ML20140B595

Petition to Intervene in Proceeding.Affidavits Encl

ML20140B595
Person / Time
Site:	Limerick
Issue date:	09/03/1981
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	NRC COMMISSION (OCM)
References
NUDOCS 8109140257
Download: ML20140B595 (8)

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, /f 'WP g,E UNITED STATES OF AMERICA '.UCLEAR RECULATORY COMMISSION 2 - g $N # 1 M

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In the matter of  : Docket Nos.J A C# x.h

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PHILADELPHIA ELECTRIC COMPANY LIMERICK CENERATING STATION 50-353

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PETITION FOR INTERVENTI0M

h. u,,'Wlyron V3 As a citizen and property owner living within 2 es of the Lime ck

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Reactor Site, I, Prank R. Romano, on behalf of myself, an , , and as Chairman of the Airfand Water Pollution Patrol, on its behalf, and on behalf of its members and supporting individuals and environmental organizations concerned with the adverse effects of nuclear reactor operation, I hereby petition the Nuclear Regulatory Commision for leave to intervene in Operat-ing License Proceeding pursuant to Sec. 2.714 of the Nuclear Regulatory Comm-ission's rule of practive, and state:

I IDENTIFICATION OF PETITIONER AND INTERESTS TO BE AFFECTED Frank R. Romano is a U.S. citizen, address 61 Forest Ave., Ambler, Pa.(Mont-gomery Co.), with property owned within 10 miles of the Limerick Generating Station in Limerick Township, Montgomery County, Pt..

The AW1.'P is a Pennsylvania incorporated association, incorporated in 1971 and open to all citizens, in particular anyone of the approximately seven million people who live within thirty miles of the proposed Limerick Generating station.

The purpose of the AWP is to concern itself with threatening or potent-ially threatening discharges from any source or origin, as it may affect the health and welfare of people and the environment, directly or indirectly.

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(2) l*

(Petitlen for intervantion cont.)

As it-relates to this petition to intervane,- i'n particular, we want to prevent the adverte community imuact which the Limerick Generating Station I

will have on our lives, our peace of mind, our homes, our land, our water and the produce of out land and water. From the Three tule Island accident re-I sulting from actions based on calculations which now have been proved as de-rived with inadequate and erroneous assurance that such an accident would not take place, we particularly want to avoid the resulting conditions thrust upon 4

the people of the Three Mile Island area, namely, violation of property,. econ-omic damage, bodily danger, psychological stress, and denial of the right to vote on whether they must endure the continued threat to thiir lives.

Inasmuch as significant and major changes in reactor construction, oper-ation, performance, and, in particular safety provisions for the public have not been made as a result of the Three Mile Island on-going experience, we, as j a group, in concert with other groups having the same concern for the hazzard-1 ous releases from routing nuclear fissioning reactions as in the process to i

be used at the Limerick Generating Station...together with the likely, and 1

_ more unacceptable hazzards of huge and highly radioactive releases from a nuc-lear accident, petition there be a public hearing at which our group can express our constitutional right of self preservation in opposing the timerick Gener-ating Station operation. In total the AWWF asserts that the operation of the Limerick Generating Station adversly affects every important aspect of the lives I

of our members if the Nuclear Regularpry Commission issues an operating license to Philadelphia Electric to operate the Limerick Generating Station.

The parameters which ANWP feels will insure unnecessary and adverse effect on the lives and the environment of its members and supporters are listed as

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contentionable subject areas set forth below. We have attached'affadavids of several members to further document our standing. These individuals reside and/or own property within twenty miles from the reactor site.

(3)

(Patition for intervcntion cont.)

STATDU2Tr OF CONTENTIONS I and the AWWP contend that part or all the adverse effects, beginning with the initial operation of the Limerick Generating Station; sometime af ter initial operation; af ter an accident that car. come at any time, adverse effects innediatedly, on-going and for many years, to life spans, and even many life spans will derive through the involvement of one or more of the foll-owing areas:

(A) Normal routine radioactive releases, as well as accident related re-leases contaminating the simylkul River, the drinking water source, or con-tributory water source for vast areas of Montgomery County and Philadelphia downstream from the Linerick Generating Station involving upwards of three million people.

(B) Because of Three Mile Island experience there musc be new all around considerations, added to considerations in deficiencies in previously approved nethods of construction and operation, together with erroneous population safety calculations. Safety considerations such as workable evacuation, concern for terrorist attack from air or otherwise, or sabatoge from within.

(C) Above average accident potential for Limerick Generating Station.

(1) Site selection , & cooling water.

(2) Construction problens (3) Ouarry blasting (4) Fractures and faults (5) NRC,Bechtel, Philadelphia Electric relationship (D) Ruin of Agricultural industry of four agricultural counties surround-ing the Linerick Generating Station.

(1) Cooling tower plume releases (2) Weather modification (3) Psychological factors I (4) Stagnant air concentrating effects.

(4)

(patiticn fer intarvIntien cent.)

e (E) NRC and statq and federal ruline,s since TMI 1r. crease rather than diminish probability of an accident at Linerick. Generating Station.

(F) Questions relating to constitutional rights.

Petitioner asserts our members have significant physical, mental, econ-onic, and constitutional stakes in the outcome of this proceeding. Therefore Petitioner requests right to full participation in order to insure democratic fairness to our members and supporters, as well as to insure completeness of the hearing record.

Respectfully submitted, AIR & WATER POLLUTI PATROL q N

Frank R. Romano, Cliairman September 3, 1981 Sworn and subscribed fefore me this_,M day of September, 1981

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AIR and WATER Pollution Patrol BROAD AXE,PA.

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.2 [- t,U AA A[lO S'I' kM N(t:N /k,asame=berofthe Air and Vlater Pollution Patrol, living within h miles of the Limerick Reactor site gives permission for Frank R. Romano, Chairman of the Air and Viater Pollution Patrol to represent me in any and all matters concerning interven- I tion in the urcoming_, operating license hearings with the Nuclear Regulatory Commission, relative to the Limerick Nuclear Generating Station as it may affect the health and welfare-of the above mentioned group, and the health and welfare of my family. M ,o

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Signed V 4 ( 'N#"e Date  ? '

Sworn and subscribed before me this 3W day of Sept., 1981

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AIR and WATER Pollution Patrol!

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River water supplied to my home and family, gives permission for Frank R. Romano, Chairman of the Pennsylvania Air and Water Pollution Patrol, to represent me in any and all matters inparticular intervention in the upcoming operating license hearings with the Nuclear Regulartcry Commission, relative to the Limerick Nuclear Reactor Generating Station as it may affect the health and welfare of 'we members of the above men-tioned group, anci the health and welfare of ray family.

Signed

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Sworn to and Subscribed Before me this ld day of h y b k ,1981 fa~1bZ424wE5v

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AIR and WATER' Pollution Patrol BROAD AX2, PA.

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~ib't c%c5 ressdThg at SVOfdch5/Am4 df , and who has schuy1x111 River water supplied to my and family, gives permission for Frank R. Romano, Chairman of the Pennsylvania Air and Water Pollution Patrol, to represent me in any and all matters inparticular intervention in the upcoming operating license hearings with the Nuclear Regulartory Commission, relative to the Limerick Nuclear Reactor Generating Station as it may affect the health and welfare of we members of the above men-tioned group, and the health and welfare of my family.

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Sworn to and Subscribed Belore me this j$. day of O2j, wv W ,1981.

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O AIR and WATER Pollution Patrel BROAD AXE, PA.

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Air and ?later Pollution Patrol, livin6 within A o miles of the Limerick Reat'or site gives permission for Frank R.

Romano, Chairman of the Air and Water Pollution Patrol to represent me in any and all matters concerning intervention in it.e upcoming operating license hearings viith the Nuclear Regulatory Commission, relative to the Limerick Nuclear Generating Station as it may affect the health and welfare of the above mentioned group, and the health and welfar j my family. e ' '

Signed /' 4 -

Q Date Sworn and subscribed before me this 4 day of Sept., 1981

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