ML20032C989

From kanterella
Jump to navigation Jump to search
Petition of Greater Ny Council on Energy to Intervene in Proceeding
ML20032C989
Person / Time
Site: Indian Point  
Issue date: 11/06/1981
From: Corren D
AFFILIATION NOT ASSIGNED
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8111130278
Download: ML20032C989 (6)


Text

._

.~

a DOCIET GUMDEit

'~

UNITED STATES OF Af1 ERICA Pn0D.& UTIL FAC.s.m...c --

00LKETED NUCLEAR REGULATORY COMMISSION USNRC l

11 NOV -9 P2 sf BEFORE THE AT0f1IC SAFETY AND LICENSING BOARD Louis J. Carter, ChairmanI5kfi$3[shiqg.

3 v

Oscar H. Paris, Member BRANCH Frederick J. Shon, Member In the liatter of

)

g

)

/sy 4' x CONSOLIDATED EDISON C0f1PANY OF NEW YORK

)

Docket',tos y t[

(Indian Point Unit 2)

)

5?,247/dp 50 28#0V2 219s[-

POWER AUTHORITY OF THE STATE OF NEW YORK

)

\\t/

g (Indian Point Unit 3)

)

0,][

}&'/

PETITI0f1 FOR LEAVE-TO INTERVEllE 1.

The Greater New York Council on Energy, Petitioner, requests leave to intervene in the hearings of the Nuclear Regulatory Comission on Indian Point Units 2 and 3, which are Ordered by the Comission in its January 8,1981 Order, amended September 18, 1981.

Petitioner requests leave to intervene pursuant to 10 CFR 2.714, of

~~

the NP.C Rule's of._ Practice. " ~

2.

The Greater New York Council on Energy (GNYCE) is an organization for the exchange of iriformation and ideas among individuals and citizens groups concerned with energy and its environmental implications. The aim of the Council is to promote the use of appro-priate technology in energy-- that is, the simplest technology applicable to a task, consistant with safety, long-term reliability,

~

efficiency, conservation of resources, maximum employment, and 9 03 J

1(

DOKo!hhhhk7

.o PDR

' 2-with democratic principles.

Members of GNYCE include _ individuals.

and representatives of citizens' groups throughout'the greater metropolitan area of New York City.

3.

Petitioner GNYCE seeks leave to intervene to protect the interests of its members, including those named below.

Continued operation of the Indian Point reactors affects the personal health and safety of-GNYCE's members, as well as their employment, professional, and business interests.

In addition, an accident at Indian Point could severely affect the personal health and safety of Petitioner's members, including those named below, and would also affect the long-term economic health of New York City and environs, wherein Petitioner's-members reside. Among the members whom Petitioner seeks leave to represene before the Commission are:

Lindsay Audin 1 Everett Avenue Ossining, New York,10562 Joseph Franceschi R.D. 2, Route 312 Brewster, New York,10509 Hannah Powsner L

88 Horatio Street l

New York, New York,10014 I

l l

l

{

_3 y

i e

- 4.-

Petitioner GNYCE specifically seeks leave to present ~

testimony _and participate on the following interests, in accordance with the Order of the Commission which set forth the Commission's areas of interest:

(a) What are the energy consequences for the New York City greater metropolitan area of an accident or sabatoge at Indian Point Units 2 and 3.

(b) What are the economic consequences 'for the New York City greater metropolitan area of an accident or sabatoge at Indian Point Units 2 and 3.

(c) Whether emergency planning is capable of mitigating the er,ergy, economic, environmental or other consequences of an accident at Indian Point, and what are the-" future and feasible improvements" to emergency planning to mitigate the energy, economic, environmental or other consequences of an accident at Indian Point Units 2 and 3.

i i

k E

5 2

1

=

fi

?

s

+

55 5e i

t -

5.

For the foregoing reasons, Petitioner Creater New York Council on Energy requests leave to. intervene to protect the interests of its members, as permitted by the Atomic Energy Act.

Respectfully submitted, i

MLY-

, /,

Dean R. Corren, Director Greater New York Council on Energy c/o Dean R. Corren New York University 26 Stuyvesant Street New York, New York, 10003 November 6, 1981.

Service list enclosed.

e

~ _ _. _ _.. _ _ _... _. _ _ _

e PETITION FOR LEAVE TO INTERVENE GREATER NEW YORK COUNCIL ON ENERGY SERVICE LIST NOVEMBER 6, 1981 Samual J.

Chilk Joan Holt Secretary

. Indian Point Project U.S.

NRC NYPIRC Wa s hing ton,

D.C.

24555 5 Beekman St.

New-York, NY 10038 Louis J.

Carter Chairman, ASLB Ellyn R, Weiss U.S.

NRC Harmon and Weiss

'a'a s h i n g t o n,

D.C.

20555 1725 I St. NW Suite 506 Washington, D.C.20006 Frederics J.

Shon Member, ASLB U.S.

NRC Washington,-D.C 20555 Oscar H.

Paris Member, ASLB U.S.

NRC Washington, D.

C.

20555 Officelof the Executive Legal Director U.S.

NRC Washington, D.C.20555 Docketing and Service U.S.

NRC Washington,.D.C.20555 General Co unsel l

PASNY 10 Columbus Circle New York, NY 10019

[

General Co un sel Consolidated Edison 4 Irving Place New York, NY 10003

5.

For the foregoing reasons, Petitioner Greater New York Council on Energy requests leave to intervene to protect the interests of its members, as permitted by the Atomic Energy Act.

Respectfully submitted, Dean R. Corren, Director Greater New York Council on Energy c/o Dean R. Corren

.New York University 26 Stuyvesant Street New York,'New York,10003 November 6, 1981.

Service list enclosed.

W

_ - - _ _ _. - -. _. _ -, - _ _ - - - _. - - _ _. ~ - _

-_