ML20154B942

Amends Chattooga River Watershed Coalition Petition to Intervene in Proceedings Re Application of Duke Energy Corp to Renew OLs for Oconee Nuclear Station,Units 1,2 & 3

ML20154B942
Person / Time
Site:	Oconee
Issue date:	09/30/1998
From:	Williams B AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel, NRC OFFICE OF COMMISSION APPELLATE ADJUDICATION (OCAA), NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#498-19600 LR, NUDOCS 9810060063
Download: ML20154B942 (2)

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, .? USNRC 4 . .! c - 98 DCT -5 P1 :35 i Chawoga Rher Watershed Coa}#ipn ( se a w R O.16 2006 o Clayan, GA 30525 (([y [cp (706) 782 6097 o F.u (706) 782 6098 ,

crwc@ acme brain.com ATTN: j Atomic Safety and Licensing Board, Administrative Judges l

Office of Commission Appellate Adjudication  ;

Office of Commission, Rulemakings and Adjudications Staff I US NRC counsel l US NRC Atomic Safety and Licensing Board members i Duke Energy Corporation attorneys September 30,1998 I l

Dear Sir / Madam. I i

Pursuant to our petition to intervene in the proceedings regarding the application of Duke Energy Corporation to l renew the operating license for Units 1,2 and 3 of the Oconee Nuclear Station (Docket Nos. 50-269,50-270 and 50- l 287), the Chattooga River Watershed Coalition, Norman "Buz2" Williams, William " Butch" Clay and W.S. lesan l hereby submit the following specific subjects as amendments to said petition to inten ene. We respectfully submit I these specific subjects to meet the requirements of 10 C.F.R. 2.714 (a)(2) and other applicable laws. l

1. We submit that the proceedings regarding Duke Energy Corporation's application to renew the operating license I for Units 1. 2 and 3 of the Oconce Nuclear Station (Docket Nos. 50-269,50-270 and 50-287), and the subsequent handling of this request by the US Nuclear Regulatory Commission (NRC) fail to fully comply with the letter and intent of the National Emironmental Policy Act (NEPA), and the Administrative Procedures Act, as follows. We submit that the expedited nature of these proceedings, where petitions to intentne are numdated before any opportunity is available for citizens to participate in public meetings, fails to comply with the letter and intent of NEPA. and furthermore, indicate arbitrary and capricious actions by the NRC. It is common knowledge that through the forum of public meetings, citizens obtain much educational information and Imr the opportunity to j become cognizant of and vettalize issues of local, regional and national scope that could merit legal standmg for l future action. It is also common knowledge that citizens do not read the Federal Register as a matter of course; thus, the vast majority of the public is totally unaware of the rigid timeline of these proceedings, and most importantly, the slim window of opportunity to gain expertise on and legal standmg for certain issues. In addition, as a result of I the aforementioned deficiencies, we hold that an adequate range of germane issues are in the process of being l excluded from consideration. meamngful analysis, and subsequent treatment.

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2. We submit that the specific issue of embrittlement of the Oconce Nuclear Station's containment sessels must be addressed in these proceedings. We hold that rigorous scientific investigations are timely and necessary, and all findings must be acted upon as well as made public. Common sense dictates that questions concerning embrittlement as well as other issues and factors d.irectly related to the aging of the Oconce Nuclear Station must be addressed before re-licensing of the facility can be considered. This is an issue of full disclosure of cumulative effects, and reasonably foreseeable potential risks and impacts to the human and natural emironment, public safety, and the public's right to know. We submit that the above issues are included in the scope of NEPA. and the Administrative Procedures Act.

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3. We submit that the specific issue of the storage of spent fuel and other radioactive substances on the site of the Oconce Nuclear Station must be addressed in these proceedings. Directly related specific issues also include: the status and capacity of the current storage facility; the potential need to design and expand storage facilitics to accommodate extended operation of Units 1. 2 and 3 of the Oconce Nuclear Station; specific safeguards to detect and plans defend against terrorist actions; transport of radioactive materials to other locations if and when storage capacity is exceeded, and, the real and potential availability and viability of other storage sites. We submit that the above issues are included in the scope of NEPA, and the Administrative Procedures Act.

i We appreciate your attention to giving due consideration to these important, specific issues. We are aware tint the NRC is responding to pressure and directions from Members of Congress, and industry. %c intent of this communication is to be cordial, and finn.

i Note: The Chattooga River Watershed Coalition is a small, non-profit organization engaged in many activitics that were ongoing before the schedule of these proceedings were listed in the Federal Register, and subsequent memorandums and orders. The limitations of the Chattooga River Watershed Coalition, as well as the scope our .

ongoing programs and presious commitments is such that the organization has had neither adequate notice nor funds availabic to retain counsel at this date. In addition, the citizens named in the petition to inten'ene (Norman " Buzz" Wilhams, William " Butch" Clay and W, S. Lesan) are all engaged in full time jobs with limited incomes, and thus also have had neither adequate notice nor funds available to retain counsci at this date. Thus, the petition and these amendments have been submined in a good faith effort to serve the public and to comply with all applicable laws and other directives.

Sincerely, ,

Buzz Williams h p)

Chanooga River Watershed Coalition Butch Clay W.S. Lesan Note: This request was sent via email to all parties involved with this proceeding, and via US Postal Senice, first class, to the same.

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