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| {{#Wiki_filter:-.NRC PUBLIC Dor"'ENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION | | {{#Wiki_filter:- |
| !EL MAR 28 19 7 | | . |
| 'Docket Nos. 9 In the Matter of
| | NRC PUBLIC Dor"'ENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION |
| )STN 50-596 | | ! |
| )and STN 50-597 New York State Electric | | ' EL MAR 28 19 7 In the Matter of ) Docket Nos. 9 STN 50-596 |
| )and Gas Corporation and
| | ) and STN 50-597 New York State Electric ) |
| )*Long Island Lighting Company
| | and Gas Corporation and ) |
| )f\NYSE&G 1 and 2
| | Long Island Lighting Company ) |
| )//;g A'2.I | | * f |
| * h Y | | \ |
| $-f ik PETITION TO INTERVENE D* * .'OF MID-HUDSON NUCLEAR g\@#M, 6 OPPONENTS, INC. ("MHNO")
| | NYSE&G 1 and 2 ) // ;g A |
| b 9 l co MHNO hereby petitions for leave to inte;vene in this proceeding as a full party. | | - $ |
| 1.MHNO is a New York Not-for-Profit corporation and an exempt organization under Section 501(c) (3) of the Internal Revenue Code. | | ik D |
| 2.MHNO's principal office is in New Paltz, New York and service upon it should be made t@un Mid-Hudson Nuclear Opponents, Inc. | | '2.I |
| P.O.Box 666 New Paltz, New York 12561 3.MHNO has approximately 2500 contributing members throughout the Hudson Valley principally in the region south of Albany and North of Newburgh. | | * hYf PETITION TO INTERVENE **. |
| 4.The primary purpose of MHNO is to act as a spokerman for its members on issues involving construction of electric generating stations and transmission lines, conservation of energy, the uses of nuclear, power and rates charged for electricity. | | ' |
| 4lb 34}7 9 0 5 2 3 040T ' | | OF MID-HUDSON NUCLEAR g\ @#M, 6 OPPONENTS, INC. ("MHNO") |
| '.MHNO has been an active participantin cases both | | b co l 9 |
| *.at the Federal and State level involving energy planning and pricing.
| | MHNO hereby petitions for leave to inte;vene in this proceeding as a full party. |
| It is a full party in case 80008, the New York State siting proceeding relating to the same facilities which are the subject of this proceeding. | | : 1. MHNO is a New York Not-for-Profit corporation and an exempt organization under Section 501(c) (3) of the Internal Revenue Code. |
| 6.The desi,gn, siting, timing, construction and operation of the facilities for which construction permits in this case are sought will have a significant impact on the followinj interests of MHNO and its menters: (a)The health and afety of the citizens in the mid-hudson region;(b)The price of electricity available;(c)The ecology of the Hudson Valley ana River, including its aestnetic and historic resources;(d)The course of energy planning in New York State. | | : 2. MHNO's principal office is in New Paltz, New York and service upon it should be made t@un Mid-Hudson Nuclear Opponents, Inc. |
| 7.MENO whishes to participate in the following aspects of this proceeding which affect it.(a)Alternate site considerations since Hudson Valley sites are the prime alternatives;(b)The need for these f acilities ar ' | | P.O. Box 666 New Paltz, New York 12561 |
| whether they would be consistent with a long range energy plan for New 18 322 York State. | | : 3. MHNO has approximately 2500 contributing members throughout the Hudson Valley principally in the region south of Albany and North of Newburgh. |
| .P..(c)Ancillary facilities which may be required in the Hudson Valley if the construction permit is granted for the New Haven site.(d)The Financial and technical ability of the applicants to construct the proposed Jacilities in a manner which would not injure MHNO and its members.(e)The capital and operating costs of the proposed facilities and the impact of these on rates charged to electric consumers in the mid-Hudson area. | | : 4. The primary purpose of MHNO is to act as a spokerman for its members on issues involving construction of electric generating stations and transmission lines, conservation of energy, the uses of nuclear, power and rates charged for electricity. 4lb 34} |
| 8.Since MHNO represents a distinct mid-Hudson area constituency with interests different than any of the parties to this case, its intervention is necessary to insure that these interests are represented in this proceeding. | | 7 9 0 5 2 3 040T ' |
| 9.In addition, through its years of participation in energy matters, MENO has developed a unique expertise on ce-tain aspects of energy planning in New York State which wil' aid the development of a full record in this case. | | |
| 10.Therefore, MHNO r.hould be permi';ted to intervene in this case as a full party. | | ' |
| March 19, 1979 Peter D.G.Brown Chairman of the Board Mid-Hudson Nuclear Opponents P.O.Box 666 New Paltz, New York 12561 (914)384-6760}} | | . |
| | * |
| | . MHNO has been an active participantin cases both at the Federal and State level involving energy planning and pricing. It is a full party in case 80008, the New York State siting proceeding relating to the same facilities which are the subject of this proceeding. |
| | : 6. The desi,gn, siting, timing, construction and operation of the facilities for which construction permits in this case are sought will have a significant impact on the followinj interests of MHNO and its menters: |
| | (a) The health and afety of the citizens in the mid-hudson region; (b) The price of electricity available; (c) The ecology of the Hudson Valley ana River, including its aestnetic and historic resources; (d) The course of energy planning in New York State. |
| | : 7. MENO whishes to participate in the following aspects of this proceeding which affect it. |
| | (a) Alternate site considerations since Hudson Valley sites are the prime alternatives; (b) The need for these f acilities ar ' |
| | whether they would be consistent with a long range energy plan for New York State. 18 322 |
| | |
| | . |
| | P |
| | . . |
| | (c) Ancillary facilities which may be required in the Hudson Valley if the construction permit is granted for the New Haven site. |
| | (d) The Financial and technical ability of the applicants to construct the proposed Jacilities in a manner which would not injure MHNO and its members. |
| | (e) The capital and operating costs of the proposed facilities and the impact of these on rates charged to electric consumers in the mid-Hudson area. |
| | : 8. Since MHNO represents a distinct mid-Hudson area constituency with interests different than any of the parties to this case, its intervention is necessary to insure that these interests are represented in this proceeding. |
| | : 9. In addition, through its years of participation in energy matters, MENO has developed a unique expertise on ce-tain aspects of energy planning in New York State which wil' aid the development of a full record in this case. |
| | : 10. Therefore, MHNO r.hould be permi';ted to intervene in this case as a full party. |
| | March 19, 1979 Peter D. G. Brown Chairman of the Board Mid-Hudson Nuclear Opponents P.O. Box 666 New Paltz, New York 12561 (914)384-6760}} |
Mid-Hudson Nuclear Opponents' Petition to Intervene as Full Party Re Alternate Site Considerations,Need for Facility, Financial Qualifications of Applicants & Cost of Proposed PlantML19224A677 |
Person / Time |
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New Haven |
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Issue date: |
03/19/1979 |
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From: |
Brown P MID-HUDSON NUCLEAR OPPONENTS, INC. |
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To: |
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References |
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NUDOCS 7905230409 |
Download: ML19224A677 (3) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20002A2101980-10-16016 October 1980 Certifies Svc of Motion to Terminate Proceeding on 801016 ML20008E0211980-10-16016 October 1980 Motion to Terminate Proceeding Due to Dismissal of Case 80008 by Ny State Board on Electric Generation Siting Re Environ Compatibility.Attempts to License nuclear-fueled Plants at New Haven or Stuyvesant Sites Abandoned ML20008E0291980-10-16016 October 1980 Withdrawal of 781109 Application to License nuclear-fueled Generation Station at New Haven or Stuyvesant Sites,Due to Dismissal of Case 80008 by Ny State Board on Electric Generation Siting ML20008E0251980-10-16016 October 1980 Withdrawal of 781109 Application to License nuclear-fueled Generation Station at New Haven or Stuyvesant Sites,Due to Dismissal of Case 80008 by Ny State Board on Electric Generation Siting Re Environ Compatibility ML19340B3861980-10-16016 October 1980 Withdraws 781109 CP Application.Cites State of Ny Siting Board 800523 Denial of Motion for Rehearing of 791012 Order, Dismissing Case in Which Applicant Sought Certificate of Environ Compatibility & Public Need,As Prime Motivator ML19323H0361980-05-23023 May 1980 Order by State of Ny Board on Electric Generation Siting & Environ,Denying Application for Rehearing.Proceeding Closed Due to Substantial Uncertainty About Facility Ownership. Related Correspondence ML19260C3971979-12-0303 December 1979 Reply in Opposition to Applicants 791112 Motion for Rehearing Re Ny State Siting Board Dismissal of Proceeding. Applicants Failed to State New Arguments.No Beneficial Purpose Will Be Served by Rehearing.Certificate of Svc Encl ML19291B8871979-11-21021 November 1979 Statement in Opposition to Applicants 791112 Motion for Rehearing Re ASLB Order Dismissing Application.Applicants Failed to Establish Present Intention to Build Plant. Certificate of Svc Encl ML19211A2321979-11-20020 November 1979 Notice by Ny State Board on Electric Generation Siting & Environ.Replies to Utils' Application for Rehearing of ASLB Order Dismissing Application for Certificate of Environ Compatibility Will Be Accepted If Filed by 791203 ML19210E7551979-11-12012 November 1979 Requests for Reversal of Ny State Board on Electric Generation Siting & Environ 791012 Dismissal of Application Or,If Reversal Denied,For Rehearing.Ownership of Proposed Station Did Not Constitute Sufficient Grounds for Dismissal ML19253C1931979-10-29029 October 1979 Motion for Indefinite Delay in Proceeding.Case 80008 Before Ny State Board on Electric Generation Siting & Environ Dismissed on 791012.Urges Deferral Until Applicants' Motion for Case 80008 Rehearing Decided.Ny State Order Encl ML19250C3801979-10-17017 October 1979 Notice to Parties by State of Ny Board on Electric Generating Siting & State Environ Dept of Public Svc. Contrary to Board 791001 Order Re Discussion of Application, Proceeding Will Continue & PASNY 791016 Argument Considered ML19209D0631979-10-12012 October 1979 Order Dismissing Application by Ny State Electric & Gas Corp & Lilco for Certificate of Environ Compability & Public Need to Construct Plant.Applicants Have Not Demonstrated Statewide Need for Facility ML19260A4261979-10-12012 October 1979 Order by State of Ny Board on Electric Generation Siting & Environ Dismissing Ny State Electric & Gas Corp & Lilco Application for Environ Capability Certificate & for Public Need to Construct Facility ML19254E6481979-10-0202 October 1979 Notice Issued by Board on Electric Generation Siting & Environ of Ny Dept of Public Svc Re Util Application for Certificate of Environ Compatibility.Public Meeting Will Be Held 791012 in Albany,Ny,Re Termination of Proceeding ML19210B7681979-10-0101 October 1979 Memorandum on Standing of County of Columbia,Town of Stuyvesant,Concerned Citizens for Safe Energy & Mid-Hudson Nuclear Opponents.Members Reside in Geographic Vicinity & Involved in Specialized Ny Electric Energy Issues ML19259D3941979-10-0101 October 1979 Suppl to Petition to Intervene Submitting Revised Contentions.Includes Allegation That Assessment & Other Related Matters Re Alternative Fuel Sources,Submitted by Applicant to Nrc,Are Inadequate ML19275A5151979-08-16016 August 1979 Opposes Briefs of Intervenors State of Ny Atty General, Public Svc Commission & Ecology Action of Oswego Submittal in Response to Util Brief in Opposition to Interlocutory Appeal.Certificate of Svc Encl ML19209A9321979-08-0606 August 1979 Response to State of Ny Dept of Environ Conservation, Columbia County,Town of Stuyvesant & Concerned Citizens for Safe Energy Comments Re State of Ny Public Svc Commission 790725 Recommendations.W/Certificate of Svc ML19253B2991979-08-0606 August 1979 Answers Util 790725 & Ny Dept of Environ Conservation Responses to Public Svc Commission 790710 Order Re Intervenor Ecology Action of Oswego Motion for Dismissal of Application.Urges Dismissal.W/Certificate of Svc ML19209B8591979-08-0303 August 1979 Brief Submitted by Intervenor State of Ny in Response to Util 790725 Brief.Supports Intervenor Ecology Action of Oswego Interlocutory Appeal Re Dismissal of Util 781122 Application.Certificate of Svc Encl ML19209A5781979-08-0202 August 1979 Response to NRC & Applicant Briefs Re 790713 Amended Petition to Intervene.Nrc Response Inadequate.Requests ASLB Expand Geographical Area Under Consideration,Based on Radiation Measured During Actual Event ML19209B4381979-08-0202 August 1979 Town of Gardiner,Ny Response to NRC & Applicant Briefs Re Town of Gardiner 790713 Amended Petition to Intervene.Nrc Should Recommend Town of Gardiner as Intervenor & Extend Intervention Limit from 50 to 200 Miles ML19208C3741979-07-25025 July 1979 Brief in Opposition to Intervenor Ecology Action of Oswego 790426 Interlocutory Appeal Re 790413 Denial of Motion to Dismiss Application.Applicant Should Have Opportunity to Prove Case.Certificate of Svc Encl ML19253B3511979-07-23023 July 1979 Request,Submitted by Intervenor Town of Kinderhook,That Ny State Board on Electric Generation Siting & Environ Dismiss Util Application.Grounds for Dismissal Thoroughly Stated by Intervenor Ecology Action of Oswego ML19209B3751979-07-23023 July 1979 Brief on Behalf of Town of Kinderhook Recommending That Application for OL Be Dismissed for Reasons Stated by Ecology Action of Oswego & Ny State Public Svc Commission ML19208C3701979-07-16016 July 1979 Request,Submitted by Intervenors Columbia County,Town of Stuyvesant & Concerned Citizens for Safe Energy,For Extension to File Supplemental Memo & for Investigation Into Applicant Intentions to Pursue Application ML19208C3281979-07-13013 July 1979 Memorandum Submitted by Applicant Re Standing of Intervenors Citizens for Safe Energy,Mid-Hudson Nuclear Opponents,Ulster County Environ Mgt Council & Town of Gardiner.Responds to E Mead & Town of Conesville 790619 Petition ML19261E7471979-07-11011 July 1979 Order Certifying Intervenor Ecology Action of Oswego 790426 Interlocutory Apppeal to Ny State Board for Electric Siting & Environ W/Recommendation for Dismissal of CP Proceedings. Application Is Premature & Legally Insufficient ML19207B4741979-07-10010 July 1979 Statement of State of Ny Dept of Environ Conservation Per 16NYCRR70.20.Lists Alternate Sites & Modes of Generation. Fossil Alternative Site Must Be Considered in Conjunction W/Use of refuse-derived Fuel ML19275A0741979-07-0505 July 1979 Notice Per 16NYCRR70.20.Columbia County,Ny,Town of Stuyvesant & Concerned Citizens for Safe Energy Will Testify Re Alternate Site,Facilities & Source of Power as Discussed in Draft Eis.Certificate of Svc Encl ML19207B5561979-06-27027 June 1979 Comments by State of Ny Dept of Public Svc on Proposed Protocol for Conduct of Joint Hearings Before NRC & Ny State Board on Electric Generation Siting & Environ Issue. Identification Should Occur After Issuance of Des ML19276G6081979-06-26026 June 1979 Reaffirms 790611 Comments.Application Is Summary of Util Findings & Conclusions.Nrc & Intervenors Must Develop Record on Which Siting Board Will Make Final Decision ML19247A8531979-06-26026 June 1979 Response to Util 790611 Proposed Joint Protocol & Discovery Rules Submitted by Intervenors Columbia County,Town of Stuyvesant & Concerned Citizens for Safe Energy.Definitions of Issues Violate NRC Rules ML19208C6421979-06-20020 June 1979 Interlocutory Appeal on Denial of 790320 Motion for Dismissal.Case 80008 Should Be Dismissed for Reasons Set by Ecology Action of Oswego ML19225C7461979-06-19019 June 1979 Resolution Authorizing County Legislature Chairman to File W/Nrc Appropriate Petition & Other Documents on Behalf of County,So as to Become party-at-interest Re Ny State Electric & Gas Co Application for Two Nuclear Units ML19241C0051979-06-14014 June 1979 Intervention Statement Offered at 790614 Public Comment Session ML19225A3581979-06-11011 June 1979 Support for NRC & State of Ny 790427 Proposed Protocol for Joint Hearings Submitted by Ecology Action of Oswego. Suggests Mod for Joint Hearings Discovery Process,Memo of Understanding,Schedule & Procedure for Joint Mailings ML19225C1051979-06-11011 June 1979 Ny Dept of Public Svc Reply to Comments Offered by Various Parties at 790523 Prehearing Conference on Proposed Joint Protocol in Case 80008 ML19224D7131979-05-31031 May 1979 Certification That 790319 Petition to Intervene & 790510 Contentions Truly Set Forth Position of Mid-Hudson Nuclear Opponents,Inc ML19241B3301979-05-29029 May 1979 Contentions Re Site Selection.Util Has Underestimated Multiple Generation Units,Has Not Considered Proximity to Schools & Has Discriminated Against Rural Populace ML19241B3331979-05-29029 May 1979 Contentions of Safe Energy for New Haven Re Environ Matters. Util Inadequately Determined Energy Needs,Has Not Performed Sufficient Research on Alternative Sources of Energy & Has Not Assessed Impact of Accident or Kv Lines ML19241B1221979-05-18018 May 1979 Initial Util Answer to Intervenor Contentions.Identifies Contentions Which Can Be Presented Unopposed at 790523 Prehearing Conference.Seeks ASLB Extension for Filing Supplemental Answers.Certificate of Svc Encl ML19224B8681979-05-11011 May 1979 Submits 40 Contentions as Suppl to Petition to Intervene Re Need for Addl Power,Consideration of Alternatives,Site Selection Process,Impact on Existing Health Facilities, Financial Capacity & Effect on High Voltage Transmissions ML19242A4251979-05-11011 May 1979 Amend to 790313 Petition to Intervene,Adding New Considerations ML19269E3671979-05-10010 May 1979 Submits Specific Contentions Re Environ & Radiological Concerns.Assessment of Impact on Farmland Is Inadequate Re Estimation of Value & Use of Land & Adverse Impact of Dust, Noise,Litter & Traffic on Area Agriculture ML19242A6381979-05-0909 May 1979 Resolution 112 Objecting to Location of Public Hearings Outside of County ML19224B8141979-05-0707 May 1979 Ny Dept of Public Svc Response to Ecology Action of Oswego Interlocutory Appeal of Denial of Motion for Dismissal of Application.Recommends Denial of Appeal ML19224B7091979-05-0404 May 1979 Request by Util for Denial of 790313 Petitions to Intervene. Filed by Town of Gardner & Ulster County Environ Mgt Council.Petitions Lack Standing & Fail to Justify Discretionary Intervention.Certificate of Svc Encl ML19224B7001979-04-27027 April 1979 Proposed Protocol for Joint Hearing Before NRC & Ny State Board on Electric Generation Siting & Environ Re Common Issues in Const Applications of Long Island Lighting Co & Ny State Elec & Gas Corp 1980-05-23
[Table view] Category:PLEADINGS
MONTHYEARML20008E0251980-10-16016 October 1980 Withdrawal of 781109 Application to License nuclear-fueled Generation Station at New Haven or Stuyvesant Sites,Due to Dismissal of Case 80008 by Ny State Board on Electric Generation Siting Re Environ Compatibility ML20008E0211980-10-16016 October 1980 Motion to Terminate Proceeding Due to Dismissal of Case 80008 by Ny State Board on Electric Generation Siting Re Environ Compatibility.Attempts to License nuclear-fueled Plants at New Haven or Stuyvesant Sites Abandoned ML20008E0291980-10-16016 October 1980 Withdrawal of 781109 Application to License nuclear-fueled Generation Station at New Haven or Stuyvesant Sites,Due to Dismissal of Case 80008 by Ny State Board on Electric Generation Siting ML19260C3971979-12-0303 December 1979 Reply in Opposition to Applicants 791112 Motion for Rehearing Re Ny State Siting Board Dismissal of Proceeding. Applicants Failed to State New Arguments.No Beneficial Purpose Will Be Served by Rehearing.Certificate of Svc Encl ML19291B8871979-11-21021 November 1979 Statement in Opposition to Applicants 791112 Motion for Rehearing Re ASLB Order Dismissing Application.Applicants Failed to Establish Present Intention to Build Plant. Certificate of Svc Encl ML19210E7551979-11-12012 November 1979 Requests for Reversal of Ny State Board on Electric Generation Siting & Environ 791012 Dismissal of Application Or,If Reversal Denied,For Rehearing.Ownership of Proposed Station Did Not Constitute Sufficient Grounds for Dismissal ML19253C1931979-10-29029 October 1979 Motion for Indefinite Delay in Proceeding.Case 80008 Before Ny State Board on Electric Generation Siting & Environ Dismissed on 791012.Urges Deferral Until Applicants' Motion for Case 80008 Rehearing Decided.Ny State Order Encl ML19210B7681979-10-0101 October 1979 Memorandum on Standing of County of Columbia,Town of Stuyvesant,Concerned Citizens for Safe Energy & Mid-Hudson Nuclear Opponents.Members Reside in Geographic Vicinity & Involved in Specialized Ny Electric Energy Issues ML19259D3941979-10-0101 October 1979 Suppl to Petition to Intervene Submitting Revised Contentions.Includes Allegation That Assessment & Other Related Matters Re Alternative Fuel Sources,Submitted by Applicant to Nrc,Are Inadequate ML19275A5151979-08-16016 August 1979 Opposes Briefs of Intervenors State of Ny Atty General, Public Svc Commission & Ecology Action of Oswego Submittal in Response to Util Brief in Opposition to Interlocutory Appeal.Certificate of Svc Encl ML19209A9321979-08-0606 August 1979 Response to State of Ny Dept of Environ Conservation, Columbia County,Town of Stuyvesant & Concerned Citizens for Safe Energy Comments Re State of Ny Public Svc Commission 790725 Recommendations.W/Certificate of Svc ML19253B2991979-08-0606 August 1979 Answers Util 790725 & Ny Dept of Environ Conservation Responses to Public Svc Commission 790710 Order Re Intervenor Ecology Action of Oswego Motion for Dismissal of Application.Urges Dismissal.W/Certificate of Svc ML19209B4381979-08-0202 August 1979 Town of Gardiner,Ny Response to NRC & Applicant Briefs Re Town of Gardiner 790713 Amended Petition to Intervene.Nrc Should Recommend Town of Gardiner as Intervenor & Extend Intervention Limit from 50 to 200 Miles ML19209A5781979-08-0202 August 1979 Response to NRC & Applicant Briefs Re 790713 Amended Petition to Intervene.Nrc Response Inadequate.Requests ASLB Expand Geographical Area Under Consideration,Based on Radiation Measured During Actual Event ML19253B3511979-07-23023 July 1979 Request,Submitted by Intervenor Town of Kinderhook,That Ny State Board on Electric Generation Siting & Environ Dismiss Util Application.Grounds for Dismissal Thoroughly Stated by Intervenor Ecology Action of Oswego ML19208C3701979-07-16016 July 1979 Request,Submitted by Intervenors Columbia County,Town of Stuyvesant & Concerned Citizens for Safe Energy,For Extension to File Supplemental Memo & for Investigation Into Applicant Intentions to Pursue Application ML19208C3281979-07-13013 July 1979 Memorandum Submitted by Applicant Re Standing of Intervenors Citizens for Safe Energy,Mid-Hudson Nuclear Opponents,Ulster County Environ Mgt Council & Town of Gardiner.Responds to E Mead & Town of Conesville 790619 Petition ML19207B4741979-07-10010 July 1979 Statement of State of Ny Dept of Environ Conservation Per 16NYCRR70.20.Lists Alternate Sites & Modes of Generation. Fossil Alternative Site Must Be Considered in Conjunction W/Use of refuse-derived Fuel ML19207B5561979-06-27027 June 1979 Comments by State of Ny Dept of Public Svc on Proposed Protocol for Conduct of Joint Hearings Before NRC & Ny State Board on Electric Generation Siting & Environ Issue. Identification Should Occur After Issuance of Des ML19276G6081979-06-26026 June 1979 Reaffirms 790611 Comments.Application Is Summary of Util Findings & Conclusions.Nrc & Intervenors Must Develop Record on Which Siting Board Will Make Final Decision ML19247A8531979-06-26026 June 1979 Response to Util 790611 Proposed Joint Protocol & Discovery Rules Submitted by Intervenors Columbia County,Town of Stuyvesant & Concerned Citizens for Safe Energy.Definitions of Issues Violate NRC Rules ML19208C6421979-06-20020 June 1979 Interlocutory Appeal on Denial of 790320 Motion for Dismissal.Case 80008 Should Be Dismissed for Reasons Set by Ecology Action of Oswego ML19225C7461979-06-19019 June 1979 Resolution Authorizing County Legislature Chairman to File W/Nrc Appropriate Petition & Other Documents on Behalf of County,So as to Become party-at-interest Re Ny State Electric & Gas Co Application for Two Nuclear Units ML19241C0051979-06-14014 June 1979 Intervention Statement Offered at 790614 Public Comment Session ML19225C1051979-06-11011 June 1979 Ny Dept of Public Svc Reply to Comments Offered by Various Parties at 790523 Prehearing Conference on Proposed Joint Protocol in Case 80008 ML19225A3581979-06-11011 June 1979 Support for NRC & State of Ny 790427 Proposed Protocol for Joint Hearings Submitted by Ecology Action of Oswego. Suggests Mod for Joint Hearings Discovery Process,Memo of Understanding,Schedule & Procedure for Joint Mailings ML19241B3301979-05-29029 May 1979 Contentions Re Site Selection.Util Has Underestimated Multiple Generation Units,Has Not Considered Proximity to Schools & Has Discriminated Against Rural Populace ML19241B3331979-05-29029 May 1979 Contentions of Safe Energy for New Haven Re Environ Matters. Util Inadequately Determined Energy Needs,Has Not Performed Sufficient Research on Alternative Sources of Energy & Has Not Assessed Impact of Accident or Kv Lines ML19241B1221979-05-18018 May 1979 Initial Util Answer to Intervenor Contentions.Identifies Contentions Which Can Be Presented Unopposed at 790523 Prehearing Conference.Seeks ASLB Extension for Filing Supplemental Answers.Certificate of Svc Encl ML19224B8681979-05-11011 May 1979 Submits 40 Contentions as Suppl to Petition to Intervene Re Need for Addl Power,Consideration of Alternatives,Site Selection Process,Impact on Existing Health Facilities, Financial Capacity & Effect on High Voltage Transmissions ML19242A4251979-05-11011 May 1979 Amend to 790313 Petition to Intervene,Adding New Considerations ML19269E3671979-05-10010 May 1979 Submits Specific Contentions Re Environ & Radiological Concerns.Assessment of Impact on Farmland Is Inadequate Re Estimation of Value & Use of Land & Adverse Impact of Dust, Noise,Litter & Traffic on Area Agriculture ML19242A6381979-05-0909 May 1979 Resolution 112 Objecting to Location of Public Hearings Outside of County ML19224B8141979-05-0707 May 1979 Ny Dept of Public Svc Response to Ecology Action of Oswego Interlocutory Appeal of Denial of Motion for Dismissal of Application.Recommends Denial of Appeal ML19224B7091979-05-0404 May 1979 Request by Util for Denial of 790313 Petitions to Intervene. Filed by Town of Gardner & Ulster County Environ Mgt Council.Petitions Lack Standing & Fail to Justify Discretionary Intervention.Certificate of Svc Encl ML19224A6871979-04-0303 April 1979 Answer Seeking Denial of 790319 Petition to Intervene Filed by Mid-Hudson Nuclear Opponents,Inc.Certificate of Svc Encl ML19224A7021979-03-20020 March 1979 Answer to Intervention Petitions of Various Groups,Including Ny State Energy Ofc,Oswego County Farm Bureau,Ecology Action & Safe Energy for New Haven.Certificate of Svc Encl ML19224A6771979-03-19019 March 1979 Mid-Hudson Nuclear Opponents' Petition to Intervene as Full Party Re Alternate Site Considerations,Need for Facility, Financial Qualifications of Applicants & Cost of Proposed Plant ML19224A6981979-03-16016 March 1979 Petitions to Intervene in Proceeding.Asserts Health & Safety Will Be Adversely Affected by Plant ML19224A6831979-03-12012 March 1979 Petition to Intervene,Submitted by Columbia County,Ny,Town of Stuyvesant,Ny & Concerned Citizens for Safe Energy,Inc ML19224A6851979-03-12012 March 1979 Supports Petition to Intervene Submitted by Columbia County, Ny,Town of Stuyvesant,Ny & Concerned Citizens for Safe Energy,Inc.Notice of Appearance & Certificate of Svc Encl ML19224A6991979-03-0808 March 1979 Petitions to Intervene in Proceeding.Asserts Health & Safety Will Be Adversely Affected by Plant ML19224A5971979-03-0505 March 1979 Ny State Energy Ofc'S Petition to Participate as Interested State.Certificate of Svc Encl 1980-10-16
[Table view] |
Text
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NRC PUBLIC Dor"'ENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
!
' EL MAR 28 19 7 In the Matter of ) Docket Nos. 9 STN 50-596
) and STN 50-597 New York State Electric )
and Gas Corporation and )
Long Island Lighting Company )
\
NYSE&G 1 and 2 ) // ;g A
- $
ik D
'2.I
- hYf PETITION TO INTERVENE **.
'
OF MID-HUDSON NUCLEAR g\ @#M, 6 OPPONENTS, INC. ("MHNO")
b co l 9
MHNO hereby petitions for leave to inte;vene in this proceeding as a full party.
- 1. MHNO is a New York Not-for-Profit corporation and an exempt organization under Section 501(c) (3) of the Internal Revenue Code.
- 2. MHNO's principal office is in New Paltz, New York and service upon it should be made t@un Mid-Hudson Nuclear Opponents, Inc.
P.O. Box 666 New Paltz, New York 12561
- 3. MHNO has approximately 2500 contributing members throughout the Hudson Valley principally in the region south of Albany and North of Newburgh.
- 4. The primary purpose of MHNO is to act as a spokerman for its members on issues involving construction of electric generating stations and transmission lines, conservation of energy, the uses of nuclear, power and rates charged for electricity. 4lb 34}
7 9 0 5 2 3 040T '
'
.
. MHNO has been an active participantin cases both at the Federal and State level involving energy planning and pricing. It is a full party in case 80008, the New York State siting proceeding relating to the same facilities which are the subject of this proceeding.
- 6. The desi,gn, siting, timing, construction and operation of the facilities for which construction permits in this case are sought will have a significant impact on the followinj interests of MHNO and its menters:
(a) The health and afety of the citizens in the mid-hudson region; (b) The price of electricity available; (c) The ecology of the Hudson Valley ana River, including its aestnetic and historic resources; (d) The course of energy planning in New York State.
- 7. MENO whishes to participate in the following aspects of this proceeding which affect it.
(a) Alternate site considerations since Hudson Valley sites are the prime alternatives; (b) The need for these f acilities ar '
whether they would be consistent with a long range energy plan for New York State. 18 322
.
P
. .
(c) Ancillary facilities which may be required in the Hudson Valley if the construction permit is granted for the New Haven site.
(d) The Financial and technical ability of the applicants to construct the proposed Jacilities in a manner which would not injure MHNO and its members.
(e) The capital and operating costs of the proposed facilities and the impact of these on rates charged to electric consumers in the mid-Hudson area.
- 8. Since MHNO represents a distinct mid-Hudson area constituency with interests different than any of the parties to this case, its intervention is necessary to insure that these interests are represented in this proceeding.
- 9. In addition, through its years of participation in energy matters, MENO has developed a unique expertise on ce-tain aspects of energy planning in New York State which wil' aid the development of a full record in this case.
- 10. Therefore, MHNO r.hould be permi';ted to intervene in this case as a full party.
March 19, 1979 Peter D. G. Brown Chairman of the Board Mid-Hudson Nuclear Opponents P.O. Box 666 New Paltz, New York 12561 (914)384-6760