ML19332B404

Addendum to 800917 Motion for Direct Certification Which Requested That CP Application Be Dismissed W/Prejudice. Applicant Withdrawal Evading Direct Confrontation W/Issues Raised & Litigated for 5 Yrs Is Unfair.W/Certificate of Svc

ML19332B404
Person / Time
Site:	05000376
Issue date:	09/18/1980
From:	Fernos G CITIZENS FOR THE CONSERVATION OF NATURAL RESOURCES, IN
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19332B398	List: ML19332B397 ML19332B404 ML19332B405
References
ISSUANCES-CP, NUDOCS 8009260681
Download: ML19332B404 (2)

Text

_ _ _ _ _ _ - _ _

q*

b 18 Scptsmbar,1980 UNITED STATES OF AMERICA BEFORE THE NUCLE AR REG ULATORY COMMISSION in the Matter of

• DOCKET NO. 50- 376 PUERTO RICO ELECTRIC POWER

• AUTHORITY ( POWER COMPANY )

Applicant

• Proposed North Coast GONZALO FERNOS, PRO SE, ET AL. Nuclear Plant (Unit 1)

Intervenors lslote Word, Arecibo, Puerto Rico

-: ADDENDUM TO MOTION FOR DIRECT CERTIFICATION :-

TO THE HONORABLE COMMISSION :

. COMES NOW the undersigned Intervenor, Pro Se, and in representation of Members of Citizens for the Conservation of Natural Resources, Inc., and respectfully subeN thefollowingaddendumto Motion for Direct Certification to Reavest Apolication Be Dismissed With Preiudice to be considered jointly with it :

e 7.-

That intervenors have been litigating this case for the lost five (5) years under very strenuous and burdensome circumstances both financially and timewise. Thus, Applicant's sudden turnobout in order to evade o direct confrontation with the issues raised by Intervenors would be extremely unfair to the latter by way of on additional hardship in the event on adjudication dismissing the application without prejudice is granted if by such an action the door were to be left open to Applicant to pursue the nuclear plant construction permit et a future date.

. 8.-

That intervenors believe that to request the Licensing Board to rule directly 1

on their request for o dismissal cf the application with oreiudice would be too slow a process in this crucial stage of the proceeding. Thus, Intervenors pray the Honorable Commission to directly adjudicate whether the opplicatio.1 should be dismissed with or without preiudice.

800gggo q g,

d Addendum to Motion.. . Docket No. 50-376 g e WHEREFORE, Intervenors pray the Honorable Commission to consider the above argu.nents jointly with all other six raised referred to in the Motion for Direct Certification, before od[udicating same.

In San Juan, Puerto Rico, this 18th day of September,1980.

Om

/ I:

e% w[

~ p h %

Gonzalo Fern 6 , F,ro Se, and in representation of Members i of CCNR I 503 Barb 6 Street Santurce, Puerto Rico 00912 i

Tels. (809) 727-0087 / 727-2287 CERTIFIC ATE OF SERVICE BY MAIL e i HEREBY CERTIFY : That on this some date 3 copies of the above addendum have been served by U.S. Air Mail upon the U.S. Nuclear Regulatory Commission, Docket-ing and Service Section ; one copy served by Air or First Class Mail on each of the following :

Hon. John F. Ahearne, Chairman, NRC ; Hon. Victor Gilinsky, Member, NRC ; Hon. Joseph M.

Hondrie, Member, NRC ; Hon. Peter A. Bradford, Member, NRC ; Alan S. Rosenthal, Esq. ,

Chairman, ASLAB ; Dr. John H. Buck, Member, ASLAB ; Sheldon J. Wolfe, Esq., Chairman, ASLB ; Dr. Richard F. Cole, Member, ASLB; Mr. Gustave A. Linenberger, Member, ASLB ; ,

Henry J. McGurren, Esq., Counsel for NRC Staff ( All the above bearing some address as follows : '

U.S. Nuclear Regulatory Commission, Washington, D.C. 20555) ; Maurice Axelrod, Esq.,

Lowenstein, Newman, Axelrod & Toll,1025 Connecticut Avenue, N.W., Washington, D.C.

20036 ; Joss F. Irizarry, Esq., legal Counsel for Applicant, Puerto Rico Electric Power Author-ity, GPO Box 4267, San Juan, Puerto Rico 00936 ; and Eng. Alberto Bruno Vega, Executive Director, Puerto Rico Electric Power Authority, GPO Box 4267, San Juan, Puerto Rico 00936.

%r 8

Mn

/ / (\/ .s I

klLU V Gonzalo Fern 6s

.