ML20032B788
| ML20032B788 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/02/1981 |
| From: | Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| *EP-20, *EP-22, *EP-24, *EP-35, *EP-36, *RS-37, *SD-38, NUDOCS 8111060322 | |
| Download: ML20032B788 (4) | |
Text
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COLKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'81 NOV -4 P4 :14 0FFICE OF SECREit&
BEFORE THE ATOMIC SAFETY AND LICENS h
In the matter of
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Consolidated Edison Company of New York ) Dockets Nos. 50-247 Indian Point Unit 2
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Power Authority of the State of New York)
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Indian Point Unit 3
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%! NOV0 61981m,.,:e PETITION FOR LEAVE TO INTERVENE
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- 1. West B7anch Conservation Association' N
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also known as, (WBCA
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Petitioner, on.its own behal and on behalf of its members, hereby petitions the Nuclear Regulatory Commission (NRC) for leave to intarvene in above captioned matter, pursuant to 10 CFR 2.714 of the NRC's Rules of Practice and to the NRC's Order dated Sept.18,1981.
2.
Petitioner is a not-for-profit organization of local citizens residing in North Clarkstown/Ramapo whose c. ailing address is 443 Buena Vista Rd., New City, N.Y.
10956.
It is a person within the meaning of 10CFR 2.4 (o). Peti-tioner represents the concerns of 350 families who live in the area of the West Branch of the Hackensack River, and j
who reside within the ten mile EPZ.
Its primary purpose is in the best use of land and water resources.
It is in-corporated in the State of New York.
it
.3 responsible for the acquisition of the 78 acre Davenport Preserve and a large part of South Mountain Park, and a "isual and oral history p6
$ b l under a grant from the NYState Council On The Arts of $5,000.
l 8111060322 811102 PDR ADOCK 05000247 8
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WBCA received 2 grants of expense money to appear before the NYState Publi Service Commission in electric rate cases from the Consumer Protection Soard of New York State.
- 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 operation of Indian Point Units 2 and 3 has affected and will continue to affect 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, Petitioner, WBCA, seeks to intervene on behalf of,itself and the following named persons, all of whom are sponsors or members of WBCA and who have speci-fically authorized WBCA to represent their interest in the Indian Point hearings and all of whom have a cognizable interest in the outcome of the proceedings:
1.
Mr.
&. Mrs. Thomas J. King, 80 Saw Mill Rd.,New City,N.Y. 10956 2.
Mrs. Melissa Levi, 36 South Mountain Road, New City, N.Y. 10956 3.
Mr. Bernard Flicker, 49 So. Mountain Road, New City, N.Y. 10956 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, West Branch Conservation Association, requests leave to intervene to represent the interests of its own members and the interests of the above named members in particular. Petitoner's interest that Indiar. Point Units 2 and 3 not continue to operate until the protection of the public health andenfety can reasonably be assured 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 issues:
a.
The feasibility of evacuation in the event of an emergency at Indian Point.
- b. The feasibility of staying in place in the event of an emergency.
The willingness of others to accept refugees from c.
the emergency.
d.She feasibility of the ten mile limit inside which we reside as a demarcation.
e.
The.-trensportation routes available.
- f. The plan for reunification of families.
- g. The safety and possible realistic life of the physical plants #2 and #3.
h.
The economic benefits of continued operation of units #2 and 53, if any. The concomitant liabilites of costs and who will be bearing them.
6.
For all the forgoing reasons Petitioner requests leave to intervene in the above captioned proceeding pur-suant to the NRC's January 8, 1981, order, amended Sep-tenber 8, 1981, in regard to the Indian Point Units 2 and 3 nuclear power stations.
Respectfully submitted, for West Branch Conservation Assn.
Dated: November 2 1981
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'1 New City, N.Y.
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%f Zipporah S.
- Fleisher, 443 Buena Vista Road Certificate of service attached.
New City, N.Y.
10956 914/634-2327
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U1NRC cNITED S m zS or n eaICA NUCLEAR RK;UIATORY CMIISSICN
'81 NOV -4 P4:14 5 CRETg E
BEFORE TIE ATCriIC SAFELY AND LINING BOARDf0SE ET G BRANCH In the Matter of
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Consolidated Edison Ccupany of New York
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Docket Nos. 50-247 (Indian Point, Unit 2)
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50-286
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Power Authority of the State of New York
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(Indian Point, Unit 3)
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u.xnnCATE OF SERVICE I wrtify that I have served copies of Petition for Leave to Intervene on the--part of West Branch Conservation Association, 443 Buena Vista Road, New City, N.Y.
- 10956, on the following parties by first class mil, postage paid this 2nd day of november
, 1981.
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Q.4 ( w rtb> {. h 4 W Lipporah S. Fleisher, Secre Ery-
- Samel J. Chilk, Secretary Docketing and Service U.S. Nuclear Regulatory Ccmnission U.S. Nuclear Regulatory Cctrcission Washington, D.C.
20555 Washington, D.C.
20555 Inuis J. Carter, Chairrean Office of the Executive Legal Director Atcnic Safety and Licensing Board U.S. Nuclear Regulatory Ccumission U.S. Nuclear Regulatory Ccrmission Washington, D.C.
20555 Washington, D.C.
20555 Counsel for Consolidated Edison Ccupuy Oscar H. Paris, hreber c/o the Secretary of the Ccumission Atcmic Safety and Licensing Board U.S. Nuclear Regulatory Ccrircissicn U.S. Nuclear Regulatory Cctrcission Washington, D.C.
20555 Washington, D.C.
20555 Counsel for the Poer Authority Frederick J. Shon, Me:rber of Nea Ydrk Atcmic Safety and Licensing Board c/o the Secretary of the Ccmrission U.S. Nuclear Regulatory Comrission U.S. Nuclear Regulatory Cctrcissicn Washington, D.C.
20555 Washington, D.C.
20555 Ellyn R. Weiss, Esq.
Joan Holt, Director Union of Concernec' Scientists Indian Point Project, hY PIRG 1725 Eye Street, Suite 506 5 Beek:ran Street Washington, D.C.
20036 Nea York, NY 10038 6