ML20062F715

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Petition for Leave to Intervene in Steam Generator Replacement Proceeding & Petition for Hearing.Wi Environ Decade Has Recognized Life,Property & Financial Interests. Certificate of Svc Encl
ML20062F715
Person / Time
Site: Point Beach NextEra Energy icon.png
Issue date: 08/10/1982
From: Patricia Anderson
WISCONSIN'S ENVIRONMENTAL DECADE
To:
NRC COMMISSION (OCM)
References
NUDOCS 8208120119
Download: ML20062F715 (3)


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U AliD 11 4040 KYT?NGYf,b BRANCR UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION Wisconsin Electric Power Company POINT BEACH NUCLEAR PLANT UNIT 1 DOCKET NO. 50-266 Operating License Amendment (Steam Generator Replacement Proceeding)

PETITION FOR LEAVE TO INTERVENE AND PETITION FOR HEARING Petitioner WISCONSIN'S ENVIRONMENTAL DECADE, INC. (" Deca d e") ,

pursuant to 10 C.F.R. S2.714 and 4 7 F.R. 30125(July 12, 1982),

hereby petitions the U. S. Nuclear Regulatory Commission (" Commission") for leave to intervene and for an opportunity to be heard in the above-captioned proceeding in wnich tne Licensee WISCONSIN ELECTRIC POWER COMPANY (" Company") ,

has applied for a license amendment to replace the major components of the steam generators at its the Point Beach Nuclear Plant Unit 1(" Point Beach") by application dated May 27, 1982.

I Natura of Petitioner's Right

1. DECADE is a non-stock, non-profit membership corporation organized unoer ch.181, Wis. Stats., to protect and enhance the quality of the human environment against, among other things, the hazards of nuclear power, with its principal office at 114 North Carroll Street Suite 208, Madison, Wisconsin 53703, and district of fices in Milwaukee and Appleton, Wisconsin.

2 8200120119 820810 DR ADOCK 05000 g

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II Nature and Extent of Pet'itioner's Interest

2. DECADE has approximately 64,000 members throughout the state of Wisconsin, including the area surrounding Point Beach as well as tne area served by the COMPANY, among whom are Joseph and Lavinia Dworak who reside and maintain a farm in Whitelaw, Wisconsin, Ann and Paul Kortens, who reside and maintain a farm in Two Rivers, Wisconsin, and Thomas Van Alyea, who resides and is served by the COMPANY in Milwaukee, Wisconsin.
3. DECADE petitions herein on its own behalf and on behalf or its members, including Joseph and Lavinia Dworak, Ann and Paul Kortens and Thomas Van Alyea, in order to protect its interest recognized uncer tne Atomic Energy Act of 1954, as amended ("the Act"), 42 U.S.C. S2232, in adequate protection of its health and sarety from operation of commercial power reactors, and its interest recognized under the Act, 42 U.S.C. S2239, in adequate protection against imprudent financial expenditures that will not provide commensurate value in service.

! III i

Effect of Order l

l 4. DECADE has a recognized life and property interest that is tnreatenea by the license amendment herein in that primary-to-secondary or secondary-to-primary leakage through ruptured steam generator tubes may lead, directly or indirectly, to the exposure of the public surrounding Point Beach, including Joseph and Lavinia Dworak and Ann and Paul Kortens, to unsafe levels of radiation, and in that the proposed modifications to Point Beach

! do not provide adequate assurances that such exposure will not WED-PA-08/10/82-P3:50266NRC.P48-1

occur.

5. DECADE has a recognized financial interest that is threatened by the license amendment herein in that the proposed modifications will raise rates that customers of the COMPANY bear but which,will not provide a commensurate increase in service in tnat the modification may not succeed in its intended public.

WHEREFORE, petitioner WISCONSIN'S ENVIRONMENTAL DECADE, INC., respectrully petitions for leave to intervene and an opportunity to be heard in the above-captioned matter.

DATED at Madison, Wisconsin, this 10 th day August, 1982.

WIS ONSIN'S ENVIRON

  • AL DECADE, INC.

by s

R ANDERSON Co-Dir or 114 North Carroll Street Suite 208 Madison, Wisconsin 53703 (608) 251-7020 CERTIFICATE OF SERVICE I certify that true and correct copies of the foregoing Peticion for Leave to Intervene and Petition for Hearing will be served this day on the Executive Legal Director of the U. S.

Nuclear Regulatory Commission and Mr. Bruce W. Churchill by depositing a copy of the same in the first cl s mails, postage pre-paid and correctly addressed. [l i U ~

k28W Q JJ Dated: C)Luv-0 Nk WED-PA-08/10/82-P3:50266NRC.P48-1