ML20039A582

Amended Petition to Intervene of Ny State Assembly & Special Committee on Nuclear Power Safety.Affidavits & Notice of Appearance in Proceeding Encl

ML20039A582
Person / Time
Site:	Indian Point
Issue date:	12/08/1981
From:	Roffe A NEW YORK, STATE OF
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20039A583	List: ML20039A582 ML20039A588 ML20039A590
References
ISSUANCES-SP, NUDOCS 8112180458
Download: ML20039A582 (6)

Text

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UNITED STATES OF AMERICA -- ,- y e> i ? - NUCLEAR REGULATORY COMMISSION T.'

s-g ATOMIC SAFETY AND LICENSING BOARD

- .;ciED 3i 'I ~~' 11 P2:37

/,AA f, - r Administrative Judges:

5 DEC17193* C Louis 3. Carter, Chairman

y. g.gw,scts -4 wasa*ecs u Dr. Oscar H. Paris j g Frederick 3. Shon N

• In t. e . atter of CONSOLIDATED EDISON COMPANY OF NEW YORK Docket Nos. 50-247-SP (Indian Point, Unit 2) 50-236-SP POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit 3)

December 3,1931 AMENDED PETITION TO INTERVENE Pursuant to Nuclear Regulatory Commission Memorandum and Order dated Octo-ber.1,1981, the New York State Assembly and the Special Committee on Nuclear Power Safety thereof, respectfully request leave to intervene in the above entitled action for the reasons as set forth as follows:

1. The New York State Assembly is one house of a separate and co-equal branch -

of the government of the State of New York. Stanley Fink is the Speaker of the New York State Assembly, duly elected by the full membership of the body. The Special Committee on Nuclear Power Safety, duly appointed and chaired by the Speaker of the Assembly pursuant to sections 1.c.(1) and 1.h., Rules of the Assembly, has jurisdiction to coordinate, investigate and other vise carry out the affairs of the Assembly in all matters relating to commercial nuclear power generation in New York State. The New Yor'. State Assembly and the Special Committee on Nuclear Power Safety have a substantial interest in the subject matter of this proceecing pursuant to 10 CFR Section 2.713(c).

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UNITED STATES OF AMERICA r...,--

3 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

",' it' 1/. P2:37 Administrative Judges: @

Louis 3. Carter, Chairman Dr. Oscar H. Paris Frederick J. Shon In the Matter of CONSOLIDATED EDISON COMPANY OF NEW YORK Docket Nos. 50-247-SP (Indian Point, Unit 2) 50-236-SP

. POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit 3)

December 3,1931 AFFADAVIT OF STANLEY FINK SPEAKER, NEW YORK STATE ASSEMBLY STANLEY FINK being duly sworn deposes and says.

1. I have been duly elected Speaker of the Assembly of the State of New York by the full membership of that body.

2. Pursuant to the Rules of the Assembly, Sections 1.c.(1), I have the power and the duty to appoint ". . . the chairmen and members of all committees . . ." of the Assembly and pursuant to the Rules of the Assembly, Section 1.h., I have the power and

the duty to ". . . appoint such other officers as (I] detin necessary to conduct the affairs of the Assembly."

3. I appointed the members and designated myself as chair of the Special Committee on Nuclear Power Safety, which has Assembly jurisdiction to coordinate, investigate and otherwise carry out the affairs of the Assembly in all matters relating to commercial nuclear power generation in New York State.

4 I have designated the following individuals to represent the Special Committee and the Assembly in the above entitled proceeding:

2. The subject matter before the Ccmmission as specified in the Commission Memoranda and orders dated January 3,1931 (CLI 31-1,13 NRC 1) and September 13, 1931 (CLI 31-2214 NRC), namely the safety of the Indian Point #2 and #3 nuclear power plants, has a direct impact on the health, welfare and safety of the citizens of New York State whom the members of the New York State Assembly are duly elected to represent and protect.

3. The New York State Assembly shares the state responsibility for emergency planning and the funding for such planning, as exemplified by the recent enactment of the Radiologic Emergency Preparedness Act of 1981 (Chapter 708, Laws of New York). That planning process is an ongoing one, and one in which the New York State Assembly must continue to play a crucial role on behalf of the citizens of the State of New York.

4. The New York State Assembly Special Committee on Nuclear Power Safety has, since its formation in May of 1979 and on behalf of the Assembly, has conducted inquiries into issues of nuclear power safety including: reactor safety, emergency preparedness, the health effects of human exposure to low-level radiation, the economics of nuclear power, and more specifically, the October 1980 accident at the Indian Point nuclear power plant.

3. As an appointee to President Carter's State Planning Council on Radioactive Waste Management, the Speaker has been closely involved in seeking solutions to the still unresolved problems of the safe, long-term disposal of both high-level and low-level radioactive wastes. In New York State, nuclear power plants are the largest generators of both high-level and low-level radioactive wastes.

Therefore, the New York State Assembly and the Special Committee on Nuclear Power Safety thereof respectfully request leave to intervene in the above entitled action to be afforded a reasonable opportunity to participate therein pursuant to 10 C.F.R. 2.715(c).

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• 4 Copies of all notices, documents and communications in this proceeding should be sent to the following:

Andrew S. Roffe, Esq.

Executive Counsel to the Speaker New York State Assembly State Capitol, Room 347-Albany, New York 12248 Richard E. Leckerling, Esq.

Senior Associate Counsel to the Speaker New York State Assembly LOB, Room 342 Albany, New York 12248 Robert A. Kurtter Staff Director Special Committee on Nuclear Power Safety New York State Assembly Albany, New York 12248 Mr. Roffe is admitted to the Bar in the State of New York. Mr. Leckerling is admitted to the Bar in the State of New York.

.-M. /*'A ANDREW S. ROFFE, Executive Counsel to the Speaker for:

STANLEY FINK, Speaker New York State Assembly Chair, Assembly Special Committee on Nuclear Power Safety l .

I

1 Andrew S. Roffe, Esq.

Executive Counsel to the Speaker New York State Assembly

' State Capitol, Room 347 Albany, New York 12248 Richard E. Leckerling, Esq.

Senior Associate Counsel to the Speaker New York State Assembly LOB, Room 842 Albany, New York 12248 Robert A. Kurtter l Staff Director {

Special ComrrJttee on Nuclear Power Safety l New York State Assembly Albany, New York 12248 // e '

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STANLEY FINK, Speaker New York State Assembly Chair, Assembly Special l Committee on Nuclear l Power Safety l Subscribed to and sworn before me this .-

" '-% day of O c . ,19 i !.

\*\ ' s . h' o u : __

Notary Publicy i

Registration N' umber . . ! 'e 'M Expiration Date

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l UNITED STATES OF AMERICA ....,---

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NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

'3; T 14 P2:2 Administrative Judges:

Louis 3. Carter, Chairman Dr. Oscar H. Paris Frederick 3. Shon In the Matter of CONSOLIDATED EDISON COMPANY OF NEW YORK Docket Nos. 50-247-SP (Indian Point, Unit 2): 50-236-SP POWER AUTHORITY OF THE STATE OF NEW YORK (Indian Point, Unit 3)

December 3,1981 NOTICE OF APPEARANCE t'

Notice is hereby given pursuant to 10 CFR Section 2.713(b) that the undersigned, ANDREW S. ROFFE and RICHARD E. LECKERLING, will appear in this matter for the -

New York State Assembly and the Special Committee on Nuclear Power 5afety, thereof, Capitol, Albany, New York 12248. Mr. Roffe and Mr. Leckerling are me.mbers in good standing of the Bar of the State'of New York.

. _; Q=

r ANDREW S. ROFFE, Executive Counsei to the Speaker Counsel to the Special Committee on Nuclear Power Safety New York State Assembly State Capitol, Room 347 Albany, New York 12243 RICHARD E. LECKERLING Senior Associate Counsel to the Speaker Counsel to the Special Committee on Nuclear Power Safety New York State Assembly LOB, Room 342 Albany, New York 12248

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