ML20035H549
| ML20035H549 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/26/1993 |
| From: | Berger W BRAND, BEENY, BERGER & WHITLER, LOUISIANA, STATE OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 9305050252 | |
| Download: ML20035H549 (8) | |
Text
.
r UNITED STATES OF AMERICA UhE'I NUCLEAR REGULATORY COMMISSION 93 APR 26 P3 :42
.r 4
In the Matter of
)
E m.re Gulf States Utilities
)
NRC Docket No. 50-458:
)
COMMENTS, PETITION FOR LEAVE TO INTERVENE, AND REQUESTS FOR A FINDING OF SIGNIFICANT CHANGE AND A-HEARING OF LOUISIANA ENERGY AND POWER AUTHORITY Pursuant to the Federal Register notice of March 25,.1993, 58 Fed. Reg. 16,246, the Louisiana Energy and Power Authority
("LEPA") submits its comments in opposition to the requests of Gulf States Utilities Company (" Gulf States") to amend its license for its River Bend nuclear station.
Unless and until Gulf States and Entergy Services, Inc. ("Entergy"), comply with existing antitrust license conditions the requests should be denied.'
LEPA also petitions for leave to intervene, and requests the Commission to (1) make a finding that significant changes in the licensees' activities or proposed activities have occurred since the completion of the previous antitrust review and (2) hold an antitrust review and hearing prior to approving the requested amendment to those license conditions.
Being filed concurrently is the Comments, Petition for Leave to Intervene, and Requests for a Finding of Significant Change-i and a Hearing of Terrebonne Parish Consolidated Government 3
Should Gulf States and Entergy fail to comply with their antitrust license conditions LEPA moves that this commission find t
them in violation of those conditions and require full, immediate compliance.
9305050252 930426 PDR ADOCK 05000458 C
PDR id t
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("Terrebonne's' Comments").
Since LEPA believes that Terrebonne's comments adequately address the reasons why this Commission should not act as Gulf States requests, and should act as l
Terrebonne requests, LEPA joins in those comments.
In order to
_l avoid overburdening the record, LEPA will incorporate l
Terrebonne's Comments by reference rather than repeat them l
herein.
.I i
LEPA only notes that for the reasons stated at pageL12 of l'
Terrebonne's Comments LEPA also meets the requirements of-l Rule 2.714 and should be granted leave to intervene.
In accordance with Rule 2.708(e), service of all papers may 4
be made on the attorneys whose names and address _ appear below.
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i WHEREFORE, for the reasons stated in Terrebonne's Comments, 7
LEPA asks this Commission to (1) withhold the requested approvals unless and until Gulf States and Entergy come into compliance I
with their NRC license conditions, (2) grant LEPA's motion for leave to intervene, (3) make a finding of significant change and (4) hold an antitrust review and hearing prior to approving the requested amendment to the license conditions.
l l
s Respectfully submitted, i
Wallace E.
Brand Sean E.
Beeny Melvin G.
Berger BRAND, BEENY, BERGER & WHITLER 1730 K Street, N.W.
Suite 1000
[
Washington, DC 20006 l
(202) 347-7002 Attorneys for Louisiana Energy and Power Authority I
i Dated:
April 26',
1993 i
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1 UNITED STATES OF AMERICA
- H
L ANEC NUCLEAR REGULATORY COMMISSION
'93 APR 26 P3 X2 In the Matter of
)
Gulf States Utilities
)
NRC Docket No. 50-458.-
. ni i r -
)
Dw.i a.:,
, i-pi D J. h t. e CERTIFICATE OF SERVICE t
I hereby certify that I have served a copy of the foregoing Comments, Petition For Leave To Intervene, and Requests For a Finding of Significant Change and a Hearing of Louisiana Energy and Power Authority, in the above-captioned proceeding by causing a copy to be deposited in the United States mail, first class postage prepaid, addressed as set forth below, except for
~
Mr. Bouknight who was served by hand, on this 26th day of April, 1993.
Melvin G.
Berger" BRAND, BEENY, BERGER & WHITLER 1730 K Street, N.W.
I Suite 1000 Washington, DC 20006
{
Attorneys for Louisiana Energy and Power Authority Philip P.
Graham Vice President River Bend Nuclear Group 5485 U.S.
Highway 61 l
Post Office Box 220 St. Francesville, LA 70715
-l Cecil L.
Johnson, Esquire Vice President - Legal Services Gulf States Utilities company 350 Pine Street Beaumont, TX 77701 i
J.A.
Bouknight, Jr.,
Esquire f
Newman & Holtzinger, P.C.
Suite 1000 1615 L Street, N.W.
Washington, DC 20036 (Representing Entergy) i r
UNITED STATES OF AMERICA 7l.li.(
NUCLEAR REGULATORY COMMISSION
'93 11PD 26 P 3 :41 In the Matter of
)
~
Gulf States Utilities
)
NRC Docket No. 50-458
)
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.
In accordance with 5 2.713, 10 C.F.R.,
Part 2, the following information is provided:
Name:
Wallace E.
Brand Address:
Brand, Beeny, Berger & Whitler Suite 1000 1730 K Street, N.W.
Washington, DC 20006 Telephone No.:
(202) 347-7002 Facsimile:
(202) 223-9183 Name of Party:
Louisiana Energy and Power Authority (LEPA)
Admission:
U.S.
Supreme Court
~
V M/s Wallace E.
Brand Counsel for Louisiana Energy and Power Authority Dated at Washington, D.C.
j i
This 26th day of April, 1993
J ri;i; i
UNITED STATES OF AMERICA
,,5 N F. C NUCLEAR REGULATORY COMMISSION i
93 M926 P 3 :44 f' ?
j'
- 4I f
In the Matter of
)
- gg, Gulf States Utilities
)
NRC Docket No. 50'458
)
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.
In accordance with S 2.713, 10 C.F.R.,
Part 2, the following l
information is provided:
Name:
Sean T.
Beeny Address:
Brand, Beeny, Berger & Whitler Suite 1000 1730 K Street, N.W.
f Washington. DC 20006 i
Telephone No.:
(202) 347-7002 Facsimile:
(202) 223-9183 Name of Party:
Louisiana Energy and Power Authority (LEPA)
Admission:
U.S.
Suprene Court tr 1
~
l Sean T.
Beeny
)
i Counsel for Louisiana Energy and Power Authority
]
l Dated at Washington, D.C.
This 26th day of April, 1993
L UNITED STATES OF AMERICA l
"*C I
NUCLEAR REGULATORY COMMISSION 93 APR 26 P3 :45
.iiy:..::;...
In the Matter of
)
t "' : 'N Gulf States Utilities
)
NRC Docket No. 50-458 "'
)
NOTICE OF APPEARANCE I
Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter.
In accordance with S 2.713, 10 C.F.R.,
Part 2, the following information is provided:
Name:
Melvin G.
Berger j
k Address:
Brand, Beeny, Berger & Whitler Suite 1000 1730 K Street, N.W.
Washington, DC 20006 i
Telephone No.:
(202) 347-7002 Facsimile:
(202) 223-9183 Name of Party:
Louisiana Energy and Power Authority (LEPA) r Admission:
Court of Appeals of Maryland W
Melvin G.
Berger Counsel for Louisiana Energy and Power Authority Dated at Washington, D.C.
l This 26th day of April, 1993
l i
UNITED STATES OF AMERICA
- hhc t
i NUCLEAR REGULATORY COMMISSION 93 wa 26 P3 :41 In the Matter of
)
f Gulf States Utilities
)
NRC Docket No. 50.458 totid-
)
OvCri M-
iFI-hi.Ma.+
CERTIFICATE OF SERVICE f
I hereby certify that I have. served a copy of the foregoing Notices of Appearance in the above-captioned proceeding by causing i
a copy to be deposited in the United States mail, first class l
postage prepaid, addressed as set forth below, except for l
l Mr. Bouknight who was served by hand, on this 26th day of April, J
1993.
i f
Melvin G.
Berger i
BRAND, BEENY, BERGER & WHITLER 1730 K Street, N.W.
Suite 1000 Washington, DC 20006 i
Attorneys for Louisiana Energy i
and Power Authority i
Philip P.
Graham Vice President River Bend Nuclear Group 5485 U.S.
Highway 61 l
Post Office Box 220 St. Francesville, LA 70715 Cecil L.
Johnson, Esquire Vice President - Legal Services Gulf States Utilities company 350 Pine Street Beaumont, TX 77701 f
J.A.
Bouknight, Jr.,
Esquire Newman & Holtzinger, P.C.
Suite-1000
(
1615 L Street, N.W.
Washington, DC 20036 l
(Representing Entergy) l l
t i
i
_ - -, _ _.