2and healthy environment, including the elimination or mitigation of the hazards posed by theoperation of the Callaway nuclear power plant.MCE has standing to intervene in this case because many of its members live, work, andown property within 50 miles of the Callaway reactor, and their interests may be affected by theresults of the proceeding.
Virginia Electric and Power Co.
(North Anna Nuclear Power Station,Units 2 and 2), ALAB-522, 9 NRC 54, 56 (1979). Their health, safety, property value, andmeans of livelihood could be adversely affected if the NRC permits Callaway to continue tooperate for an extended period in a manner that is unsafe or harmful to the environment. Forinstance, if an accident and consequent offsite radiation release were to occur at Callaway, thehealth, safety, property value, and means of livelihood of neighbors of the plant, includingmembers of MCE, could be seriously harmed. MCE has attached declarations from individualMCE members who have authorized it to bring this legal action on their behalves.
Declarations of Ruth L. Schaefer (Exhibit 1A), Mary E. Mosley (Exhibit 1B), Mark Haim(Exhibit 1C), Carla T. Klein (Exhibit 1D), and Patrick J. Wilson (Exhibit 1E).
III. CONTENTIONSContention 1: Environmental Report Lacks Information Regarding ProposedModifications to Callaway Facility1. Statement of the Contention:
The Environmental Report fails to satisfy 10 C.F.R.§ 51.53(c)(2) because it does not include information about Ameren’s plans to modify theCallaway facility in response to post-Fukushma enforcement order EA-12-049 (March 12, 2012),Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately) (“Order EA-12-049”) (ML12056A045).As also required by 10 C.F.R. § 51.53(c)(2), the Environmental Report must include a discussion