Declaration of Ws Lesan.* Declaration Expresses Concern Re Duke Power Co Application for Renewal of License for Oconee Nuclear Station,Units 1,2 & 3.Application Inadequate to Protect from Unacceptable Risk of Radiological AccidentsML20155F495 |
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Oconee |
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10/30/1998 |
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Lesan W AFFILIATION NOT ASSIGNED |
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ML20155F482 |
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LR, NUDOCS 9811060047 |
Download: ML20155F495 (2) |
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Category:AFFIDAVITS
MONTHYEARML20196E0191998-11-30030 November 1998 Affidavit.* Affidavit of Dp Cleary in Response to Licensing Board Questions Re Environ Impacts of Transportation of High Level Waste.With Certificate of Svc ML20155F4951998-10-30030 October 1998 Declaration of Ws Lesan.* Declaration Expresses Concern Re Duke Power Co Application for Renewal of License for Oconee Nuclear Station,Units 1,2 & 3.Application Inadequate to Protect from Unacceptable Risk of Radiological Accidents ML20155F5041998-10-30030 October 1998 Declaration of N Williams.* Declaration Expresses Concerns Re Duke Power Co Application for License Renewal for Oconee Nuclear Station,Units 1,2 & 3.Application Inadequate to Protect from Unacceptable Risk of Radiological Accidents ML19312B8171978-03-15015 March 1978 Statement of Util as to Available Sources of Funds to Satisfy Possible Liability Not Exceeding $30 Million ML19317E6341973-09-30030 September 1973 Affidavit of Tk Golden on 730930 Re Production of EPIC Subpoenaed Documents Listed in App A,Item 11 of Util 730516 Statement.Documents Not Yet Received.Certificates of Svc Encl ML19322B9121973-06-18018 June 1973 Affidavit of Sh Smith on 730618 Re Extent of Document Review Performed by Util ML19312C5701973-06-15015 June 1973 Affidavit of s Ragone on 730615 Re Extent of Document Review Performed by Util ML19317E5391973-04-12012 April 1973 Affidavit of s Ragone on 730412 Re 730322 Order & Supporting Motion to Quash or Limit 721120 Subpoena ML19317E7581973-04-11011 April 1973 Affidavit of Jh Fowles on 730411 Re Issuance of Subpoena Duces Tecum to Sc Electric & Gas Co.Certificate of Svc Encl 1998-11-30
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20211A1801999-08-16016 August 1999 Forwards Comments on Draft Geig Re NUREG-1437 ML20205M8401999-04-15015 April 1999 Memorandum & Order.* Orders That Petitioner Appeal of Board Ruling Be Denied.Commission Affirms LBP-98-33 in Entirety. with Certificate of Svc.Served on 990415 ML20199K8101999-01-25025 January 1999 Duke Energy Corp Brief in Opposition to Appeal of Chattooga River Watershed Coalition.* Informs That Licensing Board Decision in LBP-98-33 Should Be Affirmed.With Certificate of Svc ML20199K8231999-01-25025 January 1999 NRC Brief in Opposition to Appeal of Nb Williams,Wb Clay, Ws Lesan & Chattooga River Watershed Coalition.* Licensing Board Decision in LBP-98-33 Should Be Affirmed.With Certificate of Svc ML20199D7021999-01-14014 January 1999 Notice of Appeal.* Chattooga River Watershed Coalition Files Notice of Appeal to Commission for Review of ASLB 981230 Memorandum & Order Denying Petitioner Petition for Leave to Intervene ML20199D7241999-01-14014 January 1999 Chattooga River Watershed Coalition Brief in Support of Appeal of Order Denying Intervention Petition & Dismissing Proceeding.* Commission Should Grant Petition for Review & Remand ASLB Memorandum & Order ML20198K9911998-12-29029 December 1998 Memorandum & Order (Denying Petition to Intervene).* Denies Petitioners Requests for Intervention Because Proffered Contentions Failed to Meet Requirements for Admissability. with Certificate of Svc.Served on 981230 ML20198D2601998-12-22022 December 1998 NRC Staff Response to Petitioners New Info.* Informs That Info Provided by Petitioners Not New & Does Not Support Proposed Contentions.Recommends Proposed Contentions Be Dismissed & Proceeding Terminated.With Certificate of Svc ML20198D2191998-12-21021 December 1998 Duke Energy Corp Response to New Info Submitted by Chattooga River Watershed Coalition in Support of Processed Contentions.* Petitioner Submittal of New Info Should Be Stricken for Procedural Reasons.With Certificate of Svc ML20197J9201998-12-14014 December 1998 Order (Requests by Staff & Applicant to File Responses). Motions of 981211 Re Applicant & Staff Request for Leave to Respond to Petitioner Filing of 981209 Granted.With Certificate of Svc.Served on 981214 ML20197J9441998-12-11011 December 1998 NRC Staff Motion for Leave to Respond to Petitioner Filing.* Staff Requests Leave from Board to Respond to Info.Staff Will File Response within 3 Days After Board Order Issued,If Board Grants Request.With Certificate of Svc ML20197K1131998-12-11011 December 1998 Duke Energy Corp Motion for Leave to Respond to New Info Submitted by Chattooga River Watershed Coalition.* Requests Leave to Respond to Petitioners New Info Based on Listed Grounds.With Certificate of Svc ML20196J9051998-12-0909 December 1998 Response of Duke Energy Corp to Licensing Board Order Requesting Info Concerning high-level Radioactive Waste Transportation Rulemaking.* Util Requests That Board Certify Question Immediately.With Certificate of Svc ML20197J8691998-12-0909 December 1998 Petitioners Response to ASLB Request for Addl Info & New Info for ASLB to Consider with Petitioners First Suppl Filing.* Response Filed on Behalf of Ws Lesan,B Clay, B Williams & Chattooga River Watershed Coalition ML20196E0091998-12-0202 December 1998 NRC Staff Response to Order Requesting Information.* in Staff View,Impacts of Transportation of HLW Not Appropriate Issue for Litigation in This Proceeding ML20196E0191998-11-30030 November 1998 Affidavit.* Affidavit of Dp Cleary in Response to Licensing Board Questions Re Environ Impacts of Transportation of High Level Waste.With Certificate of Svc ML20195G5621998-11-19019 November 1998 Order (Requesting Addl Info from Staff).* Based on Directives in SRM M970612,staff Should Furnish Listed Info by 981202.Applicant & Petitioners Have Until 981209 to File Response.With Certificate of Svc.Served on 981119 ML20195D5281998-11-16016 November 1998 Response of Duke Energy Corp to Supplemental Petition to Intervene Filed by Chattooga River Watershed Coalition & Nb Williams,Wb Clay & Ws Lesan.* Request for Hearing Should Be Denied for Reasons Stated.With Certificate of Svc ML20195C1601998-11-16016 November 1998 NRC Staff Response to Petitioner First Supplemental Filing.* Petitioners Failed to Submit Admissible Contention.Iaw 10CFR2.714,petition Should Be Denied & Petitioners Request for Stay Should Be Denied.With Certificate of Svc ML20155F5041998-10-30030 October 1998 Declaration of N Williams.* Declaration Expresses Concerns Re Duke Power Co Application for License Renewal for Oconee Nuclear Station,Units 1,2 & 3.Application Inadequate to Protect from Unacceptable Risk of Radiological Accidents ML20155F4791998-10-30030 October 1998 Petitioners First Supplemental Filing.* Petitioners Request That Chattooga River Watershed Coalition Be Admitted as Party to These Proceedings & That Contentions Be Admitted for Adjudication.Unsigned Declaration for Wb Clay Encl ML20155F4951998-10-30030 October 1998 Declaration of Ws Lesan.* Declaration Expresses Concern Re Duke Power Co Application for Renewal of License for Oconee Nuclear Station,Units 1,2 & 3.Application Inadequate to Protect from Unacceptable Risk of Radiological Accidents ML20154H0771998-10-0909 October 1998 NRC Staff Answer to Petition for Leave to Intervene Filed by N Williams,W Clay,Ws Lesan & Chattooga River Watershed Coalition.Petition Should Be Denied for Listed Reasons. with Certificate of Svc ML20154A9371998-10-0101 October 1998 Order (Ruling on Request for Extension of Time).* Motion for 30-day Extension to File Amended Petition to Intervene Denied.Petitioners Have Addl 11 Days Until 981030 to File Suppl to Petition.With Certificate of Svc.Served on 981002 ML20154A0401998-09-30030 September 1998 Response of Duke Energy Corp to Request for Enlargement of Time of Chattooga River Watershed Coalition & Messrs, N Williams,W Clay & Ws Lesan.* Petitioner Request Should Be Denied for Listed Reasons.With Certificate of Svc ML20153H4191998-09-29029 September 1998 NRC Staff Response to Motion for Enlargement of Time Filed by N Williams,W Clay,W Lesan & Chattooga River Watershed Coalition.* Petitioners Failed to Establish Sufficient Cause for Delaying Submission of Amends.With Certificate of Svc ML20153F3131998-09-25025 September 1998 Notice of Appearance.* Informs That ML Zobler,Rm Weisman & Je Moore Will Enter Appearances in Proceeding Re Duke Energy Corp.With Certificate of Svc ML20153H0801998-09-22022 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Potassium (Ki) as Protective Action During Severe Reactor Accidents. Emergency Plan Calls for Evacuation of Population of EPZ in Timely Fashion to Prevent Exposure to Radiation from Oconee ML20151Z7051998-09-18018 September 1998 Memorandum & Order.* Applicant & Staff Shall File Respective Answers After Petitioners File Any Amend to Intervention Petition.Answers Shall Be Filed IAW Schedule as Submitted. with Certificate of Svc.Served on 980918 ML20151Z5681998-09-18018 September 1998 Notice of Reconstitution of Board.* Provides Notification of Reconstitution by Appointing P Cotter as Board Chairman in Place of T Moore in Duke Energy Corp Proceeding.With Certificate of Svc.Served on 980918 ML20151X9911998-09-16016 September 1998 Establishment of Atomic Safety & Licensing Board.* Board Being Established in Proceeding Re Application by DPC to Renew Operating Licenses for Units 1,2 & 3,per 10CFR54.With Certificate of Svc.Served on 980917 ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20044G7371993-05-25025 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20101R5931992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Opposes Rule ML20070E6291991-02-28028 February 1991 Comment Opposing Petition for Rulemaking PRM-73-9 Re Regulations to Upgrade Design Basis Threat for Radiological Sabotage of Nuclear Reactors ML20215D6741987-06-12012 June 1987 Suppl 4 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.Ucs Reply to Responses from NRC & B&W Owners Group.* Certificate of Svc Encl ML20210C4191987-04-0606 April 1987 Principal Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Petition Should Be Denied ML20205F2911987-03-23023 March 1987 Suppl 3 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Requests That Listed Names Be Added to List in Paragraph 1 of 870210 Petition ML20210C2691987-03-0606 March 1987 Initial Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Request for Immediate Suspension Should Be Summarily Denied.W/Certificate of Svc ML20211F5091987-02-20020 February 1987 Suppl 2 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Lists Names to Be Added to 870210 Petition & Corrects Address for Save Our State from Radwaste ML20210N4861987-02-10010 February 1987 Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W Co.* OLs & CPs for Facilities Should Be Suspended Until Listed NRC Actions Taken DD-85-19, Order Extending Time Until 860303 for Commission to Review Director'S Decision DD-85-19.Served on 8602201986-02-19019 February 1986 Order Extending Time Until 860303 for Commission to Review Director'S Decision DD-85-19.Served on 860220 ML20137L5911985-09-10010 September 1985 Response Opposing Jf Doherty 850611 Petition for Show Cause Order Requesting NRC to Institute Consolidated Proceeding Per 10CFR2.202.Certificate of Svc Encl ML20126A3531985-06-11011 June 1985 Petition/Request for Order to Show Cause Why Plants Should Not Be Shut Down Until CRD Mechanisms Inspected ML20067B2391982-12-0202 December 1982 Response to Interrogatories & Document Requests Re Commission Questions 2 & 5.Related Correspondence ML15219A0471980-04-28028 April 1980 Statement of Board of Commissioners' Position in Opposition to Radwaste Transportation Through Gaston County,Nc.Urges Transportation Via Interstates 77 & 85.Encourages Expending Energy & Money for Recycling.W/Correspondence ML19259C4811979-05-10010 May 1979 Ucs Petition for Immediate Reconsideration of Errors in Commission 790508 Order & for Immediate Shutdown of Oconee Units 1 & 2 ML19312B8171978-03-15015 March 1978 Statement of Util as to Available Sources of Funds to Satisfy Possible Liability Not Exceeding $30 Million ML19317E0201977-12-20020 December 1977 Endorsement 8 to Nelia Policy NF-248 ML19317D2511977-08-19019 August 1977 Petition for Rulemaking by Wi Electric Power Co,Wi Public Svc Corp & Bg&E Requesting Amend of 10CFR73.55(d)(1) Re Access & Physical Searches 1999-08-16
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.b UNITED STATES OF AMERICA ;
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1
l In the Matter of )
)
DUKE ENERGY CORPORATION )
) Docket Nos. 50-269-LR Oconce Nuclear Stat on, ) 50-270-LR Unit Nos. I,2, and 1) ) 50-287-LR DECLARATION of WILLIAM STEVEN LESAN I declare under the pains and penalty of perjury, and hereby affirm that to the best of my knowledge arxi belief, the following is true and correct:
- 1. My name is William Steven ("W. S.") Ixsan.
- 2. I own property and reside at 190 Daffodil Hill, Mountain Rest. South Carolina 29664. Said property is within 20 miles of Oconce Nuclear Station Units 1,2 and 3.
- 3. I am a member in good standing of the Chattooga River Watershed Coalition, Inc. (CRWC), and 1 volunteer my seniccs to contribute the CRWC's mission "To protect. promote and restore the natural ecological integrity of the Chattooga River watershed ecosystem; to ensure the viability of native species in harmony with the need for a healthy human emironment; and, to educate and empou er communitics to practice good stewardship on public and private lands." In addition, I also volunteer my senices to contribute to the CRWC's stated goals, two of which are directly applicable to these proceedings and are: " Educate the public " and " Promote public choice based on credible scientific information." I frequently visit the Chattooga River Watershed Coalition office, which is located in Clayton, Georgia, and is within 30 miles of the Oconce Nuclear Station.
- 4. My family and I live, work, recreate and travel to areas within 20 miles of Oconce Nuclear Station Units I,2 and 3. We also breathe the air, drink water and cat food produced within 20 miles of Oconee Nuclear Station Units I,2 and 3. Our food sources. air and water would be adversely afTected by normal and accidental releasts of radioactive materials during the proposed extended operation of the Oconce Nuclear Station Units I,2 and 3.
- 5. I believe that significant issues remain unresolved to the public, the Nuclear Regulatory Commission (NRC).
and Duke Powcr Company, in Duke's application to renew the opemting liense for Oconce Nuclear Station Units 1,2 and 3. Thus. the application is inadequate to protect me and my family from the unacceptable risk of a radiological accident at the facility during the proposed renewal tenu. My concern is based on my knowledge that the Nuclear Regulatory Commission stafT has responded to Duke Powes's application by requesting additional information concerning the structural integrity of the reactor sessel and containment buildings, and other critical components of the facility which are pivotal in detennining whether the facility can be safely operated now, and through the extended renewal term for Oconce Nuclear Station Units I,2 and 3. In addition, to my knowledge there air other significant issues that are unresohrd in Duke Power Company's application to renew the operating license for Oconce Nuclear Station Units I 2 and 3, specifically: the effects of aging and embrittlement of the Oconec Nuclear Station's reactor vessels and containment vessels; the status and capacity of the current storage facility for spent fuel and other radioactive substances on the site of the Oconce Nuclear Station; the potential need to design and expand aforementioned storage facilitics to accommodate extended operation of Units I,2 and 3 of the Oconce Nuclear Station; transport of radioactive materials to other locations if and when storage capacity is exceeded; the real and potential availability and viability of other storage sites; specific safeguards to dctcct terronst actions, and plans and measures to defend against terrorist attacks; and, the structural integrity of Units 1,2 and 3 of the Oconce Nuclear Station to withstand tornadoes. and carthquakes of the magnitude possible due to the nuclear station's proximity to the Brevard Fault. In addition, I belicyc that the 9811060047 981030 PDR ADOCK 05000269 G PDR
es'.ablished timeline of these proceedings presents a totally inadequate window of opportunity for members of Qc CRWC and the public at large to gain an adequate understanding of, expertisc on, and legal standing for the particular issues named above. Thus. I am concerned that me:mingful public participation is not possible in the ongoing hcense renewal proceedings. because the pubhc scoping meeting for the renewal application was held well afici the 6.auunes for obtaining legal standing in the proceedings
- 6. I belicyc that if the Oconce Nuclear Station Units I,2 and 3 has a major radiological accident during current and/or extended operation, myself and all of my family members could suffer severe illness and/or dic, and my safety, property rights and personal finances, and those of my family could be adversely affected by the NRC granting Duke Power's application for license renewal of Oconce Nuclear Station Units I,2 and 3 for an additional 20 cars.
3 if the plant cannot be safely operated for the full 20 year term of the renewal. Based on my knowledge of the aforementioned re-licensing proceedings, I have a reasonabic fear that the Oconce Nuclear Station Units I,2 and 3 may not be safely operated for the full 20 year tenn of the renewal.
- 7. I believe that if the Oconce Nuclear Station Units I,2 and 3 has a major radiological accident during cunent and/or extended operation, the staff members uorking for the CRWC may suffer severe illness and/or die, and the ability of the CRWC to function would be destroyed, thus preventing the CRWC pursuing the organization's mission and from advocating my interests in a cleaner and healthier environment. In addition, if the Oconce Nuclear Station Units 1, 2 and 3 has a major radiological accident during current and/or extended operation, the l flora, fauna, air, and aquatic resources of the Chattooga River ccosystem would be irretrievably danuged and/or destroyed. The entire 180,000 acre Chattooga River watershed lies within 40 miles of the Oconce Nuclear !
Station; approxinutely 90% of the Chattooga River watershed lies within 30 miles of the nuclear facility, with the closest point in the watershed located at 15 miles from the Oconce Nuclear Station. (I noted these mileage figures from the nup included in Volume 2 of the Oconce Nuclear Station's Final Safety Analysis Report.)
- 8. ! Sv lies e that if the Oconce Nuclear Station Units 1, 2 and 3 has a major radiological accident during current and/or extended operation, the flora, fauru, air, and aquatic resources of the Chattooga River ecosystem would be irretrievably damaged and/or destro3cd. Thus, an accidcat would adversely affect the quality of my emironment and my enjoyment of my natural surroundings.
- 9. I hereby authonze the CRWC to represent all of my interests pertaining to the Oconce Nuclear Station re-licensing matter. Should the CRWC not be granted standing to represent my interests ! hereby request permission to represent my own interests before the NRC. and participate in this proceeding in my individual capacity.
f- . 50 /f f f flWilliaiit StevenWSNLesfin~' ~ Dated 2