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| {{#Wiki_filter:}} | | {{#Wiki_filter:y ,v .ma . v, |
| | '' a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the~ Atomic Safety and Licensing Board In the matter of ) |
| | ) |
| | LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3 |
| | ) |
| | !Shoreham Nuclear Power Station ) (Emergency Planning) |
| | Unit 1) ) |
| | MOTION TO INTERVENE ON BEHALF-OF THE RESIDENTS OF NASSAU COUNTY We the Long Island Coalition For Safe Living (" COALITION") |
| | hereby petition as intervenors to be heard before the Atomic Energy and Licensing Board on the use of the Nassau County Veterans Memorial' Coliseum in the LILCO evacuation plan as part of the reopening of the record with regard to the Coliseum. |
| | The " COALITION" requests the right to intervene and participate in the reopened proceedings to present testimony and other evidence-as to why the Coliseum should not be used in the LILuO evacuation plan in the event of a nuclear accident at the |
| | 'Shoreham Nuclear Power Station. |
| | s BACKGROUND: |
| | The Long Island Coalition for Safe Living is a coalition of some of the groups in Nassau County who are concerned with the |
| | ' health and well being of the residents of Nassau County as well as Suf folk County. They are: |
| | Peoples Action Coalition Long Island Rate Payers Association |
| | ' 8505300532 850529 ' |
| | PDR ADOCK 05000322~ ^' |
| | G PDR ' 1 4 |
| | |
| | . . ~ |
| | =*i Concarnsd Mothara of Nnascu S3fo Energy . Allianca o~f' Long Island PaccoSmith Mcuso'. |
| | Mothers Alliance for Peace'-- |
| | .Long Island Progressive Coalition Long Island Citizens in Action Nurses Environmental Health Watch N.Y.' Community Action Network' |
| | _ North Shore Coalition'for Safe Energy Women, Opposed to the Nuclear. Threat Long Island Network for Peace and Justice . |
| | The residents of Nassau County began to feel the threat of the Shoreham Nuclear Power Station 'when Mr. Purcell offered the Coliseum as a decontamination center in the LILCO evacuation plan. 'We began to organize and participate in educational |
| | . programs with civic, health and community organizations. Out of- |
| | - this-experience came the conviction of not only the " COALITION" but of. the Lresidents of Nassau County that the opening of Shoreham poses a: great danger to our health and well being. |
| | .We-intend to show cause for the withdrawal of the Coliseum- |
| | - from~the LILCO evacuation' plan. |
| | We are herewith presenting briefly two issues which should compel the N.R.C. to disqualify the use of the Coliseum as p'a'r_t of.the'LILCO evacuation, plan.' |
| | ISSUES: |
| | : 1. The- Nassau County Board of Supervisors never - |
| | ,_ approved the use of the Coliseum as _ part of the 0, LILCO evacuation plan in the eventof a nuclear-accident at Shoreham. |
| | 2. |
| | The use of the Coliseum as a radiation-decontamination center poses great danger and harm-ito the residents of Nassau County, i |
| | s 2 |
| | |
| | ., _ w ARGUMENT: |
| | : 1. When'the Long Island Coalition For Safe Living appeared before the Nassau County Board of Supervisors on 3/11/85 we challenged them to remove the Coliseum from the illegal LILCO l evacuation plan. Mr. F. Purcell, Nassau County Executive declared that the Coliseum was not part of any plan. He said his of fer of help was merely a humanitarian reply. Mr. Suozzi,. Mayor of Glen Cove, Long Island and Member of the Nassau County |
| | . Board of Supervisors said that the Board never agreed that the Coliseum could be used by LILCO in their evacuation plan (attachment 1). Mrs Hannah Komanoff, also a member of the Nassau County Board o f -- Supervisors has taken the same position (attachment 2). Both have sent letters - to |
| | >the Atomic Energy and Licensing ~ Board to this effect and their public statements at the Board meeting are on record at the Nassau County Board of Supervisors. LILCO misrepresents the f acts when it includes the use of the Coliseum in their. |
| | s evacuation plan. LILCO, therefore, has a " void"in the record for an acceptable evacuation plan. |
| | : 2. In the event of a nuclear accident at the-ShorehamuN' clear' Power Plant, the majority of the 150,000 people in the 10 mile evacuation zone and others totaling more than 500,000 (LILCO estimate) 3 |
| | |
| | A' cro expected to drive some 40 miles to the Coliseum ._ |
| | where their cars will be washed down. The water run off from washing down contaminated cars will seep into the water supply in the Uniondale,N.Y. |
| | area. There is no catch basin lining in the designated parking fields as would be required in any " wash-down" zone. |
| | The people are then supposed to be monitored, checked for radioactivity then showered and sent |
| | 'to congregate care centers (52 schools). The Coliseum is inadequate for this process since there are.only thirty one showers available f or the more than 150,000 people. |
| | We also question the capability and the equipment to detect all forms of radioactive contaminants including transuranics. We also believe that there will not be sufficient accommodations f or the " sick" people who will be showing their first signs of radiation poisoning. |
| | Many of the 52 schools named as congregate care centers do not accept their designated i |
| | participation in the LILCO evacuation plan and have removed themselves leaving few o r. no congregate care centers. |
| | The people of Nassau County'are entitled to an independent s tudy showing 'that there will be no harm to them. We must be assured that: |
| | : 1. If radiation gases escape the Shoreham 4 |
| | - .. ~ _ . - |
| | |
| | g , |
| | T |
| | . , . D |
| | '# l Nuclear Power Plant they will not " reach" the ! |
| | people of Nassau County. i |
| | : 2. The evacuation of at least 150,000 people can be orderly and safe. |
| | : 3. The quantity of water used to decontaminate the victims will not seriously diminish our resources. |
| | : 4. The water from the decontamination process will not contaminate our ground water supply. |
| | : 5. No radioactive contaminants will remain in any building used as a decontamination or congregate center or along the evacuation route. |
| | The Long Island Coalition for Safe Living asserts that LILCO or the NRC cannot assure the residents of Nassau County that they will be safe and that since no Department of Environmental Conservation impact study has occured, the Coliseum should be removed from the LILCO evacuation plan. |
| | While it has been determined that the carrying out of this LILCO plan by LILCO is illegal, we wish to state and get a ruling s |
| | saying that the carrying out of this plan for the health and safety of both the victims of Suffolk County and the residents of Nassau County would be impossible by ANY OFFICIAL BODY. |
| | Submitted by: |
| | -Robert Hoffman' #0_4.[ p Sharlene Sherwin d u, f Ar~ x/- |
| | Susan Rosenfeld % |
| | / |
| | [ |
| | P.O. Box 1355 Massapecua,N.Y. 11758. May 21,1985 5 |
| | -}} |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20093G4541995-10-18018 October 1995 Comment Supporting Proposed Rules 10CFR2,50 & 51 Re Decommissioning Procedures for Nuclear Power Reactors ML20058K7381993-12-0303 December 1993 Memorandum & Order CLI-93-25.* Commission Denies State of Nj Petition for Leave to Intervene & Request for Adjudicatory Hearing Filed on 931008.W/Certificate of Svc.Served on 931203 ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20057G2141993-10-14014 October 1993 Order.* Requests for Simultaneous Responses,Not to Exceed 10 Pages to Be Filed by State,Peco & Lipa & Served on Other Specified Responders by 931020.NRC May File by 931022. W/Certificate of Svc.Served on 931014 ML20059A4581993-10-14014 October 1993 Order Requesting Answers to Two Questions Re State of Nj Request for Immediate Action by NRC or Alternatively, Petition for Leave to Intervene & Request for Hearing. Operations Plans for Marine Transportation Withheld ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20057F2191993-09-30030 September 1993 Exemption from Requirements of 10CFR50.54(q) Eliminating Licensee Requirement to Follow & Maintain in Effect Emergency Plans ML20059B1291993-09-14014 September 1993 Affidavit of Jh Freeman.* Discusses Transfer of Slightly Used Nuclear Fuel from Shoreham Nuclear Power Station to Limerick Generating Station.W/Certificate of Svc & Notice of Appearance ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20095H5611992-04-28028 April 1992 Affidavit of Lm Hill.* Affidavit of Lm Hill Supporting Util Position That Circumstances Exist Warranting Prompt NRC Action on NRC Recommendation That Immediately Effective Order Be Issued Approving Decommissioning Plan ML20094G3971992-02-26026 February 1992 Notice of State Taxpayer Complaint & Correction.* NRC Should Stay Hand in Approving Application for License Transfer as Matter of Comity Pending Resolution of Question as Util Continued Existence in Ny State Courts.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20092D2931992-02-0606 February 1992 Answer Denying Petitions for Leave to Intervene & Request for Prior Hearing Re Decommissioning ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086T7541992-01-0303 January 1992 Memorandum of Long Island Power Authority Concerning Supplemental Legislative History Matls.* Supports Legislative History & Argues That License Not Subj to Termination Under Section 2828.W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086M0791991-12-16016 December 1991 Certificate of Svc.* Certifies Svc of Petitioner Notice of Appeal & Brief in Support of Appeal in Proceeding to Listed Individuals ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20094E1041991-12-0909 December 1991 Response to Long Island Power Authority to Petitioners Joint Supplemental Petition ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20091G1971991-12-0303 December 1991 Notice of Appeal.* Informs of Appeal of LBP-91-26 & LBP-91-39 in Facility possession-only License Proceeding ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* 1995-10-18
[Table view] Category:PLEADINGS
MONTHYEARML20059B0301993-10-22022 October 1993 NRC Staff Response to Commission Questions Posed W/Respect to State of New Jersey Petition for Leave to Intervene & Request for Hearing.* Denies Petition to Intervene & Request for Hearing.W/Certificate of Svc & Notice of Appearance ML20059B0621993-10-20020 October 1993 Long Island Power Authority Response to Nuclear Regulatory Commission Order of 931014.* Requests That NRC Reject State of Nj Filing.W/Certificate of Svc ML20059B1111993-10-20020 October 1993 Philadelphia Electric Co Response to NRC 931014 Order.* State Failed to Demonstrate Entitlement to Hearing to Challenge Util Amend to Permit Util to Receive Shoreham Fuel ML20059F0191993-10-0808 October 1993 Long Island Power Authority Reply to New Jersey Filing of 931020.* Licensee Requests That NRC Deny State of Nj Intervention Petition.W/Certificate of Svc ML20097C2631992-06-0303 June 1992 Petitioner Consented Motion to Dismiss.* NRC Should Issue Order Dismissing School District & Scientists & Engineers for Secure Energy,Inc as Petitioners in Proceeding.W/ Settlement Agreement & Certificate of Svc ML20097C2911992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeal.* Dismisses 911203 Notice of Appeal W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees Due to Encl Settlement Agreement. W/Certificate of Svc ML20097C1361992-06-0303 June 1992 Petitioners Consented Motion to Dismiss.* Petitioners by Counsel Move ASLB to Dismiss Petitioners as Petitioners for Leave to Intervene & Request for Hearing in Proceeding W/ Prejudice.W/Certificate of Svc ML20097C1081992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Appeal.* Petitioners Hereby Move to Dismiss 910628 Notice of Appeal in Matter W/Prejudice & W/Each Party to Bear Own Costs & Atty Fees.W/ Certificate of Svc ML20097C2891992-06-0303 June 1992 Petitioner Consented Motion to Dismiss Appeals.* Appeals Being Dismissed Due to Encl Settlement Agreement.Nrc Should Dismiss Appeals W/Prejudice & W/Each Party Bearing Own Costs & Atty Fees.W/Certificate of Svc ML20097C3241992-06-0303 June 1992 Petitioners Consented Motion to Dismiss Joint Opposition to Issuance of Decommissioning Order Prior to Hearing.* W/Certificate of Svc ML20096A5921992-05-0707 May 1992 Motion to Withdraw Supplemental Filing.* Petitioners Urge NRC to Allow Withdrawal of Supplement for Good Cause Shown. W/Certificate of Svc ML20096A5311992-05-0606 May 1992 Long Island Power Authority Comments on SECY-92-140 & Response to Petitioner Joint Opposition to Decommissioning Order.* Util Urges NRC to Adopt Recommendation in SECY-92-140 & Approve Order.W/Certificate of Svc ML20096A5071992-05-0505 May 1992 Suppl to Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Supplements Joint Opposition Prior to Hearing.W/Certificate of Svc ML20095K8991992-04-29029 April 1992 Joint Opposition to NRC Staff Recommendation for Issuance of Decommissioning Order Prior to Hearing & Contingent Motion for Stay.* Petitioners Urge Commission to Reject NRC Staff Proposal in SECY-92-140.W/Certificate of Svc ML20094G2261992-02-25025 February 1992 Petitioner Notice of Lilco/Long Island Power Authority Exaggeration & of Commencement of State Court Action.* NRC Should Await Ny State Decision Re Matter within Special Jurisdiction.W/Certificate of Svc ML20092K9021992-02-24024 February 1992 Petitioner Opposition to Ltr Request for Dismissal of Pages.* Suggests That Transfer of License Inappropriate at Present Time.W/Certificate of Svc ML20092K9511992-02-21021 February 1992 Response of Lilco & Long Island Power Authority to Petitioner Opposition to NRC Staff Recommendation for License Transfer Approval.* W/Certificate of Svc ML20092K8701992-02-20020 February 1992 Petitioners Opposition to NRC Staff Recommendation for Approval of License Transfer.* Urges Commission to Reject NRC Recommendation in SECY-92-041 & Remand Matter for Consideration in Normal Proceeding.W/Certificate of Svc ML20091E2661992-02-20020 February 1992 Petitioner Opposition to NRC Staff Motion to Dismiss.* Petitioners Urge NRC to Deny Staff Motion or Defer Action Until Petitioners Have Fully Developed Petitions & Supplied Detailed Contentions.W/Certificate of Svc ML20091E4011992-02-18018 February 1992 Answer of Long Island Power Authority to NRC Staff Motion to Dismiss Intervention Petitions.* Util Urges NRC to Grant Motion & Dismiss Intervention Petitions.W/Certificate of Svc ML20091E3161992-02-13013 February 1992 Lilco Response to NRC Staff Motion to Dismiss Intervention Petitions on Decommissioning Plan.* Requests That Petitions Be Struck & Petitioners Be Instructed of Possible Dismissal.W/Certificate of Svc ML20091E2941992-02-0606 February 1992 Lilco Opposition to Petitioner Request for Hearing on Shoreham Decommissioning Plan.* Informs That Util Opposes Both Requests for Hearing.W/Certificate of Svc ML20091E2741992-02-0606 February 1992 Answer of Long Island Power Authority to Intervention Petitions Concerning Shoreham Decommissioning Plan.* Requests That Petitions for Leave & Requests for Hearing Be Denied.W/Certificate of Svc & Notice of Appearance ML20091E2811992-01-22022 January 1992 Scientists & Engineers for Secure Energy,Inc Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition Be Granted & Hearing Be Held.W/Certificate of Svc & Notice of Appearance ML20091E2831992-01-22022 January 1992 Shoreham-Wading River Central School District Petition for Leave to Intervene & Request for Prior Hearing.* Requests That Petition for Leave Be Granted & Hearing Held. W/Certificate of Svc & Notice of Appearance ML20086T7231992-01-0303 January 1992 Motion of Long Island Power Authority for Leave to File Supplemental Matls.* Requests That Supplemental Memorandum & Supplemental Legislative History Matls Be Filed. W/Certificate of Svc ML20086Q9281991-12-30030 December 1991 Opposition of Util to Motion for Stay of License Transfer & to Suggestion of Mootness.* Concluded That Relief Sought in Petitioner Motion & Suggestion Should Be Denied. W/Certificate of Svc ML20086Q9171991-12-30030 December 1991 Lilco Opposition to Petitioners Request for Stay & Suggestion of Mootness.* Suggests That Stay Request & Suggestion of Mootness Be Denied.W/Certificate of Svc ML20091H8261991-12-19019 December 1991 Suggestion of Mootness Due to Long Island Power Authority Imminent Demise.* Concludes That If Commission Were to Transfer Shoreham Licenses to Lipa,Nrc Could Find Itself W/Class 103 Facility W/O Licensee.W/Certificate of Svc ML20091H8661991-12-18018 December 1991 Lilco Opposition to SE2 Appeal from LBP-91-26 & LBP-91-39. Concludes That Appeal Should Be Summarily Rejected or Be Denied on Merits.W/Certificate of Svc ML20086N1661991-12-17017 December 1991 Motion for Stay of License Transfer Pending Final Order on Petition to Intervene & Request for Hearing & for Addl or Alternative Stay.W/Certificate of Svc ML20086J3521991-12-0909 December 1991 Response of Long Island Power Authority to Petitioners Joint Supplemental Petition.* Board Should Dismiss Petitions to Intervene for Lack of Standing & Reject All Contentions Proffered by Petitioners.W/Certificate of Svc ML20086J6351991-12-0909 December 1991 Lilco Opposition to Petitioners Contentions on License Transfer Amend.* Concludes That License Transfer Amend Contentions Be Rejected & Petitioner Request to Intervene Denied.W/Certificate of Svc ML20091G2051991-12-0303 December 1991 Brief in Support of Appeal.* Commission Should Consider Appeal on Basis That Findings of Matl of Facts Clearly Erroneous.W/Certificate of Svc ML20086C5381991-11-18018 November 1991 Petitioner Joint Supplemental Petition.* Petition Includes List of Contentions to Be Litigated in Hearing Re License Transfer Application.W/Certificate of Svc ML20086C5471991-11-18018 November 1991 App to Joint Supplemental Petition of Shoreham-Wading River Central School District & Scientists/Engineers for Secure Energy,Inc.* ML20082G8971991-08-0909 August 1991 Lilco Responses to Petitioner Filings of 910805 & 06.* W/Certificate of Svc ML20082G8441991-08-0707 August 1991 Motion for Offical Notice to Correct Representation.* Moves Board to Take Official Notice of Encl NRC Records to Correct Representation Made at Prehearing Conference. W/Certificate of Svc ML20082G8571991-08-0707 August 1991 Petitioners Response to Lilco Re Physical Security Plan.* Petitioners Suggest That Util post-hearing Filing Does Not Dispose of Any Issue as to Util Compliance W/Settlement Agreement.W/Certificate of Svc ML20076D0721991-07-22022 July 1991 Petitioners First Emergency Motion for Stay.* Movants Urge Commission,In Interest of Justice,To Enjoin Lilco from Taking Any Actions Under possession-only License Which Might Moot Renewed Application for Stay.W/Certificate of Svc ML20076D1541991-07-22022 July 1991 Lilco Response to Petitioner Emergency Motions.* Believes Petitioner Emergency Motions Should Be Denied to End Frivolous Pleadings & Burdens of Time & Resources of Nrc. W/Certificate of Svc ML20076D0841991-07-21021 July 1991 Petitioners Second Emergency Motion for Stay.* Petitioners Urge Commission,Ex Parte,To Enjoin Lilco,From Any & All Acts W/Respect to Shoreham Which Would Be Inconsistent W/Nrc Representation in Court.W/Certificate of Svc ML20076D2071991-07-15015 July 1991 Lilco Opposition to Shoreham-Wading River Central School District (Swrcsd) Appeal from LBP-91-26.* Appeal Should Be Denied Due to Listed Reasons.W/Certificate of Svc ML20082D4051991-07-12012 July 1991 Lilco Opposition to SE-2s Contentions on Possession Only License Amend.* Concludes That Contentions Should Be Rejected & Request for Hearing on Possession Only License Amend Should Be Denied.W/Certificate of Svc ML20082D4001991-07-12012 July 1991 Movant-intervenors Motion for Change of Venue of Prehearing Conference.* Intervenors Request Change of Venue of 910730 Prehearing Conference from Hauppauge,Ny to Washington DC Area.W/Certificate of Svc ML20082D3891991-07-10010 July 1991 Lilco Support of NRC Staff Motion for Reconsideration of LBP-91-26.* for Reasons Listed,Nrc 910625 Motion Should Be Granted & Request for Hearing & Petition to Intervene in Amend Proceeding Should Be Denied.W/Certificate of Svc ML20082B4311991-07-0303 July 1991 Lilco Opposition to Petitioner Contentions on Confirmatory Order,Physical Security Plan & Emergency Preparedeness License Amends.* Petitioner Contentions Should Be Rejected & License Amends Denied.W/Certificate of Svc ML20082B3531991-07-0202 July 1991 Unopposed Motion for Variance in Svc Requirements.* Informs That Filing & Svc Requirements Presents No Obstacle to Filing W/Aslb or Svc Upon Any Parties.W/Certificate of Svc. Served on 910702.Granted for Licensing Board on 910702 ML20082B2461991-06-28028 June 1991 Movant-Intervenor Brief in Support Accompany Notice of Appeal.* School District Urges Commission to Reverse & Remand Dismissal Order W/Appropriate Guidance.W/Ceritifcate of Svc ML20082B2571991-06-28028 June 1991 Unopposed Motion for Variance in Svc Requirements.* Petitioners Urge ASLB to Grant Variance in Svc Procedures Requested to Allow Svc of Judge Ferguson.W/Certificate of Svc 1993-10-08
[Table view] |
Text
y ,v .ma . v,
a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the~ Atomic Safety and Licensing Board In the matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3
)
!Shoreham Nuclear Power Station ) (Emergency Planning)
Unit 1) )
MOTION TO INTERVENE ON BEHALF-OF THE RESIDENTS OF NASSAU COUNTY We the Long Island Coalition For Safe Living (" COALITION")
hereby petition as intervenors to be heard before the Atomic Energy and Licensing Board on the use of the Nassau County Veterans Memorial' Coliseum in the LILCO evacuation plan as part of the reopening of the record with regard to the Coliseum.
The " COALITION" requests the right to intervene and participate in the reopened proceedings to present testimony and other evidence-as to why the Coliseum should not be used in the LILuO evacuation plan in the event of a nuclear accident at the
'Shoreham Nuclear Power Station.
s BACKGROUND:
The Long Island Coalition for Safe Living is a coalition of some of the groups in Nassau County who are concerned with the
' health and well being of the residents of Nassau County as well as Suf folk County. They are:
Peoples Action Coalition Long Island Rate Payers Association
' 8505300532 850529 '
PDR ADOCK 05000322~ ^'
G PDR ' 1 4
. . ~
=*i Concarnsd Mothara of Nnascu S3fo Energy . Allianca o~f' Long Island PaccoSmith Mcuso'.
Mothers Alliance for Peace'--
.Long Island Progressive Coalition Long Island Citizens in Action Nurses Environmental Health Watch N.Y.' Community Action Network'
_ North Shore Coalition'for Safe Energy Women, Opposed to the Nuclear. Threat Long Island Network for Peace and Justice .
The residents of Nassau County began to feel the threat of the Shoreham Nuclear Power Station 'when Mr. Purcell offered the Coliseum as a decontamination center in the LILCO evacuation plan. 'We began to organize and participate in educational
. programs with civic, health and community organizations. Out of-
- this-experience came the conviction of not only the " COALITION" but of. the Lresidents of Nassau County that the opening of Shoreham poses a: great danger to our health and well being.
.We-intend to show cause for the withdrawal of the Coliseum-
- from~the LILCO evacuation' plan.
We are herewith presenting briefly two issues which should compel the N.R.C. to disqualify the use of the Coliseum as p'a'r_t of.the'LILCO evacuation, plan.'
ISSUES:
- 1. The- Nassau County Board of Supervisors never -
,_ approved the use of the Coliseum as _ part of the 0, LILCO evacuation plan in the eventof a nuclear-accident at Shoreham.
2.
The use of the Coliseum as a radiation-decontamination center poses great danger and harm-ito the residents of Nassau County, i
s 2
., _ w ARGUMENT:
- 1. When'the Long Island Coalition For Safe Living appeared before the Nassau County Board of Supervisors on 3/11/85 we challenged them to remove the Coliseum from the illegal LILCO l evacuation plan. Mr. F. Purcell, Nassau County Executive declared that the Coliseum was not part of any plan. He said his of fer of help was merely a humanitarian reply. Mr. Suozzi,. Mayor of Glen Cove, Long Island and Member of the Nassau County
. Board of Supervisors said that the Board never agreed that the Coliseum could be used by LILCO in their evacuation plan (attachment 1). Mrs Hannah Komanoff, also a member of the Nassau County Board o f -- Supervisors has taken the same position (attachment 2). Both have sent letters - to
>the Atomic Energy and Licensing ~ Board to this effect and their public statements at the Board meeting are on record at the Nassau County Board of Supervisors. LILCO misrepresents the f acts when it includes the use of the Coliseum in their.
s evacuation plan. LILCO, therefore, has a " void"in the record for an acceptable evacuation plan.
- 2. In the event of a nuclear accident at the-ShorehamuN' clear' Power Plant, the majority of the 150,000 people in the 10 mile evacuation zone and others totaling more than 500,000 (LILCO estimate) 3
A' cro expected to drive some 40 miles to the Coliseum ._
where their cars will be washed down. The water run off from washing down contaminated cars will seep into the water supply in the Uniondale,N.Y.
area. There is no catch basin lining in the designated parking fields as would be required in any " wash-down" zone.
The people are then supposed to be monitored, checked for radioactivity then showered and sent
'to congregate care centers (52 schools). The Coliseum is inadequate for this process since there are.only thirty one showers available f or the more than 150,000 people.
We also question the capability and the equipment to detect all forms of radioactive contaminants including transuranics. We also believe that there will not be sufficient accommodations f or the " sick" people who will be showing their first signs of radiation poisoning.
Many of the 52 schools named as congregate care centers do not accept their designated i
participation in the LILCO evacuation plan and have removed themselves leaving few o r. no congregate care centers.
The people of Nassau County'are entitled to an independent s tudy showing 'that there will be no harm to them. We must be assured that:
- 1. If radiation gases escape the Shoreham 4
- .. ~ _ . -
g ,
T
. , . D
'# l Nuclear Power Plant they will not " reach" the !
people of Nassau County. i
- 2. The evacuation of at least 150,000 people can be orderly and safe.
- 3. The quantity of water used to decontaminate the victims will not seriously diminish our resources.
- 4. The water from the decontamination process will not contaminate our ground water supply.
- 5. No radioactive contaminants will remain in any building used as a decontamination or congregate center or along the evacuation route.
The Long Island Coalition for Safe Living asserts that LILCO or the NRC cannot assure the residents of Nassau County that they will be safe and that since no Department of Environmental Conservation impact study has occured, the Coliseum should be removed from the LILCO evacuation plan.
While it has been determined that the carrying out of this LILCO plan by LILCO is illegal, we wish to state and get a ruling s
saying that the carrying out of this plan for the health and safety of both the victims of Suffolk County and the residents of Nassau County would be impossible by ANY OFFICIAL BODY.
Submitted by:
-Robert Hoffman' #0_4.[ p Sharlene Sherwin d u, f Ar~ x/-
Susan Rosenfeld %
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P.O. Box 1355 Massapecua,N.Y. 11758. May 21,1985 5
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