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Amended Petition to Intervene in Proceeding As a .. - s . 02XETED. D irs.' UNITED STATES OF AMERICA NUCLEAR REGULATOR *I COMMISSION 21 CEC 14 P2:27 ATOMIC SAFETY & LICENSING BOARD . ..._ _ .. w. n c . ..s. G 1 SEP.VS. Before Administrative Judges: :'CH Louis J. Carter, Chairman Dr. Oscar H. Paris Frederick J. Shon -_____________________ ) In the Matter of: ) . ' ) CONSOLIDATED EDISON COMPANY OF NEW YORK. ) Docket Nos.--- , ) 50-247-SP (Indian Point, Unit 2) 50-286-SP , ) ~ ) - ) POWER AUTHORITY OF'THE STATE OF NEW YORK ) ) (Indian Point, Unit 3 ) _____________ ________ AMENDED PETITION FOR LEAVE TO INTERVENE Alfred B. DelBello, County Executive of the County of Westchester in the State of New York, hereby petitions for in- tervention in the above proceeding as an Interested State, pursuant to 10 C.F.R. b2.715(c). _ 8112170299 811210 PDR ADOCK 05000247 G PDR. _ . - - . - - . _ # . * * - -2- . The Indian Point nuclear power facilities are located in Buchanan, New York, . within the County of Westchester. All : -questions regarding the safety of these plaats are of paramount concern to the residents of Westchester' County. As Chief Ex- ecutive of the County, it is clearly my responsibility to repre- sent my constituents in this proceeding. The powers and duties of the County Executive of the ; County of'Westchester, set forth in Chapter 110 of the Westchester County Charter, 1937 New York Laus, Chapter 617, _as amended, include the following: - . The County Executive shal.1 be the chief ex- ecutive and administrative officer of the County and the official head of the County government. Emergency powers are delegated to County Executives by the 4 State of New York, pursuant to New York Executive Law, Article 2-B, as amended by the Radiologic Emergency Preparedness Act of 1981, 1981 New York Laws, Chapter 708. Section 24(1) of that law provides for the chief executive of a county to request i the Governor to declare a disanter emergency in the event of e radiological accident, and further provides: i Following such a declaration and during the continuance of such local state of emergency, the chief executive may promulgate local ! emergency orders to protect life and property or to bring the emergency situation under control. ~ _ _ _. ._ _ _ _ _ _ _ .__ - _ _ _ . , _ _ _ _ - . ... -3- ' - . The Westchester County Emergency Response Plan for the ; l Indian Point Power Station, now in draft pursuant to NUREG 0654 and the final emergency. planning rule, 10 C.F.R. 50.54, assigns the County Execttive lead responsibility for command cad control in the event of a radiological emergency. The County Director of Disaster and Emergency Services, who is directly responsible to the County Executive, is charged with responsibility for all preparedness functions, and County departments directly responsible to the County Executive are charged with lead responsibility for all response functions under the Plan. Therefore; County Executive-DelBello respectfully requests , ~ the Board -to grant leave to intervene as a representative of , "an interested state, county, municipality and or agencies thereof" . in accordance with 10 C.F.R. 2. 715 (c) . ALFRED B. DEL BELLO WESTCHESTER COUNTY EXECUTIVE - BY: 2 h m , ~J rE r c = e % MARIJJNE L. SUS!iMAN LEGISLATIVE ASSISTANT OFFICE OF THE COUNTY EXECUTIVE 148 Martine Avenue White Plains, New York 10601 i (914) 682-2121 | i -, _ , ... ., . UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ) CONSOLIDATED EDISON COMPANY ) Docket Nos. 50-247-SP OF NEW YHORK (Indian Point, Unit 2) ) 50-286-SP ) POWER AUTHORITY OF THE STATE OF ) . NEW YORK (Indian Point, Unit 3) ) CERTIFICATE OF SERVICE I hereby certify that ecpies of the annexed AMENDED PETITION FOR LEAVE TO INTERVENE in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class this 10th day of, December,1981. Paul L'. Colarulli, Esq. , Louis J. Carter, Esq., Chairman- . ~ Joseph J. Levin, Jr., Esq. Administrative Judge . Atomic Safety and Licensing Board' Pamela S. 'Horowitz, Esq. - U.S. Nu'elear Regulatory Commission Charles Morgan, Jr., Esq. Washington, DC 20555 Morgan Associated, Chartered 1899 L. Street, N.W. Dr. Oscar H. Paris Washington, DC 20036 Administrative Judge Atomic Safety and Licensing Board Charles M. Pratt, Esq. U.S. Nuclear Regulatory Commission Thomas R. Frey, Esq. Washington, DC 20555 Power Authority of the State of New York Mr. Frederick J. Shon 10 Columbus Circle Administrative Judge New York, NY 10019 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Ellyn R. Weis, Esq. Washington, DC 20555 William S. Jordan, III, Esq. Harmon & Weiss Brent L. Brandenburg, Esq. 1725 I Street, N.W., Suite 506 ' Assistant Generel Counsel Washington, DC 20006 Consolidated Edison Co. of New York, Inc. Joan Holt, Project Director 4 Irving Place Indian Point Project New York, NY 10003 New York Public Interest Research Group 5 8eekman Stret i New York, NY 10038 | 1 -- ___ _ . * , y. , ' - . -2- 1 John Gilroy, Westchester Coordinator Honorable Ruth Messinger Indian Point Project Member of the Council of the New York Public Interest City of New York Research Group District #4 240 Central Avenue City Hall White Plains, NY 10606 New York, NY 10007 Jeffrey M. Blum, Esq. Honorable Miriam Friedlander New York University Law School Member of the Council of the A23 Vanderbilt Hall City of New York 40 Washington Square South District #2 New York, NY 10012 City Hall New York, NY 10007 Charles 3. Haikish, Esq. Litigation Division Honorable Carol Greitzer The Port Authority of Member of the Council of the New York and New Jersey City of New York One World Trade Center District #3 New York, NY 10048 City Hall New York, NY 10007 Ezra I. Bialik, Esq. , Steve Leipsiz, Esq. "onorable Stanley E...Michels Member of the Council of the' Env'ironmental Protection Bureau - - - - New York State Attorney . City of New York- ~ ~ - Gene ~r'el's 0f fice - District #6' . ' City Hall- . Two World Trade Center New York, NY 10047 New York, NY 10007 , Andrew S. Roffe, Esq. Honorable Susan Alter New York State Assembly Member of the Council of the Albany, NY 12248 City of New York District #32 Renee Schwartz, Esq. City Hall Botein, Hays, Sklar & Herzberg New York, NY 10007 Attorneys for Metropolitan. Transportation Authority Honorable Edward C. Wallace 200 Park Avenue Member of the Council of the New York, NY 10166 City of New York Councilmember-at-Large, Manhattan Stanley B. Klimberg City Hall General Counsel New York, NY 10007 New York State Energy Office 2 Rockefeller State Plaze Honorable Mary Pinkett Member of the Council of the 1 City of New York District #28 City Hall New York, NY 10007 : ' Honorable Mary T. Codd Member of the Council of the City of New York Councilmember-at-Large, Staten Island City Hall New York g NY _10007 __ __ _ _ ^ ' .. , 6'd :. .~ . -3- j l Honorable Gilberto Gerano-Valentin Pat Posner, Spokesperson Member of the Council of the Parents Concerned About City of New York Indian Point District #11 P.O. Box 125 City Hall Croton-on-Hudson, NY 10520 , New York, NY 10007 Charles A. Scheiner, Co-Chairperson Honorable Arthur J. Katzman Westchester People's Action Member of the Council of the Coalition, Inc. City of New York P.O. Box 488 District #22 White Plains, NY 10602 City Hall New York, NY 10007 Alan Latman, Esq. 44 Sunset Drive Jonathan L. Levine, Esq. Croton-on-Hudson, NY 10520 Rockland Citizens for Safe Energy Lorna Salzman P.O. Box 74 Mid-Atlantic Representative New City, NY 10956 Friends of the Earth, Inc. 208 West 13th Street Marc L. Parris, Esq. New York, NY 10011 . - , c County Attorney County of Reckland . Zipporah S.- Fleisher - 1.1 New. Hempstead Road. West Branch Conservation Association - . ,. New City, N.Y 10956 443 Buena Vista Road . - New City, NY 10956 Geoffrey Cobb Ryan Conservation Committee Docketing and Service Section Chairman, Director Office of the Secretary New York City Audubon Society U.S. Nuclear Regulatory Commission 71 West 23rd Street, Suite 1828 Washington, DC 20555 New York, NY 10010 Mayor George V. Begany Greater New York Council Village of Bachanan on Energy 236 Tate Avenue c/o Dean R. Corren, Dire.ctor Buchanan, NY 10511 New York University 26 Stuyvesant Street Myron Karman New York, Ny 10003 Deputy Assistant Chief Hearing Council Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 w Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear' Regulatory Commission . S Washington, DC 20555 _M, -o i Harianne L. Sussman Legislative Assistant Office of the County Executive Westchester County White Plains, NY 10601.
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