ML20041F027
| ML20041F027 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 03/08/1982 |
| From: | Thatcher T NATIONAL WILDLIFE FEDERATION, OREGON ENVIRONMENTAL COUNCIL, PACIFIC NORTHWEST RESOURCES CENTER, EUGENE, OR |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8203160104 | |
| Download: ML20041F027 (7) | |
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UNITED STATES OF AMERICA
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BEFORE T!!E NUCLEAR REGULATORY COMMISSION 02 In The Matter Of Puget Sound
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Power and Light, et al.
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Docket Nos.
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Amended Application For Construction)
STN 50-522, 50 r A
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Permits and Facility Licenses,
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SKAGIT/HANFORD NUCLEAR PROJECT
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g PETITION TO INTERVENE
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.A Pursuant to the Atomic Energy Act and the Nuclear lae Commission's Rules of Practice and Procedure, 10 C.F.R.
S2.714, the National Wildlife Federation and the Oregon Environmental Council jointly petition to intervene in the above captioned proceedings.
In support of this petition, petitioners would show the following:
I.
NAME AND ADDRESS OF THE PERSON REPRESENTING PETITIONERS TO WIIOM COMMUNICATIONS CONCERNING THIS PROJECT SHOULD BE ADDRESSED:
Terence L.
Thatcher Pacific Northwest Resources Center Law Center, 1101 Kincaid Eugene, Oregon 97403 l
II.
NATURE OF PETITIONERS'S INTEREST: EFFECT OF COMMISSION ACTION National Wildlife Federation, 1412 Sixteenth St.,
N.W.,
Washington, D.C.
20036 (NWF), the nation's largest private conser-vation organization, is dedicated to the wise use and conservation of the nation's natural resources.
Over 40,000 of its associate members live in the four-state Pacific Northwest region.
In addition, 02 3 OgOSO 6
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. NWF has affiliate organizations in each of the Northwest states:
-Idaho Wildlife Federation, Montana Wildlife Federation, Oregon
' Wildlife Federation, and Washington State Sportsmen's Council.
Many of NWF's members use and enjoy the natural resources that could potentially be affected by construction and operation of the Skagit/Hanford Plant, including the Columbia River, and live in the service districts of the sponsoring utilities.
Oregon Environmental Council (OEC), 2637 S.W. Water Street, Portland, Oregon 97201, is a broad-based coalition of groups and individuals, organized to protect the environment of the state of Oregon.
Many of OEC's approximately 1,900 members live in the l
Portland metropolitan area, use and enjoy the natural resources f
that could potentially be affected by construction and operation of l
l the Skagit/Hanford Project, and are served by the two Oregon-based sponsoring utilities. /
Both NWF and OEC have interests under the National Environ-l mental Policy Act, 42 U.S.C.
S4321 et seq. and the Atomic Energy Act, 42 U.S.C.
S2011 et seq., which they seek to protect through this intervention.
See Calvert Cliffs' Coordinating Committee, Inc.
- v. United States A.E.C.,
449 F.2d 1109 (D.C. Cir. 1971).
Commission j
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approval of' the Skagit/Hanford Project application would significantly
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The responsible officials of each petitioning organization have j
authorized this petition to intervene.
In addition, the following individual members of petitioners have authorized NWF and OEC to represent them in this matter.
For NWF:' Pearl Anderson, 1865 N.E.
129th Pl., Portland, OR 97230; Barbara Bruenig, 14140 S.E.
Rhone St.,
Portland, OR 97236; Larry Sowa, 17225 S.E. McLoughlin, Milwaukie, 1
i OR 97222.
For OEC:
Charlotte Corkran, 130 N.W.
ll4th, Portland, OR 97229; Walter McMonies, 2321 S.W.
Sherwood Dr., Portland, OR 97201: Marguerite Smyth, 6261 S.W.
47th Pl.,
Portland, OR 97221.
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. increase the chances that the Project will be built and operated, with the following impacts on petitioners' interests:
Construction and operation of the Skagit/Hanford Project will increase the levels of radiological, chemical, and thermal pollution of the air and water in the project area and down-river areas of the Columbia Basin and may adversely affect the fisheries resources of the Columbia River.
Operation of the plant will increase the shipment of radioactive materials through the Pacific Northwest region, thus increasing the risks to the environmental necessities and amenities, including fish and wildlife, used and enjoyed by members of NWF and OEC.
Operation of the Project will expand the volume of radioactive waste requiring storage in this nation, at a time when no satisfactory long-term storage arrange-monts have yet to be made, threatening the long-term health of the environment and petitioners' members' use thereof.
Operation of the Skagit/Hanford Plant to serve the base-load of the Pacific Northwest region will further encourage use of the Columbia River hydropower system for peaking purposes, to the detriment of the fish and
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wildlife resources of the Columbia River basin which are exten-sively used and enjoyed by petitioners' members.
Operation of the Project will also increase the risk of catastrophic nuclear accident which could cause environmental damage, particularly to the Columbia l
l River system, and result in significant dangers to the health of l
petitioners' members.
Finally, investment of billions of dollars in the construction and operation of the Skagit/Hanford plant will limit the funds available in the region for more environmentally acceptable and cost-effective energy alternatives, such as t
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. conservation, will unnecessarily and significantly increase the electrical rates of those of petitioners' members living within the service districts of the sponsoring utilities, and could signi-ficantly increase the rates of all the Pacific Northwest members of NWF and OEC if the sponsoring utilities sold the output of the Project to the Bonneville Power Administration.
III.
SPECIFIC ASPECTS OF PROCEEDING AS TO WHICH PETITIONERS SEEK TO INTERVENE Intervenors seek through their intervention to present evi-dence and legal arguments and conduct examination of applicants' experts to demonstrate the following:
(1) that the applicants have relied on an inflated calculation of the demand for electrical power in justifying pursuit of their license and have inaccurately calculated the impacts of delay or denial of the construction permit; (2) that there are cost-effective, environmentally : refer-able alternatives capable of meeting the energy demand which the Project is designed to serve; (3) that acquisition of the Project by the Bonneville Power Administration pursuant to the Pacific Northwest Electric Power Planning and Conservation Act, P.L.96-501, is highly unlikely, and that the inability of BPA to purchase the project is a central consideration in the decision to proceed or halt the project; (4) that applicant has failed adequately to identify, discuss, and evaluate the significance of the environmental impacts of construction and operation of the plant, including, but not i
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. limited to, impacts on water quality and fish and wildlife resources of the Columbia River, dangers of catastrophic accidents, either in fuel and waste transportation or in plant operation, and the impact on the economic and environmental viability of the project from the continuing problem of devising satisfactory long-term storage arrangements for nuclear waste materval; that if those impacts are fully-assessed the Project uppears even less desirable when compared to available alternatives; (5) that the applicants' benefit-cost analysis is funda-mentally flawed by, among other things, use of misleadingly low estimates of the financial and environmental costs of the Project and by use of an inflated assumption of the Project's power avail-ability and reliability benefits for the Region which, in fact, possesses significant, less-costly alternatives for providing the same or greater benefits.
Petitioners will also wish to assess and, if appropriate, recommend alterations to, the applicants' monitoring proposals and to investigate and present evidence and argument on the legal and physical availability of water to serve the Project.
I IV.
CONCLUSION For all the foregoing reasons, petitioners National Wildlife Federation and Oregon Environmental Council respectfully request that they be granted leave to intervene in this proceeding, with the right to have notice of and appear at all pre-hearing conferences and hearings that are held, and that they may introduce
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. evidence and submit argument in sdpport of their interests as out-lined in this petition.
DATED this day of March, 1982.
Respectfully subm
- ted,
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- C M il Q ( [ k,.s Terence L. Thatcher Pacific Northwest Resources Center Law Center, 1101 Kincaid Eugene, Oregon 97403 (503) 686-3823 Counsel for Petitioners STATE OF OREGON
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County of Lane
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Tereace, L. Thatcher, being first duly sworn, deposes and says that he is an attorney for National Wildlife Federation and Oregon Environmental Council; that he is authorized to make the foregoing Petition to Intervene; that he has read the same and knows the contents thereof and that all statements contained therein are true and correct to the best of his know dge, information and beli f.
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Terence L. Thatcher Subscribed and sworn to before me this day of March, 1982.
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{ b Notary Public for'Orbgon
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My Commission Expires: 1/7/83
r CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing Petition to Intervene, together with Notice of Appearance, by mail, postage prepaid, upon the following:
Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 F. Theodore Thomson Perkins, cole, Stone, Olsen & Williams 1900 Washington Building 1325 Fourth Avenue Seattle, Wa~shington 98101
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Dated this D' day of March, 1982.
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3 Terence L. Thatcher Counsel for Petitioners D
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