ML20032D022
| ML20032D022 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/05/1981 |
| From: | Heiner C WESTCHESTER PEOPLES ACTION COALITION, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8111130309 | |
| Download: ML20032D022 (4) | |
Text
1 UNITED STATES OF AMERICA
~
,,,,n NUCLEAR REGULATORY COMMISSION P TibAC.,
x before the ATOMIC SAFETY AND LICENSING BOILghIED C
.gg y -6 P2 d6 In the Matter of Consolidated Edison Company of I
Docket Number 50-QQu%'c, New York (Indian Point Unit 2) 1 0FFICE OF SE ge g
C00iF ilHG Power Authority of the State of 1
Docket Number 6O
' ' (h P
New York (Indian Point Unit 3)
/gV12 e8lg m
IJ tr %s,kf@
PETITION FOR LEAVE TO INTERVENE Nh 1.
The Westchester People's Action Coalition, Inc
$1so Nv-known as WESPAC, Petitioner, on its own behalf and on behalf of its members, hereby petitions the Nuclear Regulatory Commission (NRC) for leave to intervene in the above-captioned matter, pursuant 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 not-for-profit corporation consisting of organizations and individuals who are concerned about the qua-lity of life, peace, the environment, justice, and human sur-vival.
Our offices are at 255 Grove Street, White Plains, NY and our mailing address is Box 488, White Plains, NY 10602.
WESPAC has been working to close Indian Point through a wide range of approaches for over five years.
WESPAC is a person within the meaning of 10 CFR 2.4 (o), and represents approximat-ely two thousand households in Westchester County, all of whom are located within fifty miles of Indian Point.
3.
Petitioner represents the interests of its members and the individuals with whom it regularly communicates.
These individuals are directly affected by this proceeding since the intermittent operation of Indian Point Units 2 and 3 has affec-ted and will continue to threaten their personal safety as well as the nature and quality of their lives, their property and leasehold values, their employment and business interests.
In this proceeding, WESPAC seeks to intervene on behalf of itself and the followin,g named persons, all of whom are members of d
s 8111130309 811105 PDR ADOCK 05000247 Q
PDR I/
e-WESPAC PETITION TO' INTERVENE PAGE 2 j*
WESPAC, have specifically authorized WESPAC to represent their interest in the Indian Point hearings, and have a cognizable
~
interest in the outcome of the proceedings:
Alan Latman, Esq.
Alvin R. Warren 44 Sunset Drive 92 Dutch Street Croton-on-Hudson, N.Y. 18528 Montrose, N.Y. 18548 Susan B. Tr William M. McKeon Dr. Abe & Pat Levy 200 Fremont Street 49 Timber Ridge i '
Peekskill, N.Y.
18566 Mt. Kisco, N.Y. 18549 4.
Section 189(a) of the Atomic Energy Act, 42 U.S.C.
2239 (a) requires that the Commission admit as a party "any person whose interest may be affected by the proceeding."
Petitioner WESPAC requests leave to intervene to represent the interests of all its members and the above-named members in particular.
Petitioner's interes't that Indian Point Units 2 and 3 be' permanently closed, since their continued operation is a threat to personal and public health and safety, is clearly within the scope of the interests that the Atomic Energy Act was intended to protect.
- 5. Petitioner seeks leave to intervene with respect to the following specific
- issues, which will be expanded in more detail when we file formal contentions:
- a. The effects of a serious accident at the Indian Point site on public health, safety, the environment, and the economic--viability-of -Westchester--county.--- -
l b.
The implementability and conformance with NRC/ FEMA l.
guidelines of the emergency reponse plans for, Indian Point, I
both within the ten-mile Emergency Planning Zone and out-side it.
The inadequacy of warning
- systems, and the l
impracticality of evacuating the people residing in areas endangered by Indian Point.
The lack of facilities and l
resources for maintaining people once they are evacuated.
The inadequate and misleading information given to local j
citizens in advance and during a potential accident.
Other issues relating to emergency response.
c.
The energy, economic, and environmental effects of I
permanently closing the Indian Point nuclear facilities.
l l
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WESPAC PETITION TO INTERVENE PAGE 3 6.
For all the foregoing
- reasons, Petitioner WESPAC requests leave to intervene in the above-captioned proceeding pursuant to the NRC's January 8, 1981 Order, amended September 18, 1981, in regard to the Indian Point Units 2 and 3 nuclear power station in Buchanan, New York.
Respectfully submitted, Charles A. Scheiner Co-chairperson, WESPAC Dated:
November 5, 1981 Service list attached.
Westchester People's Action Coalition, Inc.
P.O.
Box 488 White Plains, New York 19602 914/682-0488 Of Counsel:
Alan Latman, Esquire 44 Sunset Drive Croton-on-Hudson, New York 19520 i
9 I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD In the Matter of 1
1 Consolidated Edison Company of I
Docket Number 50-247 New York (Indian Point Unit 2) 1 1
Power Authority of the State of I
Docket Number 50-286 New York (Indian Point Unit 3) 1 CERTIFICATE OF SERVICE I certify that I have served copies of WESPAC's Petition for Leave to Intervene on the following parties by first class mail, postage paid this fifth day of November, 1981.
A Samuel J. Chilk, Secretary Docketing and Service U.S. Nuclear Regulatory Comm.
.U.S.
Nuclear Regulatory Comm.
Washington, D.C.
20555 Washington, D.C.
20555 Louis J. Carter, Chairman-Office of Exec. Legal Director Atomic Safety & Licensing Bd.
U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Washington, D.C.
20555 Oscar H. Paris, Member Frederick J.
Shon, Member Atomic Safety & Licensing Bd.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Washington, D.C.
20555 Thomas Farrelly, Esq. _
Law Department _ _
Law Department Power Authority of N.Y.S.
Consolidated Edison of N.Y.
la Columbus Circle 4 Irving Place New York, New York 19019 New York, New York 19083 e
Ellyn R. Weiss, Esq.
Joan Holt, Director Union of Concerned Scientists Indian Point Project, NYPIRG 1725 Eye St.,
NW, Suite 506 5 Beekman Street Washington, D.C.
20036 New
- York, New York 19038 4
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