ML19308A649
| ML19308A649 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/05/1979 |
| From: | Selkowitz L SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 7911280036 | |
| Download: ML19308A649 (3) | |
Text
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UNITED STATES OF AMERICA cs g*
NUCLEAR REGULATORY COMMISSION
't uta n Re: Metropolitan Edison, et al.
Docket No. 50-320 (Three Mile Island Nuclear Station, Unit 2)
Petition to Intervene and Request for a Hearing Pursuant to Paragraphs 5 and 6 of the NRC Order of October 14,1979, and pursuant to Section IV of the Order of October 18,1979 as well as 10 C.F.R.
Section 2.714, the Susquehanna Valley Alliance, by its undersigned attorneys, hereby requests a hearing regarding the licensing and operation of Epicor II at Three Mile Island and in support thereof sets forth the following:
- 1. Susquehanna Valley Alliance is a citizens group made up of residents cf the Susquehanna River Valley, who use the river water for drinking, cooking, bathing, recreation and other purposes and who are endangered by any releases of radioactivity through any pathway from Three Mile Island.
- 2. SVA has sued the NRC (and Met-Ed) in Federal Court involving some of the issues set forth in the above-referenced paragraphs thus the interests of SVA in resolving this matter are known to the Commission.
- 3. SVA hereby contends that the actions taken by the NRC in paragraphs 1,2 and 3 of its Order of October 16,1979 were not necessary to protect health and safety and minimize danger to life and property in that:
- a. Worker exposures to the entire process of
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etc. were not adequately assessed prior to approving its operation.
- b. the exposures and other factors and problems relating to solidification have not been addressed even though solidification of spent resins is required.
- c. all formerly available waste disposal sites are closed requiring Three Mile Island to become a long-term storage site, in violation of NRC license requirements and regu-lations.
- 4. For the reasons set forth in paragraph 0 herein, the actions of the NRC, and the damages resulting therefrom, will significantly affect the quality of the human environment and must be reviewed as part of an Environ-mental Impact Statement regarding the entire cleanup of Unit 2 and restart of Units 1 and 2.
- 5. The SVA files this petition to protect whatever rights it may have to proceed before the NRC but does so without prejudice to its rights to pursue its action in the Federal District Court for the Middle District of Pennsylvania, and in the U.S. Court of Appeals for the Third Circuit, or in any other appropriate Court and further states that resort to the NRC under the above referenced Orders are futile and constitutes an administrative remedy
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which need not be exhausted by petitioners.
AOLER P C.
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' Larry B. Sdlkowitz#
Widoff Reager Selkowitz & Adler, P.C.
P. O. Box 1547 Harrisburg, PA 17105 Jean Royer Kohr, Esquire Minney, Mecum & Kohr 121 East King Street Lancaster, PA 17602 Albert J. Slap, Esquire Public Interest Law Center of Philadelphia 1315 Walnut Street, Suite 1600 Philadelphia, PA 19107 Counsel for Plaintiffs Dated: November 5,1979 l
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REAGER.
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ADLER P C.
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