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Category:Legal-Correspondence
MONTHYEARML0404200352004-01-30030 January 2004
FTI Consulting Inc. Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for December 1, 2003 to December 31, 2003
ML0235701142002-11-25025 November 2002
E-Mail from John E. Matthews Tothomas Saporito Informing That the Licensing Board'S Telephone Conference Is Scheduled at 11:00 Am Eastern Standard Time, 9:00 Am Mountain Standard Time
ML0235701212002-11-25025 November 2002
E-Mail from Thomas Saporito to the Licensing Board and Parties Advis That the National Environmental Protection Center Was Unable to Connect to the Scheduled Teleconference on 11/25/2002
ML0232904072002-11-22022 November 2002
11/22/2002 - Letter to the Administrative Judges Enclosing Letter Dated, 11/22/2002 Advising That NRC Staff Does Not Oppose Licensee'S Withdrawal of 09/26/2002 License Amendment Application Pertaining to Section 5.5.9 of the Tech. Specs
ML0233300792002-11-20020 November 2002
Letter from John E. Matthews to Thomas Saporito Requesting That Further Communications with Arizona Public Service Company (APS) Should Be Directed to Morgan Lewis and Not to Individual Managers or Employees of APS
ML0235103292002-11-20020 November 2002
Letter from Thomas Saporito to John E. Matthews Acknowledging Receipt of 11/20/2002 Letter Certain and Specific References to National Environmental Protection Center'S Letter of 11/09/2002
ML0232505182002-11-0909 November 2002
Letter from Thomas Saporito to Gregg R. Overbeck Requesting Permission to Conduct a Random Sampling of Interviews with Employees at the Palo Verde Nuclear Generating Station to Learn About the Work Environment There
ML0235103602002-11-0808 November 2002
Letter from John E. Matthews Requesting That Further Service on Arizona Public Service Company (APS) Be Made to Aps'S Director of Law Department, Jane Smith Mueller, Esq., in Lieu of Service to Nancy C. Loftin, Esq
ML0235103612002-11-0808 November 2002
Letter from John E. Matthews Providing Correct Address for Janet Smith Mueller, Esq
ML18192B2491977-07-0808 July 1977
It Is Requested That Construction Permit Be Amended by the Deletion from the Caption of Each of Said Permits the Reference to Arizona Electric Power Cooperative, Inc. as an Applicant
ML18192A4471976-04-24024 April 1976
Certificate of Service Giving Authorization to Conduct Limited Work Activities for Local Officials to the Director of Nuclear Reactor Regulation
ML18219A5431976-02-10010 February 1976
Forwards Reply to the Archaeology and Historic Site Comments from Dept. of Interior of Jan. 15, 1976
ML18192A2141976-01-16016 January 1976
Pursuant to the Notice of Availability of the Draft Supplement to Final Environmental Statement Dated Nov. 25, 1975, 40 Copies of the Applicant'S Comments to Such Draft Supplement Are Submitted
ML18192A2151976-01-16016 January 1976
Pursuant to the Notice of Availability of the Draft Supplement to Final Environmental Statement Dated Nov. 25, 1975, 40 Copies of Applicant'S Comments to Such Draft Supplement Are Enclosed
ML18192A3411976-01-12012 January 1976
Figures 1 Through 12 to Opening Statement of Edwin E. Van Brunt, Jr
ML18192A7911975-12-26026 December 1975
12/26/1975 Legal Correspondence Withdrawal of Carmine F. Cardamone, Jr. as Intervenor in Proceedings
ML18192A7881975-12-19019 December 1975
12/19/1975 Legal Correspondence Withdrawal of Arizona Clean Energy Coalition as Intervenor in Construction Permit Hearings
ML18192B2761975-10-21021 October 1975
Certificate of Service Showing Service for Antitrust Review by the Attorney General, Served Upon Mr. Hugh K. Clark
ML18192A7531975-08-29029 August 1975
Response to Board'S Order of 07/21/1975 Requesting Each Party to File Report Indicating Status of Discovery
ML18192A8261975-08-29029 August 1975
Response to Board'S Order of 07/21/1975 Requesting Each Party to File Report Indicating Status of Discovery
ML18192A8291975-08-29029 August 1975
Notice of Service of Interrogatories
ML18192A7511975-08-0808 August 1975
Notice of Taking Deposition. Notice That Deposition Will Be Taken Upon Oral Examination of Kevin Dahl at Law Offices of Snell & Wilmer
ML18192A6801975-06-30030 June 1975
06/30/1975 Legal Correspondence Request for Exhibits & List of Witnesses
ML18192A6811975-06-19019 June 1975
06/19/1975 Legal Correspondence Adoption of Sub-Part I After Issuance of Draft Environmental Statement
ML18192A6821975-06-16016 June 1975
06/16/1975 Legal Correspondence Request for Copies of Subpart I & Project Independence Blueprints - Final Task Reports
ML18192A6701975-02-10010 February 1975
Request for Order Requiring Petitioner to Cure Petition Defects as Respects NRC Rules of Practice
2004-01-30
[Table view]
Category:Legal-Correspondence/Maintenance
MONTHYEARML0404200352004-01-30030 January 2004
FTI Consulting Inc. Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for December 1, 2003 to December 31, 2003
ML0235701212002-11-25025 November 2002
E-Mail from Thomas Saporito to the Licensing Board and Parties Advis That the National Environmental Protection Center Was Unable to Connect to the Scheduled Teleconference on 11/25/2002
ML0235701142002-11-25025 November 2002
E-Mail from John E. Matthews Tothomas Saporito Informing That the Licensing Board'S Telephone Conference Is Scheduled at 11:00 Am Eastern Standard Time, 9:00 Am Mountain Standard Time
ML0232904072002-11-22022 November 2002
11/22/2002 - Letter to the Administrative Judges Enclosing Letter Dated, 11/22/2002 Advising That NRC Staff Does Not Oppose Licensee'S Withdrawal of 09/26/2002 License Amendment Application Pertaining to Section 5.5.9 of the Tech. Specs
ML0235103292002-11-20020 November 2002
Letter from Thomas Saporito to John E. Matthews Acknowledging Receipt of 11/20/2002 Letter Certain and Specific References to National Environmental Protection Center'S Letter of 11/09/2002
ML0233300792002-11-20020 November 2002
Letter from John E. Matthews to Thomas Saporito Requesting That Further Communications with Arizona Public Service Company (APS) Should Be Directed to Morgan Lewis and Not to Individual Managers or Employees of APS
ML0232505182002-11-0909 November 2002
Letter from Thomas Saporito to Gregg R. Overbeck Requesting Permission to Conduct a Random Sampling of Interviews with Employees at the Palo Verde Nuclear Generating Station to Learn About the Work Environment There
ML0235103612002-11-0808 November 2002
Letter from John E. Matthews Providing Correct Address for Janet Smith Mueller, Esq
ML0235103602002-11-0808 November 2002
Letter from John E. Matthews Requesting That Further Service on Arizona Public Service Company (APS) Be Made to Aps'S Director of Law Department, Jane Smith Mueller, Esq., in Lieu of Service to Nancy C. Loftin, Esq
2004-01-30
[Table view] |
Text
6-D 77 DOCKETED USNRC December 17, 2002 (8:14AM)
DOCKET PROD. &NUMBEROFIEFSCRT UTIL FAC 5 O-5"S' OL 4OFFICE OF SECRETARYY RULEMAKINGS AND ADJUDICATIONS STAFF NE PC NATIONAL ENVIRONMENTAL PROTECTION CENTER November 20, 2002 John E. Mattews Morgan Lewis 1111 Pennsylvania Ave., N.W.
Washington, D.C. 20004 RE: John E. Mattews letter dated November 20th, 2002 to Thomas Saporito, Executive Director, National Environmental Protection Center
Dear Mr. Mattews:
This serves to acknowledge receipt of your letter dated November 20 1, 2002 regarding certain and specific references to the National Environmental Protection Center
("NEPC") letter of November 9 th, 2002 concerning your client Arizona Public Service Company ("APS"). In your letter, you assert that,
- ... further communications with APS should be directed to Morgan Lewis and not to individual managers or employees of APS... "
Mr. Mattews, insofar as NEPC's communications with the U.S. Nuclear Regulatory Commission ("NRC") licensee APS are related to the pending NRC adjudication before the NRC Atomic Safety and Licensing Board ("ASLB7), we agree that our communications are properly made to your law firm as counsel to ASP. However, with respect to NEPC's rigjht under existing authority, NEPC reserves Its right to contact MY APS employee regarding anM safety and/or health concern that NEPC has with respect to operations at the APS Palo Verde Nuclear Generating Station ("PVNGS"). In your November 2 0 th, letter, you state that,
.... be assured that APS has a robust security program, and both the NRC and the nuclear industry have enhanced security at nuclear reactor sites across the United States in response to the events of September 11, 2001. In addition, APS has a well-developed and effective program for assessing and responding to any nuclear safety-related concerns..."
We strenuously disagree that the PVNGS facility's security program is sufficient to prevent a terrorist attack similar to the September 11, 2001 event. Notably, NEPC's headquarters are approximately 7.5 miles from the PVNGS facility. Our recent observations during a recent refueling event at the PVNGS facility leave us to believe that APS could not act in a timely and sufficient manner to prevent a serious and significant terrorist attack, and especially during refueling events where the nuclear facility is most vulnerable. Unlike the undersigned, a seasoned journeyman instrument control technician with years of P. O. BOX 1021, TONOPAH, ARIZONA 85354 PHONE: 623-386-6863 FAX* 309-294-1305 NEPC@THEPOSTMASTER.NET Sec 0 seo'/3
"NATIONAL ENV1RONMENTAL PROTECTION CENTER experience In the nuclear industry, you are an attorney at law and apparently mislead about the sufficiency of the security program at the PVNGS facility. Indeed, the PVNGS facility is located in an isolated area in the middle of the dessert and vunerable to a terrorist attack.
Moreover, the high-lines leading from the PVNGS facility stretch across the dessert and are extremely vulnerable to attack by terrorists. Moreover, should a terrorist attack cause the loss of off-site power to the PVNGS facility, it is not apparently clear what might result.
NEPC has engaged the NRC Region IV authority to monitor its grave concerns with respect to APS's purported "robust" security program. To this extent, NEPC will continue to engage in "protected activity" in addressing its safety and health concerns to any NRC licensee employee at APS or to A government authority or to the media to ensure for the safety and health of the public and the environment as a whole.
You end your November 2 0 th, letter stating in relevant part that,
".. . we are very concerned regarding your solicitation of an assignment from APS - relating to your proposal to come to the plant and interview numerous Palo Verde employees..."
Mr. Mattews, yau and the law firm of Morgan Lewis & Bocklus and your client APS are hereby put on NOTICE that neither NEPC nor its undersigned executive director will tolerate any type Implied authority by you or your law firm or by APS to threaten, or to intimidate, or to otherwise dissuade NEPC, its membership, or its undersigned executive director from engaging in any type of activities deemed appropriate in furtherance of the NRC's safety regulations to ensure for the safe and proper operation of the APS nuclear facility. It is of arave concern to NEPC that your comments in your letter come on the heals of a NRC ASLB proceeding in which NEPC has petitioned the NRC ASLB for leave to intervene.
It is strongly suggested that you counsel your client APS accordingly!
Best regards, Thomas Saporito Executive Director Cc: service sheet 2
"°NATIONAL ENVIRONMENTAL PROTECTION CENTER Gary Sanborn Ann M. Young, Chair Russell Wise Atomic Safety/Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission NRC Region IV Washington, D.C. 20555-0001 Dallas, Texas Richard R. Cole Office of the Secretary Atomic Safety/Licensing Board Panel ATIN: Rulemakings and Adjudications StafiF U.S. Nuclear Regulatory Commission U.S. NUclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555 Thomas D. Murphy G. Paul Bollwerk III, Esq. Atomic Safety/Licensing Board Panel Chief Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Janet Smith Mueller, Esq.
Director of Law Department Pinnacle West Capital Corp.
Post Office Box 53999 Mall Station 8695 Phoenix, AZ 85072-3999 Sherwin E. Turk, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 3
