ML20032D018
| ML20032D018 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/06/1981 |
| From: | Blum J, Gilroy J, Holt J, Jordan W, Weiss E PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8111130306 | |
| Download: ML20032D018 (10) | |
Text
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DOCIET GU:JCE,7 PROD. & UIlL FAD.
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BEFORE TYE ALUiIC SAFEIY AND LICENSIE BOARD In the Matter of
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CONSOLIDATED EDISON CCMPANY OF NEW YORK
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Docket Nos.
(Indian Point Unit'2)
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50-247 POWER AUTHORITY OF TIE STATE OF IEW YORK
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50-286 (Indian Point Unit 3)
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fi JOINT PETITION FOR LEAVE TO IIIIERVENE u,,,g28 D
,y BY TIE UNION OF CONCERNED SCIENTISTS
'O' AND TIE NEW YORK PUBLIC INTEREST RESEAPCH GPOUk
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The Union of Concerned Scientists (UCS) and the New Public Interest Research Group, Inc., (NYPIRG), Petitioners, on their own behalfs and on behalf of their nere than 100,000 e ls, hereby petition the Nuclear Regulatory Camission (NBC) for leave to intervene in the above-captioned matter, pursuant to 10 CFR 2.714 of
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the NBC's Rules of Practice and to the Order of the Camission dated January 8, 1981, as amended Septerber 18, 1981.
2.
Petitioner Union of Concerned Scientists is a non-profit corporation organized under the laws of the District of Colurbia Its princigl office is in Ca:rbridge, Massachusetts, and it also naintains an office in Washington, D.C.
UCS is a coalition of N
scientists, engineers, and other professionals, supported by 95,000 5
citizen sponsors nationwide.
It performs independent studies on a 1i 8111130306 811106 PDR ADOCK 05000247 I
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2-range of topics concerning tha impacts of advanced. technology, including the nuclear weapons and nuclear energy programs, energy strategies, and radioactive waste disposal options.
UCS has been involved with safety. issues relating to the Indian Point reactors for the last five years.
3.
Petitioner New York Public Interest Ra aarch Group, Inc.,
is a not-for-profit, non-partisan research and advocacy organization established, directed, and suwoned by its New York State college and university st,*nt members.
NYPIBG's staff of lawyers, researchers, scientists and organizers works with students and other citizens, developing citizenship skills and shaping public policy. Consumer
. education, higher education, energy, fiscal responsibility, political reform and social justice are NYPIBG's principal areas of concern.
For the last year and a half, NYPIBG's staff has been conducting extensive research on problers relating to energency planning for the region surrounding the Indian Point reactors.
NYPIBG Iraintains seventeen campus and comunity offices within fifty miles of the Indian Point site.
4.
UCS and NYPIBG represent their own interests as organizations and those of their members.
Many members of both UCS and NYPIBG live c
in the vicinity of the Indian Point reactors and are directly affected by this proceeding since the operation of Indian Point Units 2 and 3 i
affects their personal safety as well as the nature and quality of their lives, their property and leasehold values, and their suployment and business interests.
In particular, an accident at Indian Point which involved releases or the threat of releases of radiation to the public h
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would affect our F+-Mls' personal safety'and health. UCS and NYPIBG seek to intervene in particular on behalf of those Rai=rs who have specifically authorized them to represent their interests in the Indian Point hearings before the Cemn4=sion. Those a--d--rs are:
A. UCS (All within 25 miles of Indian Point)
Rena Conley Chappaqua, New York, 10514 y
F1in % th Czoniczer Croton-On-Hudson, New York, 10520 Ieonard Jamhann Briarcliff Manor, New York, 10510 Violet Klosty Amonk, New York,10504 Odile Saisselin
- Mount Kisco, New York,-10549 l
B. NYPIRG (AllTwithin 50 miles of Indian Point)
Jodi Devido Peekskill, New York, 10566 Marla Ievenstein Bronx, New York, 10461 Iori Schreier Bayside, New York, 11364 Ellen D. Spilka Forest Hills, New York,11375 Virginia Rojack Bronxville, New York, 10'08 Joshua'Sesler Hartsdale, New York, 10530 Mark Grill Bronxville, New York, 10708 t
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5.
Section 189(a) of the Atanic Energy Act, 42 U.S.C. 2239(a) requires that the Camtission admit as a party "any person whose interest may be affected by the proceeding.."
UCS and NYPIRG request leave to intervene to protect their own interests and those of their members,' including those listed above.
UCS has long been active in nonitoring the hazards posed by the Indian Point reactors, and it effectively instituted this proceeding by the filing of its Petition for Decourissioning of Indian Point 1 and Suscension of Coeration of Units 2 and 3 on Septenber 17, 1979.
NYPIRG has for two years taken an active role in advocating the cannencement of these hearings.
Petitioners' interests that the continued operation of the Indian Point reactors not be allowed if the public health and safety carmot be reasonably assured is clearly within the scope of the interests that the Atanic Ew.rgy Act was designed to protect.
6.
Petitoners seek to intervene with respect to the following issues:
(a) hhether the energency planning for the protection of the public in the event of an accident at Indian Point (including accidents beyond the design basis for the Indian. Point units) is adequate to protect the public' health and safety.
(b) hhether the operation of the Indian Point reactors would be inimical to the public health and safety in light of-the lack of any requirenent for energency planning beyond the 10-mile Emergency Planning Zone (EPZ) to protect the public health and safety in tM event of an accident (including accidents beyond design basis for the Indian Point units), and in light of the lack of any actual energency planning beyond the 10-mile EPZ.
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(c) htether " future" and " feasible" i::provements to energency planning, both inside and outside the 10-mile EPZ will be adequate to protect the public health and safety in the event of an accident at Indian Point (including accidents beyond the design basis for the Indian Point units).
(d) hhat are the energy, econornic, enviremental, and other consequences of an accident at Indian Point?
(e) hhat are the individual and societal consegaences of an accident at Indian Point (including accidents beyond the design basis of the Indian Point units) on the health, safety and property of the population surrounding the Indian Point site?
7.
For tnese reasons, UCS and NYPIPS jointly seek leave to*
intervene in the abcve-captioned hearings.
Respectfully subnit*M, Z A t. % /9 m f; Ellyn H. Weiss YE
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William S. Jordan, III m
st Jeffrey M. Bltn Harmon & Weiss, Suite 506 1725 I Street, N.W.
Washington D.C. 20006 For the Union of Concerned Scien*ists.
and 1
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'J Holt, Project Director
'an Point Project New York Public Interest Research Group 5 Beekman Street New York, New York, 10038
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JohntGilroy, Westcheis g Coordinator Ldin Point Project New York Public Interest Research Group 240 Central Avenue White Plains, New York, 10606' For the New York Public Interest Research Group, Inc.
Dated: November 6, 1981.
Service list attached.
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UNITED STATES OF AMERICA NUCLEAR RTUIAICRY COMMISSION BENRE 'HE ATQ4IC SAFLTl AND LICD; SING B2AFD In the Matter of CDNSOLIDAZD EDISON CCr@ANY OF NB1 YORK Docket 50-247 and PCHER AU'DiORITY OF THE STATE OF NEN YORK Docket 50-286 Service for the Union of Concerned Scientists and the New York Public Interest Research Group, Inc, is requested at the following addresses:
For the Union of Concerned Scientists:
Ellyn R. Weiss, Esq.
William S. Jordan III, Esq.
Harmon & Weiss, Suite 506 1725 I Street, N.W..
Washi p., D.C., 20006 Jeffrey M. Blun, Esq.
New York University Law bchool 423 Vanderbullt Hall 40 Nashington Square South New York, New York, 10012 For the New York Public Interest Research Group, Inc.:
Joan Holt, Project Director Indian Point Project, NYPIRG 5 Beejcran Street i
New York, Nea York, 10038 Johh Gilroy, Westchester Coordinator Indian Point Project,INPIRG i
l 240 Central Avenue Khite Plains, New York, 10606
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CONSOLIDATED EDISON COMPANY OF NEW YORK
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Docket Nos. 50-247 (Indian Point, Unit 2)
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50-286
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POWER AUTHORITY OF THE STATE OF NEW YORK )
(Indian Point, Unit 3)
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AFFIDAVIT OF ROBERT D. POLLARD I, Robert D. Pollard, having been sworn, hereby make my affidavit as follows:
I personally spoke to all of the UCS sponsors named in the Joint Petition for Leave to Intervene by the Union of Concerned--
Scientists and the New York Public Interest Research Group.
All of the named UCS' sponsors specifically authorized the Union of Concerned Scientists to represent their interests in this proceeding.
I affirm that the foregoing is true and accurate to the best of my knowledge and belief.
Robert D. Pollard
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Subscribed and sworn before me
-this 4th day of November, 1981:
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UNI 2ED STA2ES OF MERICA NUCLEAR PEGULA W. G3MMISSION BEFORE 'IEE ~ ATOMIC SAEETY AND LINING BOAPD In the Matter of
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CNSOLIDA7ED EDISCN G2@ANY OF NEW YORK
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IbChet Nos. 50-247 (Indian Point thit 2)
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50-286
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POWER NmDRITY OF THE STATE OF NEW YORK (Indian Point Uhit 3)
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AFFIDAVIT OF IAN IOLT I, Joan Ibit, having been swom, hereby make my affidavit as follows:
. All of the NYPIEG nebers named in the Joint Petiticn for Leave t Intervene by the thicn of (bncerned scientists and the New York Public Interest Pesearch Group haw been spoken with by nacers of my staff inder my personal supervision. All of the ramed hWIRG nubers specifically authorimd the New York Public Interest Pesearch Group to represent their interests in this proceeding.
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I affirm that the fbregoing is true and accurate to the best of my knowled;re and belief.
j Ar E
Jo
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5 Subscribed and swom tofbre me a
this 6th day of Ibwnber,1981:
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GENE RUSSIANO Notary Publ.c. State of New York No. 24-4703499 e-Quahhed in Kince County Certifica:e f. led in New Ycrk County 7:
Commission Emires 7^4=h 30.19 m
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CERTfFICATE OF SERVICE In the Matter of:
CONSOLIDATED EDIS0N COMPANY OF NEW YORK Docket 50-247 and POWER AUTHORITY OF THE STATE OF NEW YORK :
Docket 50-286 I certify that I have served copies of JOINT PETITION FOR LEAVE IO INTERVENE BY THE UNION OF CONCERNED SCIENTISTS AND THE NEW YORK PUBLIC INTEREST RESEARCH GROUP on the following parties by first class mail, postage paid, this 6th day of November,1981.
p Jh Joan/}olt, Project Director IndiM Point Project New York Public Interest Research Group 5 Beekman Street New York, New York, 10038 Samuel J. Chilk, Secretary General Counsel U.S. Nuclear Regulatory Commission Conso'iidated Edison Company Washington, D.C. 20555 4 Irving Place New York, New York, 10003 Louis J. Carter, Chairman, ASLB l
U.S. Nuclear Regulatory Commission General Counsel Washington D.C. 20555 Power Authority of the State of New York Oscar H. Paris, Member, ASLB 10 Columbus Circle U.S. Nuclear Regulatory Commission New York, New York, 10019 Washington, D.C. 20555 Ezra Bialik, Esq.
l Frederick J. Shon, Member, ASLB Steve Leipzig, Esq.
U.S. Nuclear Regulatory Commission Environmental Protection Bureau Washington, D.C. 20555 N.Y. State Attorney General's Office Two World Trade Center l
Docketing and Service New York, New York, 10047 U.S. Nuclear _ Regulatory Commission Washington, D.C. 20555 Ellyn R. Weiss, Esq.
William Jordan. Esq.
Office of the Executive Legal Director
- Jef frey Blum, Esq.
U.S. Nuclear Regulatory Commission Harmon and Weiss', Suite 506 Washington, D.C. 20555 1725 Eye Street N.W.
Washington, D.C. 20006 i
- by hand.
L.