ML20024B086

Petition of Environ Coalition on Nuclear Power for Leave to Intervene & Request for Hearing.Certificate of Svc Encl

ML20024B086
Person / Time
Site:	Beaver Valley
Issue date:	06/30/1983
From:	Johnsrud J Environmental Coalition on Nuclear Power
To:	NRC COMMISSION (OCM)
References
NUDOCS 8307050099
Download: ML20024B086 (2)

Text

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ENVIRONMENTd'L COALITION ON NUCLEAR POWER yge.f

~ Co Duectors: Ms. F hylus 78trer-Box 761, Pottstown. Pa. 19454 215 326-9122 Dr. Juditn Jennsruc-433 orianco Avenue, state C p . Pa 801 614 737 3900 U

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, NUCLEAR REGULATORY COMMISSION c.

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Docket ho* 50-41 '

y NN 'y'N DUQUESNE' (Beaver ValleyLIGHT Power CO., 7tiition, Unit 2) -

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REQUEST FOR OPERATING LICENSE HEARING AND PETITION FOR' LEAVE TO INTERVENE THEREIi Pursuant to 48 Federal Register 24488-24490, and in accordances with 10 CFR 2.714, the Environmental Coalition on Nuclear Power (ECNP) nereby requests that the Nuclear Regulatory Commission (NRC) conduct a full adjudicative public hearing with respect to issuance of a facility operating license to possess, use, and operate Beaver Valley

• Power Station, Unit 2 (BV-2).

The Environmental Coalition on Nuclear -Power petitions the NRC for leave to intervene as a full party to the proceeding.

Interest of the Petitioner and How that Interest may be Affected by the Results of the Proceecina. ECNP is a non-profit public-interest citizens' organization composed of groups and individuals who are interested in nuclear power and the nuclear fuel cycle and who are concerned for the provision of safe, clean, reliable and affordable electric and other energy supplies. Members of ECNP -- including but not limited to Dr. and firs.

Robert Freedman, Mr. and Mrs. Richard Hayden, Ms. Gail Phelps, Mr. James Allen, Ms. Terri Roth-Gormley, Mr. James Gormley -- reside well within the fifty-mile radius of Beaver Valley, Unit 2, an area that is at risk of catastrophic damage in the event of a major nuclear reactor accident at the plant under consideration. They own or rent their homes and possess other property in th u area. Their places of employment or businesses and of recreation are within this area. They send their children to school and conduct their daily activities within the radius of the reactor which may be adversely affected by an accident. Such an accident or activities and functions associated with normal reactor operations may adversely affect their health, safety, value of and access to their property and personal possessions in the event of a major nuclear reactor accident.

Nature of the Petition _er's Richt under the Act to Be Made a Party to the Proceeding.

Section 1 of the Atomic Energy Act of 1954, as amended, states in essence that it is the obligation of the Federal government through its regulatory agency, the NRC, to assure the protection of the public health and safety and promote the general welfare. Under this authority of the Act and the provisions for timely petition in 10 CFR 2.714, any citizen or group of citizens whose interests, including thier health, safety, and financial con-dition, may be adversely affected by the proposed NRC action is permitted to participate

'as a full intervening party to the proceedino. Members of ECNP would so qualify by virtue of their places, of residence, work, and recreation.

The Board of Directors of ECNP, including members living within the designated distance from Beaver Valley, Unit'2, have appointed the undersigned member of the organization to serve as leaal representative for ECNP and its members to protect their interests in any and all proceedings before the Commission, the Courts, nr other agencies of government.

Nature and Extent of Petitioners' Property, Financial, or Other Interest in the Proceedina. These raatters are addressed above. ECNP members, to reiterate, live, work, raise their families in this area and therefore are at risk of injury, death, latent disease, genetic defects in their progeny, loss of value or access to their property or possessions as a consequence of an accident at.BV-2. They may also suffer adverse ,

health or economic impacts in consequence of normal plant operations; transportation; I l

8307050099 830630 b gDRADOCK 05000412 PDR e

, of materials related to the operation of the plant; malfunctions or n<rmal operations of the nuclear fuel cycle; uncertainty of necessary electricty supply due to anticipated or unanticipated outages, maintenance, or backfitting of the reactor; and uncertainty of i the cost of power for ratopayers whoe utilities own the plant.

Possible Effects of Any Order which may be Entered in the Proceeding on the Petitioners' Interest. The granting of a license to operate BV-2 may adversely affect the interests of these petitioners by introducing health, safety, and financial risks and uncertainties into their lives. They may be forced to move; to give up careers and jobs; to incur economic losses through negative effects on the value of their property.

. A particular hardship would result for those who are not fully able-Lodied and capable of indeoendent mobility in removing themselves from a real and cerceived hazard to their wellbeing and security.

Aspects of the Subject Matter as to which Petitioners Wish to Intervene.

Petitioners' specific contentions will be filed as an amendment to this Request and Petition at the appropriate time, ' Among the subjects that are of concern are emergucy response and evacuation planning; reactor design, quality assurance and quality control; i TMI Lessons Learned; unresolved safety issues; fuel cycle, transportation, and decot-missioning issues; management and financial issues; energy demand; worker prctection; calculated risk analyses and underlying assumptions; and environmental effects of the opera-tion of BV-2. Further specificity will be provided after proper opportunity to examine the Final Safety Analysis Report, Environmental Report, NRC Staff submissions, and other pertinent documents in this docket.

Petitioners request financial assistance from the NRC to enable them to assist the Commission in the best exercise of its responsibilities for assuring the public safety and in minimizing any potential adverse impacts of BV-2/ To aid in preparation of contentions and subsequent participation in the proceeding, because of the great distance from the location of the Petitioners' legal representative to Aliquippa or other sites of public documents in this docket, we respectfully request that-the Com-mission establish a mini-documents room, as has been done in previous proceedings, at the Schlow Public Library, Beaver Avenue, State College, Pa.

Petitioners will amend this petition to correct any deficiencies which may exist.

Respectfully submitted.

4 D ?/ 0, 4 fysu Dr.JudithH.bohnsrud

., - Co-Director and Legal Representative Environmental Coalition on Nuclear Powcr

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ated this '

day of June, 1983 433 Orlando Avenue State College, Pa. 16801 (814) 237-3900

! CERTIFICATE OF SERVICE I hereby certify that a copy of REQUEST FOR OPERATING LICENSE AND PETITION FOR LEAVE TO INTERVENE has been served by deposit in the U.S. Mail, first class, postage paid, to those persons specified in 48 FR 24488-24490 this J o day of June,1983.

/. O M. , sy AM5M Judith H. Johnsrud

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