ML20010H795
| ML20010H795 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/21/1981 |
| From: | Hershey S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8109290302 | |
| Download: ML20010H795 (6) | |
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- F2 UNITED STATES OF AllERICA Oftet cf tb Sc:retary b
Ecd 22 & SCniC0 NUCLEAR REGULATORY COMMISSION Dra::ct if Cb Cn BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD 3?lhDs In the Matter of PIIILADELPHIA ELECTRIC COMPANY DOCKET NO
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PETITION FOR INTERVENTION 9
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AND REQUEST FOR A HEARING I
rn-i Consumers Education and Protective Association- (CEPA), on its own behalf and on beh' lf of its taembern, hereby petitions dhe Nuclear _[.
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r Regulatory Commission for leave to intervene in the above-captioned proceeding, pursuant to 10 CFR'S2.714.
I.
INTEREST OF THE PETITIONER IN THE PROCEEDING CEPA is an incorporated organization founded in 1966.
CEPA is to educate the public and its members about their rights as consumers and how to best advocate and protect those rights.
CEPA has, by its past activities and conduct, exhibited a special interest in the protection of its members rights in regard to the operations of Philadelphia Electric Company.
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8109290302 8109212 PDR ADOCK 05000352 O
PDR;
CEPA's membership consists of over 900 individuals and families, the vast najority of whom live within 30 miles of the facility; members live as close as within a mile, and as far away as 50 miles.
Operation of the Limerick reactors will directly affect mem-bers of CEPA in that their health and safety an~d their children will be adversely impacted by routine releases of radionuclides into both air and water, and by accidental releases of such material, when and if such accidents occur.
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Many members are property owners, and therefore will be finan-cially affected by Limerick's proposed operation, both by decreases in property values durint norwal operations.over the life of the plant, as well as by the impacts of potential accidents at the site.
CEPA also has several members who work in institutions such as hospitals, schools and nursing homes, who will be responsible for emergency response duties in the event of an accident.
Finally, almost all of CEPA's membership are Philadelphia Electric Company ratepayers, and will therefore be affected by escalat-ing costs of construction, operation and maintenance of the facility, 1
as well as the devastating financial consequences of potential-acci-a l
dents on the utility and therefore on its customers.
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II.
i AFFECT ON PETITIONER'S INTEREST BY RESULTS OF THE PROCEEDING 4
CEPA has a long-standing concern with the impact of Limerick on the health and safety of its members and the public at large.
At
the construction permit stage of these proceedings, specific health and safety issues, technical and otherwise, dealing with the operation of the plant, were not litigated pending issuance of critical documents such as the FSAR and SER.
CEPA and its members will be adversely affected if they are denied the right to participate as a party in hearings designed to assure that no operating permit is issued unless and until there is reasonable certainty that operation "will not be inimical to the common defense and security or to the health and safety of the public".
III.
ASPECTS OF SUBJECT MATTER OF PROCEEDING AS TO WHICII PETITIONER WISIIES TO INTERVENE Pursuant to 10 CFR S2.714 (b), in accordance with the schedule to be set by the Licensing Board, Petitioner intends to file a supple-ment to this petition listing contentions that it seeks to have litigated, under the following subjcct matter areas:
1)
Energency planning 2)
Technical safety issues 3)
Availability of water supply 4)
NEPA cost / benefit (need for power) 5)
Radiation protection 6)
Security 7)
Quality assurance / quality control 8)
Operator training 9)
Management / technical resources 10)
Financial qualifications of applicant 11)
Fuel cycle
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The above list is in no way meant to limit the scope of the contentions that the Petitioner intends to file, but rather is meant to indicate the nature of Petitioner's interest.
Petitioner reserves the right to file contentions that do not appear but were intended to fall under the indicated subject matter areas, and are litigable issues pursuant to the Commission's rules and regulations.
IV.
RELIEF Based upon the foregoing, Petitioner respectfully requests a hearing in the above-captioned matter, and requests that it be granted leave to intervene in this proceeding.
Respectfully submitted, CONSUMERS' EDUCATION and PROTECTIVE ASSOCIATION fhWL2.u_
BY:
ALMW STEVEN P.
IiERSIIEY G/'
COMMUNITY LEGAL SERVICES, INC.
Sylvania llouse Juniper and Locust Streets Philadelphia, PA 19107 (215) 893-5300 Attorney for Petitioner September 21, 1981
_4_
o CERTIFICATE OF SERVICE f
I hereby certify that copies of the foregoing Petition to Intervene and Request for a Hearing were served,1by deposit in the United States mail, first class postage prepaid, upon the following on September 18, 1981:
Executive Legal Director U.S.
Nuclear Regulatory Commission Warshington, DC 20555 Troy B. Conner, Jr., Esquire Conner & Wetterhahn i
1747 Pennsylvania Avenue,'N.W.
Washington, DC 20006' 1
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Leq STEVEN P.
HERSHEY
r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PHILADELPHIA ELECTRIC COMPANY.
DOCKET NOS. 50-352 Limerick Generating Station, and 50-353 Units 1 and 2
.AFFI DAVIT I,
Lee Frissell, being first duly sworn according to law, depose and say that:
1.
I am Executive Director of Consumers' Education and.
Protective Association (CEPA) ;
2.
I have read the foregoing Petition of CEPA to Intervene t-and Request for a Hearing and it is true and correct to the best of my knowledge and belief.
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gcAO LEE FRISSBLL
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Sworn to and subscribed
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b5 fore'lde hhis'21st day j
of/,Septed;,:/her;,g1981.
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