ML20032C967
| ML20032C967 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/04/1981 |
| From: | Salzman L FRIENDS OF THE EARTH |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8111130260 | |
| Download: ML20032C967 (4) | |
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DOCKET UUEER PROD. & UTIL FAC.kNMt.b.m UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION hg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Y%
In the Matter of Il G I' R'/
N V CE Consolidated Edison Company of New York )
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-(Indian Point, Unit 2)
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Docket Nos. 50-247 50-286-jy C
Power Authority of the State of New York )
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(Indian Point, Unit 3)
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PETITION FOR LEAVE TO INTERVENE
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The Friends of the Earth, Inc., also known as F0E, Petitioner, on Tts own behalf and on behalf of its members, Tereby petitions the Nuclear Regulato-ry Commission (NRC) for leave to intervene in the above captioned matter, pur-suant to 10 CFR 2.714 of the NRC's Rules of Practice and to the NRC's Order dated September 18, 1981.
2.
Petitioner is a national ewironmental group located at 208 West 13th Street, New York, New York 10011. It is a person within the meaning of 10 CFR l
2.4 (o). Petitioner represents 28,000 members nationally and approximately 4,000 in New York State, all of whom pay dues to the national headquarters at i
124 Spear Street, San Francisco, California 94105, and some of whom also pay l
dues to the regional chapter in New York, which serves New York State.
Its primary purposes are public education, lobbying and influencing legislation, l
.:nd publishing, and litigation and monitoring of government administrative ac-l tions and implementation.
Past legal involvement includes the Vallecitos reac-tor at Livermore, California; the proposed Exxon reprocessing plant at Oak l
Ridge, Tranessee; Rancho Seco and Diablo Canyon plants in California; the
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l Shoreham, Long Island, reactor at Wading River, New York.
Friends of the i
l Earth's expertise and continual involvement in nuclear power safety issues will greatly assist in the development of a complete hearing record.
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l hDRADOCK 05000247
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Pett:ioner represents the interests of its members and the individuals wxch whom-it regularly communicates. These individuals are directly affected by this proceeding since the operation of Indian Point Units 2 and 3 has af-facted and will continue to affect' their personal safety as well as the nature and quality of their lives, their property and leaseho'.d values, their employ-ment and business interests.
In this proceeding, Petitioner Friends of the i
Earth seeks to intervene on behalf of itself and the'iollowing named persons, all of whom are sponsors or members of F0E and who have specifically authorized FDE to represent their interest in the Indian Point hearings and all of whom have a cognizable interest in the outcome of the proceedings:
1 Anthony Bambace 100 Columbus Avenue Tuckahoe, Aaw York 10707 i
Dr and Mrs. Paul-Bradlow 43 Charlton Street New York, New York 10014 Mildred M. Barker R.R. 2, Box 501 Kerhonkson, New York 12446 e
Carol Gorraan l
10 Hilliard Avenue Edgewater, New Jersey 07020 t
j Philip Powers 251 West 97th Street New York, New York f
Polly Rothstein l
Lincoln Avenue Purchase, New York 10577 l
4.
Section 189(a) of the Atomic Energy Act, 42 U'.S.C. 2239 (a) requires I
that the Commission admit as a party "any person whose interest may be affected by the proceeding".
Petitioner F0E requests leave to intervene to represent 4
the interests of its own members, and the interests of the above named mer.osrs f
in particular. Petitioner's interest that Indian Point Units 2 and 3 not con-tinue operation until protection of the public health and safety can be reason-
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ably assured is clearly within the.ecope of the interests that the Atomic Ener-gy Act was intended to protect.
5.
Petitioner seeks leave to intervene with respect to the following spe-cific issues:
- 1) Existing alternative strategies in place of continued operation of the Indian Point nuclear plants;
- 2) Economic and social benefits of such alternative strategies;
- 3) Inadequacy of the Indian Point emergency plans;
- 4) Inability of licensees and localities to implement a plan that could significantly reduce public risk;
- 5) Probability of catastrophic accident not low enough to permit con-tinued plant operation in any time frame;
- 6) Continued plant operation and national security are incompatible.
6.
For all the foregoing reasons, Petitioner requests leave to intervene in the above captioned proceeding pursuant to the NRC's January 8,1981, order, amended September 8, 1981, in regard to the Indian Point Units 2 and 3 Nuclear Power Station.
Respectfully submitte,
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Lorna Salzman Mid-Atlantic Representative Friends of the Earth Dated: November 4, 1981 i
Service list enclos,J Y
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UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Consolidated Edison Company of New York )
(Indian Point, Unit 2)
) Docket Nos. 50-247 Power Authority of the State of New York 50-286 (Indian Point, Unit 3)
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CERTIFICATE OF SERVICE I certify that I have served copies of Petition to Intervene on the fol-lowing parties by first class mail, postage paid, this 4th day of November 1981.
Samuel J. Chilk, Secretary U.S. Nuclear Regulatory Commission Office of Executive Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Louis J. Carter, Chairman Atomic Safety and Licensing Board Counsel for Consolidated Edison Company U.S. Nuclear Regulatory Commission Washington, D.C. 20555 c/o Secretary of the Commission U.S. Nuclear Regulatory Commission Oscar H. Paris, Member Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Counsel for Power Authority of New York Washington, D.C. 20555 c/o Secretary of the Commission l
l Frederick J. Shon, Member U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 j
U.S. Nuclear Regulatory Commission l
Washington, D.C. 20555 Joan Holt, Director Indian Point Project Ellyn R. Weiss, Esq.
New York Public Interest Research Group Union of Concerned Scientists 1725 Eye Street, Suite 506 5 Beekman Street i
j Washington, D.C. 20036 New York, New York 10038 Ezra Bialik, Esq.
Docketing and Service Steve Leipzig, Esq.
I U.S. Nuclear Regulatory Come.ssion Washington, D.C. 20555 Office of the Atto"ney General of the State I
l of New York
- i 2 World Trade Center, New York, N.Y.10047 i
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