ML19309F601

Supplemental Statement Re Standing.Contends That Members of United Steel Workers of America Local 1010 Are Users of in Dunes Natl Lakeshore in Which Site Dewatering Will Take Place Due to Const.W/Affidavit & Certificate of Svc

ML19309F601
Person / Time
Site:	Bailly
Issue date:	03/26/1980
From:	Frantz J UNITED STEELWORKERS OF AMERICA
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8004300133
Download: ML19309F601 (1)

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800.4300133

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UNITED STATES OF AMERICA fES NUCLEAR REGULATORY COMMISSION

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March 26, 1980 IN THE MATTER.0F: )

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NORTHERN INDIANA PUBLIC ) DOCKET No. 50-367 SERVICE COMPANY (Bailly )

Generating Station, )

Nuclear-1) )

SUPPLEMENTAL STATEMENT TO ATOMIC SAFETY AND LICENSING BOARD PREHEARING CONCERNING STANDING.

United Steelworkers of America Local 1010 seeks standing to intervene in proceedings on NIPSCO'S construction permit extension for Bailly Nuclear One as a matter of rightu. Ourscon-tention 10-B of " Petition to Deny Permit" contends that further construction of Bailly will harm the Indiana Dunes National Lakeshore Park of which many of ou'r Memb ers 'are us ers . Further, without the construction. permit extension the Bailly plant, which will adversely affect our Members, cannot be built.

Local 1010 additionally seeks standing as a matter of dis-cretion because our participation will assist in developing a more complete record. Local 1010 has previously petitioned the Nuclear Regulatory Commission requesting public hearing on NIPSCO'S proposed change in the foundation of Bailly Neclear One.

Local 1010's 19,000 Members are reside in a broad area of two

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states and their interests are such that they cannot adequately be represented by any other party to the proceedings.

@ Respectfully Submitted, w

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1 APR I% t Joe Frantz, Secretary gy C n I93D> 7, Enviromental Committee

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DCCKETES b USNRO g: APR 2E80> I

. UNITED STATES OF AMERICA ' '

, . NUCLEAR REGULATORY COMMISSION 9 Officeof theSe Dghgq g ggg 7 Sanch BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 E u

In The Matter of )

NORTHERN INDIANA PUBLIC DOCKET No. 50-367 SERVICE COMPANY ) (Construction Permit (Bailly Generating Station, Extension)

Nuclear 1)

AFFIDAVIT OF JOE FRANTZ Joe Frantz declares and states.as:follows:

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1. I reside at 535 Miami Place in the City of Gary, Indiana. My residence is located approximately 8 miles from the proposed site of the Bailly Generating Station, Nuclear.l.

2. I am secretary bf the Environmental Committee of the United Steelworkers of America, Local Union 1010, which is seeking to intervene in this construction permit extension proceeding.

3. Local 1010 represents approximately 19,000 Employees of the Indiana Harbor Works'of Inland Steel Campany, which is approximately. 15' miles from the proposed site of Bailly Nuclear One.

The general Membership of Local 1010 voted in 1976 to oppose , i construction of a nuclear generating station at the Bailly site.

The general Membership of Local 1010 voted 1979 to, authorize the Local Union to oppose the application of Northern Indiana Public Service Company for a construction permit extension for l t

i Etilly Nuclear 1, and to petition The Nuclear R~.egul'ator Commis- l

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sion f o r a hearing on the construction permit' extension in our

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4.I and many other members of Loc 51 1010 are users of the Indiana Dunes National Lakeshore. The continued construc-tion o f Bailly Nuclear One will cause further site-dewatering which harms the, interests of our members as users of the park.

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5. The continued construction of Bailly Nuclear One threatens the, health and jobs of members fo Local 1010. If Bailly Nuclear:One is built and operated, the possibility *of an accident threatens our health and j obs. This risk is aggravated by the lack of viable evacuation plans for the high-ly populated areas surrounding the site. If the ' plant is built and not operated, the utility rate increases necessary to finance both an idle generating station and emergency. sources of power will j eopardize our ability to purchase the power necessary to

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protect our health and our families'. It will also j eopardize our jobs because steelmills depend upon adequate supplies of

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electricity at reasonable rates.

6. Unless NIPSCO can demonstrate the ability to proceed with construction of Bailly Nuclear One with'out harming the-Indiana Dunes National Lakeshore, and unless NIPSCO can prove ability to protect the j obs and safety and health of our members in the event of a nuclear accident, the construction permit ex-tension should be denied. -

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. . -In.accoraance wi.th 28 U.S.C. S 1746, I !

declare under penalty of perjury that the foregoing is true and correct.

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Executed on f//Lu 4 26 , /ff'O .

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JQfFRANTZ G

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UNITED STATES OF AMERICA e

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NUCLEAR REGULATORY COMMISSION 2

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APR 4 offiarofas2 IN THE MATTER OF: ) Sbdut g NORTHERN INDIANA PUBLIC ) DOCKET No. 50-367 4 SERVUCE COMPANY (Bailly ) N g j, Generating Station, )

Nuclear-I ) -

CERTIFICATE OF SERVICE l

I hereby certify that I have served copies of the SUPPLEMENTAL STATEMENT TO ATOMIC SAFETY AND LICENSING BOARD PREHEARING AND AFFADAVIT OF JOE FRANTZ, upon each of the following persons by deposit in the United States mail, first class postage prepaid, this 27th day of March, 1980.

Herbert Grossman, Chairman Diane Cohn Atomic Licensing and Safety Board Suite 700 U.S. Nuclear Regulatory Commission 2000 P Street N.W.

Washington, D.C. 20555 Washington, D.C. 20036 Katheeen Shea Mr. Glenn Bright 1025 Connectibut Ave. N.W. ,

Atomic Safety & Licensing Board Washington, D.C. 20036 U.S. NuclearRegulatoryCommissf Washington, D.C. 20555 Dr. Richard Cole Atomic Safety & Licensing Board Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissi Washington, D.C. 20555 Washington, D.C. 20555 William H. Eichorn, Esq. . Robert J. Vollen Eichorm, Morrow & Eichorn Business & Professional People l

. 5243 Hohman Ave. For The Public Interest i

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Hammond, Indiana 46320 109 N.

Dearborn' St. Suite-1300 ,

Chicago, Illinois 60611  ;

Do eting and Service Section ou 1 he NRC Staff U.S. Nuclear Regulatory Commission Secretary of the Commission

, Washington, D.C. 20555 U.S. Nuclear Regulatory Commiss

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Robert L. Graham Washington, D.C. 20555 Jenner & Block Dean Hansell One IBM Plaza-Suite 4300 Assistant Attorney General Chicago, Illinois 4 188 W. Randolph St.

Richard L. Robbins Chicago, Illinois 60601 Lake Mich. Fed.

53 W. Jakeson Blvd.

Chicago, Illinois 60604

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