ML20032D009
| ML20032D009 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/06/1981 |
| From: | Thorsen E ROCKLAND COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20032D005 | List: |
| References | |
| NUDOCS 8111130296 | |
| Download: ML20032D009 (5) | |
Text
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DCCKETED USHRC E
UNITED STATES OF AMERICA NOV -9 P2:51
. NUCLEAR REGULATORY COMMISSION m,q;? r nCR TAny j
74 BEFORETHEATOMICSAFETYANDLICENSINGBdARDyjfCfi I
In the Matter of
)
[,ConsolidatedEdisonCompanyofNewYork
)
j; (Indian Point Unit 2)
)
Docket Nos.50-247
)
50-286 Power Authority of the State of New York )
l li-(Indian Point Unit 3)
)
I r
?
'I PETITION FOR LEAVE TO INTERVENE j
1.
The County of Rockland, also known as Rockland, 1;
i Petitioner, on its own behalf and on behalf of its citizens and members, hereby petitions the Nuclear Regulatory Commission v4 (NRC) for leave to intervene in the above captioned matter, i pursuant to 10 CFR 2.714 of the NRC's Rules of Practice and to the NRC's Order dated September 18, 1981.
i i
2.
Petitioner is a municipality with an office for the 5]'
transaction of business at 11 New Hempstead Road, New City, New York.
It is a person within the meaning of 10 CFR 2.4(o).
t I
Petitioner represents approximately 250,000 individuals who live {
t within its borders.
Rockland County is situated on the west i
i bank of the Hudson River; its geographical center lies 33 miles y,
il north of the Manhattan business district of New York City.
I f
I f Within 20 miles of Rockland County lies the Hudson River Valley I
htothenorth,WestchesterCountyandConnecticuttotheeast, 8111130296 811106
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hDRADOCK 05000247 PDR
il Northern New Jersey to the south, and Orange County to the west.
i Rockland. is a triangle of about 176 square miles, 18x19x20 miles oniits borders. A substantial portion of Rockland County is
'l located within a ten mile radius of Indian Point Units 2 and 3 t
I and approximately 114,000 of Petitioner's citizens live within
[ the Emergency,' Planning Zone.
i 3.
Petitioner represents the interests of its citizens and members, and the individuals with whom it regularly communicates. i These individuals are directly affected by this proceeding, since the operation of Indian Point Units 2 and 3 has affected, and will' continue to affect their health and personal safety, as well as the: nature and quality of their lives, their property and leasehold values; their employment and business interests.
O In this proceeding, Petitioner, the County of Rockland, seeks to I.
l intervene.on behalf of itself and the following persons, all of i
whom are both citizens and public officials of the Petitioner,
' and who have specifically authorized the County of Rockland to i
l l
represent their interests in the Indian Point hearings, and all ji of whom who have a cognizable interest in the outcome of the proceeding.
I J HN T. GRANT, Chairman of the Rockland County i
j, Legislature, Birch Drive, Thiells, New York
~!
j DR. DANIEL HYMAN, Rockland County Commissioner I
l of Health, Pomona Health Complex, Pomona, N w York j
e i
ii H
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.s' e
'A DONALD A. HASTINGS, Fire Coordinator, Fire Training Center, Pomona, New York 1
4 Section 189(a) of the Atomic Energy Act,
,i 4.
42 U.S.C.
l 2239(a) requires that the Commissioner admit as a party l
any
[
t person whose interest may be affected by the proceeding "
Petitioner, County of Rockland, requests leave to repr
-i esent the I
interests of its citizens and members, and the inter ests of the above named individuals in particular.
Petitioner's interest li that Indian Point Units 2 and 3 not continue operation I
it i
until
!j protection of the public health and safety can be reas P
onably
. assured, is clearly within the scope of the interests that the
., Atomic Energy Act was intended to protect.
U 5.
Petitioner seeks leave to intervene with respect to the
' following specific issues:
All issues ~regarding the health, safety and welfare of the citizens of Rockland County, including the following:
(A)
The current status and degree of conformance l,
with NRC/ FEMA guf.delines of state and local emergency planning within the ten mile radius of the site, and of the extent that it is
- relevant,
.'i a ten mile radius.to risks posed by the two plans beyond P
a (B)
The improvements in the level of emergency i
planning which can be expected in the near future, the time schedule involved, and whether there are other specific offsite emergency i
procedures that are feasible and should be taken to protect the public.
- I ii
I 6.
For all the. foregoing reasons, Petitioner requests i
I leave to intervene in the above captioned proceeding, j
pursuant to the NRC's January 8, 1981 Order, amended l
September 8, 1981, in regard to the Indian Point Units 2 and 3 Nuclear Power Station.
ii s
9 Dated:
New City, New York l
l November 6, 1981 Respectfully submitted, l
1[l MARC L. PARRIS, Esq.
County Attorney j.
11 New Hempstead Road New City, New York 10956 (914) 425-5180
}
By:
ERIC OLE THORSEN of Counsel Ir.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING B0nRD In the Matter of
)
)
Consolidated Edison Company of New York
)
Docket Nos. 50-247 (Indian Point, Unit 2)
)
50-286
)
Power Authority of the State of New York )
(Indian Point, Unit 3)
)
CERTIFICATE OF SERVICE I certify that I have served copies of:
on the following parties by first class mail, postage paid this day of
, 1981.
Semuel J. Chilk, Secretary Ellyn R. Weiss, Esq.
U.S. Nuclear Regulatory Commission Union of Concerned Scientists Washington, D. C. 20555 1725 Eye Street, Suite 506 Washington, D. C. 20036 Louis J. Carter, Chairman Atomic Safety and Licensing Board Docketing and Service U.S. Nuclear Regulatory Commission U.S. Nuclear Regula tory Commission Washington, D. C. 20555 Washington, D. C. 20555_
- Oscar H. Paris, Member Office of the Executive Legal Atomic Safety and Licensing Board Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Frederick J. Shon, Member Counsel for Consolidated Edison Co.
Atomic Safety and Licensing Board Brent Brandenberg, Esq.
U.S. Nuclear Regulatory Commission 4 Irving Place Washington, D. C. 20555 New York, New York 10003 Joan Holt, Director Indian Point Project, NY PIRG 5 Beekman Street N:w Yorkn New York 10038
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