ML19343B077
| ML19343B077 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/21/1980 |
| From: | Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19343B074 | List: |
| References | |
| NUDOCS 8011250327 | |
| Download: ML19343B077 (4) | |
Text
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BEEURE THE NUCLEAR REGUL74IORY C2 MISSION In the Matter of:
- Request of the Director of
- Nuclear Reactor Regulation, Byron Nuclear Power St nion
- Pursuant to 10 C.F.R. SS Lhits 1 and 2
- 2.2C.cd 2.202 RB2UEST PURSTAVf 'IO 10 C.F.R. 2.206 AND 2.202
'Ihe Rockford Ieague of Wcraen Voters (the " League") hereby requests the. Director of Nuclear Reactor Regulation, pursuant to 10 C.F.R.
S 2.206 (a), to initiate a proceeding pursuant to 10 C.F.R. S 2.202 to:
(a) Mcdify the construction license issued to Ccmnonwealth Edison Ca:pany for the Byron Nuclear PoWur Station, Units 1 and 2, so that construction may not proceed without resolution of all outstanding safety problems presently applicable to the Byrcn Station; (b)
Suspend or revoke the authority earlier granted to Ccemon-wealth Edison Carpany to construct the Byron Station unt.11 such time as Ca:m7: Wealth Edison has fornulated an acceptable and realistic plan for resolving all cutstanding safety probleans; (c)
Revoke the construction license issued to Ccanonwealth Edison Carpany for the Byron Station, if the~ outstanding safety probletus cannot be resolved prior to the ccx:pletion of ccnstruction due to Ediscn's financial condition or for othar reasons; and (d)
Pending full hearings and determinations en these requests, innediately halt further ccnstructicn of the Byron Station.
In support of this request, the league states:
8013250 M
1.
me League of Wcruen Voters is a national organization which is authorized by its Bylaws and Ccnstitution to becme involved with, and to participate in, the decisico-making process involving issues which affect its menters, including but not limited to energy and nuclear safety issues.
2.
Se League's Rockford, Illinois branch (ccr: posed of nunerous persons living near the site of the Byron Station and within the service area of Camenwealth Edison, including but not limited to Mrs. Betty Johnson of Rockford, Illinois) has been specifically dLrected to take such steps as are necessary to challenge Camenwealth Edison's cantinued constructicn of the Byron Station on de ground that the Byron Station is presently being built under a design which dces not resolve a myriad of sericus outstanding safety prcblems. If these safety prcblems are not resolved, the League and its menters, and the pWlic, will be adversely affected both as regards their health and safety and as regards their cost of electric service.
3.
Pursuant to its interest, the League has retained MHB Technical Asscciates of San Jose, D1ifornia, to do a detailed study of the outstanding nuclear safety prchlems which adversely affect the Byron Station, in the specific context of the Byron Station. That MHB study, which is in the form of a sworn Affidavit verified under oath, is attached hereto and incorporated herein as Exhibit A.
4.
The >HB stuiy demonstrates in detail that construction of the Byron Statica is proceeding apace without factoring in problems identified and recognized, as to both their existence and their seriousness, by the Ccnmission. Se bEB study further demonstrates that continued construction of the Byron Station without resolution of these safety prcblems jeopardizes the ptblic health and safety, in violaticn of the Rules and Regulations i 6
M'
of the Ca mission and specifically the authority vested in the Director of Nuclaar Reactor Regulaticn to nodify, suspend and revoke licenses (or take sxh other acticn as is appropriate) to protect the public health and safety.
MIEREFORE, on the basis of this request and the attached Affidavit containing the results of the MIB study above noted and incer-porated herein by ref'.rence, the Rockford Ieague of Eren Voters requests that the Director of Nuclear Peactor Regulation initiate, pursuant to 10 C.F.R. SS 2.206 and 2.202, the actions set forth above. Because construction of the Byron Station is now ongoing, and tends as it proceeds to prejtriice the resolution of safety issues, the Ieague requests that the Director initiate those actions as p w pLly as practicable.*
ROCKEC LEAGUE OF WCMEN Witx9
,1 F
BY:
2ts Attorney I
Myron M. Clerry Peter Flynn CIERRY & FI1NN One IBM Plaza, Suite 4501 Chicago, Illinois 60611 (312) 565-1177
- As the League understands the Cannssian's Rules and Regulations, no response to this petition is permitted (and there is no appeal to the Cmmission frm its grant or denial), so that its consideration should not be delayed for procedural reasons. While the MIB Affidavit incorporated herein is quite detailed, the League believes that the Director's expertise should enable him to reach a decision within 30 days en whether to initiate action as requested. The Ieague urges a prcept decision so that the inquiry can be pursued expeditiously (or so that the Ieague can pursue other remedies, should this request be denied), before the Byron Station becues a potentially dangerous fait acemoli. See paragraphs 1.2.3, 1.2.4, 2.3.5-2.3.8, 4.1-4.4 of the MIB Affidavit. :
PRCE OF SERVICE I certify that a copy of the foregoing Request and underlying Exhibit was served upon, by postage prepaid mail properly addressed, Harold R. Denton, Director of Nuclear Reactor Regulation, on Novenber 21, 4
1980.
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