ML19318C176
| ML19318C176 | |
| Person / Time | |
|---|---|
| Site: | 05000376 |
| Issue date: | 06/27/1980 |
| From: | Lessy R, Reis E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8007010143 | |
| Download: ML19318C176 (19) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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PUERTO RICO WATER RESOURCES
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Docket No. 50-376 AUTHORITY
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(North Coast Nuclear Plant, Unit 1)
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NRC STAFF MEMORANDUM IN RESPONSE TO APPEAL BOARD ORDER OF JUNE 4,1980 Edwin J. Reis Counsel for t1RC Staff Roy P. Lessy Counsel for NRC Staff June 27,1980 800701018G
i TABLE OF CONTENTS Page I.
Introduction......................,,,,,,
1 II.
Discussion.............................
5 III.
Co n cl u s i o n.............................
12 e
D
ii TABLE OF AUTHORITIES Page STATUTES Administrative Procedure Act, 5 U.S.C. 556(d)................
7 Atomic Energy Act of 1954, as amended 5189, 42 U.S.C. 62239...........................
9 National Labor Relations Act 9
510(b), 29 U.S.C. 5160(b).........................
9 610(e), 29 U.S.C. 8160(e).........................
REGULATIONS 9
10 C.F.R. 62.104..............................
5 10 C. F. R. 5 2.107..............................
6 10 C. F. R. 5 2.10 8..............................
10 C.F.R. 82.718..............................
6,7 7
10 C.F.R. 52.730..............................
9 10 C.F.R. 52.749..............................
9 10 C.F.R. Part 2, Appendix A........................
9 10 C.F.R. 650.35..............................
COURT CASES Federal Power Commission v. Texaco, 377 U.S. 33 (1969)...........
9 National Labor Relations Board v. Oshoa Fertilizer Corp., 368 U.S.
9 318 ( 1 9 61 )................................
United States v. Storer Broadcasting Co., 35' U.S. 192 (1956)........
9 i
Cella v. United States, 208 F.2d 783 (7th Cir. 1953), cert denied, 7
347 U.S. 1016...............................
National Labor Relations Board v. Aaron Convelescent Home, 479 F.2d 9
736 (6th Cir. 1973)............................
Rocky Mountain Power Co. v. Federal Power Commission, 409 F.2d 1122 8, 11 (D.C. Cir. 1969).............................
iii Page COMMISSION PROCEEDINGS Consolidated Edison Co. (Indian Point, Units 1, 2, 3), ALAB-319, 3 NRC 188 (1976) 10 Consumers Power Co. (Quanicassee Plant, Units 1 & 2), CLI-74-29, 8 AEC 10 ( 19 74 )..............................
5 Consumers Power Co. Quanicassee Power Plant, Units 1 & 2), CLI-74-37, 8 AEC 627 (1974)..............................
5 Consumers Power Co. (Midland Plant, Units 1 & 2), ALAB-47, 4 NRC 794 (1972)...................................
7 Detroit Edison Co. (Greenwood Energy Center, Units 2 & 3), LBP-76-56, 2 NRC 565 (1975)..............................
6 Gulf States Utilities Co. (River Bend Station, Units 1 & 2), ALAB-444, 6 NRC 760 (1977)..............................
9 Houston Power & Lighting Co. (South Texas Project, Units 1 & 2),
CLI-77-13, 5 NRC 1303 (1977)........................
11 Kansas City Gas & Electric Co. (Wolf Creek Nuclear Generating Station, Unit No. 1 ), CLI-77-1, 5 NRC 1 (1977)...................
7 Kansas City Gas & Electric Co. (Wolf Creek Station, Unit No.1),
ALAB-321, 3 NRC 293 (1976), affirmed, CLI-77-1, 5 NRC 1 (1977).......
10 Offshore Power Systems (Floating Nuclear Plant), ALAB-489, 8 NRC 194 (1978)..............................
7,11 Puerto Rico Water Resources Authority (North Coast Nuclear Plant, Unit 1), LBP-80-15,11 NRC (May 29, 1980)...............
4 Rochester Gas & Electric Co. (Sterling Power Project, Nuclear Unit No. 1), ALAB-596, 11 NRC (June 17, 1980)...............
6 OTHER AUTHORITIES Liquid Carbonic Corp.,116 NLRB No.101, 6 Ad. L.2d 416 (1956)........
9 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of PUERTO RICO WATER RESOURCES
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Docket No. 50-376 AUTHORITY
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(North Coast Nuclear Plant, Unit 1)
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NRC STAFF MEMORANDUM IN RESPONSE TO APPEAL BOARD ORDER OF JUNE 4, 1980 I.
INTRODUCTION On February 14, 1975, a notice of hearing providing opportunity for leave to intervene in this construction permit proceeding was published in the Federal Register.
Pursuant to that notice, Gonzalo Fernos, for himself, and on behalf of members of Citizens for the Conservation of Natural Resources, Inc. (here-inafter collectively referred to as " petitioner") was admitted as an intervenor in this proceeding.
Son thereafter, the discovery phase of the proceeding was initiated.
By letters dated December 3 and December 5, 1975, 3 Apolicant informed the parties of its decision to " postpone indefinitely the project" based primarily on economic consideratiors, requesting, however, an early site review at the Islote site.
Accordingly, Applicant requested that the proceeding be continued with the objective of the issuance by the Board of a partial initial decision on site S et'ter from William Miranda Marin to Bernard [ sic] Rusche (December 3,1975).
l S etter from Maurice Axelrad to James R. Yore, Richard F. Cole and Gustave l
Linenberger (December 5, 1975).
- suitability and site-related environmental issue [ On February 16, 1977, Applicant advised the Board that due to a change in its top management, a review of the timing of new generating capacity in Puerto Rico, including nuclear generation, was being undertaken, and that the review would take approximately six months.
In the interim, Applicant advised that it was continuing to develop information for the Staff in connection with the site review _4_/
On February 27, 1978, petitioner moved, inter alia, to dismiss the proceeding for various reasons, including delay.
In its response dated March 10, 1978, Applicant stated that the generation expansion study had been delayed for various reasons, and that an additional study was to be conducted under the auspices of the Office of Energy of the Commonwealth of Puerto Rico.b In order that Applicant apprise the Board and the parties of current developments, the Board ordered Applicant to file status reports on September 1,1978, and to update those reports at four-month intervals Such reports have been filed by Applicant in the ensuing months, indicating the continuing nature of the forementioned reports and studies, with no final conclusisn as to the instant application having been reached.
3 d.,
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1 S etter from Maurice Axelrad to James R. Yore, Richard F. Cole and Gustave A.
l Linenberger (February 16, 1977).
S" Motion To Dismiss Or To Grant Alternate Relief," (February 27,1978).
6
- /" Authority's Answer to Intervenor's ' Motion to Dismiss Or to Grant Alternata Relief,'" p. 3 (March 10,1978).
7/" Order Of The Board Concerning Intervenors' Motion To Dismiss Or To Grant Alternative Relief," p. 2 (May 1,1978).
On April 27, 1979, the Staff published its Site Safety Evaluat4n Report concluding that the proposed Islote site for North Coast Nuclear Plant (Unit 1) is acceptable under the guidelines of 10 C.F.R. Part 100.
In a status report to the Board dated December 28, 1979, Applicants stated that their next baseload generating unit would be a tnree-hundred megawatt (300 MW) coal-fired unit, thereby necessitating the deferral "for at least one year, and, in all likelihood, for a couple of years" further consideration of nuclear capacity at the Islote site. At that time Applicant requested that the period for submission of status reports be changed from four months to twelve monthsNNo opposition was lodged to this request and the presiding licensing board granted it, the next status report being due on December 31,1980.5 Presumably, in part, in light of the forementioned sequence of events, on April 30, 1980, petitioner filed with the Licensing Board a " Petition Requesting Evidentiary Hearings to RE;p;st Applicant to Show Cause Why Their Application Should Not Be Dismissed for Lack of Intention to Build." This petition requested the presiding Licensing Board to:
1.
Conduct a show cause hearing in Puerto Rico not later than July 1,1980, regarding the Applicant's intention to pursue the application; 2.
Issue an order dismissing with prejudice the above application; and 3.
Impose on the Applicant costs and damages in the sum of $10,000 on behalf of the Intervenors.
i 3 etter from Maurice Axelrad to Dr. Richard F. Cole and Gustave A. Linenberger L
28,1979).
l
$(December Unpublished " Order," LBP,(February 19,1980).
i l
. Responses were filed by both the Staff and the Applicant. The most recent state-ment of Applicant's perspective of the current status of its application is contained in Applicant's May 19, 1980 response before the Licensing Board in opposition to the instant petition:
However, the Intervenor neglected to mention that, in the sentence of the report immediately proceeding the language quoted by the Intervenor, the National Academy of Science also recomended that "it would be advisable to preserve the nuclear option as a possible component of Puerto Rico's future electric power system."
[ footnote omitted] The continuation of the instant application is intended to do just that, i.e., preserve the viability of the nuclear option until future planning decisions can be made. 3 On May 29, 1980, the Licensing Board issued its " Order," LBP-80-15,11 NRC (hereinafter " Slip. Op."), which stated:
We do not reach and decide the merits of the Intervenors' arguments and/or allegations. As a matter of law, the instant Motion must be and is denied.
(Slip Op., p. 2).
In denying the requested relief, the Licensing Board ruled that it had no authority to issue an order involuntarily dismissing the construction permit application on the ground, as asserted by petitioner, that the Applicant had abandoned its purpose to build the facility in question (Slip Op., p. 3).
Subsequently, on June 4,1980, the Appeal Board while conducting a sua sconte review of the Licensing Board Order, noted that "... one of the holdings contained therein [the Licensing Board Order] has such a questionable basis that, given its possible precedential importance, review of it on our own initiative may 3 " Authority's Response In Opposition To Intervenor's Petition," p. 6.
(May19, 1980).
1 now be warranted" (Aopeal Board Order, p. 1). Accordingly, the Aopeal Board requested thrit the parties address in memoranda the above ruling of the Licensing Board that it had no authority to issue an order involuntarily dismissing the construction permit application on the ground that the Applicant had sbandoned its purpose to build the facility in question.
II.
DIscilSSION Section 2.107 of the Commission's Rules of Practice,10 C.F.R. 62.107, provides in p rt that:
(a) The Commission... may, on receiving a request for withdrawal of an apolication, deny the aoplication or dismiss it with prejudice. Withdrawal of an ap-plication after the issuance of a notice of hearing shall be on such terms as the oresiding officer may orescribe.
The Comission in Consumers Power Co. (Quanicassee Plant, Units 1 & 2), CLI-74-29, 8 AEC 10 (1974), ruled that it will entertain requests by carties to oroceedinas for an order to compel an apolicant to withdraw an application on the oround that the applicant no longer wishes to construct the facility.
In a subseouent order in the same proceeding the Commission stated that a request to have an order on an application withdrawn should ordinarily be directed to and ruled on in the first instance by a Licensing Board in the course of considering a construction permit application.
Consumers Power Co. (Quanicassee Plant, Units 1 & 2),
CLI-7A-37, 8 AEC 627 n.1 (1974). Thus, the Comission had detennined that the Licensing Board had authority under 10 C.F.R. 82.107(a) to pass on the issue of whether an apolication may be ordered withdrawn for lack of intent to construct i
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's
%, ' ' - ~~ the project.
See also Detroit Edison Company (Greenwood Energy Center, Units 2 and 3) LBP-76-56, 2 NRC 565, 568 (1975). b The general powers of presiding officers to regulate the course of hearings and the conduct of proceedings similarly provide adequate grounds to entertain a motion asking inquiry into whether an application should be dismissed or ordered withdrawn because the applicant does not intend to construct the facility.
10 C.F.R. 52.718 provides:
A presiding officer las the duty to conduct a fair and impartial hearinJ according to law, to take appropriate action to avoid delay and to maintain order. He has all powers necessary to those ends, including the power to:
(e) Regulate the course of the hearing and the conduct of the participants.
(f) Dispose of procedural requests or similar matters.
(k)
Issue initial decisions; and (1) Take any other action consistent with the Act, this chapter, and sections 551-558 of title 5 of the United States Code, b censina Boards also have authority to order an involuntary dismissal liof a licensing proceeding and an application for failure to provide the Staff with requisite infomation. See 10 C.F.R. 62.108(c). See also Rochester Gas & Electric Co. (Sterling Power Project, Nuclear Unit No.1),
ALAB-596, 11 NRC (June 17,1980), where the Board stated it has inherent power to dismiss for mootness a proceeding involving a facility which the applicant said it could not construct.
This section of the Comissi~'s Rules of Practice restates Section 7(b) of the Adm.inistrative Procedure Act, now revised and codified in 5 U.S.C.1556(c).
Sect m 2.718 has been interoreted to grant the licensina board "'all oowers necessary' to carry out their duties 'to take appropriate action to avoid delay.'
Among the powers enumerated in this rule is the authority to 'take any other action consistent with the (Atomic Energy) Act,' the Comission's other regu-
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lations and the Administrative Procedure Act." Kansas City Gas and Electric Company (Wolf Creek Nuclear Generating Station, Unit No.1), CLI-77-1, 5 NRC 1, 5 (1977).
In general, presiding officers in administrative hearings have wide latitude as to all phases of the conduct of the hearing, including the manner in which the hearing will proceed.
Cella v. U.S., 208 F.2d 783 (7th Cir.1953, cert. den., 347 U.S. 1016. See also, Consumers Power Company (Midland Plant, Units 1 and 2), ALAB-47, 4 AEC 794, 795 (1972). These general powers to regulate the course of proceedings and bring them to fruition would provide authority for the Boards to entertain the subject motion and to inquire into whether the applicant into ds to use the construction ptrmit.
C_f Offshore Power Systems f
(Floating Nuclear Plants), ALAB-489, 8 NRC 194, 204-205 (1978).b Other agencies have been upheld in using their general powers in dismissing an application for failure of an applicant to go forward and establish basic matters 3 ould any doubt remain concerning the authority of a Licensing Board to Sh ultimately rule on the matter, it could seek to certify this matter, via the Appeal floard, to the Commission for final resolution.
See Offshore Power Systems, supra at 207; 10 C.F.R. 52.730(f). As also recognized in that case the powers of a board to regulate the course of proceedings do not extend to direction of the Staff in the performance of its independent respor.sibilities.
Id. at 201-202, 207.
needed for the grant of a license.
In Rocky Mountain Power Co. v. Federal Power Commission, 409 F.2d 1122,1127-1129 (D.C. Cir.1969), the court upheld a Commission order dismissing an application for inability to show economic or financial justification for the project. The court particularly held that the agency need not hold the oroject in abeyance until the applicant had the ability to ao ahead with the oroject.
Nor was there any duty to consider the project on the merits absent a showing that the applicant would proceed with the project. As the court stated:
The Commission has wide discretion in fashioning procedural ground rules which do not impinae on substantive rights.
Petitioner was unable to provide the required information during the six-year pendency of its application. The Commission gave clear warnings, and the dismissal was in keeping with its regulations and its precedents in similar cases.
In these circumstances, we cannot say that the Commission's disposition of the aoolication was un-reasonabla.
Lastly, we reach petitioner's contention that the Commission failed in a duty to consider the apDlication on its merits. But the Commission reasoned, in our view not improperly, that without even a threshold showing of its project's feasibility, "it seems useless to proceed."
Because of tha application's incompleteness, and thus the impossibility of granting petitioner a license on a deficient record, treatment of other asoects of the case would have wasted the valuable administrative resources of the Commission and the intervening state agencies, and the time and er.ergies of the other participants as well...
[ Footnotes omitted] [409 F.2d at 1128-29].
l In National Labor Relations Board v. Aaron Convelescent Home, 479 F.2d 736 (6th Cir.1973), the court faced the question of whether the Board could enter judgment on the respondent's default without hearing the merits of the proceeding.
Section 10(e) of the National Labor Relations Act, 29 U.S.C. 8160(e) (1970), provides that findings of the NLRB must be supported by substantial evidence. Section 10(b) of the Act, 29 U.S.C. 8160(b) (1970), provides that there was a "right to file an answer... and to appear in person or otherwise and give testimony..."b The court ruled that upon default, judgment could be entered under the general powers of the agency without considering the merits in the adjudication.b As recognized such powers may be placed in adjudicatory officers as well as in the Board or Comission itself.
See Liquid Carbonic Corp.,116 NLRB No.101, 6 Ad.
L.2d 416 (1956).
See also Federal Power Commission v. Texaco, 377 U.S. 33, 39-45 (1969); United States v. Storer Broadcasting Co., 351 U.S. 192, 205 (1956), both holding that statutorily required hearings need not be held where the applicants could not meet regulatory requirements for applying for a certificate or a license.$
U ompare Section 189 of the Atomic Energy Act of 1954, as amended, 42 U.S.C.
C 62239 (1979).
N ee also National Labor Relations Board v. Oshoa Fertilizer Corp., 368 U.S. 318, S
333 T1961), holding there is no need for a record or a hearing on a stipulated decree under the National Labor Relations Act.
E ection 189 of the Atomic Energy Act, as amended, 42 U.S.C. 62239, requires S
hearings on construction permit applications for nuclear power plants.
Pursuant to 10 C.F.R. ES2.104(b) and 50.35 certain findings must be made by a licensing board before a construction permit can issue.
It is required that the board detemine all the matters enumerated in those regulations.
See Gulf States i
Utilities Comoany (River Bend Station, Units 1 and 2), ALAB-444, 6 NRC 760, FOOTNOTE CONTINUED ON NEXT PAGE Thus as a matter of the law in this agency, and as a matter of general law, the agency and its hearing officers have inherent authority to take appropriate action on the inability or failure of a party to go forward, including the power to dismiss an application.
Common sense also dictates that an agency must have the power to dismiss applications where grant of such application would serve no purpose as the applicant does not intend to use the authority sought. The public's money should not be wasted and public employees hired to engage in such fruitless tasks.
For the efficiency of the agency, and so that the agency may spend its limited resources examining proposals which may come to fruition, authority must exist to dispose of moot applications regardless of an applicant's desires.
- Further, the policies of the Comission call for expeditious determination of applications in fairness to all parties.
See 10 C.F.R. Part 2, Appendix A, introductory paragraph; Kansas City Gas & Electric Co. (Wolf Creek Station, Unit No.1),
- ALAB-321, 3 NRC 293, 302 (1976), affirmed CLI-77-1, 5 NRC 1 (1977).
As we have indicated this proceeding was comenced in 1975. The Applicant apparently took little action to forward this matter.
It asked for substantial delays in EF00TNOTE CONTINUED FROM PREVIOUS PAGE 774-75 (1977); Consolidated Edison Co. of N.Y. (Indian Point, Units 1, 2, 3),
ALAB-319, 3 NRC 188,189-190 (1976).
Thus, no determination to issue a license could be made even if all contentions in dispue between the parties were settled, as a licensing board must not only resolve contested issues but must also assure itself that all applicable regulations and requirements have been satisfied. This is recognized in 10 C.F.R. 2.749(d) which provides that a summary judgment motion "may not be used to determine the ultimate issue as to whether the permit shall be issued." A dismissal for mootness or ordering a withdrawal of an application for failure of intent to construct the facility is by its terms not an action on the n:erits of an application and not within the terms of either 10 C.F.R. 52.749(d). See cases cited above.
9 1975,1977,1978 and 1979.
The Applicant's response to the Intervenor's motion filed with the Licensing Board dated May 19, 1980, does not state that Applicant still proposes to build the subject facility, but merely that it wishes to keep its options for future decisions open. The Intervenor in its motion pointed to purported facts, including the Applicant's purported disposal of the land on which the facility was to be constructed, which the Intervenor claims demonstrate
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that the Applicant has abandoned its intent to construct the facility.
In these premises, it would seem appropriate for the Licensing Board to have inquired into, and have held hearings if appropriate,E on whether the Applicant has abandoneditsintenttoconstructtheNorthCoastfacility.b N n Offshore Power Systems, supra at 207, the Appeal Nrd noted that hearings I
might be conducted into the causes and justification for c delav.
N e petition asked that the application be dismissed with prejudice.
Such a Th dismissal would not be appropriate.
Circumstances change and although the Applicant might not be entitled to a license now, it might be entitled to one at a future date.
See Rocky Mountain Power Co. v. Federal Power Comission, supra; Alabama Power Co. (Joseph M. Farley Nuclear Plant, Units 1 & 2),
ALAB-182, 7 NRC 210, 213 (1974); see also Houston Power & Lighting Co.
7 (South Texas Project, Units 1 & 2), CLI-7713, 5 NRC 1303,1321-22 (1977).
G l
III.
CONCLUSION For the above-stated reason the Intervenor's pleading should be treated as a motion to compel withdrawal of the application for Applicant's abandonment of intent to use the construction peririit sought, and rcmanded to the Licensing Board to inquire into the facts and rule on whether the Applicant has abandoned an intention to construct the North Coast nuclear facility.b Respectfully submitted, Y
Edwin J. Reis Counsel for NRC Staff f* h'a iqdf Roy. Lessy Counsel for NRC Staff Dated at Bethesda, Maryland, this 27th day of June,1980.
$ e Staff recognizes the position it takes here is not consonant with the Th position it took before the Licensing Board. However, further reflection and I
research on the particular questions propounded by the Appeal Board led to these conclusions.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of PUERTO RICO WATER RESOURCES
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Docket No. 50-376 AUTHORITY
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(North Coast Nuclear Ple.nt, Unit 1)
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NOTICE OF APPEARANCE Notice is hereby given that. the undersigned attorney herewith enters an appearance in the captioned r,atter.
In accordance with 62.713, 10 C.F.R. Part 2, the following information is provided:
Name
- Edwin J. Reis Address
- Office of the Executive Lega' Director U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Telephone Number
- Area Code 301-492-7505 Admissions
- Court of Appeals for the State of New York District Court for the District of Columbia Name of Party
- NRC Staff U.S. Nuclear Regulatory Comission Washington, D. C.
20555 ALb Edwin J. Reis Counsel for
.C Staff Dated at Bethesda, Maryland, this 27th day of June,1980.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COM:11SSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)l In the liatter of PUERTO RICO WATER RESOURCES Docket No. 50-376 AUTHORITY (NorthCoastNuclearPlant, Unit 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF MEMORANDUf1 IN RESPONSE TO APPEAL BOARD ORDER OF JUNE 4,1980" and " NOTICE OF APPEARANCE" of Edwin J. Reis in the above can'.ioned proceeding have been served on the followino by deposit in the United States mail, first class, or, as indicated hv an asterisk, throuch deposit in the Nuclear Regulatory Commission's internal mail systen, this 27th day of June,1980:
Alan S. Rosenthal, Esq., Chairman
- Mr. Gustave A. Linenberger*
Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Maurice Axelrad, Esq.
Dr. John H. Buck, Member
- Lowenstein, Newman, Reis, Axelrad Atomic Safety and Licensing Appeal
& Toll Board 1025 Connecticut Avenue, N.W.
U.S. Nuclear Regulatory Commission Washington, DC 20036 Washington, DC 20555 Esq. Jose F. Irizarry Gonzalez Michael C. Farrar, Esq.,f1 ember
- General Counsel Atomic Safety and Licensing Appeal Puerto Rico Water Resources Authority Board G.P.O. Box 4267 li.S. Nuclear Regulatory Commiss0'n San Juan, PR 00936 Washington, DC 20555 Alberto Bruno Vega, Assistant Sheldon, J. Wolfe, Esq., Chairman
- Executive Director, Planning Atomic Safety and Licensing Board and Engineering U.S. Nuclear Regulatory Commission Puerto Rico Water Resources Authority Washington, DC 20555 G.P.O. Box 4267 San Juan, PR 00936 Dr. Richard F. Cole
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555
- _ _ _ _ _ _ _ _ _ Mr. Gonzalo Fernos, Chairman Eng. Francisco Jimenez Citizens for the Conservation of Box 1317 Natural Resources, Inc.
Mayaguez, PR 00708 503 Barbe Street Santurce, PR 00912 Atomic Safety and Licensing Board Panel
- Esq. German A. Gonzalez U.S. Nuclear Regulatory Comission Attorney for Mision Washington, DC 20555 Industrial, Inc.
Mision Industrial De Puerto Rico Atomic Safety and Licensing Appeal G.P.O. Box 20434 Panel (5)*
Rio Piedras, PR 00925 U.S. Nuplear Regulatory Comission Washington, DC 20555 Mr. Mario Roche Velazquez Executive Director, Docketing and Service Section (7)*
Mision Industrial, Inc.
Office of the Secretary Mision Industrial De Puerto Rico U.S. Nuclear Regulatory Cormission G.P.O. Box 20434 Washington, DC 20555 Rio Piedras, PR 00925 Edwin J. Reis Assistant C Hearing Counsel e
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