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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20086R8381984-02-27027 February 1984 Brief on Issues Re Liability for Fees & Expenses.Certificate of Svc Encl.Related Correspondence ML20086K0471984-01-23023 January 1984 Request for Leave to Encl Reply to York Intervenors 840107 Response to Objections of NRC & Applicant to ASLB Proposed Decision & Order Re Withdrawal of Facility Application. Certificate of Svc Encl ML20086G6391984-01-0707 January 1984 Response Opposing NRC & Applicant Objections to ASLB 831214 Proposed Decision & Order Dismissing Application W/ Prejudice.Proposed Mods Should Be Rejected.Certificate of Svc Encl ML20083H6371984-01-0303 January 1984 Affidavit of Vs Boyer to Be Appended to 831229 Filing. Certificate of Svc Encl ML20083J5841983-12-29029 December 1983 Objection to & Motion for Mod of 831214 Proposed Decision & Order Dismissing Proceeding W/Prejudice.Dismissal W/Prejudice Would Require Full Adjudicatory Hearing ML20083J5991983-12-29029 December 1983 Motion for Summary Decision & for Termination of Proceedings as Moot & W/O Prejudice.Statement of Matl Facts & Certificate of Svc Encl ML20062M2741981-12-0404 December 1981 Withdrawal of 811125 Request for Extension of Time to Respond to ALAB-657.Further Evidence May Be Developed Since Decision Remanded Issue to Aslb.Reserves Right to Appeal Following Reconsideration of Issues ML20010D1581981-08-15015 August 1981 Requests to Be Included on Mailing List.Certificate of Svc Encl ML20010B2831981-08-0303 August 1981 Motion to Consolidate Fulton Case & for Extension of 15 Days to File Brief.Cases Present Common Question of Law & Fact. Intervenor Illness Necessitates Extension of Time ML20004E1671981-06-0101 June 1981 Response Supporting Util Exceptions to ASLB 810227 Memorandum & Order Dismissing Proceeding W/Prejudice. Proceeding Should Be Dismissed W/O Prejudice.Site Should Not Be Eliminated.W/Certificate of Svc & Notice of Appearance ML19345H2051981-04-27027 April 1981 Brief on Exceptions from ASLB 810227 Decision & Order Dismissing CP Application Proceeding W/Prejudice.Proceeding Should Be Terminated W/O Prejudice.Certificate of Svc Encl ML19345H1101981-04-20020 April 1981 Response Objecting to ASLB Granting Applicant 810413 Motion for Extension of Time.Intervenors Received Notice That Motion Was Granted Before Receipt of Applicant Request. Opportunity for Comment Not Allowed.Certificate of Svc Encl ML19345G6911981-04-13013 April 1981 Motion for Extension Until 810427 to File Brief on Exceptions.Counsel Family Illness Precludes Timely Completion of Brief.No Part Would Be Prejudiced by Extension.Granted for ASLAB,810415 ML20003D2691981-03-17017 March 1981 Exceptions to ASLB 810227 Decision & Order.Applicant Objects to Portion of Decision Dismissing Proceeding W/Prejudice. ASLB Incorrectly & Inconsistently Required Std of Intent W/Respect to Use of Site.Certificate of Svc Encl ML19341A6081981-01-23023 January 1981 Reply Supporting Applicant Earlier Motion to Withdraw CP Application W/O Prejudice.Opposes Intervenor York Committee for Safe Environ Response Supporting Withdrawal of Application W/Prejudice.Certificate of Svc Encl ML19340D1031980-12-17017 December 1980 Response of Intervenors York Committee for Safe Environ & Central PA Committee on Nuclear Power,In Opposition to Applicant 801205 Request to Withdraw CP Application W/O Prejudice.Certificate of Svc Encl ML19351E5771980-12-0505 December 1980 Motion to Withdraw CP Application & Terminate Proceedings. Certificate of Svc Encl ML20002A9991980-12-0505 December 1980 Motion to Withdraw Application for CP & Terminate Proceedings ML19322A3731979-07-30030 July 1979 Notice of Appearance of GL Boomsma on Behalf of Intervenor Save Solanco Environ Conservation Fund.Certificate of Svc Encl ML19276G5831979-06-0505 June 1979 Opposition by Util to Intervenor Save Solanco Environ Conservation Fund 790524 Motion to Terminate Docket.Petition Presents No Logal Basis for Relief.Arguments Are Outside ASLB Jurisdiction & Are Premature ML19276G5791979-06-0505 June 1979 Philadelphia Electric Co Motion to File Motion Out of Time in Opposition to Petition to Terminate Docket ML19246B7811979-05-25025 May 1979 Util Answer to Save Solanco Environ Conservation Fund 790514 Motion to Terminate Docket.Requests Response Due Date of 790604,due to Delay in Receipt of Petition.Certificate of Svc Encl ML19261D7711979-05-14014 May 1979 Requests by Save Solanco Environ Conservation Fund That NRC Order Util to Show Cause Why Application Should Not Be Terminated 1984-02-27
[Table view] Category:PLEADINGS
MONTHYEARML20086K0471984-01-23023 January 1984 Request for Leave to Encl Reply to York Intervenors 840107 Response to Objections of NRC & Applicant to ASLB Proposed Decision & Order Re Withdrawal of Facility Application. Certificate of Svc Encl ML20086G6391984-01-0707 January 1984 Response Opposing NRC & Applicant Objections to ASLB 831214 Proposed Decision & Order Dismissing Application W/ Prejudice.Proposed Mods Should Be Rejected.Certificate of Svc Encl ML20083J5841983-12-29029 December 1983 Objection to & Motion for Mod of 831214 Proposed Decision & Order Dismissing Proceeding W/Prejudice.Dismissal W/Prejudice Would Require Full Adjudicatory Hearing ML20083J5991983-12-29029 December 1983 Motion for Summary Decision & for Termination of Proceedings as Moot & W/O Prejudice.Statement of Matl Facts & Certificate of Svc Encl ML20062M2741981-12-0404 December 1981 Withdrawal of 811125 Request for Extension of Time to Respond to ALAB-657.Further Evidence May Be Developed Since Decision Remanded Issue to Aslb.Reserves Right to Appeal Following Reconsideration of Issues ML20010D1581981-08-15015 August 1981 Requests to Be Included on Mailing List.Certificate of Svc Encl ML20010B2831981-08-0303 August 1981 Motion to Consolidate Fulton Case & for Extension of 15 Days to File Brief.Cases Present Common Question of Law & Fact. Intervenor Illness Necessitates Extension of Time ML20004E1671981-06-0101 June 1981 Response Supporting Util Exceptions to ASLB 810227 Memorandum & Order Dismissing Proceeding W/Prejudice. Proceeding Should Be Dismissed W/O Prejudice.Site Should Not Be Eliminated.W/Certificate of Svc & Notice of Appearance ML19345H1101981-04-20020 April 1981 Response Objecting to ASLB Granting Applicant 810413 Motion for Extension of Time.Intervenors Received Notice That Motion Was Granted Before Receipt of Applicant Request. Opportunity for Comment Not Allowed.Certificate of Svc Encl ML19345G6911981-04-13013 April 1981 Motion for Extension Until 810427 to File Brief on Exceptions.Counsel Family Illness Precludes Timely Completion of Brief.No Part Would Be Prejudiced by Extension.Granted for ASLAB,810415 ML20003D2691981-03-17017 March 1981 Exceptions to ASLB 810227 Decision & Order.Applicant Objects to Portion of Decision Dismissing Proceeding W/Prejudice. ASLB Incorrectly & Inconsistently Required Std of Intent W/Respect to Use of Site.Certificate of Svc Encl ML19341A6081981-01-23023 January 1981 Reply Supporting Applicant Earlier Motion to Withdraw CP Application W/O Prejudice.Opposes Intervenor York Committee for Safe Environ Response Supporting Withdrawal of Application W/Prejudice.Certificate of Svc Encl ML19340D1031980-12-17017 December 1980 Response of Intervenors York Committee for Safe Environ & Central PA Committee on Nuclear Power,In Opposition to Applicant 801205 Request to Withdraw CP Application W/O Prejudice.Certificate of Svc Encl ML19351E5771980-12-0505 December 1980 Motion to Withdraw CP Application & Terminate Proceedings. Certificate of Svc Encl ML20002A9991980-12-0505 December 1980 Motion to Withdraw Application for CP & Terminate Proceedings ML19276G5831979-06-0505 June 1979 Opposition by Util to Intervenor Save Solanco Environ Conservation Fund 790524 Motion to Terminate Docket.Petition Presents No Logal Basis for Relief.Arguments Are Outside ASLB Jurisdiction & Are Premature ML19276G5791979-06-0505 June 1979 Philadelphia Electric Co Motion to File Motion Out of Time in Opposition to Petition to Terminate Docket ML19246B7811979-05-25025 May 1979 Util Answer to Save Solanco Environ Conservation Fund 790514 Motion to Terminate Docket.Requests Response Due Date of 790604,due to Delay in Receipt of Petition.Certificate of Svc Encl ML19261D7711979-05-14014 May 1979 Requests by Save Solanco Environ Conservation Fund That NRC Order Util to Show Cause Why Application Should Not Be Terminated 1984-01-07
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N G e" 15 August, 1981 l
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0 UNITED STATES OF AMERICA F6 duc2o * " 9 N UC LEAR REG ULATORY COMMISSIO N i
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' BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD ( ASLAB )
q w-p N M he Matter of
- PHILADELPHIA ELECTRIC COMPANY DOC KETS NOS : 50- 46
( Fulton Generating Station, Units 1, 2 ) 4,0 L'4%4'jg GONZALO FERNOS, ET AL. /
Petitioners * {
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- h o,u *' ir PETITIO N FOR INCLUSIO N IN T HE SERVICE O-L u.5#cd PAPERS '
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TO THE HONORABLE APPEAL BOARD :
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e COMES NOW the undersigned petitioner *, Pro Se, and in representation of Members of Citizens for the Conservation of Natural Resources, Inc. ( CCNR ), and respectfully states and prays :
. 1.- That on August 3,1981, the intervenors in Docket No. 50-376 requested the Appeal Board to consolidate Dockets No. 50-463,464 with Docket No. 50-376 for appeal purpose only ( E X H I B lT " A "). Although the consolidation was den:ed, it did not change the fact that the circumstances of both cases are very similar and concurrently under advisement by each Appeal Board.
e 2.- That the Intervenors of Docket No. 50-376, to pursue their appeal, for obvious reasons wish, inter alia, to follow closely the development of the appeal on Docke!s 50-463 and 50-464.
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- The undersigned petitioner and those he represents, of course,are not a party to this pro-l ceeding. Our interest in this case stems from the amazing similarity of the instant case and Docket No. 50-376 in which we are Intervenors. Thus. we respectfully ask leave from the Appeal Board to address the latter in such an unprecedented parallel circumstances betweer.
the two cases.
g333 8108240064 810815 /
PDR ADOCK 05000463 G PDR // O
y e WHEREFORE, it is respectfully requested pursuant to 10 CFR I 2.712(a) and the Public Information Act, that the Honorable Appeal Board issue order to include the under-signed petitioner in the mailing list of those to be served with orders, decisions, notices and other papers issued by the Commission, the Appeal Booro and all parties with regard to the instant case.
e in San Juan, Puerto Rico, this 15th day of August,1981.
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3 Gonzalo Fern 6s, Pro Se, and
' (G representing Members of CCNR.
503 Barb 6 Street to Santurce, Puerto Rico 00912 TELS : (809) 727-0087 / 727-2287 CERTIFICATE OF SERVICE BY Mall e i HERcBY CERTIFY : That on this same date copy of the above writ entitled :
PETITION FOR INCLUSION IN THE SERVICE OF PAPERS has been served by First Cbss Air Mail upon the following : Samuel J. Chilk, Esq., Secretary of the Commission ; Atomic Safety and Licensing Appeal Board Panel ; Atomic Safety and Licensing Board Panel ; Joseph R. Gray, Esq., Counsel for NRC Staff ; Docketing and Service Section, Office of the Secretary ( All the above bearing same address as follows : U.S. Nuclear Regulatory Commission, Washington, D.C.
20555 ) ; Theodore A. Adler, Esq., Widoff, Reager, Selkowitz & Adler, P.O. Box 1547, Harrisburg, Pa.17105 ; Michael J. Scibinco, Esq., Special Assistant Attorney General, Department of Natural Resources, Tawes State Office Building, Annapolis, MD 21401 ;
Executive Director, Susquehanna River Basin Commission,1721 N. Front Street, Harrisburg, Pa.17102 ; Mr. George L. Boomsmo, Save Solonco Environment Conservation Fund, P.O. Box 64, Ouarryville, Pa. 17566 ; Mr. Walden S. Randall, Riverhill Form, R.D. ' 2, Holtwood, Pa.
17532 ; Jean Royer Kohr, Esq. , Minney , Mecum & Kohr,150 E. Chestnut Street, Lancaster, Pa.
17602 ; to James A. Humphreys,111, Esq., Barley, Snyder, Copper & Barber, Attorneys for Applicant,115 E. King Street, Lancaster, Pa. 17602 ; Hugh K. Clark, Esq., Chairman, ASLB, P.O. Box 127A, Kennedyville, Maryland 21645 ; Dr. Donald P. de Sylva, Associate Professor of Marine Science, Rosentiel School of Marine and Atmospheric Science, University of Miami, Florida 33149 ; Mr. Gustave A. Linenberger, ASLB, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 ; Lawrence Sager, Esq., Sager & Sager Associates, 45 High Street, Pottstown, Pa.19464 ; Dr. A. Dixon Callihan, Union Corbide Corporation, P.O. Box Y, Ook Ridge, Tennesee 37830 ; W. Jeffrey Sidebottom, Esq., Barley, Snyder, Copper & Barber,115 East King Street, Lancaster, Pa.17602 ; Gilbert G. Malone, Esq., Ports, Beers, Feldmann &
Malone,145 East Market Street, York, Pa.17401 ; and to Mr. Donald-P.. Williams, Hunton &
Williams, P.O. Box 1535, Richmond, Virginia 23212. \
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