ML19273C192

Petition to Intervene Re Effect of Increased Fuel Storage Capacity at Facility.Public Health & Safety Not Adequately Protected.J Decastro Affidavit Encl

ML19273C192
Person / Time
Site:	Hatch
Issue date:	09/14/1979
From:	Flack G GEORGIANS AGAINST NUCLEAR ENERGY, MYER, BOWMAN, STROUP & FLACK
To:	NRC COMMISSION (OCM)
Shared Package
ML19273C191	List: ML19273C190 ML19273C192
References
NUDOCS 7911050411
Download: ML19273C192 (5)

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_. O UNITED STATES OF AMERICA 7

NUCLEAR REGULATORY COMMISSION 1 ~

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IN THE MATTER OF

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GEORGIA PONER COMPANY', et al.

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(Hatch Units No..1&2)

) Amendment (Increase Spent Fuel Storage Capacity)

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PETITION FOR LEAVE TO INTERVENE Georgians Against Nuclear Energy (GANE), on its own behalf and on behalf of its members , hereby petitions the Nuclear Regulatory Commission (NRC) for leave to intervene in the above-captioned matter pursuant to Section 2.714 of the NRC's Rules of Practice.

Georgians Against Nuclear Energy (GANE)

GANE is an unincorporated association with approximately 300 individual nembers residing in the State of Georgia. GANE has made a 10 C. F. R. 2.206 Request in Dockets 50-424 and 50-425.

Its request for reconsideration is still pending. GANE has intervened in the Georgia Power Company's Request for a Rate Increase before the Public Service Commission of the State of Georgia. GANE has testified before various federal, state and local forums to present its views on various issues regard-ing nuclear energy. GANE's principal concern of relevance here i

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is with the potential financial, health, safety and environmental problems associated with storage and possible release of radio-active waste contained in Hatch spent fuel rods. On information and belief, no other parties have sought to intervene herein.

GANE's participation will be a means to represent the public interest in this matter. GANE's participation will not cause unnecessary delay in the proceedings, but will assist in the consideration of a thorough analysis of all the issues presented.

Interests To Be Affected GANE is concerned that a proposal to store substantially larger amounts of spent fuel in Hatch and to keep that spent

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fuel in Hatch for a substantially longer period than original-ly contemplated increases the risk to its members and the

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general public to exposure to radioactive waste products which can seriously affect the health and safety of the citizens of Georgia and other states and seriously affect the quality of the environment. Thus, the Hatch proposal subjects them to a potential health, safety and environmental risk not adequate-ly considered in any previous hearing. In addition, GANE is ascerned about the additional financial burdens this proposal will impose on consumers of electricity in Georgia. This is particularly urgent in light of the $122 million rate increase recently granted to Georgia Power.

4 . g Contentions

1. On information and belief, the Applicant has not sub-mitted sufficient information to determine whether there is reasonable assurance of adequate protection for the public health and safety.

2 Applicant has not provided sufficient information to demonstrate that taking account of all financial, health, safety and environmental considerations optimizes the benefits with respect to the alternative courses of action.

3. If Applicant submits sufficient information to meet the requirements outlined above, the proposed modification should not be approved unless it is conditioned upon Applicant utilizing a safe and environmentally acceptable location and method for storage of spent fuel from Hatch within five years from the date of approval of the proposed modification and that from and after five years from the date of approval of the proposed change, Applicant will not store more than 840 spent fuel assenblies at Hatch Unit No. 1 or more than 1120 spent fuel assemblies at Hatch Unit No. 2 for more than six months and will not store any spent fuel at Hatch for longer than 12 months. If the condition is not met, Hatch should be shut down unless and until the condition is met.

Effect of Participation The effect of GANE's participation will be the incorpora-tion of the analyses, views and concerns of Georgians (besides

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the licensee) into the decision-making process. To the extent that these views differ from the licensee's, they will enhance the adversary decision-making orocess. The effect of an NRC order based on GANE participation will be to protect the finances, health, safety and environment of the members of GANE and others similarly situated in Georgia.

Conclusion For all these reasons, we urge that the Applicant's pro-posal not be approsed or if approved, that it be approved on the basis of the stated contentions.

Respectfully,

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wT GARY FLACK 1515 Healey Building 57 Forsyth Street, N. W.

Atlanta, Georgia 30303 (404) 522-1934 COUNSEL FOR PETITIONER

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AFFIDAVIT OF JOHN de CASTRO Comes JOHN de CASTRO, and being on oath deposes and says:

1 That he is a member of GANE and Statewide Coordinator for intervention proceedings.

2 That his home address is 68 Pinetree Circle, Decatur, Georgia 30032,

3. That he is aware of the contents of the Petition to Intervene and attests that the information contained therein is true and correct to the best of his personal knowledge and belief.

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/ ~ JOHN de CASTRO

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Subscribed and sworn to before me, 104119 this /Sk day of September,19 79. c l e/, a ja ?/ $* \\

NOTARY PUBLIC ggi "

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My Commission expires: 4 -JA. 90 .

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(Official Seal) #

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