ML20010H208

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Petition to Intervene in Proceeding & Request for Hearing. Certificate of Svc Encl
ML20010H208
Person / Time
Site: Limerick  
Issue date: 09/18/1981
From: Lochstet W
AFFILIATION NOT ASSIGNED
To:
NRC COMMISSION (OCM)
References
NUDOCS 8109240140
Download: ML20010H208 (4)


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United States of America

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Nuclear Regulatory Commission

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C' In the Matter of 4 3 j.s ;

Philadelphia Electric Co.

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Docket Nos.

50-352 and (Limerick Generating Station'

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50-3 3. d A s Units 1 and 2)

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9 Request for Hearing and Petition for Leave to Interveg%W

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in Evidentiary Hearings on Prpposed Operating License (q},

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N2b In response to the Nuclear Regulatory Commission's (NRG#.r.I notice (46 Federal Register 42557, dated 21 August 1981), and in accordance with 10 CFR part 2, I, William A. Lochstet hereby reauest a hearing with respect to this matter, and petition for leave to intervene in these evidentiary hearings.

1 Nature of the pertitioner's right under the Atomic Energy Act to be made a party to ghe proceeding.

The rights of this Petitioner are set forth in and result from sections 1, 2, 3,170, and 189 of the Atomid Energy Act, as amended. It is held that the operation of Limerick c 1 and2 will adversely affect my health, mental health,

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. social and oolitical status, and genetic condition of my progeny. Therefore, my general welfare as well as health, safety and security will be affected.

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Nature of the petitioners property, financial, or other interest in the proceeding.

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I own real properyy arl reside in State College, Pa., which is located approximately 190 km ( 120 mi.)

from Limerick 1 and 2 I have legitimate reasons to travel past the plant at distances of less than 5 km (3 mi.).

I thus have occasion to breathe the air D503 s

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2 in the vicinity of the plant. I also consume food grawn in the area both on those occasions of visitation to the area and also while residing in State Colleg3.

There

'_s thus uncertainty in the amounts of radioactivity contained in the foodstuffs of these areas due to the distribution of possibly coritaminated foods grown in the vicinity of Limerick 1 and 2. Tnis cloud upon foodstuffs exists even if the action levels for condemnation are not reached. Since the linear, non-threshold relationship between radiation dose adn effect must be used for public health considerations, anf exposure, or any consumption of food containing radioactive products from Limerick 1 and 2 must be considered a health threat.

To avoid contaminated foodstuffs would require more care and time spent in selecting foods, and create an unreasonable burden. In some cases, the origin of the foodstuffs is difficult or impossible to ascertain, thus making such selection impossible.

Such concerns in the general public could make the entire area undesirable as a place to reside and depress property values.

The fuel for Limerick 1 and 2 will be obtained, at leasb in part, icom mines in the western United States.

This operation

.ill release radon gas into the air which is present in w

State College, and will have an adverse affect on my progeny.

3 Possible effect of any order which may be entered in the proceeding on the petitioner's interest.

An order which permits the operation of Limerick 1 or 2 will effect the cuantities of radioactive materials emitted to i

the air, water and soil in the plant vicinity, and also to the overall airshed of eastern United States. In particular, if the design or technical specifications are inadequate, an unforseen condition may result which could result in an unusually large releases.

The magnitudes of normal releases which will occur if operation is permitted will,also be affected l

3 by plant desigh and technical specifications.

If operation is not permitted or permitted will have an effect on the amount of uranium mining and thus effect the radon content of the air in State College and all of Pennsylvania and the area.

It is because of this control of the releases and their health effect as dencribed above that the petitioners interests are affected.

4 Contribution to the proceeding.

The petitioner is a party to the Three Mile Island Unit 2 Technical Specifications

( Docket 50-320 OLA ) proceeding and has made a substantial contribution therein.

Further, the petitioner holds an earned Ph.D. in physics, and is thus knowltgable in the matters to be considered.

In accordance with 10 CFR 2.714 (a)(1)(v) the participation of the petitioner will broaden and contribute to the proceeding.

Contention 1:

The proposed operating license does not provide adequate protection of my mealth, sagety and property, or those of my progeny.

Respectfully submitted, f/

k' William A. Lochstet 119 E. Aaron Dr.

State College Pennsylvania 16801

4 Certificate of Service I hereby certify that cor.les of

" Request for Hearinc and Petition for Leave to Intervene in Evidentiary Hearings on Proposed Operating License" have been served on the following by deposit in the United States Mail, first class, postage paid this 18 th day of Septeuber 1981.

s William A. Lochstet Office of the Secretary U.S. Nuclear Regulatory Commission

-g' \\4 Washington, D.C., 20555 Attention: Docketing and Service Section

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  • t-Executive Legal Director p,,.,T ~r,.

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}{jjj7 U.S. Nuclear Regulatory Commission s

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' Washington, D.C., 20555 (6

?a t Mr. Troy B. Conner, Jr., Esq.

Conner & Wetterhahn 1747 Pennsylvania Ave, N.W.

Washington, D.C., 20006

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