ML20011A108

Petition to Intervene in Proceeding.Affidavit & Certificate of Svc Encl

ML20011A108
Person / Time
Site:	River Bend
Issue date:	09/30/1981
From:	Falkenheimer D, Falkenheiner D, Irving S AFFILIATION NOT ASSIGNED, FALKENHEINER, D., IRVING, S.M., LOUISIANA CONSUMER'S LEAGUE, INC.
To:	NRC COMMISSION (OCM)
References
NUDOCS 8110070268
Download: ML20011A108 (6)

Text

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NUCLEAR REGULATORY COMMISSION -

O IN THE MATTER OF DOCKET NOS. 50-458; GULF STATES UTILITIES CO. 50-459 (River Bend, Units 1 & 2)

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CI Q ,N N f 0 PETITION FOR LEAVE TO INTERVENE QCI O M" IN FACILITY OPERATING LICENSE PROCEEDINy,g,S( fgy*" C I. IDENTIFICATION OF PETITIONER A s ee J'i' ,\ \

Q' The Louisiana Consumer's League, Inc. (LCL) on 4.ts own behalf, and on behalf of its members, petitions the Nuclear Regulatory Com-mission (NRC) for leeve to intervene in the above-captioned matter pursuant to.the Commission's " Rules of Practice for Domestic Licensing Proceedings" in 10 CFR, Part 2.

Petitioner is a non-profit corporation organized under the laws of the State of Louisiana. Its objectives and purposes include:

1. To promc A the interests and rights of all consumers in the State of Louisiana, in harmony with the general welfare of our state and nation, by whataver maans determined and developed by the member-ship or directors or officers of the League, and

2. To represent the interests of Louisiana consumers before legislative and administrative bodies at the national, state and local levels, and where appropriate, to provide assistance to Louisiana og

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consumers in pursuing judicial remedies provided by law. 5

1. number of petitioner's membere live within 15 and 30 miles of 8110070268 810930 PDR ADOCK 05000450 PDR g

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NOS. 50-458; GULF STATES UTILITIES CO. 50-459 4

(River Bend, Units 1 & 2)

PETITION FOR LEAVE TQ INTERVENE IN FACILITY OPERATING LICENSE PROCEEDINGS I. IDENTIFICATION OF PETITIONER The Louisiana Consumer's League, Inc. (LCL) on its.own behalf, i

and,on behalf of its members, petitions the Nuclear Regulatory Com-mission (NRC) for leave to intervene in the above-captioned matter

. pursuant to the commission's " Rules of Practice for Domestic Licensing.

Proceedings" in 10 CFR, Part 2.

Petitioner is a non-profit corporation organized under the laws of the State of Louisiana. Its objectives and purposes include:

1. To promote the interests and rights of all consumers in the State of Louisiana, in harmony with the general welfare of our state ,

and nation, by whatever means determined and developed by the member-ship or directors or officers of the League, and

2. To represent the interests of Louisiana consumers before legislative and administrative bodies at the national, state and local, levels, and where appropriate, to provide assistance to Louisiana-consumers in. pursuing judicial remedies provided by law.

A number of petitioner's members live within 15 and 30 miles cf

s the proposed facility. An even larger-number of petitioner's members-obtain their drinking water from the regional aquifer over which the proposed facility is to be located.

II. INTERESTS OF THE PETITION,ER The interests of petitioner and the Louisiana residents it represents which may be affected by the results of this proceeding are the potential financial, health, safety and environmental pro-blems associated with this nuclear power station.

III. SPECIFIC ASPECTS OF THE SUBJECT MATTER FOR WHICH INTERVENTION IS SOUGHT Intervenor. believes that without its intervention adequate consideration will not be given in this proceeding to its views in regard to:

1. The adequacy of. nuclear waste storage fccilities for waste that will be generated in the operation of this nuclear power station.

2. The adeq'tacy of evacuation plans for low-income and moderate-income persons, especially those residing in public facilities, such as Louisiana State Penitentiary and East Louisiana State Hospital, within a 50-mile radius of this nuclear power station.

3. The safe operation of this nuclear power station.

4. The adequacy of the consideration of the probability of risk of a major nuclear accident at this. nuclear power station.

IV. CONCLUSION

Petitioner prays that its request for leave to intervene be granted and furthermore, that the request for an operating license not be approved.

Alternativcly and if the request for an operating license be approved, then petitioner prays that the specific contentions to be made by petitioner be considered and included as part of the conditions of such operating license.

DATED:

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/'J[d ' Me 4 El DORIS FALKENIIEINER Attorney _ht Law 535 North 6th Street Baton Rouge, LA 70802 .

504/383-4528 N

STEPHEN M. IRVING Attorney At Law 535 North 6th Street Baton Rouge, LA 70802-504/383-4528 COUNSEL FOR LCL, INC.

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0 AFFIDAVIT OF JOHN F. ROBBERT V.

STATE OF LOUISIANA PARISH OF ORLEANS BEFORE ME, the undersigned notary public, appeared JOHN F. ROBBERT who, being duly sworn to tell the truth I

deposed that:

1. He is the President of the Louisiana Consumers' League ~. Inc.

. . His business address is:

829 Baronne Street, New Orleans, Louisiana 70113-1183

3. He is aware of the contents of the Petition for l Leave to Intervene in Facility Operating Proceedings by the Louisiana Consumers' League, Inc. and attests'that the information contained therein is true and correct to the i

best of his information and belief.

ff9bNF.ROBBERT SWORN TO AND SUBSCRIBED before me on this __ ,) 6 day of September, 1981 at New Orleans, Louisiana.

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VI. CERTIFICATE OF SERVICE

'I HEREBY CERTIFY that a copy of the foregoing petition for leave to intervene was mailed on-the I8 day of'-

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1981, postage' pre-paid,;first class.U.S. Mail to'the following:

1. Secretary to the Commission -

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Section

2. Executive Legal Director U.S.. Nuclear Regulatory Commission Washington, D.C. 20555

3. Mr. Troy B. Conner,-Jr.

Attorney at Law 1747 Pennsylvania Ave., NW

-Wa.shington, D.C. 20006 I

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