ML20031C542
| ML20031C542 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/02/1981 |
| From: | Rothschild G, Selbin J AFFILIATION NOT ASSIGNED, LOUISIANIANS FOR SAFE ENERGY, INC. |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20031C543 | List: |
| References | |
| NUDOCS 8110070261 | |
| Download: ML20031C542 (7) | |
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W 0 01 UNITED STATES OF MRICA D
NUCLEAR REGUIldORY 3M11SSION IN THE MNITER OF DOCKET NC3. 50-458; GULF STATES LTILITIES C0.
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i PETITION FOR LEAVE 'IO IIEERVENE
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IN FACILITY OPERATING LICENSE PIU'EEDINGS 4N
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This is a petition to the Nuclear Pegulatory Cmmission (NFC) for leave to intervene filed on behalf of Iouisianians for Safe Energy, Inc. (ISE), on behalf of its nurbers, and on behalf of Gretchen Reinike Rothschild, in accordance with Section 2.714 of the Carlission's " Rules of Pra5tiw for Dmestic Licensing Proceedings" aid with respect to the operating license application filed to ccrmence operation at River Bend, Units 1 & 2.
I. IDI2EIFICATION OF PETITIONEPS l
A. Iouisianians for Safe Energy, 'nc., is a non-profit cor-poration organized under the laws of the State of Iouisiana. The i
~3 objectives and purposes of the organization include the education
.5 of the citizens of Iouisiana regarding the various energy options
/f available to meat the energy needs of the State and i's citizens, 8110070261 811002'.., -
PDR ADOCK 05000450 o
PDR.
s 5,i with particular reference tb:
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- 1. The demand for electrical energy,
- 2. Particular' dangers and hadards the various energy options pose to the health and welfare of the people of the State, and
- 3. The relative econcraic cost of each of the various energy options.
bbst of the members of petitioner LSE live within 15 and 30 miles of the proposed facilitie:s and obtain their drinking water frcrn t'le aquifer over which the proposed facilities, River Bend Units 1 & 2, will bi located.
B. Gretched Reinike Rothschild is a ratepayer of Gulf States Utilities and a property owner in the vicinity of tne proposed facilities in West Feliciana Parish.
II. INILM OF PETITIONERS A. The interests of petitioner IS2 include:
- 1. Property Ownership - Several' members of LSE ote real estate-in West Feliciana Parish and near the proposed facilities, 1
and therefore have a genuine financial stake in property values in the area.
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- 2. Safety, Environmental, and Health Concerns - Petitioner is concerned for the safety, health, and environnent of its members -
-r and all people of the state of Imisiana. Many members living in e
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the vicinity of the proposed facilities grow their osm food, and obtain their tinking supply frun the regional aquifer over which the proposed facilities will be located.
- 3. Financial Interorts - flany of petitioner's nurbers are Applicant's ratepaprs, and chus have an ongoing economic interest in the operations and financial stability of Gulf States Utilities.
B. The interests of petitioner Gretchen Peinike Pothschild include both the environmental, health, and safety and financial interests enumerated in part A.
Petitioner is a ratepayer of Applicant as well as an owner of real estate in the close vici-nity of the proposed facilities.
III. IKM PETITIONER'S IIEERESTS WILL BE AETDCTED The interests of petitioners in this licenaing' proceeding 5
will be adversely affected by the 1roposed action in the following ways:
A.
Property Or.ership Those persons, nentioned in section II 6f this petition, cwning property near the proposed facilities could suffer an adverse lowering of property values due to the existence and operation of the proposed facilities. Additionally, property values could be lowered adversely in the event of a nuclear accident or occurrence.
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Safety,.Envilenmentbl, and IIealth Concerns t
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Petitioner LSE is. concerned that the safety, health,
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and environnent of its mmbeis'and 'of the people of the State f
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of Iouisiana could be adversely affected by radioactive e-missions fran,the proposed facilities, including but not t
limited to the possibility, that' the food and water thei consume f
oauld be thus radioactively contaminatal. Petitioner Rothschild shares these concerns.'
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Additionally, the interests of petitioners will be adversely affected by the operation of facilities having sig-j nificant safety deficiencies due to numerous Unresolved Safety i
Issues. Petitioners interest in~a healthful environment will l
be adversely affected by the creation and introduction of.
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radioactive material into the environment by the operation of the proposed facilities, during ncrmal operations, as well 1
as during a potential accident. The petitioners interest in a healthful environment will also be affected adversely by the i
indefinite storage of radioactive wastes on the site of the J
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proposed facilities, and the future transportation and disposal i
of these wastes.
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Financial Interests t
As ratepayers, petitioners are concerned that they will
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j be adversely affected financially from 1) higner electric rates due to the inclusion of the costs of the proposed facilities i
into Applicant's rate base, and 2) possible increased costs to
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t Applicant, and ultimately to Applicant's ratiepayers, resulting fran unforeseen nuclear accidents or occurrences, and/or the decccmissioning of the plant.
1e IV.
SPEEIFIC ASPECTS OF THE SUIUErf EUR MIIGI IhTERVE7 PION IS SOUGliT Consistent with petitioners understanding of the Ccr. mission's regulation, section 2.714, it is not the purpose of this
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regulation to require petitioners to set forth specific contentions.
Petitioners her / indicate that they are interested in all aspects of the subject matter of the proceedings, insofar as they relate to the following issues:
1.
Necessity in the Public Interest for the construction and operation of the proposed facilities.
3 2.
Financial stability of Applicant to a) ccraplete the construction of the proposed facilities, and b) absorb the i
financial costs associated with possible nuclear accidents or occurrences, and/or future deconraissioning of the facilities.
3.
The adequacy of evacuation plans in the event of a nuclear accident or occurrence.
4.
Safety hazan1s created by construction and operation of the proposed facilities, including but not lintited to the following:
a) Failure to adequately evaluate the safety l
risks which y.ould' result frcm't'he operation of the proposed L
facilities due to Unresolved Safety Issues.
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b) Failure to adequately evaluate the hazards created by the temporary storage of spent fuel on-site of the proposed facilities, and the transportation and ultimato f
disposal of radioactive nuclea wastes that will be generated and the operation of these facilities, c) Failure to adequately evaluate risks created by hydraulic events involving the Mississippi. River.
d) Health issues relating to the escape of loe-t level radiation into the environment.
e) The probability of risk of a nujor nuclear accident at the proposed nuclear facilities and the potential l
harm to residents of the state of Iouisiana, including petitioners, and potential harm to future generations of residents of the state.
V.
CONCLUSION For all of the rearons set forth hereinabove, petitioners i
urge that their petition to intervene be granted and their standing to participate in these proceedings be recognized, and after due proceedings be had herein, that the Applicant's 4
operating license application be disapproved; or, if approved, that it be approved subject to such additional safeguarri and provisions as are just under these proceedings.
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h DATED: October 2, 1981 TU FC[Mt ??LttlhJ f
')C b? t h (l Gretchen Reinike Rothschild 1659 Glenmore Avenue Baton Ibuge, Louisiana 70808 (504) 924-1519 Joel Selbin President, LSE P.O Box 17250 Baton Rouge, Iouisiana 70893 (504) 383-2053
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