ML20065P841

Petition of Concerned Citizens of Louisa County for Leave to Intervene & Request for Hearing Re Proposed License Amend Authorizing Increase in Capacity of Spent Fuel Pool.Notice of Appearance & Certificate of Svc Encl

ML20065P841
Person / Time
Site:	North Anna
Issue date:	10/22/1982
From:	Jay Dougherty DOUGHERTY, J.B.
To:	NRC COMMISSION (OCM)
References
NUDOCS 8210260355
Download: ML20065P841 (7)

Text

.

a 10/22/82,

. DCLKETED U3HRC UNITED STATES OF AMERICA 82 CCT 25 A11 d NUCLEAR REGULATORY COMMISSION

^ : li./ii.* P '

Mirv 1:!

) . ;:.C':

In the Matter of )

)

)

VIRGINIA ELECTRIC AND POWER COMPANY )

(North' Anna Power Sta., Units 1 and 2) Docket Nos. 50-338

)

~ (Proposed ' Amendment to Operating License )

to Permit Increase in Spent Fuel Storage )

Capacity) )

)

N PETITION FOR LEAVE TO INTERVENE Concerned Citizens of Louisa County (hereinafter

" Citizens") hereby moves the Nuclear Regulatory Commission (hereinaf ter "NRC" or " Commission") for leave to intervene with respect to the Commission's consideration of the Aug-ust 20, 1982 application by the Virginia Electric and Power Company ("VEPCO" or " Applicant") for an amendment to the operating license for the North Anna Power Station author-izing an increase in the capacity of the plant's spent fuel storage pool from 966 to 1737 fuel assemblies. VEPCO's ap-plication was noticed in the September 22, 1982 edition of the Federal Register, 47 Fed. Reg. 41893. Citizens further requests that the Commission hold a hearing on VEPCO's ap-plication.

~

?!P!88erdgeggga m >

Tj6D3

3 7

DESCRIPTION OF THE' PETITIONER AND HOW ITS INTERESTS WILL BE AFFECTED Concerned Citizens of Louisa County is a not-for-

' profit organization comprised of approximately 70 persons who reside in the vicinity of the North Anna power plant.

Citizens was established because of concern on the part of its members over threats to the safety and health of the public, and to the quality of the environment, which may be posed by the operation of the North Anna plant. Fore-most among the goals of the group are to assure that the plant is -operated safely, and to educate its members and the general public on matters related to the plant's safe operation.

Citizens submits that' it has standing to participate in the above-captioned proceeding as a representative of its members, most if not all of which reside within 20 miles of the North Anna plant and thus satisfy the prevail-ing rules governing standing in NRC licensing proceedings.

In particular, the following members have authorized Citizens, through counsel, to represent their interests in this matter:

• Donna M. Dellett, Rick W. Dellett, and their children -

Christen, age 4, and Andy, age 1 - reside in Bumpass, Vir-ginia, within 10 miles of the North Anna plant. In addition, the Delletts are the proprietors of a retail store in Buupass, amuser The Delletts' health and safety, as well as their financial

. h\

-gh interest in the store, are threatened by VEPCO's proposal

=.

( to increase the amount of nuclear waste to be stored at the North Anna plant. If authorized, VEPCO's proposal would increase the amount of radioactive discharges which routinely emanate from the plant, and create a risk of spent fuel pool accidents causing even greater harm to the Delletts.-

• Collette Cole resides in Mineral, Virginia. The prop-erty on which her home is located lies adjacent to Lake Anna, into which the North Anna plant discharges thermal and radioactive effluents. Because of the risk of accidents and the chronic, long-term radioactive discharges to which VEPCO's proposal, if approved, will give rise, Ms. Cole's interest in her personal health, and in the quality of the-Lake Anna area's environment, will be affected by the pro--

, posed license amendment.

• Pamela H. and Frederick S. Richardson reside, with their 6-year old son, Joel, in Mineral, Virginia. Their home lies within 10 miles of the North Anna plant. Should the Commission approve VEPCO's license amendment application, the Richardsons' property and environmental interests will be impaired because of the resultant increased levels of radioactive effluents that will be discharged by the North Anna plant.

• Gary and Theresa Schwartz reside in Louisa, Virginia, within 15 miles of the North Anna plant. Their children,

Lydia and Graham, attend the Mineral Elementary School in Mineral, which is located less than 10 miles from the North Anna plant. Should the proposed license amendment be granted, the Schwartz family's health and property interests will be impaired by the increased levels of pollution emanating from the plant, as well as the enhanced risk of an accident involving the spent fuel pool.

CONTENTIONS Citizens makes the following specific contentions con-cerning (1) alternatives to VEPCO's proposed action, (2) the risk of accidents involving the North Anna spent fuel pool, and (3) the NRC's statutory obligations to evaluate the-environmental implications of the proposed license amend-ment. Citizens intends to amend and/or supplement this list I

in the near future.

(1) Applicant has not demonstrated that the proposed mod-ification of the spent fuel pool is environmentally and economically preferable to the construction and use of a dry cask spent fuel storage facility at the Surry Power' Station.

(2) Applicant has not demonstrated that the proposed.~ mod-ification of the spent fuel pool is environmentally.and economically preferable to increasing the capacity of the

. spent fuel pool at the Surry Power Station.

O

(3) Applicant has not shown that the proposed modifi- '

cation of the spent fuel pool is environmentally and economically preferable to operating the Surry Power Station at a reduced rate of output. '

(4) Applicant has not shown that, in the event of an accident involving the spent fuel pool, the resulting radioactive releases would not be inimical to the public health and safety.

(5) Applicant has not shown that, in the event of a

" Class 9" (i.e., catastrophic) accident involving North Anna Units 1 and/or 2, the resulting radiclogical releases from the spent fuel pool would not be inimical to the pub-lic health and safety.

(6) The proposed license amendment constitutes a major federal action significantly affecting the environ'ent m and~

, tnus may not be granted prior to the preparation of an .en-vironmental impact statement.

Respectfully submitted, Dated this 22nd day  %-

of October, 1982 Jhmes~B. Dop'herty Ls' Counsel for Concerned Citizens of Louisa County 3045 Porter St., N.W.

Washington, D.C. 20008 (202)362-7158 e

. 00.tKETED

_yaC UNITED STATES OF AMERICA 3q NUCLEAR REGULATORY COMMISSION '82 00I

) n!

In the Matter of ) MN

)

)

VIRGINIA ELECTRIC AND POWER COMPANY )

)

(North Anna Power Sta. , Units 1 and 2) )

Docket Nos. 8

)

(Proposed Amendment to Operating License )

to Permit Increase in Spent Fuel Storage )

Capacity) )

)

NOTICE OF APPEARANCE Name: James B. Dougherty Address: 3045 Porter St., N.W.

Washington, D.C. 20008 Telephone: (202)362-7158 Client: Concerned Citizens of Louisa, County Admitted to practice: United States Supreme Court United States Court of Appeals for for the District of Columbia Circuit United States District Court.for for the District of Columbia District of Columbia Court of Appeals i

_ LW & _

qaInes B. Dqligherty {/

O r -- -' - -

e ** .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 82 00125 ;m 35 afi rN

) '";i-YkSEiN,tCE In the Matter of ) ERANCH

)

)

VIRGINIA ELECTRIC AND POWER COMPANY )

)

(North Anna Power Sta., Units 1 and 2) Docket Nos. 50-338 (Proposed Amendment to Operating License )

to Permit Increase in Spent Fuel Storage )

Capacity) )

)

CERTIFICATE OF SERVICE I certify that copies of -the foregoing ' PETITION FOR LEAVE TO INTERVENE were served this 22nd of October, 1982, by deposit in the U.S. Mail, upon the following:

, Michael 3. Maupin, Esq.

Hunton & Williams ,

P.O. Box 1535 Richmond, VA 23212 Executive Legal Director

' Nuclear Regulatory Commission Washington, D.C. 20555

) '

O%-TCCM/. ~

Jam 6s B. Doughdrty 4 9

e

• e: , e -

e n,