ML20215F279

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Comments on Proposed Rule Changes.Changes Directed Toward Curtailing Citizen Participation in Licensing Process.Nrc Should Lower Contention Stds,Open Discovery Vs Nrc,Expand Intervenor Cross Exam & Restrict Use of Summary Disposition
ML20215F279
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 08/30/1986
From: Anthony R
ANTHONY, R.L.
To:
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20215F231 List:
References
NUDOCS 8612230338
Download: ML20215F279 (1)


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'..jf'Fesrottry U.S.Nuc1ccrof tho Cercicaicn Regulctery Ccamiccica August 30,1986 Wachidg(ca, D.C. 20555 TO THE SECRETARY AND MEEBERS OF THE COMMISSION:

As an intervonor in the licensing process for the Philadelphia Electric Company's Limerick nuclear plant under the name of Robert L. Anthony / Friends of the Earth in the Delaware Valley I wish to submit the following comments in opposition to the changes in the rules proposed by NRC which threaten the ability to intervene and to function in the Ifcensing process of citizen advocates like myself. These rule changes come under 10 CFR Sections 2 714, 2 720,2 743 and 2 749.according to my understanding. ,

DISCOURAGEMENT OF CITIZEN PARTICIPATION NRC ' r proposed changes in the sections above are directed toward curtail-ing citizen participation in the licensind Process for nuclear plants. I have been active in this process for the Limerick plant for more than 5 years. I am seither a lawyer or a person trained in engineering or science. In spite of this I have been able to understand the safety and legal issues from the

" gut" reactions of a person who is compelled to confront the dangers to me and my family and friends from the operahton of the Limerick reactor and also the ocoromic impact on me and on the areas economy from the rate hikes re-quired to pay for this expensive, dangerous source of power.

EXPERIENCE WITH NRC REGULATIONS AND BOARDS The proposed rule changes are in a completely opposite direction from en-couraging citizen imput and bringing increasing safety into nuclear plant ope ration. NEPA and AEA legislation included citizen participation as a fundamental base. My experience of the past 5 years with Linierick is that a citizen like myself has to fight for ever chance to challenge licensee sub-missions and NRC actions. Only because of extreme persistence was I able to be admitted as an intervenor and to have three minor contentions accepted.

I submitted about twenty contentions. Had I been able to pay for professional help I probably could have prevailed on some of the technical contentions I raised and h ve argued them with the help of a lawyer before the hearing board. As a result a number of safety issues that are vital to the community were never explored. Consequently I have been fored to challenge each auth-orization by NRC from bringing fuel to the site,to my present efforts to bave the operating license suspended. I have spent thousando of hours of my time without any recompense and hundreds of dollars of my own funds. I do not re-l gret this investment in the attempt to protect my health and interests and those of my family and frkgde but I submit that this is an ertremely waste-ful process. It is all based on an adversary relation between myself as a citizen and NRC. We should be working together to protect me and the com-munity. There should be funds,public funds,to pay for legal and technical experts for citizens,even NHC staff members available to baly citizen cases.

ERROR IN THESE PROPOSED CHANGES.

l The rule changes I would have NRC sponsor are those opening more chances for citizen participation as touo-hed on above. As a citizen I have been impeded by the present regulations. I earnestly request the NBC to 1. lower contention criteria, 2.open discovery vs the Staff, 3. expand intervenor cross examination,

4. further restrict the use of summary disposition vs. contentions,and 5. expand the scope of issues which can be appealed on citizen initiative. In the in-terest of safe plant operation and the safety and health of the public ereject this rule for changes in the above regulations. Two press releases about some of my participation are encioned. Very sincerely your ,

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