ML20051J707

Amend to Petition to Intervene Including Individual Member Affidavits & Listing Aspects within Which Petitioners Wish to Intervene

ML20051J707
Person / Time
Site:	Harris
Issue date:	05/10/1982
From:	Newman P CITIZENS AGAINST NUCLEAR POWER
To:	NRC COMMISSION (OCM)
Shared Package
ML20051J586	List: ML20051J556 ML20051J707
References
NUDOCS 8205170268
Download: ML20051J707 (7)

Text

,g.

E

!b~

Citizens Against Nuclear Power 2309 Weynouth Court DOCKETED Raleigh, North Carolina 27612 ussac

~82 MY 13 P1:26 IN THE MATTER OF CAROLDM POWER & LIGff

)

A'tendment to petition Co. g.g. (Shearon Harris Nuclear Power Plants), ) for leave 2 M h g p:

p Dockets 50-400 and 50-401

)

g,g7jg g 3 RANCH Citizens Against Nuclear Power (CANP) filed a petition for leave to intervene in the above captioned proceedings by letter' posted frca Raleigh, '

N.C. on Feb. 27, 1982. As this petition was judged to be tinely filed, and this amendment is merely to add detail and specificity to that anendaent, CANP now moves that this amendment be considered tinely filed for purposes of con-sidering the petition for leave to intervene.

CANP makes the following anendaents:

CANP was founded in December, 1977 as a non-profit, volunteer group of citizens in the area of Raleigh, N.C. concerned about the proposed construc-tion and subsequent operation by Carolina Power & Light conpany of a nuclear power station at New Hill, N.C.

CANP requests leave to intervene as an organization on behalf of its nanbers. Appended hereto below are sworn statements by several CANP members, which statements set forth their individual interests in the above captioned proceedings and their individual requests that CANP represent them in these proceedings.

CANP member John Cowgell, 621 Brooks Ave., Ral., N.C., 27607, is duly authorized by CANP's membership to serve as CANP's representative in the above captioned proceedings.

Mr. Cowgell's written notice of appearance is attached hereto below.

The aspects of the above captioned proceeding with respect to which CAh?

wishes to intervene include, but are not limited to:

1.

The adequacy of evacuation and othcr emergency planning providing for the safety of nearby life and property in the event of a substantial radiation release at the Shearon Harris Nuclear Power Station (SHNPS).

2.

The safety-related adequacy of SENPS's engineering design, particularly that of the steam generators.

3.

The safety-related adequacy of construction practices in the building of SHNPS.

4.

The adequacy of Carolina Power & Light's nunagerial capacity for the safe operation of SHNPS.

5.

The adegaacy of radiation protection for the surrounding ccmuunities envisioned by SHNPS engineering design and the adequacy of the radiobiological data base on the basis of which the health effects of emissioned radiation exposure are evaluated.

8205170268 e

e e

G-~

,~

2

~

- ps;. - g r-

. g m.'

~

6.

The adequacy of radiological nonitoring of enviramental. releases envisioned for SHNPS, particularly in view of the lack of any provision for nilti-site continuous. radiological monitoring conducted. independently of Carolina Power & Light Co..

The undersigned, Patricia T. Newnan and Slater E. Newman, first4being duly sworn, depose and say that they are Co-coordinators of Citizens Against Nuclear Power, have read the foregoing amendment of the petition to intervene and affirm that the same is true to the best of their knowledge.and belief.

Signed 05 T N4469nN Patricia T. Newman, Cosoordinator, Citizens Against Nuclear Power Signed M-C-d- h Slater E. Newman, Co-coordinator, Citizens Against hb: lear Power Dated this day of din

/h,

h r - p 1

1 Affirmed and subscribed before me this

/O day of May, 1982.

8'J141 fl,/

Notary Public

//.

/-

QCammission bpires 8 23-84 e

1

^~j'^"

Docksto No. 50-400/50-401 AFFIDAVIT OF JOHN COWGELL I am John Cowgell and I live at 621 Brooks Avenue, Raleigh, North Carolina, within 25 miles of the site of the' SHEARON HARRIS NUCLEAR POWER STATION (SHNPS).

I am employed as manager of Universal Printing & Publishing Co. of 1901 Smallwood Drive, Raleigh, North Carolina, also within 25 miles of SHNPS.

I believe that the normal operation of SHNPS will pose

~

radiological threat to my health and that both foreseen and unfonscen accidental radioactivity releases from SHNPS threatennotonlymyhealthbutalsomylivelhhood, inasmuch as a substantial accident would necessitate local evacuation and consequent disruption of the local economy and loss of business to my firm.

I am a member of Citizens Against Nuclear Power (CANP),

2309 Heymouth Court, Raleigh, North Carolina and have author-ized CANP to represent me and my interests in NRC proceedings concerning the licensing of SHNPS.

Signed N

g Cowge 4 Q

[

Dated this day of /Nh 8 /9f 7_.

/ /

Affirmed and subscribed before me, this A day of May, 1982.

s h

rN Notary Public y w/d mf FA 2y, 685'.

9 0

~

1

DockOt No. 50-400/50-401 621 Brooks Avenue Raleigh, NC 27607 May 3, 1982 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Sir:

I, John Cowgell, 621 Brooks Avenue, Raleigh, North Carolina 27607, (Tel: 919/821-5021), having been duly authorized by Citizens Against Nuclear Power (CANP) 2309 Weymouth Court, Raleigh, North Carolina 27612, to represent CANP in any NRC proceedings for which CANP holds intervenor standing, do herewith file written notice of appearance pyrsuant to the provisions of 10 C.F.R. h 2.713(b).

SignedU"*t*P ()

/

Dated this day of [h w T hhb.

f>

af' l Affirmed and subscribed before me, this 8 day of May, 1982.

i, s

,1

&na j

% Notary Public

() h h U

j m

' ' 1:

9p FJ 29 lW' j

m q

. m:

Dockets No. 50-400/50-401 AFFIDAVIT OF PAIRICIA T. NN I am Patricia T. Newman. 'I live at 2309 Wey::outh Court, Raleigh, North Carolina within 25 miles of the site of the SHEARON HARRIS. NUCLEAR POWER S'TATICN.

I have personal property at 2309 Weymouth court, Raleigh, North Carolina and jointly own with Slater E. Newman real property at that address and at 315 Shepherd Street, Raleigh, ' North Carolina. Both-sites am within 25 miles of the site of the Sheartn Harris Nuclear Power Station.

I believe that the normal operation of the Shearon Harris Nuclear Power station will pose radiological threat to my health and that both foreseen and unforeseen accidental radioactivity release frcm the Shearon Harris Nuclear Power Station will threaten my health and the value of my Property.

I am a nmber of Citizens Against Nuclear Power (CANP), 2309 Weynouth Court, Raleigh, North Carolina and have authorized CANP to represent me and my interests in NRC proceedings concerrdng the licensing of the Shearon Harris Nuclear Power Station.

Signed dia'('e EL [ hhm )

Patricia T. Newman Dated this day of

//A

[b, /

)

e g

Affi and subscribed before me this

/O cay of May, 1982.

!4idJO Mun

= % &m,

~

Notary Public o

e 9

g

=

z.

T L

~

.k..=.?.

. ?ll E.Yll!

5.~

? k S :=

~ -

5

~

~~

. -~

x

~a

} ' ml2k ' s.~ y* k. sr _.o W5 yi '==.5 %W '7 f

--: +

- m -:-

=.

Nw f *""

- ' ' ? - - ?'

~?-

~

~*' ';~ '**

-**?

.. -c

-e

~'

=

3 e-w-.

e T s, -

w v-

Dockets No. 50-400/50-401 AFFIDAVIT OF SIAIER.E. NDNAN I am Slater E. Neman. I live at 2309 Weymouth Court, Raleigh, North Carolina within 25 miles of the site of the SHEARCN HARRIS NUCLEAR POWIR STATION.

I have personal property at 2309 Weynouth Court, Raleigh, North Carolina and jointly own with Patricia T. Newman real property at that address and at 315 Shepherd Street, Raleigh, North Carolina. Both sites are within 25 miles of the site of the Shearon Harris Nuclear Power Station.

I believe that the normal operation of the Shearon Harris Nuclear Power Station will pose radiological threat to my health and that both foreseen and unforeseen accidental radioactivity release frcm the Shearon Harris Nuclear Power Station will threaten my health and the value of my property.

I am a member of Citizens Against Nuclear Power (cat @), 2309 Weynouth Court, Raleigh, North Carolina and have authorized CAIG to represent me and my interests in NRC proceedings concerning the licensing of the Shearon Harris Nuclear Power Station.

Signed A F. %

Slater E. Newman Dated this day of b4

/O, /k) i g

r Affirmed and subscribed before me this

//)

day of May, 1982.

MvA db fM Notary Public My Comm!rsion bptres S 23-8j

'D

...,..w.

7 2512 Kenmore Drive Raleigh, N.C.

27608 May 4, 1982 United States Nuclear Regulatory Commission Washington, D.C. 20555 Commissioners:

1.

We are Phyllis Mahon Tyler and Lloyd P. Tyler.

We live at 2512 Kenmore Drive, in Raleigh which is roughly 20 miles from the Shearon Harris Nuclear Power Plant.

2.

We own personal and real property at this address.

3.

We feel that the Shearon Harris Nuclear Power Plant is

a. threat to our health, property, and livlihood.'

4.

We are members of Citizens Against Nuclear Power and wish them to represent our interests in Nuclear Regula-tory Commission proceedings regarding the licensing of the Shearon Harris Nuclear Power Plant.

Nr4Wr Wm Phyllis Mahon Tyler u

0. 5 Llofd P. Tyleif fu. sa)w A4:

p&-

M sn maw c, u,<.,

l

^

n h

e Y

f f

EII B

d e

.