ML20079N161

Joint Petition of Georgians Against Nuclear Energy for Leave to Intervene & Request for Hearing

ML20079N161
Person / Time
Site:	Vogtle
Issue date:	01/26/1984
From:	Stangler C, Teper D GEORGIANS AGAINST NUCLEAR ENERGY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20079N163	List: ML20079N161 ML20079N165
References
NUDOCS 8401300096
Download: ML20079N161 (11)

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UNITED STATES OF AMERICA DOCKETED l NUCLEAR REGULATORY COMMISSION USNRC BEFORE THf. ATOMIC SAFETY AND LICENSING BOARD In the Matter of c4 JAN 27 All 6 I

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et al. Docket Nos. 50-424~and":50:425

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(Vogtle Electric Generating Plant, )

Units 1 and 2) )

JOINT PETITION FOR LEAVE TO INTERVENE AND RE0 VEST FOR HEARING Introduction 1.

By application dated September 13, 1983, Georgia Power Company, acting for itself and as agent for co-owners, applied for an operating license for 2 pressurized water nuclear reactors, designated as the Vogtle Electric Generating Plant, Units 1 and 2.

Each unit, located on the applicant's site in Burke Co., j Georgia is designed for an electrical output of 1160 megawatts. (

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2. On December 28, 1983 a notice of Receipt of Application for Facility f

Operating Licenses; Availability of Applicants' Environmental Report; Consideration  !

of Issuance of Facility Operating License; and Notice of Opportunity for Hearing was l

published in the Federal Register in the Matter of Georgia Power Co. et al., Docket f

Nos. 50-424 and 50-425. This notice set January 27, 198'4 as the deadline for receipt of petitions for leave to intervene and requests for hearings. Pursuant to 10 CFR 2.714, Georgians Against Nuclear Energy and Coastal Citizens for a Clean "

' Environment and their members hereby submit their joint petition for leave to intervene and request for hearing.

Description of Joint Petitioner  :

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Georgians Against Nuclear Energy (GANE) is a non-profit citizen group, organized in 1978; with a current membership of over 800, GANE is the largest and most active antinuclear organization in Georgia. Through educational activities a

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and political involvement, GANE works towards its goals of phasing out the use of 5 nuclear energy, optimizing the use of energy conservation and solar energy, and 8401300096 840126 PDR ADOCK 05000424 9 PDR ~ s

. eliminating the production and use'of nuclear weapons.

4. Since its inception,- GANE has been actively involved in proceedings that involve the operation and construction of nuclear facilities. It intervened before 4 the Georgia Public Service Comission (PSC) on the Georgia Power Company's rate hike requests in July 1981 and June 1983. It also intervened before the PSC during the Public Utility Regulatory Policies Act (PURPA) hearings in 1980. GANE members have testified at the Interagency Review Group Hearings on Nuclear Waste, Boston, 1978, Department of Transportation hearings on Preempting Local Authorities on the Transportation of Nuclear Waste, Atlanta, 1980; Department of Energy hearings on the Start-up of the Savannah River Plant L-Reactor, Augusta,1983; and the Georgia Public ' Service Comission hearings on Nuclear Power, Atlanta,1980. FANE has also testified on utility issues before Georgia legislative comittees in 1980, 1982 and 1983.

5. Coastal Citizens for. a Clean Environment (CCCE) is a non-profit membership organization formed in 1976 by citizens concerned about the degradation of the environment. CCCE works to promote the use of alternative and renewable energy.

sources through' education and environmental legislation.

6. CCCE lobbied before the Georgia General Assembly in 1983 to defeat Senate <

, , Bill 18 which would have allowed power companies to impose rate increases prior to  ;

Public- Service Comission review. CCCE has also presented information to local and i

' county-government officials on issues of concern to its members.

Interest and Standing of Petitioner i

7. Several members of GANE, including Peter Bull and Edward A. Giusto, whose i affidavits are attached, reside within the fifty-mile radius of the Vogtle plant ,

site. These and other members of GANE live, own property, work, travel to and engage in outdoor recreational activities including gardening, fishing, boating,

.swirrming, hunting, hiking and camping in the environs of Plant Vogtle. They consume vegetables, dairy products and meat produced in the area that will be immediately

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affected by plant operations; the air they breathe and the water they drink will also be affected by operation of the plant.

8.

Members of GANE are consumers of energy for residential, recreational and bu:iness uses.

All members now purchase electric energy from commercial sources but they would make more extensive use of reasonable alternative energy sources such as solar, wind, bio-mass and conservation techniques if such were more readily available and competitively priced.

GANE's members include retail electric customers of Georgia Power Company, Oglethorpe Power Corporation and Municipal Electric Authority of Georgia.

9.

The members of CCCE live downstream from Plant Vogtle; the air they breathe and the water they drink will be affected by operation of the plant.

10.

Members of CCCE are consumers of energy for residential, recreational and business uses.

All members now purchase electric energy from commercial sources but 3 they would make more extensive use of reasonable alternative energy sources such as solar, wind, bio-mass and conservation techniques if such were more readily $

available and competitively priced.

CCCE's members include retail electric i customers of the Savannah Electric and Power Company, a member of the Southeastern 4

Power Pool with the Georgia Power Company.

How Petitioners Interests May Be Affected

11. 5 The above-stated interests of GANE and its members may be affected by 5 the proposed operation and on-site storage of spent nuclear fuel at Plant Vogtle. .

The operation of a nuclear power plant at the site may endanger the health and "

safety of Petitioner's members on many counts. w Routine and accidental releases of .

.4 fonizing radiation from the plant may contaminate the air, food and water essential i for members' survival.

The safety and well-being of members may be adversely b affected by the possibility of a nuclear accident damaging or destroying their l,k livelihood, homes, property and lives.

Recreation may be jeopardized by the .5 project's effect upon the water and aquatic life of tne Savannah River and the "

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surrounding environment. A nuclear accident at the plant may affect the economy of the region. Insurance would not adequately compensate losses sustained by members of GANE in case of an accident.

12. The above-stated interests of CCCE and its members may be affected by the proposed operation and on-site storage of spent nuclear fuel at Plant Vogtle. The operation of a nuclear power plant at the site may endanger the health and safety of CCCE's members on many counts. CCCE's members, who live downriver from the plant, eat fish and shellfish that might be contaminated or eliminated by planned and accidental releases from the plant. The safety and well-being of members may be adversely affected by the possibility of a nuclear accident damaging or destroying their livelihood, homes, property and lives. A nuclear accident at the plant may affect the economy of the entire region, including the area where CCCE members live and work. Cumulative effects of the over-concentration of nuclear facilities upriver from members' residences may contaminate their air and water supply.

13. The proposed operation of Plant Vogtle will place an excessive burden on Petitioners' members who are electrical ratepayers. An Order granting an operating license in this case may subject Petitioners' members to undue risks to health, life and property interests.

Specific Aspects of the Subject Matter

]?. GANE and CCCE, if grcnted leave to intervene in this proceeding, will file l

( contentions on the following aspects:

There exists no reasonable assurance that:

A. Construction will have been completed in accordance with the rules and regulations of the Commission given:

1) The f act that inferior materials have been used at the site.

2) The poor performance and defects of currently operating Westinghouse reactors of the same models as those installed at the Vogtle site.

3) Defective workmanship including documented drug abuse by Vogtle workmen;

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B. The Applicant possesses the technical ability to operatt the project in accordance with the rules and regulations of the Commission; C. The geology of the site has been properly assessed and has been considered in the engineering design of the project especially in light of new data made available by the U.S. Geological Service; D. Emergency response plans are adequate; E. The routine and accidental releases of radiation from the plant will not result in carcinogenic, teratogenic and mutagenic effects endangering public health

-and. safety.

F. The Applicant possesses tnt V ity to conform to NRC-approved quality control and quality assurance procedures for operation of the plant; G. The operat?on of the plant will not contaminate the underlying groundwater and the Ocala Aquifer; H. That the over-concentration of nuclear facilities in the Savannah River are will not result in the dangerous accumulation of radionuclides in the water and

. air of the region.

I. Le proposed carrying capacity of transmission lines from the plant will not endanger the lives and health of humans, livestock and plants exposed to the electromagnetic radiation; J. The salt drift emissions from the cooling towers will not threaten public ~

health and safety; K. The fear caused by living adjacent to a nuclear facility will not threaten the security and 'well-being of the community; m

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L. The effect of atmospheric patterns, particularly Pasquille Type A, has been adequately assessed in relation to impacts on the plant; M. Conditions have not changed since the construction permit was issued in June, 1974; N. Transportation of nuclear and spent fuel to and from the plant will not

z threaten the lives of citizens in light of recent train derailments in Buckhead and Greensboro, Georgia.

Effect of Intervention 15.

The participation of GANE and CCCE and their members in previous regulatory proceedings is indicative of its ability to assist in the development of a sound record due to its familiarity with the process and the issues, and its access to expert witnesses.

16.

Petitioners' interest in protecting their members from probable harm to their health, safety and economic interests can only be protected through full participation as parties to this proceeding with the right to offer evidence and to confront evidence offered by other parties. No other parties can adequately represent Petitioners' interest.

Conclusions

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Georgians Against Nuclear Energy and Coastal Citizens for a Clean Environment having established herein a standing of right under the Atomic Energy Act of 1954 as amended, the National Environmental Policy Act of 1969 and Chapter 10 of the Code of Federal Regulations, Part 2.714, are entitled to receive the hearing requested on the Georgia Power Company's application for operating license for the Vogtle Electric Generating Plant, Units 1 and 2 and an Order granting this joint -

petition for. leave to intervene. .

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5i l January 26, 1984 Respectfully submitted, f Carol A. St'an'gler Wehb '

b I3 425 Euclid Terrace, N. II6uglps C. Teper / .;

Atlanta, GA 30307 1209 N. Decatur Road "S Atlanta, GA 30306 404-223-0786 404-876-2217

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I' 00CKETED UNITED STATES OF AMEP.ICA USNRC NUCLFAR REGULATORY COMMISSION

'84 JAN 27 All:36 In the Matter of Docket Nos. 50-424 CFFICE OF $C.NJ -

V0GTLE ELECTRIC GENERATING PLANT 90c",EityJh SE M ~

Q BRANCH Facility Operating License for Units 1 & 2 AFFIDAVIT Personally appeared before the undersigned officer, duly authorized by law to administer oaths, PETER S. BULL, who, after being duly sworn on oath, deposed and says as follows:

1.

I reside at 519 Wrights Avc. , Augusta, Georgia. I reside within 50 miles of the Vogtle Electric. Generating Plant located near Waynesboro, Georgia. I believe the plants are cetually about 30 miles from my house.

I own my residence and the land surrounding it.

2.

I am a member of the Georgians Ag-inst Nuclear Energy (GANE). .

I an aware of GANE's petition for Leave to Intervene in this application to obtain an operating license for Plant Vogtle. I am concerned about potential health, safety, and environmental problems related to the operation of this plant. I authorize GANE to represent me in this proceeding.

This affidavit is made for the purpose of satisfying the Nuclear Regulatory Commission that GANE has membership residing within fifty miles of Plant Vogtle that is concerned about the proposed operation of d this plant.

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Peter 6. Bull Sworn to and subscribed before me this 2 /g day of #muum , 1984.

l h NOTARY PUBLIC Nd My commission expires Mu1;m[ $ 8 / f((

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g United States of A.merica Nuclear Reguintory Cemission DOLMETED USNRC In'the matter of Vogtle Electric Generating Plant, Dockets Nos. 50-424,50-425 Facility operating license for Units 1.T i2, gp7,;g g7 SEu v,;

00CXEilNG & SEP /7 5%NCH AFFIDeWIT Personally appeared before the undersigned officer, duly authorized by law to administer oaths, 6,/ubu/ A. C,'ah ,who, after being duly sworn on oath, deposes and says as f011cws:

1) I reside at _ //-@,' 7%,4& s 9. Mwsk,[/ foW6 .

I reside within 50 miles of the Vogtle Electrict Generating Plant located near Waynesboro, Georgia. I believe the plant is actually 21 miles from my home. I own my own home and the land around it. I also own a business in the area.

2) 1 am a member of Georgians Against Nuclear Energy (GANE). I am aware of G\NE's Petition for Leave to Intervcne in this application to obtain an operating license for Plant Vogtle. I am concerned about potential health, safety, and environmental problems related to the operation of this plant.I authorize GANE to represent me in this proceeding.

3)'Ihis Affidavit is made for the purpose of satisfying the Nuclear Regulatory Comission thtt G%'E'has membership residing within 50 miles of Plant Vogtle that is concerned about the proposed operation of this plant.

X Y._ - b Eden)//.6,hh Sworn to-and submitted to ma this 24th day of .Tanuary,1984 Notary X e >~ J a.

mycommissaptcypire.(:. a m =.12.1;u

AFFIDAVIT DOCKET,ED USNR.,

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State of Georgia County of Fulton jss. 84 JAN 27 A11:36

' FF!;E OF SECr. :/.f -

J D I, Marita Roos, being first duly sworn, do depose and say abC5MfEEM-

1. That I am coordinator of Georgians Against hbclear Energy (GANE).

2. That the foregoing petition was prepared under my supervision and direction and that, to the best of our knowlwdge and belief, it and the facts contained therein are true and correct.

3. That GANE members, Carol Stangler, Douglas Teper, Dan Feig, and Jeanne Shorthouse have been duly appointed to represent Georgians Against Nuclear Energy, in this proceeding in the matter of Georgia Power's application for an operating license at Plant Vogtle.

Signed:

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J Naw Marida Roos, Coordinator GANE Subscribed and sworn to before me this MM day of Ln,mvg/ , 1984 i

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Nats.1yPubl.ic/"

. rry Mhe, Gwgh. Sn at tirge My car. mission expires: 3 ce=Fn'm De*' Nc' 15 N5

In.the matter of the Vogtle Electric Generating P1 KE ED docket #50-424and#50-425FacilityOperatingLicensefor*y["

Units #1 and # 2.

'84 JAN 27 All:37 AFFIDAVIT OFF E OFSEgt g,,

h 00CnEimG A SEs / ira BRANCH S tate o f Georgia, County of Chatham Personally appeared before the undersigned officer, duly authorized by law to administer oath, William T. McLaughlin, who after being duly sworn on oath, deposes and say as follows:

I reside at 403 Tattnall Street, Savannah, Georgia, which is downwind and downriver from the location of the Vogtle Electric Generating Plant. I am therefore subject to future planned and accidental releases from this plant.

In addition to the potential threat of contamination of our future water supply, both ground and surface water, I question the cumulative affects on our health and safety due to numerous , existing and planned nuclear operations in the immediate vicinity of Plant Vogtle.

I am a member of Coastal Citizens for a Clean Environment.

(CCCE). I am aware of CCCE 's petition for leave to intervene in this application for an operating license for Plant Vogtle.

I am concerned about the potential health, safety, environmental and economic problems related to the operation of this plant. c.

I authorize CCCE to represent me in-this procedure.

.dt Lw c R LA William T. McLaughlin Sworn to and subscribed before ne this 25th day of January, 1984.

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Not'ary Public' '

Commission Expires. Notary Pu .c. Chatnam County, w e e.o.a. u. t

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