ML20079N751
| ML20079N751 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/26/1984 |
| From: | Fowler L CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8401300321 | |
| Download: ML20079N751 (10) | |
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UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USHRC BEFORE-THE ATOMIC SAFETY AND LICENSING B0@D JiS27 All:38 In the Matter of
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Docket Nos. SU ~424?and.50-425 1-et al.
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(Vogtle' Electric Generating Plant,
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Units 1 and 2)-
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PETITION-FOR LEAVE TO INTERVENE AND RE0 VEST FOR' HEARING Introduction 1.
By' application dated September 13, 1983, Georgia Power Company, acting for
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itself and as agent for_ co-owners, applied for an operating license for two pressurized water nuclear reactors, designated as the Vogtle Electric Generating Plant, Units 1 and 2.
Each of the' reactors, 1ccated on the applicant s site in
- Burke Co., Georgia is designed for an electrical outout of 1160 mecawatts.
2.
On December 28, 1983 a notice of Receipt of Application for Facility 4
Operating Licenses; Availability of Applicants' Environmental Report; Consideration i.
of Issuance of Facility Operating License; and Notice of Opportunity for Hearing was published in the Federal Register-in the Matter of Georgia Power Co. et-al., Docket
'Nos. 50-424 and 50-425.
This notice set January 27,-1984 as the deadline for
-receipt of. petitions for leave to intervene and reauests for hearings.
Pursuant to 10 CFR 2.714, the Campcign for a Prosperous-Georgia and its members hereby submi't
' their petition for leave to intervene and request for hearing.
. Description of Petitioner
~ 3. ?The Campaign for a Prosperous Georgia (CPG) is a membership organization formed. in early 1983 by a coalition of consumer groups, environmental organizations,
' business operators, labor activists, government officials and other citizens concerned about the economic and environmental impacts of electric utilities operating in Georgia.
-4.
CPG has intervened before the Georgia Public Service Commission in rate 8401300321 S g 4 90}
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proceedings, wherein CPG presented expert testimony, cross-examined witnesses for the applicant and intervenors, presented briefs'and fully participated as a party in the hearings. -CPG has also presented testimony and other information to state and federal legislators on issues of concern to its membership.
- 5.. Members and staff of CPG have served on an advisory panel to the Nuclear
' Regulatory Commission to review utility cost recovery for decommissioning nuclear
= reactors and have participated as 1ntervenors in construction licensing proceedings for the Vogtle Electric Generating Plant before the Atomic Energy Comnission and the Nuclear Regulatory Commission.
Interest ano Standing of Petitioner 6.
Several members of CPG, including Benjamin Reynolds, Thomas Reynolds and Claire Hicks, whose affidavits are attached, reside within the fif ty-mile radus of the Vogtle plant site.
These and other members of CPG live, own property, work, 7
travel to and engage in outdoor recreational activities including fishing, ioating, swimming,' 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 affected by plant operations; the air they breathe and the water they drink will also be.affected by operation of the plant.
7.
Members of CPG are consumers of energy for residential, recreational and business 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 i
available and competitively priced.
Petitioner's members include retail electric l
customers of Georgia Power Company and retail customers of wholesale customers of Oglethorpe Power Corporation and' Municipal Electric Authority of Georgia.
H W Petitioner's Interest.; May Be Affected
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-8.
The above-stated interests of Petitioner and its members may be affected by I
the proposed cperation and on-site storage of spent nuclear fuel at Plant Vogtle.
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The operation of a nuclear power plant at the site may endanger the health and safety of Petitioner's members on many counts.
Routine and accidental releases of ionizing radiation from the plant may contaminate the air, food and water essential
'for members' survival.
The safety and well-being of members may be adversely D
affected by the possibility of a nuclear accident damaging or destroying their livelihood, homes, property and lives.
Recreation may be jeopardized by the project's effect upon the water and aquatic life of the Savannah River and the surrounding environrent. A nuclear accident at the plant may affect the economy of the region.
Insurance would not adequately compensate losses sustained by members of CPG in case of an accident.
The proposed operation of Plant Vogtle will place an excessive burden on Petitioner's members who are electrical ratepayers.
An Order granting an operating license in this case may subject Petitioner's members to undue risks to health, life and property interests.
Specific Aspects of the Subject Matter S.
CPG, if granted leave to intervene in this proceeding, will file contentions on the fellowing aspects:
There exists no reasonable assurance that:
- a. Georgia Power Company and co-owners have the financial ability to safely operate Plant Vogtle;
- b. The production capacity of Plant Vogtle is needed;
- c. A reasonable exploration of alternatives to the plant has been considered by the Applicant;
- d. Conditions have not changed since the construction permit was issued in June, 1974;
- e. The Applicant possesses the technical ability to operate the project in accordance with the rules and regulations of the Commission;
- f. 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;
- g. Emergency response plans are adequate;
- h. The Applicant possesses the ability to conform to NRC-approsed quality control q
and quality assurance procedures for operation of the plant;
- i. The operation of the plant will not contaminate the underlying groundwater and t'he Ocala Aquifer:
- j. The 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;
- k. The salt drift emissions from the cooling towers will not threaten public health and safety;
- 1. The fear caused by living adjacent to a nuclear facility will not threaten the security and well-being of the community;
- m. The effect of atomspheric patterns, particularly Pasquille Type A, has been adequately assessed in relation to impacts on the plant;
- n. Construction will have been completed in accordance with the rules and regulations of the Commission given:
- 1) The fact 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;
- o. Transportation of nuclear and spent fuel to and from the plant will not threaten the lives of citizens in light of recent train derailments in Buckhead and Greensboro, Georgia.
Effect of Intervention 10.
The participation of CPG and its 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.
11.
Petitioner's interest in protecting its members from probable harm to their health, safety and economic interests can only be protected through full participation as a party to this proceeding with the right to offer evidence and to confront evidence offered by other parties. No other party can adequately represent Petitioner's interest.
Conclusions 12.
The Campaign for a Prosperous Georgia having established herein a standing of right under the Atomic Energy Act of 1954 as amendec', the National Environmental Policy Act of 1969 and Chapter 10 of the Code of Federal Regtiations, Part 2.714, is 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 petition for leave to intervene.
Janua ry 26, 1984 Respectfully submitted, uux laurie Fowler for:
Legal Environmental Assistance Foundation 1102 Healey Building /57 Forsyth St. NW Atlanta, GA 30303 404-688-3299 5
Attorney for Petitioner Campaign for a Prosperous Georgia 5
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00CKETED USNRC
'84 JM27 N158 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
<Jer;E OF SECfj~
- C,,LTUG 6 53-B?,1"Cr In The Matter of
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DOCKET NOS. 50-424
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50-425 VOGTLE SLECTRIC
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GENERATING PLANT
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facility operating
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license for Units
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1& 2 Affidavit State of Georgia )
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County of Burke
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Personally appeared before the undersigned officer, duly authorized by law to administer oaths, THOMAS REYNOLDS, who, after being duly sworn on oath, deposes and says as follows:
1.
I reside at Wood Valley Road, P.O.
Box 227, Waynesboro, Georgia 30830.
I reside within 50 miles of the Vogtle Electric Generating Plant located near Waynesboro, Georgia.
I believe the plants are actually about 20 miles from my house.
I use the Savannah River near Plant Vogtle for water skiing and swimming.
I hunt in the area surrounding my residence.
My family and I obtain drinking water from a ground well on the property.
2.
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I am a member of Campaign for a Prosperous Georgia (CPG).
I am aware of CPG's petition for Leave to Intervene in this application to obtain an operating license for Plant Vogtle.
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am concerned about. potential health, safety and environmental problems related to the operation of this plant.
I authorize CPG to represent,me in this proceeding.
This affidavit is made for the purpose of satisfying the Nuclear Regulatory Commission that CPG has membership residing within fifty miles of Plant Vogtle that is concerned about the proposed operation of this plant.
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s cM As Thdmas Reynol Sworn to and subscribed before me This 95 day of
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,w Notary / Public My commission expires
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g ETED sac 3R 27 SN b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIO G h
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'ga;. ACM In The Matter of
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DOCKET NOS. 50-424
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50-425 VOGTLE ELECTRIC
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GENERATING PLANT
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facility operating
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license for Units
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1& 2 Affidavit State of Georgia )
)ss:
County of Burke
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Personally appeared before the undersigned officer, duly authorized by law to administer oaths, BENJAMIN REYNOLDS, who, after being duly sworn on oath, deposes and says as follows:
1.
I reride at Wood Valley Road, P.O.
Box 227, Waynesboro, Georgia 30030.
I reside within 50 miles of the Vogtle Electric Generating Plant located near Waynesboro, Georgia.
I believe the plants are actually'about 20 miles from my house.
I use the Savannah River near Plant Vogtle for water skiing and swimming.
I hunt in the area surrounding my residence My and I obtain drinking water from a ground well,owndh.'by family tho. city. of Tle ynesboro.
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2.
I am a member of Campaign for a Prosperous Georgia (CPG).
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am aware-of CPC*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 CPG to represent me in this proceeding.
This affidavit i's made for the purpose of satisfying the Nuclear Regulatory Commission that CPG has membership residing within fifty miles of Plant Vogtle that is concerned about the proposed operation of this plant.
DO
/t Benjarrdn Reynolds '
Sworn to and subscribed before me This
.23 day of 74 aun e u 1984.
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h NotaryPplic' wtpry Pubi c Gecera. Sats At Ler e My C mmission Empires Fcb 19.1S35 My commission expires i---
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My ncma in W.C1ciro Hicks cnd I live at 2109 Richmond Ave.
in Augusta, Georgia.
I am opposed to the issuance of an operating license for the Vogtle Nuclear plants for the fol&owing reasons:
- 1) "he facility, if completed and placed in operation will indangdr my health, as well as that of the child I hope to conceive.
- 2) Th'e plants, unnecessary to meet my need for power, if placed in the rate base of the Georgia Power Company will increase my electric rates with no commensurate improve-ment in the character of the service.
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- 3) In the event of an accident at the facility the danger to my health will be increased proportionate to the sevdr ity of the event.
- 4) The liability coverage possessed by the applicant Geor-gia Power Company is insufficient to adequately insure me
$88k35ntp ssible damages I may incur in the event of an
- 5) In view of the fact that the Vogtle Nuclear Plant is adjacent to the Savannah River Plant of the Department of Energy, the already highlevel of risk of radioactive con-contamination of the Augusta area is increased still-fur 3 ther", with no commensurate benefit to me.
I hereby designate the Campaign for a Prosperous Georgia to represent my interdsts in the proceding for an operat-ing license for the Vogtle Nuclear plants.
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UNITED STATES OF AMERICA 00CKE1E?
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HUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 84 JAN 27 All:38 In the Matter of
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0FF:;E OF SElia H Docket Nos. 50-424"ind ~5j-MEM;.'
GEORGIA POWER CO.
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g et al.
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(Vogtle Electric Generating Plant,
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Units 1 and 2)
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REQUEST FOR A HEARING IN ATLANTA For the convenience of the parties in the matter of Georgia Power Company's application for an operating license for Vogtle Electric Gersrating Plant, Units 1 and 2, petitioner Campaign for a Prosperous Georgia requests that hearings before the Atomic Safety and Licensing Board be held in Atlanta, Georgia.
The offices of Campaign for a Prosperous Georgia and its counsel are located in Atlanta as are the regional offices of the Nuclear Regulatory Commission and the offices of state agencies that might participate in the hearings as interested parties.
Respectfully submitted, AA
~ Laurie Fowler for:
Legal Environmental Assistance Foundation 1102 Healey Building /57 Forsyth St.
Atlanta, GA 30303 404-688-3299 Attorney for Petitioner Campaign for a Prosperous Georgia
UNITED STATES OF AMERICA CCtKETE NUCLEAR REGULATORY COMMISSION
'JNRC BEFORE THE ATOMIC SAFETY AND LICENSING B0 D JM 27 All :38 In the Matter of
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Q GEORGIA POWER CO.
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Docket Nos. h 2h' t 4$
et al.
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Ba.wCH
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(Vogtle Electric Generating Plant,
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Units 1 and 2)
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NOTICE OF APPEARANCE The undersigned enter a notice of appearance on behalf of Petitioner Campaign j
for a Prosperous Georgia in the matter of Georgia Power Company's application for an l
operating license for Vogtle Electric Generating Plant, Units 1 and 2.
Both Laurie Fowler and Vicki Breman are members of the State Bar of Georgia and have been admitted to practice in the Federal District Courts in Georgia and in the State Courts of Georgia.
Respectfully submitted M.
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Ne Laurie Fowler and Vicki Breman for:
Legal Environmental Assistance Foundation 1102 Healey Bldg., 57 Forsyth St.
Atlanta, GA 30303 404-688-3299 Attorneys for Petitioner Campaign for a Prosperous Georgia I
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION cc(.KETEC tsN;C BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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'84 JAN 27 E :38
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GEORGIA POWER CO.
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Docket Nos.,,50.424 and;,50-425 b
et al.
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cYckETisG'E 3G 5'if
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BRANCH (Vogtle Electric Generating Plant,
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Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that I have this day served upon the persons below named at the addresses set forth the attached Pctition to Intervene and Request for Hearing by depositing the original in the hands of the Federal Express agent in Atlanta, Georgia and the copies with the U.S. Postal Service in Atlanta this 26th day of January 1984.
Secretary of the Commission George F. Trowbridge U.S. Nuclear Regulatory Commission Shaw, Pittman, Potts and Trowbridge Attn:
Docketing & Service Section 1800 M Street NW Washington, D.C.
20555 Washington, D.C.
20036 Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 5
m [au u m A t f
4 Laurie Fowler for:
Legal Environmental Assistance Foundation 1102 Healey Building /57 Forsyth St. NW Atlanta, GA 30303 404-688-3299 l
Attorney for Petitioner Campaign for a Prosperous Georgia NOTICE FOR SERVICE Notice is hereby given pursuant to 10 CFR 2.708 that service upon Petitioner should be made at the following addresses:
Laurie Fowler & Vicki Breman Tim Johnson Legal Environmental Assistance Foundation Campaign for a Prosperous Georgia l
1102 Healey Building 175 Trinity Avenue, S.W.
l Atlanta, GA 30303 Atlanta, GA 30303 L