ML20052D080
| ML20052D080 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/29/1982 |
| From: | Fleisher W, Fleisher Z WEST BRANCH CONSERVATION ASSOCIATION |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-SP, NUDOCS 8205060255 | |
| Download: ML20052D080 (5) | |
Text
-
UNITED 5TATES OF AMERICA j
(
NUCLEAR REGULA ORY COMMISSION g h U4* hfil&[L&fAf0 HIC SAFE-TY-AND- % LEBs 067LLUh$'W h\\
. 3
'n ~.3
-ICENSING-8 ARD LZ B e-f+ee-A dminis t r-a-t-i+ e-Jud g es :
[m (
(. f d f x p
\\
faa urt mn-e-GrCa r t e r, Chairman D6W 0
s r
.v
'/M/GW
[
In the Matter of
')
/ /
)
i CONSOLIDATED EDISON COMPANY OF
)
NEW YORK, INC. (Indian Point,
)
Unit No. 2)
)
Docket Nos. 50-247-SP
)
50-286-SP M(t, i
POWER AUTHORITY OF THE STATE OF
)
N NEW YORK, (Indian Point,
)
April 29, 1982 S-
'qd o
Unit No. 3)
)
C j.-
i
)
d a ll g
C~,
- n _.
WEST BRANCH CONSERVATION ASSOCIATION'S REPLY pf '
k3 STATE OF NEW YORK POWER AUTHORITY'S NOTICE OF $
APPEAL OF THE GRANTING OF INTERVENTION TO MOST OFNTHEg ORGANIZATIONS ACCEPTED BY THE ATOMIC SAFETY AND LICEN4 N SING BOARD AND ITS SUPPORTING BRIEF OF APRIL 19 1982 The documents offered on April 19 do not conform l
to the instructions we received from the ASLB requiring the date and signature of the transmitter to be on the
{
first page and requiring an index on any document ex-l i
ceeding ten pages.
West Branch Conservation Association (WBCA) was not included but all the other intervenors were, in i
submitted by
(
c Dg3 Zipporal / S/. /Fleisher, Secretary 3
l 443 Buena Vista Road I
New City, N.Y. 10956
}
914/634-2327 y
i B205060255 820429 PDR ADOCK 05000 G
?.
q the rude attempt by PASNY to disqualify the interve-l nors that had been accepted by the ASLB.
In our 10 1
years as active intervenors in some 16 proceedings before the New York State Department of Environmental Conserva-tion and the New York State Public Service Commission we have never witnessed such a perverse attack through
]
the use of inuendo and slurs that could not be sustained 1
as evidence in a court of law.
In their petitions to eliminate fear as an issue, I
in their answers to petitions for leave to intervene, and now in the wasteful appeal to the Commission, PASNY has dragged down the name of the State of New York.
I It is particularly distressing that a State su-thority, created to enhance the health and welf are of the I
people of the state, feels free to attack the very people j
it is supposed to help, in the worst McCarthylera type of red-baiting and guilt-by-association, completely dis-1
]
regarding the citizens' right to dissent.
Known to most 4
of us the first amendment of the constitution of the i
United States.
l If the PASNY counsels feel the proceedings are a l
waste of time and the people involved are not worth hearing, then they can rest comfortably knowing that the feeling is mutual, and get on with it instead of wasting l
the tax payers' money.
i j i i
l-r
\\;
The request to dismiss parties because they may oppose nuclear power is absurd legally. We would have no courts of justice if such dismissals were tolerated.
If the representatives of PASNY are so sure of the probity of their case then they should welcome an investigation without fear of the outcome. Or at the very least, tolerate it with grace and manners.
WBCA seems to have met PASNY's requirements and it alone of the intervenors has done so. We might wonder if we are proud or embarrassed. But it seems opportune, therefore, for us to bother to speak up albeit we would prefer to save the money necessary to reply and to reproduce the many copies we must to serve the parties' list.
PASNY owes the court and the intervenors an apology and should back off, relax, join the pro-ceedings with intent to expedite them rather than wear all of us down with tedium and diversions.
We beseech the Commission to deny the April 19 motions made by PASNY.
Respectfully submitted, MY xc: Gov. Carey EEhrahS.
Flei er
- Rep. Gilman
- Sen. Winikow h M M F' M Assemblyman Moraha} ice-President
- Com. Dyson
- parties
- Assemblyman Levy i
l
UNITED STATES OF AMERICA i
7 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Administrative Judges:
0
,u-
- .a 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)
CERTIFICATE OF SERVICE I hereby certify that I have placed in the U. S. mails, first class, a copy to all parties listed below, of the Interrogatory to the Licensees and of WBCA Reply to PASNY8s Notice of Appeal to Granting Intervention...of April 19,1982' on this 30th of April, 1982.
Brent L. Brandenburg, Esq.
Docketing and Service Branch Assistant General Counsel Office of the Secretary Consolidated Edison Company of New York,Inc.
U.S. Nuclear Regulatory Commission Washington, DC 20555
" f]!"E E"[Y10003 Janice E. Moore, Esq.
Paul F. Colarulli, Esq.
Henry 3. McGurren, Esq.
Joseph 3. Levin, Jr., Esq.
NRC Staff Counsel Pamela S. Horowitz, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Charles Morgan, Jr., Esq.
M rgan Associates, Chartered Washington, DC 20555 1899 L Street, N.W.
Washington, DC 20036 Louis 3. Carter, Esq., Chairman.
Administrative Judge Charles M. Pratt, Esq.
Atomic Safety and Licensing Board Thomas R. Frey, Esq.
7300 City Line Avenue Power Authority of the State of New York Philadelphia, Pa.19151 10 Columbus Circle Dr. Oscar HI Paris New York, NY 10019 i
Administrative Judge Atomic Safety and Licensing Board Ellyn R. Weis, Esq.
i William S. Jordan, III, Esq.
i U.S. Nuclear Regulatory Commission Harmon & Weiss Washington, DC 20555 1725 I Street, N.W., Suite 506 Washington, DC 20006 Mr. Frederick 3. Shon Administrative Judge Atomic Safety and Licensing Soard Jean H lt, Project Director U.S. Nuclear Regulatory Commission Indian Potnt Project -
New York Public Interest Research Group
)
Washington, DC 20555 5 Seekman Street New York, NY 10038
Greatcr Now York Council on E.crgy clo D an R. Corren, Director John G11rsy, Wcstenest:r Coordinat:r N w York Univ rsity Indian Point Project 26 Stuyvesant Street New York Public Interest Research Grous New York, NY 10003 240 Central Avenue White Plains, NY 10606 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission 3:ffrey M. Blum, Esq.
Washington, DC 20335 N w York University Law Senoel ASL Appeal Board Penel a
a 623 Vanderbilt Hall Pat Posner, Spokesperson 40 Washington Square South Parents Concerned About Indian Point New York, NY 10012 P. O. Box 125
- "#~
Charles 3. Malkish, Esq.
Litigation Division -
Charles A. Scheiner, Co-Chairperson Port Authority of New York and New Jersey Westchester People's Action Coalition, Inc.
One World Trade Center P. O. Box 438 New York, NY 10048 White Plains, NY 10602 Alfed B. DelBell Alan Latman, Esq.
,Westchester county Executive 44 Sunset Drive Croton-on-Hudson, NY 10520 18 tl e Aven White Plains, NY 10601 Lorna Salzman Mid-Atlantic Recresentative Ezra I. Blalik, Esq.
Friends of the Earth, Inc.
Steve Leipsiz, Esq.
208 West 13th Street Environmental Protection Bureau New York, NY 10011 New York State Attorney General Two World Trade Center Judith Kessler New York, NY 10047 Rockland Citizens for Safe Energy P. O. Box 74 Renee Schwartz, Esq.
Botein, Hays, Sklar 6: Herzberg New City, NY 10956 Attorneys for Metropolitan Transportation Auth-Mayor George V. Begany 00 Park Avenue Ylltage of Buchanan New Yorx, NY 101066 236 Tate Avenue Buchanan, NY 10511 Stanley B. Klimberg M n. Richard Brodsky General Counsel county Legislature New York State Energy Office county office Building Agency Building #2 White Plains, N.Y. 10601 Empire State Plaza Albany, NY 12223 Andrew S.
Roffe, Esq.
N. Y. State Assembly Honorable Ruth Messinger Albany, N.Y. 12248 Member of the Council of the City of New York Ms. Amanda Potterfield, Esq.
y g
3 New York, NY 10007 3
Marc L. Parris, Esq., Eric Thorsen, Esq, New York, New York 10014 County Attornev County of Rockiand David H. Pikus,Esq., Richard Czaja, EsGg 11 New Hempstead Road 330 Madison Avenue New City, NY 10956 New York, N.Y.
10017 Geoff rey Cobb Ryan by Zipporah S.
Fleisher Conservation Committee Chairman, Director Secretary N M 4A.
/.
y New York City Auducon Society 71 West 23rc Street, Suite 1323 y-New York. NY 10013