ML20010H207

Petition to Intervene in Proceeding & Request for Hearing. Certificate of Svc Encl

ML20010H207
Person / Time
Site:	Limerick
Issue date:	09/18/1981
From:	Nogee A KEYSTONE ALLIANCE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20010H206	List: ML20010H205 ML20010H207
References
NUDOCS 8109240136
Download: ML20010H207 (5)

Text

NUCLEAR REGULATORY COMMISSION i

In the Matter of  : Docket Nos. 50-352 and Operating License Application of  : 50-353 Philadelphia Electric Company  : N gg) R , 7' s Limerick Generating Station  : /Dd Units 1 and 2  : / C00:tno

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The KEYSTONE ALLIANCE, on its own behalf and on behalf of it's members, hereby petitions the Nuclear Regulatory Commission for leave to intervene in the above capticred proceeding pursuant to Sec. 2.714 of the Nuclear Regulatory Commission's rule of practice and states:

INTEREST OF PETITIONER IN PROCEEDING

1. The Keystone Alliance is an unincorporated association comprised of citizens and residents of the five county Greater Philadelphia area, including Philadelphia, Delaware, Chester, Montgomery and Bucks Counties.

Members reside and/or own property within a 10 mile radius of the Limerick Generating Station, as well as a larger area out to approximately 50 miles from the Limerick Station. The large majority of members are ratepayers to the Philadelphia Electric Company, the owner and proporsed operator of the Limerick Station.

2. All members are interested in the protection of themselves and their neighbors from potential hazards of nuclear plant operation and fuel cycle supporting operations, and developing the most economical and efficient energy resources. Members have undertaken numerous activities disseminating information about these topics.

3. The Keystone Alliance, by its past and present activities and conduct, has exhibited a special interest in the protection of Delaware Valley residents from all nuclear related potential hazards, and is first and foremost concerned that such nuclear power plants not be built when 8109240136 810918 PDR ADOCK 05000352 G PDR

it is not in the public interest to do so. Petitioner is pledged to oppose the use of nuclear power as an electric generation source where it is unsafe, uneconomical or unnecessary. The petitioner has analyzed and studied, to the extent information has been available, the Linarick Generating Station, Units 1 and 2, and is concerned that their operation will have deleterious public healt h and safety, environ-mental and economic effects on its members and residents of the Delaware Valley, which effects could be avoided.

3. The Keystone Alliance, in addition to its educational activities on the above issues, has been an active intervenor in the last three rate cases of the Philadelphia Electric Company before the Pennsylvania Public Utility Commission, and is an active intervenor in the current Public Utility Commission investigation into the need for and economy of the Limerick Generating Station.

HOW THE INTERESTS OF PETITIONER WILL BE AFFECTED BY THE OUTCOME OF PROCEED-ING 4.The Keystone Alliance believes that its members and residents of the Greater Philadelphia area will be subject to adverse health and safety consequences as a result of operation of the Limerick Nuclear Generating Station. Petitioner also believes that Limerick operation will produce deleterious environmental effects, and will unnecessarily raise electric rates.

AREAS OF INTERVENTION

5. Keystone Alliance areas of intervention include plant safety, energency planning, adequacy of emergency planning zones, sitir g, popu-lation density, risk assessment, security, operator training, radiation monitoring and protection, transportation of nuclear materials, nuclear

waste disposal, availabilty of water supply, environmental impact of Station and water supply projects, external threats to plant (e.g., air-plane crash, seismic conditions, etc.), management competence, financial qualific ations of applicant, need for power and economics of available alternatives.

WHEREFORE, petitioner Keystone Alliance reque-ts leave to intervene <

in the above-captioned proceeding.

Respectfully submitted, Keystone Alliance Dy:

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Alan J. Nogee .

3700 Chestnut Street Philadelphia, PA 19104 Representative of Petitioner Date: September 18, 1981 l

AFFADAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF PHILADELPHIA  :

Alan J. Nogee, being duly sworn according to law, deposes and says that he is the duly authorized representative of the Keystone Alliance to represent it in the foregoing petition and in this proceeding, and that the facts contained in the foregoing petition cre true and correct to the best of his knowledge, information and belief.

Alan J. Nogee Sworn and subscribed wa f

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CERTIFICATE OF SERVICE Alan J. Nogee, duly authorized representative of the Keystone Alliance, hereby certifies that on September 18, 1981, he served the foregoing Petition For Intervention on the Executive Legal Director of the Nuclear Regulatory Commission, Washington, D.C. 20555 and on the attorney for the applicant, Troy B. Conner, Esq., Conner & Wetterhahan, 1747 Pennsylvania Avenue, N.W., Washington, D.C. 20006, both by first-class mail.

Alan J. Nogee Sworn and subscribed before me this\Q, 1981. day ,q\ .h/

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