ML19224A699

Petitions to Intervene in Proceeding.Asserts Health & Safety Will Be Adversely Affected by Plant

ML19224A699
Person / Time
Site:	New Haven
Issue date:	03/08/1979
From:	Daly H, Weber S ECOLOGY ACTION OF OSWEGO
To:
References
NUDOCS 7905250353
Download: ML19224A699 (3)

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______ ___________; NUCLEAR REGULATORY3/ CCMMISSIC'P In the matter et ) -

) Docket No. SIN 50-596 and 597 New York State Electric and Gas Co. )

and Long Island Lighting Co. ) PETITION TO INTERVENE NYSEG 1 and 2 )

__________________y Petitioner, Ecology Action, individually and in behalf of the members of Ecology Action and of the public, hereby petition to intervene 21 this proceeding pursuant to Section 189 of the Atomic Energy Act of 1954, as a=ented, Sections 5 & 6 of the Administrative Procedure Act, as amended, and Section 2.714 f the Nuclear Regulatory Co==ission Rules of 'ractice.

1. Ecology Action is an unincorporated association of private citicens residing in the area of Oswego, New Yerk, formed to conserve and to protect the natural resources and physical enviren=ent of the region, including Lake Ontario.

2. Since its formation in January, 1971, Ecology Action has actively sought to promote and represent the public interest in protecting the Central New York 2nviron=ent fro: unwarranted and unlawful exploitation and degradation by public utilities (including the Applicant) intent upcn using the region for the generation and transmission of vast arounts of electricity for co mucption elsewhere ih New York State and the United States. In this regard, Ecology Action's purposes would be thwarted by the construction of new generating or transmission capacity in the region in violation of existing law.

3. In pursuance of its objectives, Ecology Action has conducted an educational ca=paign to apprise the people of the region of the environ = ental effects of the large-scale generation of pcwer and of the health and safety hazards incident thereto.

Ecology Action has intervened in Proceedings of the State of New York Public Service Con =ission under Article VIII, in Case 80005 (Sterling nuclear plant), and under Article VII, Case 26559 (765 kv transmission through Sterling), and in Proceedings before the Atc=ic Energy Cc==ission and Nuclear Regulatory Co==ission, Docket No.

STN 50-410 (Nine Mile Point d2), STN 50-485 (Sterling nuclear plant di). The purpose D ' Af mfi$ .

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2 of c:ch interventions were, and are, to help develop a complete evidentiary record, in the public interest, sufficient to enable the approprate Ce==issions to evaluate the need for such facilities, and the environmental impact of their construction.

4 The =e=bers of Ecology Action are residents, variously, of the City of Oswego, and Towns of Oswego, Minetto, New Ha'ren, Fair Haven, Sterling, and Hannibal.

Each of these persons reside, and =ost own real property, within the zone that would be affected by a =ajor accident at the Applicant's plant, and would be seriously, if not fatally, inju.ed by such an accident. Me=bers would also be subject to injury from lesser releases of radioactivity frc= the facility. Furthermore, =any of Ecology Action's =e=bers use the Lake and its beaches for a variety of recreational and aesthetic purposes, including swi==ing, boating, fishing, and birding.

5. All of the a ,rementioned interests of petitioners =ay be affected by this proceeding. The petitioner's interests in health and safety will be adversely affected by radiological ha:ards incident to nor=al plant operation, associated activities such as the storage and transport of highly toxic wastes, and by the possibility of accident in connection with plant operations or such associated activities, unless all issues of design safety, quality assurance, and emergency plans are fully explored and soundly resolved. In addition, the petitioners aforesaid interests as well as their interests in the quality of Lake Ontario will be adversely affected unless the environmental impact, and alternative to, the proposed plant is thoroughly considered, the benefit-crst analysis of the proposed plant is fairly made and the permit applied for herein, if issued, is appropriately conditioned to protect environmental values.

6. Petitioners should be permitted to intervene since they have a statutory right to intervene under the Atomic Energy Act of 1954, as amended, and under the ad=inistrative procedure act, as amended, since their health and safety (as well as health and safety of the public whose interests they seek to represent) may be adversely affected by the results of this proceeding and since their interests in 452 0455

3 environ = ental values (as well as the public's interest in environmental values which petitioners seek to represent) nay also be adversely affected.

'4herefore Petitioners respectfully request that the within petition to intervene be granted, in all respects.

M l Suzanneuieber , c' resident Ecology Action

\ R$.u Helen Daly, Ecology Ahtien Intervention Coordinater March 3, 1979 Service address Ecology Action c/o Helen Daly

'4 . River Fd. RD #5 Oswego, N.Y. 13126 452 M6