ML20034C798
| ML20034C798 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/05/1990 |
| From: | Saporito T NUCLEAR ENERGY ACCOUNTABILITY PROJECT |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20034C799 | List: |
| References | |
| CON-#290-10343 90-602-01-OLA-5, 90-602-1-OLA-5, OLA-5, NUDOCS 9005150038 | |
| Download: ML20034C798 (4) | |
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- .} l0D P' UNITED STATES.0F AMERICA NUCLEAR REGULATORY COMMISSION.
00g0 ATOMIC SAFETY AND'LICENSINGiBOARD May 5, 1990
'90 - ttAY -9 P4 :03-In the Matter of-
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Docket-Noa Mbb;f56f ~d{k4V d D-2 (QO'L'A-'S
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5 FLORIDA. POWER & LIGHT
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COMPANY-
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Technical Specifications
-Turkey Point Plant
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- Replacement
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(Unit Nos. 3 and 4)
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ASLBP No. 90-602401-OLA-5.
NEAP'S RESPONSE TO THE ASLB'S MEMORANDUM AND ORDER
'On April 24. 1990 the ASLB issued a Memorandum and Order
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requiring that NEAP submit a filing to. support their' standing in this proceeding.
Specifically, NEAP was ordered to-provide:-
A.
A statement signe'd by an authorized officer of NEAP that:
1.
The organization has decided.that it desires to continue be represented in this proceeding.
2.
Sets forth the name of the-organization's authorized representative in this proceeding.
T 3.
Explains the nature of and privileges:of memnbership in i
NEAP and how the organization 1 determines whether a.
particular person is a member.
Ii-4.
States that each of the persons on whom NEAP relies for standing is a member =and that'they'have been a member i
since the beginning of1this proceeding until the present date.
B.
Statement required from at least one member on.whom standing may be based that:
1.
They desire to be represented by NEAP in this proceeding.
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2.
Establishes that they have a personal interest in the proceeding (such as their place of residence ~or the-other contacts that establish that they have a direct 1
interest;.and-the nature of thecinterst theyeseek to protect).
p 3.
Establishes-the date they'became a member of NEAP and that they are currently: members of NEAP.
4.
Communicates-their understanding concerning their
-privileges as anmember of NEAP =and the-nature of theirf participation in NEAP activities.-
REAP'S RESPONSE TO THE ASLB'S INQUIRIES In responding to inquiry'A'1., NEAP would: state that: the organization has decided that'it desires to continue to be represented in thisLproceeding.
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In responding to inquiry A.2., NEAP would state that.the~
organization's authorized: representative in-this proceeding is I
d its Executive Director, Thomas J.
Saporito, Jr..
Although'Mr.
1 Saporito has withdrawn his; personal standing'in this proceeding, the Board of Directors has failed to fihd a more qualified-a
.i" representative at th t late date.
Therefore, Mr.<Saporito, in the upmost interest for public safety, has agreed to represent L.
d' NEAP in this proceeding.
E In responding to inquiry A.3.,
NEAP would state'that,
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pursuant to NEAP's bylaws germane to membership, that:-
(i) Membership shall be open to all'those i
interested individuals, who wish to i
particip' ate in accomplishment of the objectives of this corporation.
-Membe rs -
1 will be entitiled to receive information and newsletters, but they will.have'no 1
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voting-rights unless otherwise authorized by the board.
(ii) Members may be required from time-to-time to pay dues which shall be set by-the board.
(iii) Membership in this' corporation.shall tus approved by the board.
(iv) Each-member agrees to release, hold harmless, and idemnify the corporation,-.
its board of directors, officers, agents or members from all claims-for. damages arising from complaints or unlawful acts against:the member.
In rosponding to inquiry A.4., NEAP would state that NEAPL relies on its member Ms. Shirley Brezenoff who resides at 3765-N.W.
35th Street, Coconut Creek,: Floridac33066 for standing 'in this proceeding.
Ms. Brezenoff became a member of NEAP on i
November 29, 1989, (since the beginning of-this proceeding),-and f
is currently a member of NEAP.'
In responding to inquiries B.1.,
B.2.,
B.3.,
and B.4.,
NEAP
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- would state that an affidavit from Ms. Brezenoff and an application for membership from els Brezenoff are attached to 1
this filing.
Collectively, these documents satisfy the requirements of the ASLB's inquiries B.1-.,
B.2.
-B.3.,
and B.4.
and are hereby submitted for the record.
We note here that no requirement has been made by the ASLB to require that NEAP submit an affidavit from its membei NEAP submits this affidavit because it already had posession of the-
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document and further inquiry and1 requests to our member is not-warranted at this time.
In-responding to' inquiry'C, NEAP would rely'on the ASLB's wisdom and knowledge of the law as it applies to standing and would trust that the ASLB would hold upmost, public safety, in their determination of NEAP's= standing in this proceeding.-
For all the foregoing reasons and upon consideration of the entire record in this matter, the ASLB should: grant NEAP i
i standing in this proceeding.
For Public Safety, l
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,.;;f Thomas-J. Sapor'
.-Jr.-
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Executive Director, NEAP; P.O. Box 129 2,
Jupiter, Florida 33468-0i29 i
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(407) 743-0770
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