ML19210B963

Final Formal Contentions of Intervenors Newberry Township TMI Steering Committee,M Minnich,Rj Zloger,Ls Carlisle, V Phillips,Cw Wolfe,Li Dominoski,Pa Smith,Dk Umhaltz, CM Clark & ML Glock.Certificate of Svc Encl

ML19210B963
Person / Time
Site:	Three Mile Island
Issue date:	10/19/1979
From:	Cunningham J FOX, FARR & CUNNINGHAM, NEWBERRY TOWNSHIP, YORK HAVEN, PA
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7911130094
Download: ML19210B963 (3)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD cs

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METROPOLITAN EDISON COMPANY,

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FINAL FORMAL CONTENTIONS OF THE NEWBERRY TOWNSHIP T.M.I. STEERING COMh1TTEE

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AND MICKEY MINNICH; RICHARD J. ZLOGAR; LINDA S. CARLISLE; VIRGINIA PHILLIPS; C. WILLIS WOLFE; LINDA I. DOMINOSKI; PATRICIA A. .W.ITH; DONNA K. UMHOLTZ; COLLEEN M CLARK;

\ND MICHAEL L. GLOCK, M.D.

AND NOW, to wit, this 19th day of October, 1979, comes the Petitioners, by and through their counsel, JORDAN D. CUNNINGHAM, ESQUIP2, and files these final and formal contentions pursuant to 10 C.F.R. 2.714(b) 21, 1979, and the Atomic Safety and Licensing Board's Grder of September as follows:

1. The Newberry Township T.M.I. Steering Co=mittee's concern is concentrated, for the purposes of this intervention, to the issue of the psychological and emotional impact upon the citizens of Newberry Township if reactivation of Unit Number 1 is authorized by the NRC in light of the recent accident of Match 28, 1979. Operation of Unit Number 1 would be a constant reminder of the trauma which was experienced by the members of the Committe throughout the accident and the possibility that they would tock re-experience the same trauma if, in the future, a similar accident placc. It is averred that this is a health concern which involves the quality of the human environment, and therefore is embodied in the NE 1323 015 g s 19111so oy

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.i and thus is an issue and/or contention which is proper for the NRC to consider.

2. The individual petitioners contend that the psychological impact upon themselves as a result of the acclient of March 28, 1979, is also an aspect which is relevant to the quality of the human environment and is embodied in the NEPA. Petitioners further contend that the psychological fear generated in the ptalic mind as a result of the March 28, 1979, accident has resulted in a de facto p .olic bias and prejudice against the Newberry Township area with regard co the siting of new residential building, new businesses, and the purchasing of the existing improved parcels of real estate tithin the Township. It is also contended that the threat of reactivation of Unit Number 1 has and will, in the future, continue to effect the above-enumerated economical concerns. Petitioners aver that these contentions conce;aing health and socio-economic aspects are embodied in the spirit and language of the NEPA.

3. Evacuation planning done by Metropolitan Edisor. and the Nuclear Regulatory Cacnission is inadequate to assure the safety of the public, particularly these persons who .'ive within a five mile radius of the plant. 0;eration of T.M.I. Unit Number 1 should not be resumed until a plan is in place for the evacuation of the public in the maximum area which could be effected by an accident.

Respectfully submitted, FOX, F CUNNIN DATED: October 19, 1979 BY: # _

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't CERTIFICATE OF SERVICE I, JORTAR D. CUNNINGHAM, hereby. certify that copies of the Final Contentions in the foregoing matter have been served upon the following, by deposit in the United States 5bil, First Class, postage V

prepaid, this ] Vday of October, 1979.

Executive Lega1 Director U. S. Nuclear Regulatory Cc==ission Washington, D.C. 20555 Mr. George F. Trowbridge, Esq.

SHAW, PITMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C. 20036 Secretatf, U. S. Nuclear Regulatory Co=nis tion Washington, D.C. 20555 ATTN: Chief, Docketing and Service Section

. Ivan W. Smith Atomic Safety and Licensing Board Panel U. S. Nuclear Regulato Cemmision Washington, D.C. . 555

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ttorney 4or Pet ers

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