ML20039C988

Amend to 811202 Petition to Intervene.Affidavits Encl

ML20039C988
Person / Time
Site:	Indian Point
Issue date:	12/02/1981
From:	Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION
To:	Carter L, Paris O, Shon F Atomic Safety and Licensing Board Panel
References
CONTENTION, ISSUANCES-SP, NUDOCS 8112310180
Download: ML20039C988 (6)

Text

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WEST BRANCH CONSERVATION ASSOCIATION M3 BUENA VISTA ROAD NEW CITY N Y 10958 December 2, 1981 To:

Administrative Law Judges Hon. Louis J. Carter, Chairman i Dr. Oscar H. Paris d Hon. Frederick J. Shon 43W f Atomac Safety and Licensing Board Dockets No. 50-247-SP U. S. Nuclear Regulatory Commission 50-287-SP At:

Public Prehearing Conference - Amendment to Intervenor Application of Nov. 2.

Gentlemen:

With refrence to the statement of the Staff of the Nuclear Regulatory Commission of November 24, 1981., we hereby submit affidavits from members that state they are members of the West Branch Conservation Association and an affidavit from the Recording Secretary relating the time and date of Directors ' meeting where a motion was passed to participate in these proceedings in order.

to represent the interests of the members.

Regarding the contentions which we put forth:

1. Injury to our members has - aiready taken place in that there is no workable emergency plan in place to date and we have expected one before this date.

No measures have been taken to assuage the fears of the members' health and safety to an extent that any plan is in place. ,,

l l Persons who presented the plans to us at meetings and who represented the companies hired to confect plans were so unbelievable that our members lost confidence in safety measures put forth for emergencies in many ways, whether evacuation or not.

l 2. Therefore, we have listed the contentions we considered outstanding in our first application of

" (ffth aJ/ ' November 2, 1981. We had not been more specific because we were not arguing our case on application. We expect e 6D to offer witnesses who will butress our assertions.

UThe argncant that our contentions are too general is 6"c'@ Spj' d~ "not timely. We have taken our contentions from the nr S '

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r Energency Plan's own index. If our contsntions are too general then so is the Plan.

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3. We agree to withdraw 5d. since it is generic .

and we have enough other contentions without it.

4. Our very lives, our homes and our health are all in possible jeopardy. Most of our membership lives within' l the ten mile EPZ. We cannot see how anyone can construe that l I

we are not clearly threatened or affected by whatever is done '

for us or to us where we live. To say that we are not pro-viding sufficient injury is a farce. If our homes became ,

irradiated we would have no way of returning to them or of l financial recompense. Since the plan cannot assure us that i the risk and probability is nil, we are threatened every day.

S. Our organization is a membership association, nowhere did our application use the word " sponsor." The NRC Staff l implied that our members might not be members. We did not j so aver. '

6. The' certificate of Service states the title of Sec-retary which should also have been on the appli'ation c to intervene, under the name of Zipporah S. Fleisher and which is amended by the accompanying statement from Joan H. King, Recording Secretary.

7. In regard to NRC's Sept. 18 Memorandum and Order and that of January 8, WBCA contends that the risks surrounding Indian Point ~are greater than that of many other operating stations due to the design and condition of the stations. We expect to provide witnesses to illustrate that' the condition and design are riskier than many other stations.

8. We request that all documents referenced in the Orders

' governing these hearings be placed in the New City Library, North Main. Street, New City, N.Y. 10956, as well as a copy of the daily stenographic minutes (transcriptl. New City is the County seat of Rockland. We would be severely handicapped were we to have to drive to White Plains for references.

t (NUREG-0715, NUREG - CR-0400, NUREG - 0654 Revised., etc.)

9. We agree to supply one copy each to Con-Ed and PASNY of our documents. Our income is limited and we would find it a financial hardship when the time comes to offer testi-many to have to supply three each as requested. We do not have free copying equipment.

Respectfully submitted, hh Sipporah 6 3 S. Fleisher l

attached affidavits Secretary West Branch Conservation As6 443 Buena Vista Road New City., N.Y. 10956 December 2, 1981

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4 WEST BRANCH CONSERVATION ASSOCIATION 443 BUENA VISTA ROAD NEW CITY N Y 10956 To whom'it may concern:

This will attest that I, - Melissa Levi, residing at 36 South Mountain Road in New City, N.Y., Rockland County, and within the ten mile Emergency Planning Zone for Indian Point, do hereby give permission to the West Branch Conservation Association to represent me before the Hearing Board of the Nuclear Regulatory commission in hearings commencing with a prehearing conference at Croton-on-Hudson, New York, on December 2, 1981, and any and all subsequent hearings and con-farences that may ensue therefrom.

I am a member of West Branch Conservation Asso-ciation and a-member of the Board of Directors.

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/o u b Melissa Levi Sworn before me this mber, 1981 1 30 g of AbidAW $

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4 WEST BRANCH CONSERVATION ASSOCIATION 443 BUENA VISTA ROAD NEW CITY N Y 10956 To whom it may concern:

This will attest that I., Joan H. King, and I, Thomas J. King, residing at 80 Saw Mill Road, New City.,

New York, Rockland County, and within the 10 mile Emergency Planning Zone, do hereby give permission to the West Branch Conservation Association to represent us before the Hearing Board of the Nuclear Rsgulatory

, Commission on hearings regarding the emergency plans for the area of Indian Point commencing with a pre-hearing conference in Croton-on-Hudson, New York, on December 2, 1981., and any and all subsequent conferences and hearings that may ensue therefrom.

, We are both members of the West Branch Conserva-tion Association and Joan H. King is Recording Secretary.

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. 1LJA Thomp J. King Sworn before md this 30th day of November, 1981 0 -

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Notary Babh J O H N .r. COYLE J R. - _

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'Sidin! in Rockland County

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WEST BRANCH CONSERVATION ASSOCIATION 443 BUENA VISTA ROAD NEW CITY N Y 10956 To whom it may concern:

I am Joan H. King, Recording Secretary of the West Branch Conservation Association, elected at its annual meeting on May 16., 1981, in New City, N.Y.

At a meeting of the Board of Directors on October 28, 1981, in New City, New York, a resolution was moved by Bernard Flicker and seconded by Walter Fleisher to apply for the Association to become an intervening party in the hearings to be held before the Hearing Board of the Nuclear Regulatory Commission regarding the emergency plans for Indian Point; and that the Directors do hereby authorize Zipporah Fleisher, Secretary, Walter Fleisher, Vice-President and Martus Granirer, President, either singularly or collectively to appear at the prehearing conference (in Croton-on-Hudson, New York, on December 2, 1981) and at all conferences and hearings that may ensue therefrom.

The motion was passed unanimously. 15 Directors were present and voted. There are 20 Directors. 6 are a quorum as per the by-laws.

m Joan 'H. K1 Recording cretary G

Sworn before me this l

30th day of November, 1981 ,

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• i 8 a WEST BRANCH CONSERVATION ASSOCIATION 443 BUENA VISTA ROAD l NEW CITY N Y 10956 l

To whom it may concern:

The West Branch conservation Association is a not-for-profit corporation filed in 1971 with the New York Department of State.

1 The by-laws call for an annual ~ membership meeting which we have'never failed to have.. At the meeting I the Directors are elected. The by-laws provide for the l

usual requirements spelling out how meetings are called, notice, quorums, etc.

The membership operates the Association and dele-gates the usual duties to the officers and directors.

In the past we have received grants from America j The Beautiful, New York State Council On The Arts, the New Hudson.

York State Consumer Protection Board and Scenic l

We have appeared as parties in interest since 1974 before the Public Service Commission of New York State and the New York State Department of Environmental Con-servation, bringing our witnesses and preparing our own cases following them through from start to finish.

Attested by, jflh EL Zipporah S. Fleisher Secretary December 2, 1981 l

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