named PANE members have a cognizable interest in the proceedings which may be affected by its outcome. They
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all live within 5 miles of the Three Mile Island facility. In the af termath of the accident at TMI-Unit 2, Petitionefs mental and emotional health would be adversely affected by the operation of a nuclear power plant in such close proximity. Such a concrete, direct interest clearly establishes standing. Consumers Power Co. (Palisades Nuclear Plant) LBP-79-20 July 24, 1979. (3) The Possible Effect of an Order Which May be Entered in the Proceeding on the Petitioner's Interest. The effect of an order allowing the resumption of operations at TMI-1, even assuming implementation of the so-called "short term actions" identified on pages 5-8 of the Order and Notice of Hearing and committment to the "long-term actions" contained on pages 7-8, would be to unreasonably threaten the physical, mental and emotional well being of the named PANE members. (4) The Specific Aspects of the Subject Matter of the Proceedings as to Which Petitioner Wishes to Intervene PANE will take the position that the Nuclear Regulatory Commission has the obligation, as part of its duty to protect the public health and safety, to prevent impairment of the mental health and stability of the communities in which nuclear plants are located. PANE will contend that its members and the ii84 259
community surrounding Three Mile Island have suffered a unique trauma as a result of the accide.nt at Unit 2 of the facility, and consequently, that operation of Unit 1 poses a threat to the stability and health of the area. For this reason, Unit 1 cannot be operated without endangering the health and safety of the public. Respectfully submitted Pecple Against Nuclear Energy By their Attorney: Karin P. Sheldon Sheldon, Harmon, Roisman & Weiss 1725 I Street, N.W. Suite 506 Washington, D.C. 20006 (202) 833-9070 D?.TED: September 14, 1979 H84 260
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AFFIDAVIT of John M. Garver, Jr. My name is John M. Garver, Jr. I make my Affidavit as foHows: John M. Garver, Jr. , 114 Park Circle Road, Middletown, Pa. I am a resident within a 5 mile area of Three Mile Island and I am a member of PANf, People Against Nuclear Energy. I authorize PANE to intervene on my behalf before the NRC Commission to prevent renewal operation of Three Mile Island Unit I. My concern is for the Health, Safety and Well-being, both physical and mental, of my family and community. 1 ,
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AFFIDAVIT State of Pennsylvania ) ( ss: County of Dauphin ) Before me the subscriber personally appeared Paula Louise Kinney, who being duly sworn, according to law, doth depose and say: APPIDAVIT OF PA07.J LOUISE KINNEY. I make my affidavit as follows: Paola Louise Kinney, I2 Ray Road, Middletown, Pennsylvania, I7057. I am a resident within the five mile area of Three Mile Island and a member of P.A.N.E. (People igainst Nuclear "alergy) . I authorize P. A.N.E. to intervene on my behalf before the Nuclear Regulatory Commission to prevent the renewed operation of Three Mile Island Unit #I. My concern is for the health, safety, well-being, both physical and mental, of my family and my community. .
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AFFIDAVIT State of Penns'rIvania ) ( ss: County of Dauphin ) Before me the subscriber personally appe'ared Elizabeth Mae Chavey who being duly sworn, according to law, doth depose and say: AFFIDAVIT OF ELIZABETH MAE CHAVEY I make my affida rit as follows: Elizabeth Mae Chavey, II4 Donald Avenue, Middletowl., Pennsylvania, I7057. Ian a resident within the five mile area of Three Mile Island and a member of P;A.N.E. (People Against Nuclear Energy). I authorize P.A.N.E. Commission to to prevent the renewed operation of Three Mile Island Unit #I. My concern intervene on my behalf before th~e Nuclear Regulatory is for the health, safety, well-being, both physical and mental, of my family sud my commity.
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Affidavit of Morris Field I make my affidavit as follows: Morris Field, 50l+ Hemlock Hall, Middletown, PA 17057 I as a resident vi+.nin the 5-mile area of Three Mile Island and a member of PAE (People Against Nuclear Energy). I authorize PAE to intervene on my behalf be .~ 3re the Nuclear Begulatory Commission to prevent renewed operation of Three Mile Island Unit #1. My concern is for the health, safety, and well-being, both physical and mental of my family and c~mmity.
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AFFIDAVIT of Donald H. Konkle I make :ny affidavit as follows: Donald H. Konkle, 320 Elm C Aart, Middletown, PA 17057 I an a resident within the 5-mile area of Three Mile Island and a member of PANE (People Against Nuclear Energy). I authorize PANE to intervene on my behalf before the Nuclear Regulatory emi*sion to prevent the renewed operation of Three Mile Island Unit
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Affidavit of James B. Hurst I make my affidavit as follows: James B. Hurst, 617 Briarcliff Road, Middletown, PA 17057 I am a resident within the 5-mile area of Three Mile Island and a member of PAE (Ibople Against Nuclear Ener6y). I authorize PAE to intervene on my behalf before the Nuclear BeEulatory Commission to prevent renewed operation of Three Mile Island Unit fl. My concern is for the health, safety, and well-being, both Itysical and mental of my family and cccmunity. G^ / /
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Mrw /Yh4/ es B. Hurst s Suorn to and subscribed before me this
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AFFIDAVIT State of Pennsylvania ) ( ss: County of Dauchin ) Before ma the subscrl'b er personally appeared Donald E. Hossier, who being duly swo rn , according to law, doth depose and say: Affidavit of Donald E. Hossler I sake my affidavit as follows: Donald E. Hossler, 501 Vine Street, Middletown, PA 17057 I am a resident within the 5-c11e area of Three Mile Island and a member of PANE (Brople Against Nuclear Energy). I authot e PANE to intervene on my behalf befolt the Nuclear Begulatory Cor.wission to prevent rencved operation of Three Mile Island Unit </1. My concern is for the health, safety, and well-being, both physical and mental of my family and com= unity. L % 9 . .x b v '
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Swo rn to and subscribed before me th i s g m 10th day of September 1979.
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AFFIDAVIT State of Penisylvania ) ( ss: County of Dauphin ) Before me the subscriber personally appeared Joyce Ann Corradi, who being duly sworn, according to law, doth depose and say: Joyce Ann Corradi, 2 South Nissley Drive, Middletown, rennsyivania, 17057. I am a resident wIthIn the fIve mi1e area of the Three Mile Island and a membe r o f. P . A.N .E . (People Against Nuclear Energy ). I autho ri ze P . A.N.E . to Intervene on my behalf before the Nu l cear Regul atory Commi ss ion to prevent the renewed operation of Three Mlle Island Unit #1. My concern is for the health, safety, well-being, both physical and mental, of my family and my community.
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4 10th day of September 1979. Notary Pub I i c MAR'C 4. CORDOI. WAEY PUBUC t.0WER SWATARA T#P., DAUPHIN COUNTY , M1 C:*A*JR;n LtPIRES SEPT.B. L']60 Ve .Sar.Fensfi v1n a A. CAM.* .f.tiv -s
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I'nake ny affidavit as follows: Oenevieve 2urner Zmerick, h69 'illow Street, Highspire Jennsyl'.snia, huphin County. - I an a recident within the five nile area cf Three ".ile Icland and a nenter of PA'E (?eople Against :!uclear 2ncrgy). I authorire ?%5 to a intarviee on ny be$tif ':efore the Tuclear .legulater Connitsien to prevent the revowed operation of Three 7.ile Island, Uni: Cne.
*y concern is for the health, safety and well 'ceing, both physical and mental, of ny fanily and ny connunity.
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AFFIDAVIT OF: MARCELLA J. HEICHER I make my affidavit as follows: Marcella J. Heicher, 326 Second Streer, Highspire, Dauphin County, Pennsylvania. I am a resident within the five mile area of Three Mile' Island and a member of PANE (People 6A einst Nuclear Energy). I authorize PANE to intervien on my behalf before the Nuclear Regulatory Commission to prevent the renewed operation of \' Three Mile Island, Unit One. My concern is for the health, safety and well being, both physical and mental, of my family and my community. . f&M6 ! /t
, MARCELLA K HEICHER G ma N' y b ,odsubis d b.d before, cw A[lv .
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AFFIDAVIT OF: BARBARA G. COATES I make my affidavit as follows: BARBARA G. COATES, 380 High Street, Highspire, Dauphin County, Pennsylvania. I am a resident within the five mile area of Three Mile Island and a member of PANE (People Against Nuclear Energy). I authorize PANE to intervien on my behalf before the Nuclear Regulatory Commission to prevent the renewed operation of ne. Three Mile Island, Unit My concern is for the health, safety and well being, bot;h physical and mental, of my family and my community. I' O
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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METROPOLITAN EDISON COMPANY, ) et al., ) Docket No. 50-289 (TEree Mile Island Nuclear ) Station, Unit No. 1) )
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NOTICE OF APPEARANCE Notice is hereby given that the undersigned will appear in this matter for the People Against Nuclear Energy (PANE). Name: Karin'P. Sheldon Address: Sheldon, Harmon, Roisman & Weiss 1725 I Street, N.W. Suite 506 Washington, D.C. 20006 Telephone: (202) 333-9070 Admissions: Supreme Court of the State of Washington District of Columbia Court of Appeals U.S. District Court, District of Columbia t i Karin P. Sheldon DATED: September 14, 1979 g a b e 1
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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METROPOLITAN EDISON COMPANY, ) et al., ) Docket No. 50-289 (TEree Mile Island Nuclear ) Station, Unit No. 1) )
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CERTIFICATE OF SERVICE I hereby certify that I have this 14th day of September, 1979 served copies of the PANE Petition to Intervene by. first-class U.S. mail, postage prepaid, to the following:
- Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Chief, Docketing & Service Section
*Exqcutive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 George F. Trowbridge, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D.C. 20036 Karin P. Sheldon g occrms S
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