ML19282C398

Citizens for Fair Util Regulation'S Intervention Petition. Avers Interests to Be Affected & Requests Local Hearing. Affidavit of Nh Jacobson & Certificate of Svc Encl

ML19282C398
Person / Time
Site:	Comanche Peak
Issue date:	03/03/1979
From:	Jacobson N CITIZENS FOR FAIR UTILITY REGULATION
To:
References
NUDOCS 7903300102
Download: ML19282C398 (4)

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- NRC PUELIC DOCUMENT ROOM 4

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wC:<ET ::U:cERS 50-45 A:;0 50-446 g>4 4 RE: APPLICATIO:: OF TEXAS I 9 =RQ ,

U*IL: TIES GE:!EFATI:!C CCMPANy i BEFCPE .. ,

FOR A;I CPr*MT!!:G LICO::SE I WCLEAR REGULATCR7 . W

• FCR CCMAMC!!E PEAK STEAM l OF T G T!!TFD STATES ELEC*RIC STAT:Cu U:::TS 1 Ana 2 i or Aara:0A Gte MAR 1219T3 PE*:T:Cu rCR LEAVE To : = ER;E:E w C!T!OIN3 FCR F A!R U*!L!"? P E-"IAT!CN F"R)

CW CCMES citizens for Fair Utility Regulation (CFUR) and files this its Petition for Leave to Intervene in the above-captiened mat-ter, pursuant to Nuclear Regulatory C:rrraission Rules of Practice Sec-tien 2.T14, and in support of its Petition wculd respectfully show the follcwing:

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!OE'fTIFTCATION CF PE*!T!CNER CTUR is an organization of citizens of

• arrant County, Texas, who, and many of whose families, reside and either werk er attend school in Tarrant c unty, which is approximately thirty-five miles northeast of C manche Peak Steam Electric Statien. Therefere, CFUR and its members have a direct and proper interest in the safe Opera-ti:n of C manche Peak Steam Electric Station and in Ony regulat:ry prcceeding concerning Texas Utilities Generating Company's applicati:n for an operating license for C manche Peak Steam Electric Station.

The members of CFUR also are all residential cust:mers of Texas Electric Service C:mpany, an affiliate of Texas Utilities Generating C:mpany, which plans to deliver and bill cust:mers for pcwer generated by C:manche Peak Steam Electric Station. Therefore, CFUR and its members have a direct and pr:per interest in any ccats incurred by Texas Utilities Generating C:=pany as a result of cw.;tructien, reg-ulation and operation of Cemanche Peak Steam Electric Station which would optimize the cafe operatien thereof.

CFUR has been a participant, either as a public participant er as Intervenor, in electric utility and gas utility rate cases affect-o ing residential consumers in Tarrant County since January, 1976.

CFUR is currently an Intervenor in hearings in Austin, Texas, bef:re the Public Utility Cceraissicn of Texas in Re: Application of Texas Electric Service C:mpany for Authcrity to change Rates and Inquiry by Public Utility Commissien of Texas into certain Affiliated

?ransactiers of Texas Electric Service Company, Texas Pcwer & Light Ccmpany and Dallas Pcwor & Light Company (Decket No. 1903, also ::cc-kat Ncabers 1517, 1789, 1913 and 2019). Cn'R was also an Interven:t in the criginal Application of Texas Elecaic Service C =pany f:r Authcrity t: Change Rates ( riginal Docket 1303) in 1978 bef:re the Public Utility C--4ssion of Texas.

As such participa..t and/or Intervencr, CFUR's interest in such regulatory proceedings has been frem the standpoint of the residential censumer with an environmental awareness.

CF"R has thus demonstrated an engeing, respcnsible participation in regulatory preceedings over a peried cf three years.

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CFVR is financed c:mpletely and 7:luntarily at O f the pc=ket.;

cf its meeers, and has never solic;ted contributa 's from anyone.

Contributiens fr m mecccrs have always been c:::.pletely channelec into CFLT.'s participation in a particular regulat:ry prtee+31ng. ::a :ccm-bor of CF"a has ever received remunerati:n Or ::nJ t jeration cf valae for such .M rticipation, ner has CFUR re sived Jm: . There Lre, it can be seen that CFUR is in a strict sense a 1: cal, cita: ens Organi:4-tien which has participated in government regulat un resp:nsibly.

II I???EFESTS TO 9E AFTEC??O WHEREAS CFUR's members reside, ge about their daily lives, Own preperty, persvnal and/:r real, and in seme cases +arn their liveli-hoods, in an area about thirty-five miles from Cf.1anche Peak Stasm Electric 't. len, and pay electric races affected by all cos:s ass:-

clated with construction, regulation and operation of C:manche Peak Steam Electric Station, and WHEREAS the health, safety and value of pr: pert'f and livelih::d

[f the gereral public in Tarrant :unty may be affec:ed by either r:utine Opersti:n :f C manche Peak Steam ERetric Stati:n er by any accident invciving release of radicactive elements, ar i WFEREAS the above-captiened prec3edings are designed to ensure that Comanche Peak Steam Electric Station will cperate with maximum conditions of safety for the general public,

• EEREFCRE, it can be seen that CFLV and its  ?. ambers have a direct and creper interest in these same abcve-capti:ned reculatory pr:cced-ings, and shculd be permitted Inter /enor status by the :.uclear Reg-ulatery Cemrtission.

FURTMERMCRE, the participation of Cn.*R is necessary to assure the broad public participation in such proceedings which is intended by the Rules of the !Tuclear Regulatcry Cerntissi n and by, the public an;.:uncements of the ::cclear Regulatory Ccemis sien, as well as by its mandate trem the United States Congress.

WHEREFCRE, AI,I, PREMISES CC1:SIOERED, CFUR prays that this its Petitien for Leave to Intervene be granted.

III RECLTS* FCR LCCAL M RING SI"'E CFUR radpectfully requests that any and all Prehearing COnfar-ences and Hearings in the above-captioned proceeding te located in er ar:und the ? uclear Regula".Ory Ccranission Regicnal Office in Arling-ten, Texas, f:r the following reascns:

1. There is a uclear Regulatory C:rnissien Regi:nal Office located in Arlington,

• uas f:r ebvious goed reason.

2. There is a mas.ive pcpulation area located around that office. in the :allas-Fcrt Werth metroplex, which will be affect d by the :peratien Of C:manche Peak Steam Electric Stati n.

3. It would work a hardship and gecpardice the right o f CI"3 and possib1'; :ther parties to intervene and to participate fully in the aMva-esptiened pr:ceeding if Prehearing C:nferences and Hearings were held in Washington er ance.% r *. cale which wculd be 6-

a lcng dit e fr:m the ma:cr pcpulaticn center .:1:se to Comanche Pes < Steam :tri: Station.

4 It wculd af *ect adversely sny etha- public participati:n and thus ]*cpardi:e the rights of the gerieral putelte to participato in the pro.: ceding to fail to hold the Hearings in the major pcpala-tien center close to C nu.cne Peak Steam Ele:Pric Station.

5. T: h:13 the Hearings in the maj:t pcpulati:n center wcul present an pportuni'.y f:r educati:n of t. public which is Otherwise los t.

WHEREFCRE, FREMISE3 CCNSIOERED, CTUR prays that its request be granted and that all Prehearing Centerences ana Hearings its une abcve-captioned proceeding be scheduled in er at und Arlis.gt:n, Texas.

. Respectfully submitted,

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Jancy ilGidam JaC CSCC C E';R 1400 tiemphill Fort Worth, CC 761.4 (817) 923-6431 CERTIFICATE OF SERVICT I hereby certify that a true and correct copy of this CTUR's 1.a <~m..o w.*..~

Petition f:r Leave to Intervenerwas mailed en this the ,

day of March, 197') by United States . Mail, pestage prepaid, to the f 1-1: wing:

Secretary f the C:t=tiJsion U. S. Nuclear Regulatory Cczztission Washi.; ten, D. C. 20555 Attn: Docketing and Service Branch Nicholas S. Reynolds Esq. -

Oecevoise 4. Licerman 1200 l'th Street, N.W.

Washington, D. C. 20036 Legal Director t' . C. Suelear Regulat:ry Ct-ission

<Lshinct:n, C. C. 20555

/r .., s, ,..,

, Nancy licidam Jacgbsen

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THE STATE OF TEXAS CCCITY CF T.UL~ TANT 3EFCES TES CDERSICNE) AUTECRITT on this day personally appeared

TA'iCT E09A:1 JACO3 SON, who, having been placed under oath by =e , did depose as follows:

I as of legal age and a

"(1) 1.:7 name is Nancy Eoldam Jacobson.

resident of Forest Hill, in Tarrant County, Texas. ':7 = ailing address is 6954 Cobblestone Court, Fort Worth, Texas 76140. At that sa:e address I co-own, with my husband Jonald J. Jacobson, real property, consisting of land and personal residence.

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(2) I was one of the founding seven =ombers of Citisens for Fair Utility Hegulation (CFU3) and as presently Coordinator, having been such since "ay, 1976. I have consulted with the ce=ters of CFUR and they have authorized me to represent them in filing this Petition for Ioave to Intorvens in Een Application of Tezas Utilities. Generating Company for an Operating License for Cocanche Peak Steam Electric Station Units. 1 and 2.

(3) I have reviewed the representations contained in the attached Petition for Ioave to Intervene , specifically regarding Identification of Petitioner and Interests to be Affected, and such representations are true and accurate to the best of =y knowledge."

9?dm khsa .ed&

3ancy Hol m Jacobsoy SU3SCRI233 AN) S'JCRN TO BEFCRE MS by the said Nancy Holdam Jacobsen on this 1 day of :.: arch,1979 /

w< J er Q Notar;, Public in and for Tarrant County, Texas My Cec =ission expires wor 3/. /e n