ML20011A613

Amended Petition to Intervene.Notice of Appearance, Affidavits & Certificate of Svc Encl

ML20011A613
Person / Time
Site:	Limerick
Issue date:	10/23/1981
From:	Dorsey J LIMERICK ECOLOGY ACTION, INC.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8110290181
Download: ML20011A613 (10)

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.g USN C UNITED STATES OF' AMERICA .. .. , _ ,

NUCLEAR REGULATORY COMMISSION' ET 26 P1 -M BEFORE THE ATOMIC SAFETY AND LICENSING BOMp Dc r.CE OF OCKETING SECRETARY

& SERVtCE .

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In the Matter of  : gg / p PHILADELPHIA ELECTRIC COMPANY  : <@, /

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Limerick Generating Station,  : Docket Nos.-50-35 g. .

Units 1 and 2  :

50-35 OCT2 7193;u AMENDMENT TO PETITION TO INTERVENE S.2 86LWsua tman e.%,

Limerick Ecology Action, on its own behalf and on b if h of its members, hereby supplements and amends its Petition to Intervene

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in the above-captioned proceeding, pursuant to 10 CFR S2.714.

1. Limerick Ecology Action (hereinafter LEA) is an incorporated organization, not an unincorporated association, as stated in its

! Petition to Intervene.

2. Additional affidavits are attached; petitioner indicated its intent to submit additional affidavits at the time it filed its original Petition to Intervene.

3. LEA wishes to clarify the affidavit of David Spontak, emplcyee of Pottstown Memorial Medical Center. LEA does-not intend, nor.

did it'put forth in its Petition to Intervene any intent, to repre-I sent the interests of the Medical Center in the Limerick hearings.

Rather, it intends to represent the interests of its member David Spontak, who as an employee of the Center, will be called upon to l.ogg perform certain tasks related to emergency planning and carrying z)303 mr I

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88 n- 4. Petitioner herewith submits Notices of Appearance for Judith IIt F3 C A.Dorsey and Charles W. Elliott, attorneys at law, and Phyllis i

no Zitzer, President of LEA. Con *.rary to the position of Applicant.

l ~$N EM # in-its Answer to Limerick Ecology Action Petition to Intervene,.

LEA does not interpret 10 CFR 52.713 (b) to force it to choose between representation by a lawyer and representation by any other duly authorized representative. There may be occasions when neither of LEA's counsel can be present at a portion of the hearing due to scheduling conflicts, and when Phyllis Zitzer could capably represent the interests of the organization. It would seem preferable to permit such representation on occasion,.

rather than to cause delays in the hearing schedule which would otherwise not be necessary.

Respectfully submitted, Limerick Ecology Act on By /Ah ' /

JUDITH A. DORSEY l'Ol) 1315 Walnut St., Suite 1632 Philadelphia, PA 19107 (215) 735-7200 CHARLES W. ELLIOTT 123 U. 5th St., Suite 101 Allentown, PA 18102 (215) 821-8100 Attorneys for Petitioner October 23, 1981

UNITED STATES OF AMERICA NUCLEAR. REGULATORY. COMMISSION.

BEFORE THE ATOMIC SAFETY AND' LICENSING BOARD-In-the' Matter of-

-PHILADELPHIA ~ ELECTRIC COMPANY  :- Docket No. 50-352 I 50-353 Limerick Generating Station,-  :

Units 1 and 2  :

[ NOTICE OF APPEARANCE Notice is hereby-given1that the undersigned attorney herewith enters an appearance in the above-captioned matter.

't In accordance_ with 10 CFR S2. 713 (a) , the following information is- .l

) provided:

4 Name: ' Judith A. Dorseys Address: 1315 Walnut St.,' Guite 1632

{ Philadelphia, PA 19107-Telephone: (215) 735-7200 Admissions: Supreme Court of Pennsylvania i U.S. District Court, Eastern District of Pennsyl -

vania U.S. District Court, Middle District of'Pennsyl-vania -

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Name of Party

Limerick Ecology Action P.O. Box.761

Pottstown, PA 19464 Respectfully submitted,-.

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'wVl<y Judith.A. Dorsey j

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Counsel for LEA-l: October 23, 1981

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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,  : '50-353 Units 1 and 2  : .

NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.

In accordance with 10 CFR S2.713 (a) , the following information is provided:

Name: Charles W. Elliott Address: 123 N. 5th St., Suite 101 Allentown, PA~18102 Telephone: (215).821-8100 Admissions: Supreme Court'of Pennsylvania U.S. District Court, Eastern District of.Pennsyl-vania Third Circuit Court of Appeals Name of Party: Limerick Ecology Action P.O. Box 761 Pottstown, PA 19464

' Respectfully submitted, h6'$ lb! ! Yag,

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Charles W. Elliott Counsel for LEA October 23, 1981 i

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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of  :

PHILADELPHIA ELEC'?RIC COMPANY  :

Limerick Generating Station,  : Docket Nos. 50-352 Units 1 and 2  : '50-353 NOTICE OF APPEARANCE Notice is hereby given thats the. undersigned herewith enters an appearance in hte above-captioned ~ matter. In accordance with 10 CFR S2.7.3(a), the following information is provided:

Name: Phyllis Zitzer Address: P.O. Box 761 Pottstown, PA 19464 Telephone: (215) 326-9122 Basis of authority to act: See affidavit of Phyllis Zitzer, attached to Petition to Intervene and Request for Hearing Nan. 3 of Party: Limerick Ecology Action P.O. Box 761 Pottstown, PA 19464 Respectfully submitted, f.LjbbC2 $/' Up,;

Phyllis Zitzer' President, Limerick Ecology Action October 23, 1981

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'I, Robert Boyer, reside and own property on a farm located 11 miles from the site of the Limerick reactors, where'I live with my wife and 3 children. My responsibilities as manager of a _250 acre farm include caring for 42 pure bred registered Belted Galloway cattle, 6 horses, and over 100 pigs. .l There would be no way to evacuate these animals in the event of an accident at Limerick, and they would require feed and care within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of my departure. I am opposed to the licensing of the Limerick reactors because they threaten the j health and economic well-being of myself and my family. I-am i

a member of Limerick Ecology Action and wish to have my interests represented before the Nuclear Regulatory Commission by LEA's legal counsel.

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We, James and Lulu Gaut, live in the Borough of Pottstown at 76 Queen Street, less than 2 miles from the site of the-Limerierc Nuclear Power Plants. We both work nithin 5 miles from Limerick, as well. We oppose the issuance of an cperating license for the Limerick reactors because they will adversely affect our health and well-being, and that of our 3 gr.ndchildren -

ages 4,2, and 9 months who also live within 2 miles from the site. We believe even the "so called routine releases" of ra-diation from the plant, will seriously affect ourselves and our loved ones. As members of Limerick Ecology Action,'we wish to be represented before the NRC in the licensing proceedings Unit 1 by for(and Unit 2 EA's legal counsel.

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We, James and Nancy Crater, live in North coventry Township, Chester County, approximately 5 miles from th2 construction site of the Limerick Power Plants. We oppose the granting of an operating license for Limerick for health, safety and economic 1 asons.

We seriously doubt the ability of Philadelphia Electric Co. ,

with assets of 5.7 billion dollars, to safely secure and maintain a nuclear generation unit with a construction cost of over 4 billion dollars and an estimated lifetimo cost of 17 billion dollars.

We are also deeply concerned aLout the shadowing effect the normal operation of this plant would have on our neighbors downwind, hindering their potential for solar energy development.

As members of Limerick Ecology Action, we wish to be represented in the operating license hearings on Limerick I and II before the Nuclear Regulatory Commission by Limerick Ecology Action's icgal counsel.

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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Amendment' to Petition to Intervene 'were ser ved, by deposit- in the United States mail, first class postage prepaid,'upon the following on October 23, 1981: 1 Lawrence Brenner, Chair Administrative Judge U.S. NRC Washington, DC 205S3 Dr. Richard F. Cole Administrative Judge U.S. NRC Washington, DC 20555 Dr. Peter A. Morris Administrative Judge U.S. NRC Washington, DC 20555 Stephen H. Lewis, Esq.

Office of Executive Legal Director U.S. NRC Washington, DC 20555 Conner & Wetterhahn 1747 Pennsylvania Ave., NW Washington, DC 20006 Atomic Safety and Licensing Appeal Panel U.S. l.RC Washington, DC 20555 Robert Adler, Esq.

Commonwealth of PA, DER 505 Executive House P.O. Box 2357 Harrisburg, PA 17120 Martha Bush, Esq.

Office of Atty General Office of Consumer Advocate 1425 Strawberry Sq.

Harrisburg, PA 17120

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-JUDITH A..DORSEY (f