ML19351D115

Reply to NRC 800925 Response to Author 800910 Petition to Intervene.Original Petition Inadequate.Requests Permission to Renew & Resubmit Petition.Certificate of Svc Encl

ML19351D115
Person / Time
Site:	Callaway
Issue date:	10/02/1980
From:	Jeffrey Reed AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8010090045
Download: ML19351D115 (3)

Text

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UNITED STATES CF AF1RICA NUCLEAR REGULATGY COM2SSICN g g 4 e BEFCRE THE ATOMIC SAFETY AND LICENSING E0ARD In the Matter of )

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UNION ELECTRIC C0FPANY ) Docket Nos. STN 50-483 1

) STN 50-486 i (Callaway Plant, Units 1 and 2) )

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PETITIONER REPLY TO E E RESPONSE OF E E NRC ,

STAFF TO PETITION FILED BY JCHN G. REED I 1

Petitioner concurs with Staff findings that original petition of the undersigned, docketed by the Docketing and Service Branch on l 10 September 1980, fails to meet the requirements of 10 CFR 2.714 and does contain other discrepancies identified by Staff Counsel.

Original petition was submitted without knowledge of 10 CFR requirements, nor details of Union Electric's amended application for the issuance of an operating license. Mr. Reed, now, feels that he can satisfactorily meet the requirements of 10 CFR 2.714 if permitted to renew and resubmit his petition.

In view of the Staff Counsel's recorcr.endation that petitioner be afforded the vpportunity to renew and refile its petition, the undersigned has begun drafting such a document. Resubmission of l

said document being dependent upon the decision of the board which will rule upon this matter.

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Petitioner has requested copies of the following court n. lings or board findings:

Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 & 2), CLI-76-27, 4 NRC 610 (1976).

Wisconsin Public Service Corporation, et al. (Kewaunee Nuclear Power Plant), LBP 78-24, 8 NRC 78, 82 (1978).

Documents were referenced in Staff Response, identified above, but were not found in Local Public Document Room, Fulton Library, Fulton, Missouri. Request for above documents has been made to LPDR, Division of Rules and Records, Office of Administration, U.S. NRC, Wash., D.C.

AT'IN: Jona Souder, LPDR Coordinator. Information contained in these rulings may have impact upon refile of petition. Mr. Reed, requests such assistance as may be appropri2te to expedite delivery of above information.

Respectfully submitted, 3

John G. Reed Citizen of the United States of America Dated at Kingdom City, Missouri this 02nd day of October 1980.

UNITED STATES OF nMERICA NUCLEAR REGULATORY COMESSICN BEFCRE 'lHE A'1VMIC SAFETY AND LICENSING SOARD In the Matter of )

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UNICN ELECTRIC COFPANY ) Docket Nos. STN 50-483

) S'IN 50-486 (Callaway Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Petitioner Reply to the Response of the NRC Staff to Petition Filed by John G. Reed" were served this 03rd day of October,1980, by deposit in the U.S.

nail, first class postage prepaid, upon the following:

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Conrission Washington, D.C. 20555 4

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Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Roy P. Lessy, Jr., Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Conrission Washington, D.C. 20555 Gerald Charnoff, Esq. '

Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge i 1800 M Street, N.W.

Washington, D.C. 20036 )

Atomic Safety and Licensing Appeal Board {

U.S. Nuclear Regulatory Conrission l Washington, D.C. 20555 l

/ John G. Reed Citizen of the United States of America