ML19253B344

Suppl to Petition to Intervene Per ASLB Order.Applicant Failed to Meet Environ & Safety Aspect Requirements,Failed to Consider Alternative Sources of Energy & Other Pertinent Factors & Did Not Demonstrate Financial Qualifications

ML19253B344
Person / Time
Site:	05000599, 05000600
Issue date:	09/10/1979
From:	IOWA SOCIALIST PARTY
To:
References
NUDOCS 7910150344
Download: ML19253B344 (1)

Text

UNITED STATES OF AMERICA LOWS Socialist NUCLEAR REGULATORY COMMISSION g~4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gy ,

8- O -2 Nd cg In the Matter of )  ; '

COMMONWEALTH EDISON COMPANY,-

Docket Nos. L (p%$ [* &

et al. -

TCarroll County Site) 550-599 PA.RTY 550-600 yj _ _

0 PETITION FOR LEAVE TO, INTERVENE SUPPLEMENT 10, In accordance with the order of the Atomic Safety and Licensing Board in the above captioned matter, the Iowa Socialist Party hereby enter a statement of their contentions with supporting basis for each.

1. In their Site Safety Report, the applicants have not demonstrated all the safety and environmental aspects of the site have been adequately met under the requirements of 10 CFR and the National Environmental Policy Act, in that:

a. adverse effects on land use patterns in the area have not all been fully con-sidered and detailed, such as, (i) lack of safe and adequate roads in the site area for transportation to and from the site and for evacuation in the event of an on-site accident.

(ii) failure to adequately consider geological characteristics of the area such as the Plum River Fault.

b. the economy of the area would be negatively impacted to a greater degree than described by the applicants, for example, 1) ii) greater loss in proverty values than described. greater loss in producti iii) greater impact on the local housing market than described.

c. the siting of the plant would increase than likelihood of adverse effects on comunity characteristics of the area, for example, (1) an increase in the likelihood of disease from low-level radiation effects would increase migration from the area.

(ii) people would move " rom the area in fear of an accident.

d. adverse effects on crops, livestock, and other vegation nav'e not all been full considered and detailed, such as, (1) loss of productive capacity from low-level radiation.

(ii) risk of contamination in case of an accident.

2. The applicants have failed to meet the requirements of 10 CFR Part 51,10 CFR Part 2, and the National Environmental Policy Act in their forecast for the need for power in the area and that the plant will supply by failing to consider fully the impact of conserva tion, alternative sources of energy and other factors decreasing demand.

3. The applicants have failed to show why the early site review should be approved at this time when,

a. the future of commercial nuclear power is being debated in the political arena

b. the full impact of the Three Mile Island Unit 2 accident has not been studied.

c. the applicants have failed to show they are financially qualified to construct the facility.

d. the applicants have failed to meet the requirements of the National Environmen al Policy Act in not allowing full consideration and hearing on all factors, since some of these arise out of the construction permit process.

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