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Category:BRIEFS
MONTHYEARML20040A0491982-01-18018 January 1982 Addendum Updating Statement of Case in Appellant 820111 Brief.Nrc Notified Nfs on 820111 That Nfs Application for Amend to Provisional OL CSF-1 Denied W/O Prejudice.W/ Certificate of Svc.Related Correspondence 1982-01-18
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20065B0201982-09-0909 September 1982 Discussion of NRC Handling of Change 32 to License. Certificate of Svc Encl ML20058J6591982-08-0909 August 1982 Order Extending Time within Which Commission May Act to Review ALAB-677 Until 820917 ML20054M1821982-07-0808 July 1982 Memorandum & Order ALAB-679,affirming ASLB 820430 Denial of Idj Bross Two Requests for Hearing on Change 32 to License. NRC Cannot Hold Hearing on DOE Administration of Waste Solidification Project Where DOE Not Party ML20063C9251982-06-18018 June 1982 Response to NFS & Ny State Energy R&D Authority 820524 & 27 Ltrs,Respectively,Answers to Sierra Club 820318 Petition for Reconsideration.Nrc Erred in Not Publishing Notice of License Amend in Fr & Allowing Comment.W/Certificate of Svc ML20053E5681982-06-0404 June 1982 Corrected Page 7 to DOE Brief Opposing Idj Bross Appeal of ASLB 820430 Memorandum & Order.Certificate of Svc Encl ML20053D9811982-06-0303 June 1982 Brief Opposing Idj Bross Appeal of ASLB 820430 Memorandum & Order Denying Bross Request for Hearing on Changes 31 & 32 to License CSF-1.ASLB Decision That NRC Has No Jurisdiction Is Correct.Certificate of Svc Encl ML20053E7921982-06-0303 June 1982 Request for Reconsideration of Decision Granting DOE Motion for Amicus Curiae Status on Change 32.DOE Is Already Party to Case.New Status Deprives Petitioner of Symmetric Opportunities of Adversary Sys.Certificate of Svc Encl ML20052F3741982-05-0707 May 1982 Appeal of 820430 Order Denying Idj Bross Request for Hearing.Brief Supporting Appeal & Certificate of Svc Encl ML20050B9391982-03-26026 March 1982 Show Cause Petition on Why Change 32 to License CSF-1 Should Not Be Rescinded Pending Public Hearing.Termination of Nfs License Responsibilities Is Major NRC Action Approved W/O Prior Fr Notice of Receipt & Availability of Application ML20041E3271982-03-0808 March 1982 Response to ASLB 820219 Memorandum & Order,Answering Question 10 & Stating Views on Questions 7 & 8.No Further Action of Commission or ASLB Necessary Except to Note Withdrawal & Dismiss Hearing.Certificate of Svc Encl ML20049J7101982-03-0808 March 1982 Response to ASLB 820219 Memorandum & Order Directing Filing of Positions on Effect of License Change 32.Change Is Not in Issue Before ASLB Since No Issues Are to Be Decided by ASLB Re Nfs Request for Hearing.W/Certificate of Svc ML20041E4621982-02-19019 February 1982 Order Granting Nfs Motion for Voluntary Dismissal of Proceeding.Respondent Motion for Extension of Time to File Brief Dismissed as Moot ML20049H4551982-02-18018 February 1982 Settlement Agreement,Stipulation & Order.Nfs Will Surrender Low Level Storage Facilities Upon DOE Takeover & Authority Will Assume Responsibility.Accepted & So Ordered by Us District Court,Western District of Ny ML20041B5611982-02-16016 February 1982 Answers to ASLB 811231 Memorandum & Order Directing Filing of Further Info.Lists Present Status & Projected Schedule of Litigation Between Nfs & Ny State Energy R&D Authority. Certificate of Svc Encl ML20040G6151982-02-11011 February 1982 Withdrawal of 811013 Request for Hearing.Nrc Issued Amend Removes Licensee Objections to Change 31 ML20040G6101982-02-11011 February 1982 Motion for Voluntary Dismissal of Petition for Review,W/O Prejudice.All Parties Agree.Certificate of Svc Encl ML20040G6051982-02-0909 February 1982 Memorandum of 820205 Telcon W/Aslb,Nrc & Nfs Re Ny Energy R&D Authority Request for Extension of Time to Answer ASLB 811231 Order.Extension Granted Until 820216 for Authority & DOE Answer & Until 820302 for Nrc.Certificate of Svc Encl ML20040G3231982-02-0808 February 1982 Responds to ASLB 811213 Memorandum & Order Directing Filing of Further Info & Issues.Answers Questions 3,4 & 5. Certificate of Svc Encl ML20040C3471982-01-22022 January 1982 Answer to ASLB 811231 Memorandum & Order Directing Filing of Further Info.Specific Answers to Six Questions Contained in Pages 3 Through 5 of Order Delineated.Notices of Appearance & Certificate of Svc Encl ML20040A0491982-01-18018 January 1982 Addendum Updating Statement of Case in Appellant 820111 Brief.Nrc Notified Nfs on 820111 That Nfs Application for Amend to Provisional OL CSF-1 Denied W/O Prejudice.W/ Certificate of Svc.Related Correspondence ML20039E1451981-12-31031 December 1981 Notice Correcting Typographical Error on Page 3 of Certificate of Svc Attached to Jl Larocca 811217 Ltr to LC Rouse.Certificate of Svc Encl ML20062M2521981-12-0808 December 1981 Decision 531,reversing & Remanding for Trial Us District Court,Western District of Ny Decision Ordering NFS to Vacate Facility.Issue of Parties' Intent Re Transfer of Possession on Termination of Lease to Be Tried ML20038B9261981-12-0303 December 1981 Notices of Appearance in Proceeding.Certificate of Svc Encl ML20038B5641981-11-19019 November 1981 Petition to Intervene in Proceeding as of Right.Util Was Party to Proceeding Below & Util Is Corp Whose Interests Are Affected by Agency Action in Question.Certificate of Svc Encl.Related Correspondence ML20154N5111977-06-15015 June 1977 Testimony Before Environment & Atmosphere Subcommittee of House Committee on Science & Technology Re Nuclear Fuel Services,Inc,West Valley,Ny on 770615 ML20154N5001977-03-0808 March 1977 Testimony Before Environ,Energy & Natural Resources Subcommittee of House Committee on Govt Operations, Presented by Cv Smith,Jr on 770308 Re Nuclear Fuel Services Inc,West Valley,Ny ML20078G2651963-10-29029 October 1963 Statement in Support of NFS 631023 Motion Requesting Commission Take Actions on Loan Arrangements & Submittal of Financial Repts.Draft NFS Motion,Certificate of Svc & Term Loan Agreement Encl 1982-09-09
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IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT
'82 J' ,18 P3 52
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Nuclear Fuel Services, Inc., ) i-
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Petitioner )
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- v. ) No. 81 .
Nuclea r Regulatory Commission,
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et al. ) v .
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Respondents. ) , l
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, ic . y' ADDENDUM TO APPELLANT'S BRIEF \ ,
This addendum updates the STATEMENT OF THE CASE in appellant's brief dated January 11, 1982, based on informa-tion received after the brief was filed. On January 11, 1982, the Nuclear Regulatory Commission (NRC) notified the appellant, Nuclear Fuel Services, Inc. (NFS), by letter that NFS's application for amendment to Provisional Operating License No. CSF-1 was denied, without prejudice. (A copy of January 11th letter is attached.) This action by the NRC has no effect on NFS's motion before this Court.
Respect lly Submitted, i
t &
Ge'orge . Edgar l
Attorney for Nuclear Fuel Services, Inc. g50 s l 1
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l Dated: January 18, 1982 8201200260 820118 PDR ADOCK 05000201 C PDR
IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT
)
Nuclear Fuel Services, Inc., )
)
Petitioner, )
)
- v. ) No. 81-2114
)
Nuclear Regulatory Commission, )
et al., )
)
Respondents. )
)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing addendum were served this 18th day of January, 1982, by first-class nail, postage prepaid, on the following parties:
i Leonard Beckwit, Jr., Esquire General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Guy H. Cunningham, III, Esquire Director and Chief Counsel Office of the Executive Legal Director U.S. Nuclear Regulatory Commission ,
Washington, D.C. 20555 1 Carmine J. Clemente, Esquire General Counsel New York State Energy Research and Development Authority Two Rockefeller Plaza Albany, New York 12223
Harren E. Bergholz, Jr., Esquire Office of General Counsel U.S. Department of Energy 1000 Independence Avenue, S.W.
Washington, D.C. 20587 Nunzio J. Palladino, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Peter Bradford, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John F. Ahearne, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard E. Cunningham, 111 Director, Division of Fuel Cycle and Material Safety U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lawrence Brenner, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
l l
Dr. Jerry Harbour Atonic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Peter A. Morris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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GEORGE L. EDGAR Attorney for Nuclear Fuel Services, Inc.
DATED: January 18, 1982 i
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