ML20009E654

Petition to Intervene & Request for Hearing.Affidavits, Notice of Appearance & Certificate of Svc Encl

ML20009E654
Person / Time
Site:	Catawba
Issue date:	07/22/1981
From:	Guild R GUILD, R., PALMETTO ALLIANCE
To:	NRC COMMISSION (OCM)
References
NUDOCS 8107280338
Download: ML20009E654 (23)

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' 7/Zz/gi MOf, jy' "x UNITED STATES OF AMERICA ^ ,

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BEFORE THE NUCLEAR REGULATORY COMMISSIOC- o i.Q i

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Ex Parte: PALMETTO ALLI ANCE, ) b

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In the Matter of: ) DOCKET NOS, 50-413

) and N DUKE POWER COMPANY, ET AL. ) @j '/

(Catawba Nuclear Station, ) 50-${4 y {,'%a Units 1 and 2), ) 76 '- g.

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PETITION TO :NTERVENE AND REQUEST FOR HEARING \p'r y

\ o>/ m Palmetto Alliance, on its own behalf, on behalf of its members, and on behalf of other persons who are similarly situated, hereby petitions for leave to intervene in the above-captioned license proceedings as a party of record, requests that public hearings be conducted at which it will be afforded an opportunity to be heard, and requests this Application for Operating License be denied, or be so conditioned, as Petitioner will hereafter demonstrate, in order that the operation of the facility will be consistent with the terms and underlying policy of tne anti-trust laws of the United States and with the protection of the health and safety of the public. This relief is sought under provisions of the Alcaic Energy Actof1954,asamended,42U.S.C.A.552135and2239;10C.F.R.$2.714; and pursuant to Notice of Receipt of Application for Facility Operating Licenses, published June 25,1981, 46 F.R. 32974. In support of this Petition and Request for Hearing, Palmetto Alliance would respectfully show:

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1. That Palmetto Alliance is a not-for-profit membership organization incorporated under the laws of the State of South Carolina, with its principal offices at Columbia. It has a state-wide membership which has organized for the purposes of promoting the development of safe and renewable energy sources to meet human needs, and educating the public about the dangers and costs of commercial nuclear power and radioactive wastes. Its members include persons who live, work, engage in recreational activities, and participate in civic affairs in York County, South Carolina.

2. Members of Palmetto Alliance live, work, engage in outdoor recreational activities including fishing, boating, swimming, hunting, hiking and camping; consume vegetables, dairy products and meat, and breathe the air in close proximity to the Catawba Nuclear Station, Units 1 and 2, now under construction on Lake Wylie in York County. Members of Palmetto Alliance are consumers of energy for residential, recreational and business uses.

All now purchase electric energy from commercial sources and would make use of energy sources which are reasonably interchangeable with electricity such as solar, wind, bio-mass, and conservation techniques if such energy sources were more readily available and competitively priced. Petitioner's members include retail electric customers of Duke Power Company. York electric cooperative, and City of Rock- Hill municipal system.

3. That Petitioner's interest in protecting its members from probable hann to their health, safety, and economic interests can only be protected through full participation as a party to this proceeding with the right to offer evidence and to confront evidence offered by other parties. No other party can represent Petitioner's interest including the State of South Carolina whose participation is expected to be limited, the Commission

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I Staff which cannot represent the individual interests of Petitioner's members, and the Applicant;, whose interest is believed to be adverse I

to Petitioner's.

4. That Petitioner is informed and believes that a reasonable probability exists that the granting of the license sought by the Applicants and their joint ownership and operation of the Catawba Nuclear Station, Units 1 and 2, will contravene the anti-trust laws of the United States and the policies clearly underlying those laws. That significant changes attributable to the App W, ants have occurred sinc. the issuance of the construction permit for this facility warranting the conduct of an anti-trust review and hearing in this matter and either the denial of the application for the operating license or the conditioning of such license on such tenns as are necessary to minimize adverse anti-trust impacts.

Petitioner is informed and believes that the Applicants Duke Power Company, et al., have engaged individually and together in acts an'd conspiracies in restraint of trade, to acquire and inaintain monopoly power, and to coninit unfair trade practices to the direct injury of Petitioner's members who are consumers of electric energy sold by Duke Power Company, rural electric cooperatives and municipal power systems in South Carolina.

Petitioner's members are forced to pay higher prices for such electricity and are denied access to reasonably interchangeable alternate energy sources or must pay higher prices for such alternatives because of such conduct.

5. Petitioner is informed and believes tnat the grant of an operating license to Duke Power Company, et al., and the operation of the facility will result in direct physical harm to the health, safety, and economic l

interests of its members, their families and other persons similarly situated.

6. Petitioner is informed and believes that. such adverse impact will result to its members, in part, because, and that the Commission should deny or condition the operating license for reasons including:

a) The long term somatic and genetic health effects of radiation releases from the facility during normal operations and from the uranium fuel cycle, even where such releases are within existing guidelines, have been sufficiently underestimated by the Applicants and Commission Staff so as to compromise the validity of the cost-benefit balance struck at the construction permit phase of this license proceeding. The work of K.2.

Morgan, Bernd Franke of Heidelberg, and others calls into serious question the analysis relied upon including that of the BEIR III report and the Commission's food chain analysis, strongly suggesting that the health effects of ionizing radiation have been seriously underestimated, b) The Applicarts and Commission Staff have failed to adequately assess the impact of a serious accident, beyond design basis, on both the cost-benefit balance struck at the construction permit phase of this proceeding and the ability of Applicants, and local and state officials, to implement radiological emergency response plans sufficient to protect residents living in proximity to the plant. The probabilistic analysis employed in the Reactor Safety Study (WASH 1400) has been so seriously criticized as to make its use in licensing prcceedings as a basis for decision-making entirely inappropriate. "The consequence model used in WASH - 1400 should be substantially improved, and its sensitivities explored, before it is

used in the regulatory process." NUREG CR 0400, " Risk Assessment Review .

Group Report to the U.S. Nuclear Regulatory Commi:sion H.W. Lewis, Chairman", p. xi.

c) Substandard workmanship and poor quality control strongly suggest that actual plant construction is substantially below NRC standards in many safety related areas. A number of former Duke Power Company con-struction workers, including a certified Quality Control Inspector, have complained of systematic deficiencies in plant construction and company pressu~.! to approve faulty workmanship.

7. Petitioner reserves the right, and hereby asserts its intention, to hereafter file a supplement to this Petition to Intervene under provisions.

of 10 C.F.R. 5 2.714 (b) including a list of the contentions which it seeks to have litigated in this proceeding together with the bases therefor. It further reserves its right if admittted as a party to this proceeding, to amend this Petition in such manner as is deemed necessary and proper.

WHEREFORE, having set forth its interest which will be a#fected in this proceeding, having allegM at least one litigable contention and the basis therefor with reasonable specificity, and having annexed hereto the Affidavits of more than one of its members who will suffer injury in fact from the operation of this facility, which Affidavits are incorporated herein by reference, Palmetto Alliance respectfully requests leave to intervene in these proceedings, the conduct of hearings, and the denial

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l of this Application for Operating License unless so conditioned as to prevent injury to Petitioner's health, safety economic interests.

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July 22, 1981 Robert Guild V j 314 Pall Mall Columbia, South Carolina 29201 803-252-0929 i

! Attorney for Petitioner Palmetto Alliance I

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j UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: PALMETTO ALLIANCE, )

)

Petitioner, )

AFFADAVIT In the Matter of: l DOCKET NOS 50-413 and DUKE POWER COMPANY, ET AL. 50-414 (Catawba Nuclear Station, Units 1 and 2),

Applicants, PERSONALLY APPEARED before me, Anne Springs Close and Frances Close Hart, who, being duly sworn, say:

1. That she, Anne Springs Closg resides at Highway 160, Box 100, immed-iately west of Fort Mill, South Carolina, at a distance of approximately 8 miles from the Catawba Nuclear Station, Units 1 and 2. She operates a farm adjacent to her residence which farm she leases from a trust established for the benefit of her children one of whom is her daughter, the affiant Frances Close Hart. This farm consists of approximately 6,000 acres of land, about 2/3 of which is forested and 1/3 of which is under cultiva-tion. On this land she grows peaches, corn and other produce for sale and personal consumption, as well as various feed grains and about 250 head of beef cattle for sale and for some limited personal consumption.

That numerous ponds and streams are located on this land from which cattle and horses drink. Potable water for her residence is pumped from a source on the Catawba River downstream of the nuclear station.

2. That she, Frances Close Hart, resides at 2430 Terrace Way, Columbia, South Carolina. She and her minor children often visit her mother the affiant, Anne Springs Close at the aforementioned property near Fort Mill, South Carolina about 8 miles from the nuclear plant.

3. That both she, Anne Springs Close, and she, Frances Close Hart, have an ownership interest in Springs Mills, Inc., a manufacturer of textiles with properties in York, Chester, and Lancaster Counties.

4. That both affiants live, work, and engage in outdoor recreational activities including running, riding, hiking, camping, swinning and tennis throughout York County and in areas in close proximity to the Catawba Nuclear Station, Vaits 1 and 2.

5. That both affiants are infomed and believe that the grant of an operating license to Duke Power Company, et al. and the operation of this facility will result in direct physical hann to the health, safety and economic interests of themselves and their families.

6. That both affiants are further infonned that their interest in this matter can only be protected through participation in this operating license prot.ading, and that this interest will not be adequately re-presented by any of the other parties to the proceeding. They authorize Palmetto Alliance, of which they are members, or its representative, to protect their interest in this matter through participation in this proceeding.

JLbb Anne Spoings C16se Mb e Frances Close Hart SWORN to and subscribed SWORN to and subscribed me thisYd5y of

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beforemethishdayof y 81. J ly :.981 __

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NOTMlY PUBL! R SGUTI C R0 LINA ~ OTAR PUBLIC FU UTH ( LINA '

My Commissio xpires o ty Co1 mission Ex es: 25} f /

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: PALMETTO ALLIANCE, ) i

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Petitioner, )

AFFADAVIT In the Matter of: l DOCKET NOS. 50-413 DUKE POWER COMPANY, ET AL. ) and (Catawba Nuclear Station, ) 50-414 Units 1 and 2), )

Applicants, PERSONALLY APPEARED before me, Mary F. Freeman, who being duly sworn, 1 says: -

1. That she resides at Banks Street Extension, Post Office Box 682, Fort Mill, South Carolina 29715, together with her husband Palmer and x4 w s byy two minor children, John and Will, at a distance of approximately 4memey miles from the Catawba Nuclear Station, Units 1 and 2. That she has lived at this residence for about seven years.

2. That she and her family live in a home situated on approximately 9 acres of land which they own.

3. That she and her family live, work, and engage in outdoor recreational activities throughout York County, including areas in close proximity to the Catawba Nuclear Station, Units 1 and 2 on Lake Wylie. Her outdoor activities include running, swimming, hiking, boating, tennis and camping.

She and her family consume vegetables, meat, produce and dairy products raised in the area including vegetables from a garden on their land.

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2 c',e and her family breathe the air and drink the water in the area in close proximity to the nuclear plant.

4. That she and her family are residential electric customers of Duke Power Company.

That she is informed and believes that the grant of an operating license R) Duke Power Company, et al. and the operation of this facility will result in direct physical harm to the health, safety and economic interest of herself and her ismily.

That she is further info med that her interest in this matter can only be protected through participation in this operating license proceeding, and that this interest will not be adequately represented by any of the other parties to the proceeding. She authorizes Palmetto Alliance, of which she is a member, or its representative, to protect her interest in this matter through participation in this proceeding.

W Mary FVFreeman

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SWORN to and subscribed before me this NAday of Jul 1.

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NOTAR] PUBLIC 0 SOUT CA LINA My commission ires:(Y I

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: PALMETTO ALLIANCE )

PETITIONER )

AFFADAVIT

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In the Matter of: )

DOCKET NOS. 50-413 DUKE POWER COMPANY, ET AL. and (CATAWBA NUCLE AR STATION, UNITS 1 and 2) . 50-414

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APPLICANTS PERSONALLY APPEARED before me, Nolan R. Hoopingarner,II, who does af firm and says:

1. That he resides at Route 5, Box 227, Clover, South Carolina in York County, South Carolina, together with his wife and two minor children, at a distance of about 4 miles from the Catawba Nuclear Station, Units 1 and 2. He has lived at this residence about 4 years.

2. That he owns the above premise where he resides and from which he conducts his business which includes operation of a kennel for breeding and handling show dogs, in addition to Son-Light Services, which offers home improvements.

3. That he was employed by Duke Power Company at the Catawba Nuclear Station, Units 1 and 2 as a builder and scaffold builder for about 3 years and through this experience became aware of negligence on all levels of the construction department management. He approached the resident inspector for the Nuclear Pegulatory Commission with concerns about worker safety and management negligence of construction commitments and later became convinced that a cover-up of plant safety problems and construction deficiencies - s in progress.

4. Thr.t he and his factly live, work and engage in outdoor recreational activities thrcaghout York County including swimming in Lake Wylie, bicycling, walking, hunting, fishing and camping in areas in close proximity to the Catawba Nuclear Station, Units 1 and 2. He and his family grow vegetables for personal use and for sale to others and consume produce grown on their land. He and his family raise chickens

for food for themselves and for sale to others and keep about 24 chickens for laying eggs for personal use and for sale to others. He and his family raise hogs for personal use and for market sale. He and his family raise beef cattle for their own personal consumption.

S. That he and his family are residential customers of the York Electric Coope ra t ive.

6. That he is a member of the Palmetto Alliance and has been active in the organization since about July 1981. That thrcugh his participation in the programs of the organization he has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Catawba Nuclear Station, Units 1 and 2.

7. That he is informed and believes that the grant of an operating license to Duke Power Company and the operation of this facility will result in direct physical harm to the health, safety, and economic interest of himself and his family, the community and God's environment.

8. That he is further informed and believes that the interest of himself and his family can only be protected through participation in this .

operating license proceeding. He authorizes Palmetto Alliance, or its representative, to protect the interest of himself and his family.

AFFIRMED and subscribed to yg

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No..an R. Hoopingarner,

~t i NOTARY PUBLIC FOR SOUTH CAROLINA

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f UNITED STATES OF AMFRICA BEFORE THE NUCLEAR REGULATORY COMMISSION

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Ex Parte: PALMETTO ALLIANCE )

PETITIONER )

) AFFADAVIT In the Matter of: )

) DOCKET NOS. 50-413 DUKE POWER COMPANY, ET AL.

(CATAWBA NUCLEAR STATION, UNITS 1 and 2). ) 50-414 APPLICANTS

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PERSONALLY APPEARED before me, Ruth S. Love, who does affirm and says:

1. That she resides at Route 1, Box 381, Rock Hill, South Carolina in York County, South Carolina at a distance of about 9 miles from the Catawba Nuclear Station, Units 1 and 2 and that she has lived at this residence about 20 years.

2. That she owns the above premise where she resides on about 96 acres of land and she is employed by The York County Council on Aging.

3. That she lives, works, and engages in outdoor recreational activities throughout York County, including areas in close proximity to the Catawba Nuclear Station, Units 1 and 2. She raises vegetables (and fruit) in a garden on the above premises and consumes produce from this garden. She rents about 20 acres to a local farmer for the production of soybeans and grain.

4. That she is residential electric customer of Yc,rk Electric Cooperative.

5. That she is a member of Palmetto Alliance and has been active in the organization since about July 1981. That through her participation in the programs of the organization she has become educated on the probable effects of the operation of the Catawba Nuclear Station, Units 1 and 2.

6. That she is informed and believes that the grant of an operating license to Duke Power Company and the operation of this f acility will result in direct physical harm to her health, safety and economic interest.

7. That she is further informed that her interest in this matter can

, only be protected through participation in this operating license proceeding. She authorizes Palmetto Alliance, or its representative to protect her interest in this matter through participation in this proceeding.

AFFIRMED and s sp ibed to '

befor me thi - day of Ju 1 81. j '

Ruth S. Love

(, 1 NOlARY PUBLIC SOUTH CAROLINA h l

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte: PALMETTO ALLIANCE, )

PETITIONER ) AFFADAVIT

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) DOCKET NOS. 50-413

) and In the Matter of: ) 50-41 4

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DUKE POWER COMPANY, ET EL. )

(CATAWBA NUCLEAR STATION, UNITS 1 and 2). )

APPLICANTS )

PERSONALLY APPEARED before me, Alice S. McAfee, who d6es affirm and says:

1. That she resides at Route 3, Ecx 66, Clover, South Carolina in York County, South Carolina together with her teenage son, at a distance of about 15 miles from the Catawba Nuclear Station, Units 1 and 2 and that she has lived at this residence about 16 years.

2. That she owns the above presise where she resides on about 88 acres of land and she is enployed by the Clover School District, Clover, South Carolina.

3 That she and her family live, work, and engage in outdoor recreational activities throughout York County, including

the Carowinds these park and other areas in close proximity to the Catawba Nuclear Station, Units 1 and 2.

l 4. That she is a residential customer of the York Electric I

Cooperative.

5 That she is a menber of the Palmetto Alliance and has been

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active in the organization since about July 1981. That through her participation in the programs of the organization sne has become educated on the subject of the design and operation of the Catawba Nuclear Station, Units 1 and 2.

6. That she is informed and believes that the gran't of an operating license to Duke Power Company and the operation of this facility will result in direct physical harm to the health, safety, and economic interest of herself and her family.

7 That she is further informed that her interest in this matter can only be protected through participation in this operating license proceeding. She authorizes Palmetto Alliance, or its representative, to protect the interest of herself and her' family in this matter through participation in this proceedini.

bscribed to -

f A?FURNED abd sy#" day of

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before me this - O-July 1991. /

Alice S. McAfee N

NOTARY PUBLIC FOR SOUTH CAROLINA wNrOs ff& '

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION .

Ex Parte: PALMETTO ALLIANCE, ) )

PETITIONER ) AFFADAVIT

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In the Matter of: ) DOCKET NOS. 50-413

) and DUKE POWER COMPANY, ET AL. ) 50 414 (CATAWBA NUCLEAR STATION, UNITS 1 and 2), )

APPLICANTS )

PERSONALLY APPEARED before me, William R. McAfee, who does affirm and says:

1. That he resides on Highway 5, west of York, in York County, South Carolina at a distance of approximately 15 miles from the Catawba Nuclear Station, Units 1 and 2. He has lived at the above residence about 2 years and in York County about 20 years.

2. That he and his father own the above premise where he resides and about 60 acres of farmland. He is self employed as a sub-contractor for local companies involved in the installation of polyurethane insulation.

3 That he holds a Bachelor of Arts (Biblical Literature and LANGUAGES) degree from Gardner-Webb College in Boiling Springs, North Carolina and has done post graduate study at Vanderbilt University in Nashville, Tennessee. He worked at the Catawba Nuclear Station, Unit. 1 and 2 for about 2 years. As Utility worker, he poured concrete and later became a pre-pour runner who helped coordinate concrete placement in all areas of the

plant. He was trained and certified as an Electrical Quality {

Control Inspector and as a result of this job and previous experiences became aware of the poor workmanship and inadequate quality control in the construction of the plant.

4. That he lives, works, and engages in outdoor recreational activities including walking , bicycling , and fishing throughout York County, South Carolina, including areas in close proximity to the Catawba Nuclear Station, Units 1 and 2. He grows vegetables and consumes produce grown in a garden at his residunce.

5 That he is a residential electrical customer of the York Electric Cooperative.

6. That he owns 6 shares of Duke Power Company c6daan stock.

7 That he is a member of the PaLnetto Alliance and has been active l

l in the organization since about July 1931. That through his participation in the programs of the organization he has become educated on .the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Catawba Nuclear Station, Units 1 and 2.

8. That he is informed and believes that the grant of an operation license to Duke Power Company and the operation of this facility will result in direct physical harm to his health, safety and economic interest.

9 That he is further informed and believes that his interest in this matter can only be protected through participation in the operating license proceeding. He authorizes Palmetto Alliance, or its representative, to protect his interest.

e AFFIRMED and su cribed to WA2wd 8' W ",M . " "'

William R. McAfee M

NOTARY PUBLIC FOR SOU - ROLINA ww& sfp h& ' ! '

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Ex Parte PALMETTO ALLIANCE )

PETITIONER ) AFFADAVITS

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In the Matter of: ) DOCKET NOS. 50-413

) and DUKE POWER COMPANY, ET EL. ) 5 0-414 (CATAWBA NUCLEAR STATION, UNITS 1 and 1). )

APPLICANTS )

PERSONALLY APPEARED before me, Susan B. Smith, who does affirm and says:

1. That she, with her husband and two minor children, resides at 4 Bratton Avenue, York, South Carolina in York County, South Carolina at a distance of about 9 miles from the Catawba Nuclear Station, Units 1 and 2. She and her family ha"e lived in the above residence for 3 years and in the immediate area for about 7 years.

2. That she is a homemaker and her husband works at Bojangles Restaurants. *

3. That she and her family live, work, and engage in outdoor recreational acitvities throughout York County, including areas in close proximity to the Catawba Nuclear Station, Units 1 and 2. She and her family grow vegetables and consume produce grown.in a garden near her home and within 10 miles of the Catawba Nuclear Station, Units 1 and 2.

4. That she and her family are residential electrical customers of Duke Power Company.

5. That she is a member of the Palmetto Alliance-and has been active in the organization since July 1981. That through her participation in the programs of the organization she has become educated on the subject of the design and operation of nuclear power plants and the probable effects of the operation of the Catawba Nuclear Station, Units 1 and 2.

6. That she is' informed and believes that the grant of an operating license to Duke Power Company and the operation of this facility will result in

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direct physical-harm to the health, safety, and economic interest of herself and her family.

5 7. That she is further informed that her interest in this matter can only be protected through participation in this operating license i proceeding. She authorizes Palmetto Alliance, or is representative, to protect the interest of herself and her family.

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AFFIRMED and subscribed to .

before me this#E day of July 1981. -

! Susan B. Smith

• T NOTARY PUBLIC FOR SOUTH CAROLINA wase& Q $&9 /

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMilSSION Ex Parte: PALMETTO ALLIANCE, )

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Petitioner, )

In the Matter of: DOCKET NOS. 50-413

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) and DUKE POWER COMPANY, ET AL. )

(Catawba Nuclear Station, ) 50-414 Units 1 and 2),

Applicants, )

NOTICE OF APPEARANCE Please take notice that the undersigned attorney hereby enters an appearance in the above-captioned matter in accordance with 10 .

C.F.R. 5 2.713:

Name: Robert Guild Address: 314 Pall Mall Columbia, S.C. 29201 Telephone Number: 803-252-0929 Admissions: United States Court of Appeals for the Fourth Circuit; United States District Court for the District of South Carolina; Supreme Court of South Carolina 1

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V Rtbert Gui d Counsel fo Petitioner Palmetto Alliance July , 1981 Colu , South Carolina

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CERTIFICATE OF SERVICE I hereby certify that I have this day served upon the persons below named at the addresses set forth the affached Petition to Intervene and Request for He ng by depositing same in the United States Mail, postage prepaid, this ay of July 1981.

Secretary of the Commission Michael McGarry, III, Esq.

United States Nuclear Regulatory Debevoise and Liberman Commission 1200 Seventeenth Street, N.W.

Att: Docketing & Service Section Washington, D.C. 20036 Washington, D.C. 20555 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 e ,

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Attorney fo J etitioner Palmetto Alliance NOTICE FOR SERVICE t

Notice is hereby given pursuant to 10 C.F.R. 1 2.708 that service upon Petitioner should be made at the following addresses:

Robert Guild Palmetto Alliance Attorney at Law 2135 Devine Street 314 Pall Mall Columbia, South Carolina 29205 Columbia, South Carolina 29201 l

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