ML19208C376

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Brief on Standing of Intervenors & Status of Contentions. Intervenors Hudson Valley Should Be Granted Discretionary Intervention Re Alternate Siting.Requests Extension Until 790817 for Intervenors to File Revised Contentions
ML19208C376
Person / Time
Site: New Haven
Issue date: 07/13/1979
From: Lewis S, Mulkey M
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 7909260169
Download: ML19208C376 (22)


Text

DLIC DOCU.ygyT 1 7/13/79 5,.

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p UNITED STATES OF AMERICA f

NUCLEAR REGULATORY COMMISSION

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6-BEFORE THE ATOMIC SAFETY Afl0 LICENSING BOARD 3

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's In the Matter of

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6 ci t NEW YORK STATE ELECTRIC & GAS CORP.

Docket Nos. STN 50-596 AND LONG ISLAtlD LIGHTIflG CO.

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SIN 50-597

)

(New Haven 1 and 2)

)

NRC S1AFF BRIEF UN STANDING OF HUDSON VALLEY PETITIONERS AND STATUS REPORT ON flEGOTIATION OF CONTENTIONS I.

Introduction This pleading addresses the following three matters as directed by the Atomic Safety and Licensing Board:

1.

the " legal standing" of the petitioners from the Hudson River Valley 1/

area" (see Pre-Hearing Conference Report, dated June 20,1979);

2.

the status of negotiations with the admitted Intervenors and with petitioners as to their contentions (see Pre-Hearing Conference Report); and 3.

the Staff's response to the request of Emerson Mead that he, as an individual, and the Town of Conesville be admitted as Intervenors in this proceeding (see Board flotice of June 25,1979).

,1f Columbia County, Town of Stuyvesant, Concerned Citizens fo:' Safe Energy, Mid-Hudson Nuclear Opponents, Ulster County Environmental Managerrent Council (EMC),

and Town of Gardiner. Based upon our review of the transcript of the May 23, 1979 pre-hearing conference it was not clear to us on what basis Mr. Kafin would seek to assert standing as of right on behalf of his clients. We have, therefore, chosen to await his brief and respond accordingly.

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II. Legal Standing of Hudson Valley Petitioners The question has arisen in this case whether petitioners from the Hudson River Valley can demonstrate legal standing in the NRC proceeding (and thus be able to assert whatever relevant contentions they wish to raise) or whether they can only be admitted discretionally based upon their proximity to an identified alternate site (and thus be limited to raising issues related to that alternate site).

The Staff has earlier taken the position that the Hudson Valley petitioners fail 2/

to satisfy the requirements of 10 CFR 52.714 regarding interest, but that they should be granted discretionary intervention on the subject of alternate siting in view of their apparent ability to contribute to the record on this subject.-3/

Subsequent to the taking of that position, the Staff received amended petitions for leave to intervene from the EMC U and from Gardiner.E Both the EMC and Gardiner now assert that they would be directly affected by the siting of a nuclear power plant at New Haven since an accident at that site could "significantly increase the radiation to which citizens" of the Ulster County area would be exposed (Gardiner amended pctition, p. 2). Petitioners both rely principally on the report that radioactivity believed to have been 2/ NRC Staff Answer to Petitions to Intervene Filed in Columbia / Ulster County Area (April 2, 1979).

3/ NRC Staff Supplemental Answer to Petitions to Intervene filed in Columbia / Ulster

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County Area (May 2, 1979).

4j Letter of May 11, 1979 to Chairman Wenner.

-5/ " Amendment to Petition for Leave to Intervene in New Haven 1 and 2, And Alternates" (May 11,1979).

1013 142 z

. associated with the March 28, 1979 accident at Three Mile Island (TMI) was detected at Albany by the New York State Department of Health. Petitioners assert that this new evidence requires a change in the Commission's position

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as to the geographical area within which a person will be considered to be potentially affected by the operation of a nuclear power plant (Gardiner, p. 2; EMC, p. 1 ).

The geographical proximity test for standing was addressed by the Staff in its April 2,1979 answer to petitions (Staff Answer, sual at 3-5).

In summary, it has been held that a petitioner may base standing upon a showing of residence (or conducting of everyday activities) "within the geographical zone that might be affected by an accidental release of fission products". ff Although no specific distance from the plant has evolved to define the outer boundary of this geographical zone, it has been held that 50 miles "is not so great as necessarily to have precluded a finding of standing based upon residence".7/

The Staff estimated that the distance between the New Haven site and the nearest boundary of Ulster County is approximately 130 miles.

In order to assess whether the detection of radioactivity from TMI-2 at Albany dictates an expansion of the geographical area which will be deemed to be "affected" for purposes of determining standing, Charles M. Ferrell, a member of the Accident Analysis Branch of the NRC, has analyzed the information presented by petitioners. The results of his analysis are set forth in the attached affidavit.

pf Louisiana Power & Licht Co. (Waterford), ALAB-125, 6 AEC 371, 372 n. 6 (1973);

Gulf States Utilities Co. (River Bend), ALAB-183, 7 AEC 222, 226 (1974).

_7f Tennessee Valley Authority (Watts Bar), ALAB-413, 5 NRC 1418, 1421 n. 4 (1977).

1013 143

-4 Mr. Ferrell's review of the newspaper article cited by Gardiner and apparently also relied upon by EMC indicated that it stated:

1.

the radioactivity " posed no health threat";

2.

'1:i]ts radioactivity was 2 percent of the hourly dose that persons normally receive from naturally existing background radiation"; and 3.

the cumulative radiation for the two-day period when the gas cloud was tracked totaled about four one-thousandths of 1 percent of annual background.

Using these reported percentages and other data on natural background radiation Mr. Ferrell found that the cumulative dose from the TMI accident is a small percentage of reported variations in natural background.

Mr. Ferrell also stated that radioactivity from a release such as occurred at TMI can be expected to disperse eventually into a large part of the global atmosphere and that the radioactivity measured at Albany, which was at the lower end of detectability, is an indication of this pattern. Mr. Ferrell concludes that the information cited by EMC and Gardiner does not indicate that there would be any significant increase in radioactivity in the Ulster County area in the event of an accident of the type which occurred at TMI at the proposed New Haven plant.

On the basis of this affidavit, we do not believe that EMC and Gardiner have demonstrated any reason why the Commission's articulation of the geographical 1013 144

. area in which a person will be deemed to be pctentially affected by the eneration of a nuclear power plant should not still apply. Mr. Ferrell's affidavit indicates that the radioactivity released at TMI would be expected to disperse widely 4

into the global atmosphere and it follows that any impact associated with it would be " shared in substantially equal measure by all or a large class of citizens". !/ This type of asserted harm is a " generalized grievance" which, by itself, cannot confer standing on EMC and Gardiner. 9/ EMC and Gardiner have not, therefore, demonstrated an " interest" in this proceeding, such as to qualify them for intervention as of right. This does not, of course, change our previously expressed view that EMC and Gardiner should be granted discretionary intervention on the subject of Gardiner as an alternate site to New Haven.

g/ Edlow Internation Co., CLI-76-6, 3 NRC 563, at 576 (1976), quoting from Warth v. Seldin, 422 US 490, 499 (1075).

9/ Id.

1013 145

. III.

Status Report on Negotiation of Contentions,

Pursuant to the Joint Board's Order of April 30, 1979, all petitioners were directed to file supplements to their petitions for leave to intervene, including contentions, by May 11, 1979. The NRC Staff (and Applicant) responded on May 18, 1979 to those supplemental petitions which it had received on a timely basis. Working from the sets of contentions filed by the petitionerU,0]

Staff has carried on negotiations, principally by telephone, aimed at achieving agreements regarding the admissibility of contentions.

We have not yet been in contact with all of the Intervenors (petitioners), but have made significant headway in refining contentions of a number of them. We have been advised that a number of the Intervenors (cetitioners) have or are sendina to NRC Staff this week revised contentions.

Even if received prior to the filing of this pleading, we will not be in a position to indicate at this time whether we support or oppose the admission of these contentions.

In view of the large number of Intervenors (petitioners) involved and the substantial length of some of the lists of contentions, we propose that all 10 CFR 62.714 Intervenors (petitioners) be allowed until August 17, 1979 to file with the Board revised contentions and that NRC Staff and Applicant (and any other party wishing to do so) be allowed until August 31, lof At the May 23, 1979 prehearing conference the various Oswego area petitione s were admitted as Intervenors (or as interested governmental entities under 10 CFR 52.715(c)).

A decision on party status was deferred with respect to the Hudson Valley petitioners pending review of the late-received supplemental petitions of the EMC and Gardiner and of the briefs which any of the Hudson Valley petitioners may file on standing. Although the status of the Hudson Valley petitioners has not yet been ruled upon, the Staff has undertaken discussions regarding their contentions in order to make the best use of time available. The Licensing Board's ruling on their interest will, of course, clarify the areas which those petitioners may raise by contentions.

1013 146

. 1979 to file responses thereto,11/ We have discussed this time schedule with representatives of some of the Intervenors (petitioners) and with counsel for Applicants and none with whom we have spoken has any objection to it.

IN Although the initial discussions on refining contentions have been only between NRC Staff and the various Intervenors (petitioners), we intend to send a copy of revised contentions (as received) to Applicants' counsel.

We also intend to send a copy to PSC Staff counsel for distribution to agencies working on the DES.

1015 147

IV.

Response to Petition to Intervene Filed by Emerson Mead At the June 14, 1979, public comment session in this proceeding, Mr. Emerson Mead presented an oral statement requesting "to be an individual intervenor in this proceedings" and requesting "[a]s Town Supervisor in the Town of Conesville, Schoharie County;..[that] the Town be admitted as an intervenor." A written and signed copy of Mr. Mead's statement has since been sent to the service list in this proceeding (letter of June 19, 1979 from S. Lewis to Atomic Safety and Licensing Board). For the reasons set forth below, the NRC Staff submits that Mr. Mead's request should be denied.

In support of his petition, Mr. Mead stated that he is " concerned about all people within fifty miles of Stuyvesant as this is a real danger zone in case of a meltdown" and that "the town's water supply, farmland, the people and their homes would be in danger and no doubt destroyed by a nuclear meltdown at Stuyvesant." These statements of interest are, therefore, linked directly to the prospect of construction and operation of a nuclear power plant at Stuyvesant.

However, the application for a construction permit currently before the fluclear Regulatory Commission and the subject of this proceeding is for two nuclear reactors to be located at flew Haven, New York.

Decisions reached in this proceeding would not be binding upon future litigants who might participate in a proceeding snould an applicad na be filed for construction of a nuclear power plant at Stuyvesant.

See, Consolidated Edison Co. of N.Y., Inc.

(Indian Point fluclear Power Station, Units 1-3), ALAB-304, 3 ilRC 1 (1976).

1013 148

9-Accordingly, the statements of interest put forward by Mr. Mead do not, on oneir face, meet the requirements of 10 CFR 52.714(a)(2) that a petitioner set forth with particularity how his " interest may be affected by the results of the proceeding nor the interest requirement of 10 CFR 52.715(c) as.it might relate to the Town of Conesville.

As the above discussion makes clear, there is nothing in Mr. Mead's petition to favorably distinguish his allegation of interest from that of the other petitioners for intervention in this proceeding who are from the Hudson Valley area. Accordiagly, our discussions of remoteness from the proposed facility as it affects interest which are contained in our April 2,1979 response to petitions to intervene filed in Columbia / Ulster County area and in this filing, supra, apply to this petitioner as well.

The petition to intervene was presented to this Board approximately three months after the last day for filing of petitions to intervene provided for in the Federal Register Notice of Hearing (44 Fed. Reg. 8392) for this proceeding. Under the Commission's Rules of Practice, nontimely petitions to intervene will not be entertained absent a determination by the Board that the petition should be granted based upon a balancing of the five factors identified in 10 CFR 62.714(a)(1). The only reference made to nontimeliness in Mr. Mead's petition is the statement that he "only recently heard about this hearing." General statements that a petitioner was unaware of the Notice and the Commission's Rules of Practice do not constitute a showing of good cause 1013 149

for failure to file on time. See, Tennessee Valley Authority (Browns Ferry Nuclear Plant, Units 1 and 2), ALAB-341, 4 NRC 95 (1976). Although the

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petition also requests intervention for the Town of Conesville, the fact of a petitioner's governmental status will not, in and of itself, excuse untimely petitions to intervene. Public Service Co. of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-339, 4 NRC 20 (1976). Where no good cause is established for late filing, a petitioner's demonstration of reasons for admission to the proceeding should be particularly strong on the other four factors identified in 10 CFR 52.714(a)(1).

Puget Sound Power and Light Company (Skagit Nuclear Power Project), ALAB-552, (July 9,1979), slip opinion at 7.

On the basis of the petition before us, petitioner has made no showing on these factors. We believe, however, that petitioner should be afforded a reasonable opportunity to make such a showing.

With respect to other petitioners who are from the Hudson Valley area, we have supported a grant of discretionary opportunity to intervene limited to participation on the alternate sites issue. A discretionary grant of such intervention by the Board is, under the Comission's case law, to be based on the facts and circumstances of the case, with consideration given to the criteria set forth in 10 CFR 52.714(a) and 10 CFR 52.714(d). The primary consideration is whether a petitioner's participation would likely make a valuable contribution to the development of the record. Virginia Electric and Power Company (North Anna Power Station, Units 1 and 2), ALAB-363, 4 NRC 631 (1976). The other Hudson area petitioners are located at or very 1013 150

. near sites which have been identified as alternatives to the New Haven site.

Since we believed that they would therefore have special knowledge of those sites which would assist in the Commission's investigations, pursuant to the

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National Environmental Policy Act, of alternatives to the proposed action, we s'., ported their participation on that issue on a discretionary basis.

Mr. Mead's residence and the Town of Conesville, on the other hand, are apparently located some 35 miles from the nearest identified alternative site.

Further, there are already before the Board petitions to intervene from both private and public entities located much closer to that site (including the Town of Stuyvesant itself).

Nevertheless, as noted above, we believe Mr. Mead should be afforded t'te opportunity to demonstrate that he, individually, or the Town of Conesville can contribute to the compilation of a sound record and that their concerns will not be adequately represented by petitioners.from the Hudson Valley area (assuming they are admitted into the proceeding).

V.

Conclusion The Staff has provided responses, as set forth above, to the matters which the Licensing Board directed us to address.

We will respond to any briefs on standing filed by Hudson Valley petitioners by the August 3, 1979 response date established by the Licensing Board.

Respectfully submitted, D{

bW Stephe~ H. Lewis Counsel for NRC Stai f

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Marcia E. Mdlkey

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Counsel for NRC Staff 1013 151 Dated at Bethesda, Maryland this 13th day of July,1979.

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

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In the Matter of

)

NEW YORK STATE ELECTRIC & GAS CORP.

Docket Nos. STN 50-596 AND L0tlG ISLAND LIGHTING CO.

)

STN 50-597 (New Haven 1 and 2)

AFFIDAVIT OF CHARLES M. FERRELL I, Charles M. Ferrell, being duly sworn, do depose and state as follows:

1.

I am employed as a Site Analyst by the U.S. Nuclear Regulatory Commission in the Accident Analysis Branch of the Office of Nuclear Reactor Regulation.

I have prepared the following analysis of the assertions in the amended petitions of the Ulster County Environmental Management Council (EMC)

(May11,1979) and the Town of Gardiner (May 11,1979) regarding potential impacts of a radiological accident at the proposed New Haven site upon the Ulster County area.

2.

I have also prepared a statement of my Professional Qualifications which is attached hereto.

3.

I do not agree with the statement in the petitions that concludes that the Three Mile Island accident caused sionificant increases of radiation at distances of 200 miles from the plant.

The attached New York Times article of May 3,1979, was cited by the Town of Gardiner (p. 2) as the basis for this statement and EMC appears to be relying on the same information. My review of the article revealed that

~1013 152

- it did not imply that significant increases in exposure occurred at Albany; rather, it stated that no health threat was expected as a result of the cloud.

It went on to say that "its radioactivity was 2 percent of the hourly dose that persons normally receive from naturally existing background radiation." This amounts to a whole bo'dy dose rate of 0.000192 MR/ hour at Albany, New York. The total exposure, according to the New York Times article was four one-thousandths of 1 percent of the annual dose that an individual would receive from natural background radiation.

This accident dose in the Albany, New York area would be 0.00017 Mrem / year.

It should be noted that an individual in the Albany, New York area is exposed to natural radiation from three sources:

cosmic radiation, terrestrial radiation and natural radioisotopes from within his own body.

For an individual living in the Albany area, these sources produce a total exposure rate of about 84 Mrem per year.1/ The component contributors are: cosmic radiation, 40.9 Mrem / year; terrestrial radiation, 25.1 Mrem / year; and internal radiation, from such emitters as potassium 40,18 Mrem / year.

4.

The total exposure reported in the New York Times article is a small percentage of reported variations in background radiation.

For example, the NCRP report No. 45 " Natural Background Radiation in the United States -

November 15, 1975" indicates that in the area between Harrisburg, Pa.,

,1f "atural Radiation Exposure in the United States (OPR/SID 72-1), U.S.

Environmental Protection Agency, June 1972.

1013 153

-3 and Gardiner, NY, the terrestrial background radiation alone varies from 35 to 75 MR/ year. Radiation exposure can also vary substantially based upon such factors as the construction material of one's home. One study has indicated that the mean gamma radiation for a person living in a wooden house would be 74 MR/ year and in a brick house 126 MR/ year. 2/

5.

The release of radioactive materials such as occurred at Three Mile Island can be predicted to disperse eventually into a large part of the global atmosphere.where it will be removed by radioactive decay. The radioisotope Xe-133, which was detected at Albany, N.Y., has a half-life of 5.27 days.

I view the radioactivity measured at Albany, which was at the lower end of detectability, as an indication o.f this dispersion.

If similar equipment had been operating at other locations at comparable distances it might also have picked up such trace quantities.

6.

On the basis of these comparisons, I conclude that there was no significant increase of radiation exposure due to the Three Mile Island incident in the Albany, NY area, and therefore that there would be no significant increase in radiation to the town of Gardiner and to Ulster County even in the event of an accident of the type experienced at Three Mile Isla:d at the proposed New Haven Plant, which is located approximately 130 miles to the northwest of Ulster County.

2/ Background Radiation, A Literature Search, W. M. Lowder and L. R. Solon,

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UY EC, July 1956, NY0-4712.

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. 7 The statements contained in this affidavit and in my statement of professional qualifications are true and correct to the best of my knowledge and belief.

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4 Charles M. Fdrrell

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Subscribed and sworn to before me this /I day of G4

, 1979.

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My Commission expires:

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'jf,.y CHARLES M. FERRELL g

1 PROFESSIONAL QUALIFICATI0IlS

  1. 5 '

ACCIDENT ANALYSIS BRAfCH JC DIVISION OF SITE SAFETY AND ENVIRONMENTAL ANALYSIS 2m t.z

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.$5l I am a site analyst in the Accijent Analysis Branch, Division of Site Safety

.+W end Environmental Analysis, U.S. Nuclear Regulatory Commission. My present 55.5 duties in this position include the evaluation of site related environmental y

safety aspects of nuclear power generating facilities and design basis acci-9 dent analysis.

I graduated from Salem College in West Virginia in 1950 with

'~.4 a BS degree in physics and a teaching field also in chemistry, biology, and J..

mathematics. Upon graduation, I was drafted, and after completion of armored 7

infantry training at Fort Knox, Kentucky, was assigned as a military physicist M

to the Radiological Division of the U.S. Army Chemical Corp. at Edgewood, jf.t, Maryland.

I spent ap;'roximately two years in research involving nuclear weapon "O

~ thermal radiation, nuclear radiation shielding studies and fallout analysis.

,.l

.I was released from active duty and worked for two years as a civilian physi-

...;, j cist in Aerosol Physics (Aerobiology) Research at the U.S. Army Chemical Corps Biological Warfare Laboratory at Fort Detrick, Frederick Maryland.

In 1954

.4 I applied for and was granted an AEC Fellowship in Radiological Physics at

^;

Vanderbilt University and the Oak Ridge National Laboratory in Tennessee..An jnj a' dditional year of graduate work in physics was taken at West Virginia Univer-d'!g

'sity. Hight school classes in Nuclear Engineering from th6 University of

v.,

Maryland plus short sum.er courses from MIT in Air Pollution, Heat Transfer, and. Nuclear Power Reactor Safety constitute the remainder of my formal educa-f:1 tion.

In April, 1974, I completed a tuo week course in Pressurized Water

<A Reactor Systems at the Westinghouse Training Center in Monroeville, Pennsyl-vania.

I am a charter member of the Health Physics Society.

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I have been a member of the AEC.'s (now NRC's) Regulatory staff since 1956.

3-2

'Of these twenty-three years, five years were spent in duties involving the

.i safe industrial and medical use of radioisotopes, in the evaluation of

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spent reactor fuel shipping casks and the promulgation of reactor fuel f.Q shipping regulations.

Eight years were served as the Technical Assistant

.;3

~to the Office of Hearing Examiners, U.S. Atomic Energy Commission in which 4.-j I assisted in approximately 40 hearings on nuclear power reactors, fuel

4 reprocessing plants, and in addition contract appeals hearings on nuclear

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submarine components and nuclear equipment.

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In January.1969, I transferred to my present position. Since that time I have served as the site analyst on forty one nuclear power plants, two U.S. Navy nuclear submarine reactors and a proposed nuclear powered crude

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oil tanker.

I served as one of the technical reviewers of Chapter 7, a:.3

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" Assessment of Reactor Safeguards" in Acolied Radiation Protection and 7:M.

Control by J. J. Fitzgerald, published uncer tne auspices of the uivision gng.

of Technical Information United States Atomic Energy Commission.

--. - e I have testified in licensing hearings on six nuclear facilities. These

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include San Onofre 2/3, Beaver Valley Unit 1, Hutchinson Island (now 3Ed St. Lucie 1), Yellow Creek 1 and 2, Duane Arnold Unit 1 and Trojan Unit 1.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of

)

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Docket Nos. STN 50-596 NEW YORK STATE ELECTRIC & GAS CORP. )

STN 50-597 AND LONG ISLAND LIGHTING CO.

)

)

(New Haven l and 2)

)

STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE BOARD UN ELECTRIC GENERATION SITING AND THE ENVIRONMENT In the Matter of the Application of the

)

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)

NEW YORK STATE ELECTRIC & GAS CORP. )

Case 80008 AND LONG ISLAND LIGHTING CO.

)

)

(New Haven 1 and 2)

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CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF BRIEF ON STANDING OF HUDSON VALLEY PETITIONERS AND STATUS REPORT ON NEGOTIATION OF CONTENTIONS, in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, ' his 13th day t

of July, 1979.

Seymour Wenner, Esq., Chairman Thomas R. Matias, Administrative Law Judge Atomic, Safety and Licensing Board New York State Department of Public Service U.S. Nuclear Regulatory Commission Empire Stat Plaza Washington, D.C.

20555 Agency Building No. 3 Albany, New York 12223 Dr. Oscar H. Paris, Member Atomic Safety and Licensing Board Dr'. Sidney A. Schwartz U.S. Nucicar Regulatory Commission New York State Department of Washington, D.C.

20555 Environmental Conservation 50 Wolf Road Dr. Walter H. Jordan, Member Albany, New York 12233 Atomic Safety and Licensing Board 881 West Outer Drive Oak Ridge, Tennessee 37830 1013 159

_ Moderick Schutt, Esq.

. Atr. William Keeping, Supervisor Huber, Magill, Lawrence & Farrell Town of Gardiner 99 Park Avenue Gardiner, New York 12525 New York, New York 10016 Dr. Stephen J. Egemeier, Chairman Robert Grey, Esq.

Environmental Management Council State of New York Department 300 Flatbush Avenue of Public Service Kingston, New York 12401 Empire State Plaza Albany, New York 12223 Peter D. G. Brown Chairman of the Board Stanley B. Klimberg, Acting Counsel Mid-Hudson Nuclear Opponents New York State Energy Office P.O. Box 666 2 Rockefeller Plaza New Paltz, New York 12561 Albany, New York 12223 Mr. Alman J Hawkins David A. Engel, Esq.

County Planning Director New York State Department of Oswego County Planning Department Envircamental Conservdon 46 East Bridge Street 50 Wolf Road vswego, New York 13126 Albany, New York 12233 Ms. Barbara J. Campbell Ms. Linda Clark village Clerk Safe Energy for New Haven village of Mexico Box #22 - RD #1 P. O. Box 26 Mexico, New York 13114 Alexico, New York 13114 Ecology Action Richard P. Feirstein, Esq.

c/o Helen Daly Department of Agriculture and Markets W. River Road, RD #5 Albany, New York 12235 Oswego, New York 13126 Ms. Susan Link Mrs. Nancy K. Weber R.D.1, Dewey Road RD #3 Mexico, New York 11114 Mexico, New York 13114 Edward M. Barrett, General Counsel s

Robert J. Kafin Long Island Lighting Cempany Attorney for Columbia County, Town of 250 Old Country Road

,'~

Stuyvesant & Concerned Citizens for.

Mincola, New York 11501 Safe Energy. Inc.

11 Chester Street, P. O.

Box 765 Glens Falls, New York 12801 1013 160

Mr. Michael J. Hay Mark R. Gibbs, Supervisor New York State Electric & Gas Corp.

Town of Mexico 4500 Vestal Parkway East S. Jefferson Street Binghamton, New York 13902 Mexico, New York 13114 Henry G. Williams, Director of Thomas G. Griffen, Esq.

State Planning Town of Kinderhook New York State Department of State 542 Warren Street 162 Washington Avenue Hudson, New York 12534 Albany, New York 12231 G. Jeffrey Haber, Supervisor Samuel J. Abate, Executive Director 1777 Columbia Turnpike,

Hudson River Valley Commissiod Castleton, New York 12033 The Governor Nelson A. Rockefeller Empire State Plaza Ralph Schimmel, Representative Agency Building No: 1 Town of Cocymans Albany, New York 12238 Russell Avenue Ravena, New York 12143 Commissioner New York State Dept. of Health James P. McGrath, Esq.

attn: Director - Office of Public Health City of Oswego Tower Building - 14th Floor 38 East Utica Street Empire State Plaza Uswego, New York 13126 Albany, New York 12237 John D. Hotaling, President Commissioner Columbia Co. Fruit Growers New York State Dept. of Commerce R.D.1 99 Washington Avenue Hudson, New York 12534 Albany, New York 12245 Vivian Rosenberg Mr. Robert Fickies Box 274 Energy - Environmental Geology Walker Mill Road New York State Geological Survey Germantown, New York 12526 Education Building Annex Albany, New York 12234 Ms. Jeanne F. Fudala Ecology Action - Tompkins Co.

William Tyson, Executive Director 140 West State Street St. Lawrence - Eastern Ontario Commission Ithaca, New York 14850 317 Washington Street Watertown, New York 13601 Ms. Anne F. Curtin Concerned Citizens for Safe Energy, Inc.

Thomas E. Brewer, Director P.O.

Box 88 Rensselaer Co. Dept. of Health Stuyvesant, New York 12173 Troy, New York 12180 1013 161

Commissioner Orin Lehman Margaret A. Sprague, President New York State Dept. of Parks & Recreation

, Mexico Academy and Central School The Governor Nelson A. Rockefeller Mexico, New York 13114 Empire State Plaza Agency Building No.1 Doris Brown Albany, New York 12238 League of Women Voters of Tompkins County 86 Uak Crest Road H. Lee Davis, President Athaca, New York 14850 Citizens to Preserve the Hudson Valley, Inc.

Samuel R. Madison, Secretary P. O.

Box 412 New York State Department of Catskill, New York 12414 Public Service The Governor Nelson A. Rockefeller Mrs. Jeffrey Braley, President Empire State Plaza Columbia County Farm Bureau Agency Building No. 3 Star Route Box 22 Albany, New York 12223 Chatham, New York 12037 Atomic Safety and Licensing Clara Glenister, Town Clerk Board Panel Town of New Haven U.S. Nuclear Regulatory Commission P.O.

Box 115 Washington, D.C.

20555 New Haven, New York 13121 Atomic Safety and Licensing John F. Shea, Esq.

Appeal Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Department of Law Washington, D.C.

20555 Two World Trade Center New York, New York 10047 Docketing and Service Section Uffice of the Secretary Mr. Doug Buske U.S. Nuclear Regulatory Commission Plumbers & Steamfitters Washington, D.C.

20555 Local No. 27 R. D. #1 Oswego, New York 13126 Heilly and Like, Esgs.

200 West Main Street Babylon, New York 11702 John M. Mowry, Esq.

~

Mowry, Mowry & Seiter Main Street Mexico, New York 13114

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, ktW Stephef1 H. Lewis 10\\5 \\62

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