ML20085D848
| ML20085D848 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/26/1983 |
| From: | Jun Lee AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8307290138 | |
| Download: ML20085D848 (3) | |
Text
.
.. J M o
xy
,g' 4
2' U?
. NUCLEAR EEGULATOEY CCFMISSICN
-,y n...
jv
-1 EEFO:E THE ATC'MIC SAFE"Y AND LICENSING 30A D X
In the Matter of July 26, 1983 Metropolitan Edison Company, Et. Al Docket No. 50-289 (Three Mile Island Nuclear Station (Steam,GeneratorAmendment)
Unit No.1) i JANE LEE ET AL EESPONSE TO NEC INEVENTION EEQUIED5:NTS FO:. ADJUDICATOFY HEARING ON STEAM GE E ATOE EEPAT AMENDMENT NEC Staff alleges that Jane Lee, Eruce molholt and Norman Aamodt fail to satisfy requirements for a request to petition for a hearing on the GPU amendment for TMI, Unit -1 to permit operation using recently-repaired steam generators.
The following clearly fulfills the letter-of-the-law and therefore gives all parties in question qualifying status.
NEC Staff notes (pg 8) "7 hat Petiticner Lee has set forth, below her l
name and address in Etters, Pennsylvania which she presumably wishes to serve as her mailing address for service of pleadings.
It appears that Etters, pennsyl-l vania is within close geographical proximity to TMI-1.
Whether or not the address is also Ms. Lee's residence is_ not aptareni, from her Petition.
Petitioners Molholt and Aamodt list addresses which approach 50 miles frot the TMI-1 site."
(emphasis added) l In all intervenor correspondence for 'the past four years Lee does not i
recall a single instance where NI C Staff has indicated doubts about the veracity i
or intregrity of intervenors' addresses.
l 8307290138 830726 PDR ADOCK 05000289 G
PDR n
< }y; )
('
?
2 As NEC Staff points out (pg 6) "Be Appeal Board has ruled that the geocraphical proxicity of a petitioner's residence, standine alone, is sufficient te satisfy the interest requirements.
Virginia Electric and Power Cenpany (North Anna Nuclear Power Station, Unit's 1 and 2).
ALA3-522, 9 NiC 54, 56 (1979) a NEC Staff's challenge on the validity of Petioner Lee's address after five years of consistent correspondence and service list cailings with the NFC, appears unseej::ly and leaves qtialification debates on a nit-picking level, Not only does this demean the intent and purpose of the Atomic Safety Licensing Board, but it pursues a time-consuning endeavor that is unworthy of the. Staff and that unnecessarily prolongs the licensing Board's decision-making process.
Lee reiterates, for the record, that her address is and has been for the past ten years: 183 Valley Ed., Etters, PA,17319...formerly F.D.#1, Etters, Pa., 173?9 (same residence).
This residence is located three and one-half miles North-West of Three Mile Island.
Bis residence is the site of a dairy operation which includes goats, geese, a dairy herd of approximately 75 to 85 head, 30 cats and two dogs.
hence, our interest in operating a nuclear plant that has incurred steam generator dwage that will release radioactive material and ultimately create a health hazard to the animals, the reproductive cystem in picular, and to our own health.
As NEC Staff has clearly shown, Petitioner Lee is fully' qualified to petition the Licensing 3 card on any litigable subject applicable to TMI Unit-1 reauest er Unit 11 and therefore, we request that NEC Staff's denial /of Lee,Molholt, and Aamodt petition be rejected by the Board and that Jane Lee, Bruce Molholt and Norman Aamodt be given full petition status to intervene in connection with a request by GFU Nuclear Corp. for an amendment to the license of TMI Unit-1 to permit operation using recently-repaired steam generators.
F espe etfully'subnitted.
JANE LEE
'L
/#%
!M Valley had
, fan / //[e Lee rrrtRS. PA 17319
(
r
/
3 CEF.TIFICATE OF E VICE Sheldon J. Wolfe, Chainan Docketing & Service Adninistrative Judge Office of the Secretarv Atomic safety & Licensing Board Panel U.S. Nuclear Eegulatory Commission U.S. Nuclear Regulatory Com.
Washington, DC 20555 Washington,, D.C.
20555 Dr. James C. Lambe, III Administrative Judge Atomic Safety & Licensing Appeal repartment of Environmental Sciences Board Panel and Engineering U.S. Nucle'ar Fegulatory Comm.
University of North Carolina
'/ashington, DC 20555 Chapel Hill, North Carolina 27524 Dr. David L. Hetrick Administrative Judge Department of Nuclear Engineerir4 University of Arizona -
Tuscon, Arizona 85721 George F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.
Washington, DC 20036 Nuclear Regulatory Commission 1717 H. Street, N.W.
Washington, D.C.
20555 Three Mile Island Alert 1011 Creen St:eet Harrisburg, PA Mr. Bruce Molholt Haverford College Haverford, PA 19041 NoI=an & Marjorie Aamodt E.D. 5, Box 428 Coatesville, PA 19320
/
N4f/,
Vi_
July 26, 1983 Jane Lee JANE LEE 183 Vallev Road ETTERS PA 17319