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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20039E9551982-01-0606 January 1982 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 821222 Petition for Review.Request Untimely & Unsupported.Matters Should Have Been Raised Before Aslab.Certificate of Svc Encl ML20039D8371981-12-29029 December 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc.811218 Petition for Stay of Aslab 811207 Decision.Intervenors Failed to Seek Stay of ALAB-622 from Aslab.Certificate of Svc Encl ML20039C6971981-12-22022 December 1981 Petition for Review.Commission Should Remand Case to ASLB for ASLB to Delineate & Impose Conditions Upon Applicant for Granting Dismissal of CP Application W/O Prejudice. Certificate of Svc ML20069A9931981-12-18018 December 1981 Petition for Stay of Aslab 811207 decision,ALAB-622, Dismissing Proceeding W/O Prejudice.Certificate of Svc Encl ML20010D1621981-08-0303 August 1981 Request for Consolidation W/Fulton Proceeding & for 15-day Extension to File Brief.Instant Case & Fulton Proceeding Present Common Question of Law & Fact.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 ML20009E4291981-07-21021 July 1981 Petition for Reconsideration & Request for Extension of Time to File Brief.Belated Mailing of Microfiche Collection & NRC Issuances Adversely Affects Intervenor Opportunity to Conduct Necessary Research ML19352B3371981-06-29029 June 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 810613 Motion to File Sworn Statements.Intervenors Failed to Justify Reopening of Record ML20005A9051981-06-29029 June 1981 Notice of Appearance Re Facility.Certificate of Svc Encl ML19351A1671981-06-16016 June 1981 Comments on Various Matters in Proceeding.Intervenors Concerned That Aslab 810611 Order Does Not Mention Compelling ASLB to Keep Record Open on Applicant Past Performance.Certificate of Svc Encl ML20004F7621981-06-13013 June 1981 Motion for Leave to File Encl Sworn Statements as Evidence of Damage to Public Interest Which Would Be Caused & Remain If Application Dismissal W/O Prejudice Were Sustained on Appeal.Certificate of Svc Encl ML20004E8961981-06-0606 June 1981 Petition to Reconsider Aslab 810601 Order Denying Intervenors' 810512 Request for Extension of Time to File Brief.Requests Aslab Investigation Into NRC Failure to Serve NRC Response to Intervenors' Request.W/Certificate of Svc ML20004B6321981-05-21021 May 1981 Response to G Fernos & Citizens for Conservation of Natural Resources Notice of Appeal & Request for Extension of Time to File Brief.Opposes Delay in Filing.Leave to File Appeal Granted Earlier.Certificate of Svc Encl ML19347F6291981-05-12012 May 1981 Notice of Appeal of ASLB 810218 Memorandum & Order. Intervenors Take Exception to Granting Applicant Motion to Terminate Proceeding & Granting Withdrawal of Application W/O Prejudice.Certificate of Svc Encl ML20003J3821981-04-25025 April 1981 Response Opposing Applicant 810417 Response to Intervenor Petition for Temporary Stay & Extension of Time.Applicant Motion Lacks Support & Time to File Appeal Has Not Expired. Certificate of Svc Encl ML17328B0611981-04-17017 April 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources 810406 Request for Stay of ASLB 810218 & 0326 Decisions & Petition for Extension of Time to File Appeal.Certificate of Svc Encl ML19347D9201981-04-0606 April 1981 Request for Extension Until 810515 to File Appeal & for Stay of ASLB 810218 & 0326 Orders Granting Applicant Withdrawal of Application W/O Prejudice & Denying Intervenor Petition for Reconsideration,Respectively.Certificate of Svc Encl ML19350B5271981-03-12012 March 1981 Answer Opposing G Fernos 810303 Request for Reconsideration of ASLB 810218 Order Granting Withdrawal W/O Prejudice of Util Application.Also Opposes Request to Stay Decision.No New Info Presented.Certificate of Svc Encl ML19347D2291981-03-0303 March 1981 Request for Reconsideration of ASLB 810218 Order Granting Application Withdrawal W/O Prejudice.Applicant Actions & Clear Lack of Necessity for Plant Demand That Dismissal Be W/Prejudice.Certificate of Svc Encl ML20002C0871980-12-31031 December 1980 Reply to Intervenor 801203 Submittal Stating Withdrawal Application Should Be Dismissed W/Prejudice.Accusation of Hidden,Deceitful Action Is Unsubstantiated.Proceeding Should Be Terminated W/O Prejudice.W/Certificate of Svc ML19351F1431980-12-0303 December 1980 Reply to Applicant & NRC Contention That Withdrawn Application Should Not Be Dismissed W/Prejudice.Urges That Application Be Dismissed W/Prejudice.Certificate of Svc Encl ML19351C8811980-10-0303 October 1980 Response in Opposition to Citizens for Conservation of Natural Resources Motion for Direct Certification Urging Dismissal of Application W/Prejudice.Future Applications May Not Be Barred Unless Public Harmed.Certificate of Svc Encl ML19332B4051980-09-18018 September 1980 Motion for Stay of Proceeding Until Commission Rules Upon Direct Certification Seeking Dismissal of Application W/ Prejudice.Certificate of Svc Encl ML19332B4041980-09-18018 September 1980 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 ML19332B3971980-09-17017 September 1980 Motion for Direct Certification Requesting That CP Application Be Dismissed W/Prejudice Rather than Accepting Applicant Withdrawal Terminating Proceeding.Certificate of Svc Encl ML19332A9111980-09-13013 September 1980 Requests Commission Take No Action Re ALAB-605.Intervenor Must Present Case to ASLB Before Commission Acts to Review ALAB-605.Intervenor Counsel in Hosp Until After Commission Action Deadline of 800919.Certificate of Svc Encl ML19332A4911980-09-11011 September 1980 Motion for Termination of Proceeding Due to Encl Withdrawal of Application.Certificate of Svc Encl ML19332A4891980-09-11011 September 1980 Motion for Withdrawal of Application for CP ML19332A1801980-09-0303 September 1980 Motion Advising of Temporary Substitution of Author.Requests Incorporation of T Morales on Svc List in Absence. W/Certificate of Svc ML19332A1931980-09-0303 September 1980 Interrogatories & Request for Production of Documents Directed to Applicant.Questions Applicant Financial Statement Re Past & Future Total Investment in Project. Certificate of Svc Encl ML19331D9091980-08-27027 August 1980 Motion for Ruling on Intervenor 800718 Submission Seeking Legal Assistance During Hearings Plus Round Trip Travel & Lodging Expenses for Counsel.Certificate of Svc Encl ML19331D9071980-08-27027 August 1980 Motion for Clarification of Scope of Single Issue to Be Tried in ASLB 800819 Order Re Intervenor 800430 Petition on Lack of Intention to Build.Draws Attention to Util Inaction & Contradictory Actions.W/Certificate of Svc ML19331B7341980-08-0404 August 1980 Response to Applicants' 800718 Memorandum Alleging That ASLB Has No Jurisdiction to Dismiss CP Application as Moot.Urges Reversal of ASLB 800529 Order in Order to Address Merits of Intervenors' 800430 Request.W/Certification of Svc ML19321A5071980-07-18018 July 1980 Response to NRC 800627 Memorandum,In Reply to Aslab 800630 Order.Interlocutory Review of ASLB Order Re Dismissal of CP Application W/O Hearing on Health,Safety & Environ Is Not Warranted.Certificate of Svc Encl ML19321A6281980-07-18018 July 1980 Memorandum in Response to Aslab 800604 Order Re Validity of ASLB 800529 Order Denying Petition to Intervene.Urges Reversal of ASLB Order & Institution of Hearings. Certificate of Svc Encl ML19320C2721980-07-0909 July 1980 Motion Seeking Option to Respond to Applicant by 800808,if Applicant Responds to NRC 800627 Memorandum by 800718,re Aslab 800630 Order.Certificate of Svc Encl ML19320A7771980-06-27027 June 1980 Memorandum in Response to Aslab 800604 Order.Interlocutory Review of ASLB Order Denying G Fernos Petition to Dismiss Application Not Warranted Unless Legal Boundaries Are Not Explored.W/Certificate of Svc ML19312E9181980-05-19019 May 1980 Response in Opposition to Intervenor G Fernos 800430 Request for Issuance of Order to Show Cause Why Application Should Not Be Dismissed.No Time Frame Requirememts Exist for License Processing.W/Certificate of Svc ML19318A2771980-04-30030 April 1980 Petition Urging ASLB to Hold Evidentiary Hearings to Request Applicant to Show Cause Why Application Should Not Be Dismissed Due to Lack of Intention to Build.Requests Costs & Damages.W/Certificate of Svc & Supporting Documents ML19209B8361979-08-31031 August 1979 Status Rept as of 790831.Natl Academy of Sciences Is Studying Overall Energy Situation in Pr.Portion of Study Is Being Prepared by Electric Power Sys Subcommittee. Certificate of Svc Encl ML20076B1551979-04-30030 April 1979 Status Rept by Puerto Rico Water Resources Authority Re Facility Application,As of 790430.Electric Power Sys Will Issue Rept by Late May.Certificate of Svc Encl ML19263B6711978-12-29029 December 1978 Status Rept as of 781229 Re Puerto Rico Water Resources Authority'S Application.Internal Review of Generation Expansion Not Yet Completed.Westinghouse Contract Re Nuclear Steam Supply Sys Cancelled.W/Certificate of Svc ML20148C4311978-10-16016 October 1978 Discovery Status Rept as of 781016.Internal Review Incomplete.Requests That NRC Issue Site Safety Review Re Seismicity & Geology.Applicant Does Not Expect to File Motions in Near Future.Certificate of Svc Encl 1982-01-06
[Table view] Category:PLEADINGS
MONTHYEARML20039E9551982-01-0606 January 1982 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 821222 Petition for Review.Request Untimely & Unsupported.Matters Should Have Been Raised Before Aslab.Certificate of Svc Encl ML20039D8371981-12-29029 December 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc.811218 Petition for Stay of Aslab 811207 Decision.Intervenors Failed to Seek Stay of ALAB-622 from Aslab.Certificate of Svc Encl ML20039C6971981-12-22022 December 1981 Petition for Review.Commission Should Remand Case to ASLB for ASLB to Delineate & Impose Conditions Upon Applicant for Granting Dismissal of CP Application W/O Prejudice. Certificate of Svc ML20069A9931981-12-18018 December 1981 Petition for Stay of Aslab 811207 decision,ALAB-622, Dismissing Proceeding W/O Prejudice.Certificate of Svc Encl ML20010D1621981-08-0303 August 1981 Request for Consolidation W/Fulton Proceeding & for 15-day Extension to File Brief.Instant Case & Fulton Proceeding Present Common Question of Law & Fact.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 ML20009E4291981-07-21021 July 1981 Petition for Reconsideration & Request for Extension of Time to File Brief.Belated Mailing of Microfiche Collection & NRC Issuances Adversely Affects Intervenor Opportunity to Conduct Necessary Research ML19352B3371981-06-29029 June 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources,Inc 810613 Motion to File Sworn Statements.Intervenors Failed to Justify Reopening of Record ML19351A1671981-06-16016 June 1981 Comments on Various Matters in Proceeding.Intervenors Concerned That Aslab 810611 Order Does Not Mention Compelling ASLB to Keep Record Open on Applicant Past Performance.Certificate of Svc Encl ML20004F7621981-06-13013 June 1981 Motion for Leave to File Encl Sworn Statements as Evidence of Damage to Public Interest Which Would Be Caused & Remain If Application Dismissal W/O Prejudice Were Sustained on Appeal.Certificate of Svc Encl ML20004E8961981-06-0606 June 1981 Petition to Reconsider Aslab 810601 Order Denying Intervenors' 810512 Request for Extension of Time to File Brief.Requests Aslab Investigation Into NRC Failure to Serve NRC Response to Intervenors' Request.W/Certificate of Svc ML20004B6321981-05-21021 May 1981 Response to G Fernos & Citizens for Conservation of Natural Resources Notice of Appeal & Request for Extension of Time to File Brief.Opposes Delay in Filing.Leave to File Appeal Granted Earlier.Certificate of Svc Encl ML20003J3821981-04-25025 April 1981 Response Opposing Applicant 810417 Response to Intervenor Petition for Temporary Stay & Extension of Time.Applicant Motion Lacks Support & Time to File Appeal Has Not Expired. Certificate of Svc Encl ML17328B0611981-04-17017 April 1981 Response Opposing G Fernos & Citizens for Conservation of Natural Resources 810406 Request for Stay of ASLB 810218 & 0326 Decisions & Petition for Extension of Time to File Appeal.Certificate of Svc Encl ML19347D9201981-04-0606 April 1981 Request for Extension Until 810515 to File Appeal & for Stay of ASLB 810218 & 0326 Orders Granting Applicant Withdrawal of Application W/O Prejudice & Denying Intervenor Petition for Reconsideration,Respectively.Certificate of Svc Encl ML19350B5271981-03-12012 March 1981 Answer Opposing G Fernos 810303 Request for Reconsideration of ASLB 810218 Order Granting Withdrawal W/O Prejudice of Util Application.Also Opposes Request to Stay Decision.No New Info Presented.Certificate of Svc Encl ML19347D2291981-03-0303 March 1981 Request for Reconsideration of ASLB 810218 Order Granting Application Withdrawal W/O Prejudice.Applicant Actions & Clear Lack of Necessity for Plant Demand That Dismissal Be W/Prejudice.Certificate of Svc Encl ML20002C0871980-12-31031 December 1980 Reply to Intervenor 801203 Submittal Stating Withdrawal Application Should Be Dismissed W/Prejudice.Accusation of Hidden,Deceitful Action Is Unsubstantiated.Proceeding Should Be Terminated W/O Prejudice.W/Certificate of Svc ML19351F1431980-12-0303 December 1980 Reply to Applicant & NRC Contention That Withdrawn Application Should Not Be Dismissed W/Prejudice.Urges That Application Be Dismissed W/Prejudice.Certificate of Svc Encl ML19351C8811980-10-0303 October 1980 Response in Opposition to Citizens for Conservation of Natural Resources Motion for Direct Certification Urging Dismissal of Application W/Prejudice.Future Applications May Not Be Barred Unless Public Harmed.Certificate of Svc Encl ML19332B4051980-09-18018 September 1980 Motion for Stay of Proceeding Until Commission Rules Upon Direct Certification Seeking Dismissal of Application W/ Prejudice.Certificate of Svc Encl ML19332B4041980-09-18018 September 1980 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 ML19332B3971980-09-17017 September 1980 Motion for Direct Certification Requesting That CP Application Be Dismissed W/Prejudice Rather than Accepting Applicant Withdrawal Terminating Proceeding.Certificate of Svc Encl ML19332A9111980-09-13013 September 1980 Requests Commission Take No Action Re ALAB-605.Intervenor Must Present Case to ASLB Before Commission Acts to Review ALAB-605.Intervenor Counsel in Hosp Until After Commission Action Deadline of 800919.Certificate of Svc Encl ML19332A4911980-09-11011 September 1980 Motion for Termination of Proceeding Due to Encl Withdrawal of Application.Certificate of Svc Encl ML19332A4891980-09-11011 September 1980 Motion for Withdrawal of Application for CP ML19332A1801980-09-0303 September 1980 Motion Advising of Temporary Substitution of Author.Requests Incorporation of T Morales on Svc List in Absence. W/Certificate of Svc ML19331D9071980-08-27027 August 1980 Motion for Clarification of Scope of Single Issue to Be Tried in ASLB 800819 Order Re Intervenor 800430 Petition on Lack of Intention to Build.Draws Attention to Util Inaction & Contradictory Actions.W/Certificate of Svc ML19331D9091980-08-27027 August 1980 Motion for Ruling on Intervenor 800718 Submission Seeking Legal Assistance During Hearings Plus Round Trip Travel & Lodging Expenses for Counsel.Certificate of Svc Encl ML19331B7341980-08-0404 August 1980 Response to Applicants' 800718 Memorandum Alleging That ASLB Has No Jurisdiction to Dismiss CP Application as Moot.Urges Reversal of ASLB 800529 Order in Order to Address Merits of Intervenors' 800430 Request.W/Certification of Svc ML19321A5071980-07-18018 July 1980 Response to NRC 800627 Memorandum,In Reply to Aslab 800630 Order.Interlocutory Review of ASLB Order Re Dismissal of CP Application W/O Hearing on Health,Safety & Environ Is Not Warranted.Certificate of Svc Encl ML19321A6281980-07-18018 July 1980 Memorandum in Response to Aslab 800604 Order Re Validity of ASLB 800529 Order Denying Petition to Intervene.Urges Reversal of ASLB Order & Institution of Hearings. Certificate of Svc Encl ML19320C2721980-07-0909 July 1980 Motion Seeking Option to Respond to Applicant by 800808,if Applicant Responds to NRC 800627 Memorandum by 800718,re Aslab 800630 Order.Certificate of Svc Encl ML19320A7771980-06-27027 June 1980 Memorandum in Response to Aslab 800604 Order.Interlocutory Review of ASLB Order Denying G Fernos Petition to Dismiss Application Not Warranted Unless Legal Boundaries Are Not Explored.W/Certificate of Svc ML19312E9181980-05-19019 May 1980 Response in Opposition to Intervenor G Fernos 800430 Request for Issuance of Order to Show Cause Why Application Should Not Be Dismissed.No Time Frame Requirememts Exist for License Processing.W/Certificate of Svc ML19318A2771980-04-30030 April 1980 Petition Urging ASLB to Hold Evidentiary Hearings to Request Applicant to Show Cause Why Application Should Not Be Dismissed Due to Lack of Intention to Build.Requests Costs & Damages.W/Certificate of Svc & Supporting Documents 1982-01-06
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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'81 DEC 30 A;;;58 Before the Nuclear Regulatory Commission Orrnu CF si;g n In the Matter of ) 00N y#p g & ,
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AUTHORITY ) Docket No. 50-376 N g /
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AUTHORITY'S RESPONSE IN OPPOSITION TO "t 2D' h INTERVENORS' PETITION FOR A STAY OF APPEAL BOARD'S - ' T" - ( /
DECISION OF DECEMBER 7, 1981 2
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On February 18, 1981, tae Licensing Board in th above-captioned proceeding issued a Memorandum and Order which dismissed without prejudice the application of Puerto Rico Electric Power Authority (Authority) for a construction permit for the North Coast Nuclear Plant, Unit 1. This order was affirmed by a decision of the Appeal Board in ALAB-662, dated December 7, 1981. Gonzalo Fernos and Citizens for the Conservation of Natural Resources, Inc.
(Intervenors) have now filed with the Nuclear Regulatory Commission a " Petition for a Stay of Appeal Bcard's Decision 1/
of Dec. 7, 1981" (Petition), dated December 18, 1981. ~-
The Authority hereby submits its response in opposition to the Petition.
1/ On April 6, 1981, the Intervenors filed an application for a stay of the Licensing Board's February 18, 1981, decision. The Appeal Board " implicitly denied a stay."
See ALAB-648, 14 NRC 34, 35 (1981).
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The Petition is patently without merit, and it may be denied for any one of several reasons. First, contrary to the requirements of 10 CFR S 2.788 (f) , the Intervenors could have sought, but did not seek, a stay of ALAB-662 from the Appeal Board. This constitutes a ground for automatic denial of the Petition. Second, the Intervenors have not addressed whether a stay is warranted upon a consideration of the 2/
four factors in 10 CFR 5 2.788 (e) .~ This defect alone is a sufficient ground for rejecting the request for a stay.
Kansas Gas and Electric Co. (Wolf Creek Generating Station, Unit 1), ALAB-412, 5 NRC 1415, 1416-17 (1977). In particular, the Intervenors have not alleged that they will suffer i
irreparable injury as a result of a denial of a stay of the Appeal Board's decision. Finally, the decision did-not authorize the Authority to commit any action which it could not have otherwise committed, and thus there is i "nothing for [the Commission) to stay." See Long Island l
Lighting Co. (Jamesport Nuclear Power Station, Units 1 and 2), ALAB-481, 7 NRC 807, 808 (1978).
2/
~
Those factors are: 1) whether the moving party has made a strong showing that it is likely to prevail on.the merits; 2) whether the party will be irreparably injured l unless a stay is granted; 3) whether the granting of a stay would harm other parties; and 4) where the public j interest lies.
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In short, the Petition is procedurally defective and the Intervenors have provided no basis for a stay.
Consequently, the request for a stay of ALAB-662 should be denied.-
Respectfully submitted, f
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Maurice Axelrad - I Lowenstein, Newman, Reis &
Axelrad 1025 Connecticut Avenue, N.W.
Kashington, D.C. 20036 Telephone: (202) 862-8400 Attorneys for Puerto Rico Electric Power Authority l
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- UNITED STATES 0F AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of )
)
PUERTO RICO ELECTRIC POWER )
AUTHORITY ) Docket No. 50-376
)
North Coast Nuclear Plant, ) December 29, 1981 (Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of the Authority's Response in Opposition to Intervenors' Petition for a Stay of Appeal Board's Decision of December 7, 1981, were served on the following by deposit in the United States mail, first class and postage prepaid, this 29th day of December, 1981.
Chairman Nunzio J. Palladino Alan S. Rosenthal, Esq.
U.S. Nuclear Regulatory Chairman Commission Atomic Safety and Licensing Washing ton, D.C. 20555 Appeal Board U. S. Nuclear Regulatory Commissioner Victor Gilinsky Come.ission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr John H. Buck Member Commissioner Peter A. Bradford Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Commission U. S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 i Commissioner Thomas M. Roberts l U.S. Nuclear Regulat',ry Atomic Safety and Licensing Commission Appeal Panel Washington, D.C. U. S. Nuclear Regulatory Commission Commissioner John F. Ahearne Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 I
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Sheldon J. Wolfe, Esq. Henry J. McGurren, Esq.
Administrative Judge Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 German A. Gonzalez Dr. Richard F. Cole Suite 501 Administrative Judge Condominio Le Mans Atomic Safety and Licensing Avenida Munoz Rivera 602
, Board Hato Rey, PR 00919 U. S. Nuclear Regulatory Commission Gonzalo Fernos Washington, D.C. 20555 Chairman Mr. Gustave A. Linenberger Citizens for the Conservation of Natural Resources, Inc.
Administrative Judge 503 Barbe Street Atomic Safety and Licensing Santurce, PR 00912 Board U. S. Nuclear Regulatory Dr. Thomas Morales-Cardona Commission Department of Pharmacology Washington, D.C. 20555 School of Medicine Secretary of the Commission University of Puerto Rico U. S. Nuclear Regulatory GPO Box 5067 Commission San Juan, PR 00936 Washington, D.C. 20555 (Original and 2 copies) Eng. Franciseo Jimenez Box 1317 Attention: Docketing and Mayaguez, PR 00708 Service Section l
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l Maurice Axelrad Lowenstein, Newman, Reis &
Axelrad 1025 Connecticut Avenue, N.W.
Washington, D.C. 20036 l Telephone: (202) 862-8400 Attorneys for Puerto Rico Electric Power Authority
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